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🔎 Key takeaways
- Fluorinated gases and personnel certification: New certification procedures related to F-GAS III regulation
- Plastic flexibility/PPWR: Introduction of a specific exemption from the 100% reuse obligation (scheduled for 2030) for pallet packaging and transport straps.
- Borings, drillings, wells, underground structures: New reporting requirements related to the economic life simplification law.
- Reflective roof coatings : exemption cases from the obligation to integrate renewable energy production processes and green roofing systems
- Small public access buildings: Exemption from the administrative authorization request for works and opening
- Occupational health: New templates for fitness-for-work notices and medical certificates must be taken into account
Here are the main regulatory topics for May 2026 concerning energy, environment, and safety.
ENVIRONMENT
Adaptation to European law regarding certification for working on fixed fire protection equipment containing fluorinated greenhouse gases (F-gases)
Order of 23 May 2011 issued pursuant to Articles R. 521-59, R. 521-60, R. 521-61 and R. 521-63 of the Environmental Code for the fixed fire protection equipment sector AMENDED BY the Order of 23 April 2026 [JORF of 3 May 2026]
Issued pursuant to Regulation (EU) 2024/573 of 7 February 2024 on fluorinated greenhouse gases ("F-Gas III") and Implementing Regulation (EU) 2025/625 of 28 March 2025, the Order of 23 April 2026 aligns French regulations with European regulations concerning certification for working on fixed fire protection equipment.
Thus, new personnel certification procedures are introduced. These certificates now have a 7-year validity limit (previously, they had no validity limit). Provisions for refresher training for already certified personnel are also added. Furthermore, a company wishing to obtain a certificate must now include, in its application file, the certificates already issued and the refresher training certificates of its personnel.
In the same spirit and in accordance with F-GAS III Regulation concerning the certification of personnel involved in:
- the recovery of F-gas-based solvents
- fixed electrical switchgear containing F-gases or their recovery
the relevant French orders are also adapted.
Exemption from the 100% reuse obligation for pallet packaging and straps
Commission Delegated Decision (EU) 2026/429 of 25 February 2026 supplementing Regulation (EU) 2025/40 of the European Parliament and of the Council by exempting certain economic operators using pallet packaging and straps from the 100% reuse requirements for these packaging formats [OJEU of 6 May 2026]
Regulation (EU) 2025/40 of 19 December 2024 (known as "PPWR") introduces a reuse obligation applicable to economic operators who use transport packaging or sales packaging for the transport of products within the Union, including for online commerce, particularly in the form of pallets, including the straps used to stabilize and protect products placed on pallets during transport.
As of 1 January 2030, a 100% reuse obligation for these packaging types will apply to the transport of products:
- within the territory of the Union, between different sites where the operator carries out its activity, or between one of the sites where the operator carries out its activity and the sites of any other linked undertaking or partner undertaking within the meaning of Article 3 of the Annex to Recommendation 2003/361/EC (excluding online commerce)
- for the purpose of delivering products to another economic operator in the same Member State.
This decision relaxes these provisions by introducing a specific exemption for pallet packaging or straps used to stabilize and protect products placed on pallets during transport.
New reporting requirements under the mining code for soundings, boreholes, wells, underground structures, and excavation work
Mining Code Articles L. 411-1 to L. 411-3-4: Excavations and geophysical surveys - Prior declarations AMENDED BY Law No. 2026-403 of May 26, 2026, on the simplification of economic life [Official Journal of May 27, 2026]
Previously, the mining code required a prior declaration to the administrative authority by any person carrying out a sounding, an underground structure, or excavation work, regardless of its purpose, with a depth exceeding 10 m.
Law No. 2026-403 of May 26, 2026, revises this requirement and now stipulates a prior declaration to an entity designated by decree, by the project owner, project manager, or contracting company carrying out a sounding, borehole, well, underground structure, or excavation work, regardless of its purpose, with a depth exceeding 10 m.
However, when it concerns the exploration, monitoring, or temporary or permanent extraction of groundwater, this prior declaration is mandatory, regardless of depth.
Furthermore, the law now requires the project owner, project manager, or contracting company to inform the aforementioned entity upon completion of the work.
These provisions are to come into force on a date set by decree, and no later than December 31, 2027.
ENERGY
Possibility of requiring a reflective roof coating in case of exemption from the obligation to integrate renewable energy production processes and greening systems
Construction and Housing Code Articles L. 171-1 to L. 175-2: Energy and environmental performance AMENDED BY Law No. 2026-403 of May 26, 2026, on the simplification of economic life [Official Journal of May 27, 2026]
As a reminder, the competent authority for urban planning permits may grant exemptions due to technical, safety, architectural, heritage, or economic constraints from the obligation to integrate renewable energy production processes and greening systems on the roofs of certain types of buildings.
In the case of exemptions due to technical, safety, architectural, or heritage constraints, Law No. 2026-403 of May 26, 2026, now offers the competent authority for urban planning permits the possibility to make the granting of all or part of these exemptions conditional on the integration of a reflective roof coating to achieve energy savings. A decree must set the conditions allowing the competent authority to impose such a solution, and an order must specify the minimum characteristics of these coatings.
SECURITY
Waiver of the administrative authorization request for construction work and the opening of public-access buildings (ERP)
Construction and Housing Code, Articles L. 122-2 to L. 122-6: Declarations and Authorizations AMENDED BY Law No. 2026-403 of May 26, 2026, on the simplification of economic life [Official Journal of May 27, 2026]
Law No. 2026-403 of May 26, 2026, introduces changes concerning the authorization required for the creation, development, or modification of public-access buildings (ERP) to verify their compliance with accessibility and fire safety regulations (depending on their category and planned occupancy).
Thus, it is specified that the work authorization procedure is, by way of derogation, replaced by a procedure for declaring the conformity of the works with accessibility and fire safety regulations for public-access buildings (ERP) under 300 m² that have a fire extinguishing system adapted to the fire risk or are located in a train station, provided they maintain the same activity. A decree will specify the conditions for applying this procedure.
Furthermore, micro-enterprises and small and medium-sized enterprises can, upon request, benefit from a preliminary advisory visit before the inspection of accessibility and fire safety regulations.
New models for opinions, individual health monitoring certificates, and certificates of no medical contraindications
Order of October 16, 2017, Order of December 20, 2017, establishing the model for fitness opinions, unfitness opinions, individual health monitoring certificates, and proposals for workstation adjustments, and Order of September 26, 2025, establishing the models for certificates of no medical contraindications for the performance and execution of certain operations, as provided for in Articles R. 4323-56 and R. 4544-9 of the Labor Code AMENDED BY the Order of May 6 [Official Journal of May 10, 2026]
New models:
- for fitness opinions, unfitness opinions, individual health monitoring certificates, and proposals for workstation adjustments;
- certificates of no medical contraindications.
are to be taken into account since the 1stst June 2026
The order aims to remove, without altering existing legal provisions, references to the national health identity (INS) from the templates of opinions or certificates issued by health professionals in occupational health and prevention services and agricultural occupational health services.
As a reminder, these documents are provided by health professionals from occupational health and prevention services to employees examined, following the various types of examinations and visits conducted as part of the individual health monitoring of workers.