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🔎 Things to remember
We invite you to take stock of the main regulatory deadlines for 2026 and the regulatory developments to watch out for.
Digitization of accident/incident reporting for ICPE facilities
Operators of classified facilities for environmental protection (ICPE) must now submit their reports on the platform https://entreprendre.service-public.gouv.fr/vosdroits/R71939.
- reporting of accidents or incidents arising from the operation of the installation that are likely to affect the protected interests;
- the accident or incident report.
Note: The following must be submitted in hard copy:
- information relating to defense facilities;
- information that could harm confidential interests.
New EPR scheme for commercial packaging
The new EPR scheme for professional packaging will come into effect on July1, 2026.
Companies using packaging must identify whether they are considered to be the producer of the packaging (see PPWR regulation) and whether it is professional packaging (see, in particular, the scope decree).
Professional packaging producers will be required to:
- Either set up an approved individual system,
- Either join (at the company level) an eco-organization that is certified for the professional packaging sector.
Many companies will therefore be affected by this new EPR sector.
To learn more, check out our article on Extended Producer Responsibility (EPR)
Employer prevention passport
The prevention passport will be available to employers on March 16, 2026.
Employers will be required to report training conducted internally and, for training conducted externally, ensure that the training organization has reported the training.
We invite you to check with your HR department to ensure that this issue has been taken into account.
To learn more, check out our article on the prevention passport
Shade structures over parking lots
Outdoor parking lots with an area greater than or equal to 10,000 m² existing on July 1, 2023, must be equipped by July1, 2026, covering half of their surface area.
- either shade structures incorporating a renewable energy production process across their entire upper surface providing shade;
- either mixed processes corresponding to a proportion of shade structures covering at least 35% of half the surface area of the parking lot and greenery contributing to the shading of the remaining surface area to be covered;
- either in whole or in part, a renewable energy production system that does not require the installation of shade structures, provided that this system allows for production equivalent to that which would result from the installation of shade structures incorporating a renewable energy production process set up on the unequipped area.
Exemptions are possible (economic criteria, technical criteria, etc.).
It is also possible to extend this deadline to January1, 2028, under certain conditions.
Conducting an energy audit for newly affected companies
Energy audits are now mandatory for companies that have not implemented an EMS when their average annual final energy consumption exceeds 2.75 GWh. These audits must be carried out every four years.
For companies that were not subject to the old criteria, the first audit must be carried out by October 11, 2026, at the latest.
Reminder of previous criteria: 250 employees or annual turnover exceeding €50 million or a balance sheet total exceeding €43 million.
To learn more, read our article on the new scope of energy audits and the EMS
Implementation of a certified energy management system
An energy management system (EMS) must be implemented in companies whose average annual final energy consumption is greater than or equal to 23.6 GWh. It is certified by an accredited certification body. The EMS must be certified by October 11, 2027, at the latest.
The implementation of such a system must be anticipated as early as this year for the companies concerned.
Please note that the following are exempt from the audit:
- companies that have implemented an environmental management system compliant with ISO 14001:2015/Amd. 1:2024 or any other equivalent standard, where this system is certified by an accredited body and includes an energy audit equivalent to that required by the regulations;
- companies implementing an energy performance contract (EPC).
For more information: https: //www.tennaxia.com/blog/nouveau-perimetre-des-audits-energetiques-et-du-sme
Greening or solarization of existing building roofs
By January 1, 2028, at the latest, all buildings or parts of buildings used for commercial, industrial, craft, or administrative purposes, buildings or parts of buildings used as offices or warehouses, hangars not open to the public that are used for commercial purposes, hospitals, sports, recreational, and leisure facilities, school and university buildings or parts of buildings, and covered parking lots accessible to the public, buildings or parts of buildings existing on July 1, 2023, with a footprint of at least 500 square meters must incorporate:
- either a process for producing renewable energy;
- either a greening system based on a cultivation method that uses drinking water only as a supplement to recovered water, ensuring a high degree of thermal efficiency and insulation and promoting the preservation and restoration of biodiversity;
- or any other device that achieves the same result.
At present, only exemptions related to ICPEs have been defined.
The texts defining the criteria for exemption, particularly economic or technical exemption, are awaited.
As soon as they are published, companies will have to check whether they meet the exemptions or plan the work required to ensure compliance.
New occupational exposure limit (OEL) for acrylonitrile
The binding OEL for acrylonitrile (CAS No.: 107-13-1) comes into effect on April 5, 2026:
As acrylonitrile is a substance classified as CMR 1B, an annual check of this ELV by an accredited body must be put in place.
New provisions concerning the cross-border shipment of waste
These new provisions, laid down in Regulation (EU) 2024/1157 of April 11, 2024, will enter into force on May 21, 2026.
In particular, transfers of waste for disposal within the European Union (except for exemptions) and exports of plastic waste to non-OECD countries are prohibited.
A centralized platform enables the digitization of information and data exchange on waste shipments throughout the EU.
Labeling of firefighting equipment containing PFAS
As of October 23, 2026, when the concentration of all PFAS exceeds 1mg/L, labeling requirements apply:
- to firefighting foams placed on the market, excluding portable fire extinguishers,
- for users, unused stocks of firefighting foams, as well as waste containing PFAS, including wastewater, resulting from the use of these foams.
The label, which must be visible, legible, and indelible, shall bear the following statement: "WARNING: Contains per- and polyfluoroalkyl substances (PFAS) at a concentration equal to or greater than 1 mg/L for the sum of all PFAS."
To learn more, read our article onthe ban on PFAS in firefighting foams
PFAS discharges
A decree imposed PFAS measurement campaigns on certain authorized ICPEs (Classified Installations for Environmental Protection). Following these campaigns, actions to eliminate the source were launched in order to reduce industrial PFAS emissions.
The implementation of regulations on the monitoring of PFAS in industrial wastewater discharges should become widespread.
A specific ICPE section for batteries?
Regulatory work is underway to implement a specific ICPE 2926 section for batteries with associated decrees. Consultations are expected shortly.
Digitization of medical waste disposal slips?
The digitization of slips for infectious medical waste on the Trackdéchet platform has been possible since June 2023. It will eventually become mandatory, but we are awaiting the regulatory texts.
Strengthening provisions for IED installations
The transposition of Directive 2024/1785 of April 24, 2024, is expected before July1, 2026.
In order to strengthen the rules on integrated pollution prevention and control in industrial activities, this directive amended the IED Directive, notably by extending its scope to new activities and more intensive livestock farming, and by strengthening or imposing requirements.
Among these provisions is the requirement to audit the environmental management system before July1, 2027.
Conclusion
We recommend, if you have not already done so, that you take these issues into account in your action plans and budgets and remain attentive to upcoming regulatory changes in 2026.