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In this article, we review the changes to the nomenclature for Classified Installations for Environmental Protection (ICPE) that took place in 2021, for which it may be necessary to submit a grandfathering request to the authorities.
As a reminder, when the ICPE nomenclature is modified and:
- It impacts the classification regime of an existing activity or installation, either raising or lowering it;
- It brings an activity or installation under a classification regime.
The operator must submit a grandfathering request to the authorities within one year of the effective date in order to continue operating the activity or installation in question.
Note: If an activity or installation is no longer classified due to this nomenclature change, it is advisable to notify the authorities as well. Please note that a classified activity or installation that remains inactive for three consecutive years loses its classification status.
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January1st, 2022: Nomenclature modification – headings 1510, 1511, 1530, 1532, 2662, 2663, and 2160
(Decree No. 2020-1169 of September 24, 2020)
These nomenclature changes came into effect on January1st, 2021. Any necessary grandfathering request must be submitted before January 1stst January 2022.
Heading 1510 : Warehouses storing more than 500 tonnes of combustible material
- Revision of warehouse volume calculation methods in accordance with the updated warehouse classification guide [https://aida.ineris.fr/liste_documents/1/102942/0]
- Modification of the authorization regime:
- Warehouse construction projects subject to systematic environmental assessment (*) are now subject to the authorization regime, regardless of their volume.
- The authorization regime has been relaxed. The lower threshold for this regime has been increased from 300,000 m3 to 900,000 m3 (warehouse volume). Consequently, the registration regime has been expanded. The upper threshold for this regime has been increased from 300,000 m3 to 900,000 m3 (warehouse volume).
- Elimination of dual classification with headings 1511, 1530, 1532, 2662, and 2663.
Heading 1511: Exclusively refrigerated warehouses
- Elimination of the authorization regime. Consequently, the registration regime has been expanded to include warehouses with a volume of 50,000 m3or more.
- Elimination of dual classification with heading 1510.
Heading 1530: Storage of paper, cardboard, or similar combustible materials
- Elimination of the authorization regime. Consequently, the registration regime has been expanded to include storage facilities with a volume of 20,000 m3or more.
- Elimination of dual classification with heading 1510.
Heading 1532: Storage of wood or similar combustible materials
- Changes to the authorization regime. It now only applies to the storage of materials capable of releasing flammable dust with a storage volume exceeding 50,000 m³. For other types of materials, storage facilities are classified under the registration regime when the volume exceeds 20,000 m3.
- Removal of dual classification with heading 1510.
Heading 2662: Polymer storage
- Removal of the authorization regime. Consequently, the registration regime has been expanded to include storage facilities with a volume of 1,000 m³ or more3.
- Removal of dual classification with heading 1510.
Heading 2663: Storage of tires and products where at least 50% of the total unit mass consists of polymers
- Removal of the authorization regime. Consequently, the registration regime has been expanded to include storage facilities with a volume of 2,000 m³ or more3 (for cellular or expanded products) or 10,000 m³ or more3 (in other cases).
- Removal of dual classification with heading 1510.
Heading 2160: Silos and bulk storage facilities for cereals, grains, food products, or any organic product that releases flammable dust
- Removal of dual classification with heading 1532.
September 1, 2022: Amendment to the nomenclature – headings 2910 and 2921
(Decree no. 2021-976 of July 21, 2021)
These changes came into effect on September 1st , 2021. Any requests for grandfathering must be submitted by September 1st , 2022.
Heading 2910: Combustion installations
Changes to the calculation method for the rated thermal input used for classification. This rated thermal input is now calculated at the installation level rather than the site level. Consequently, a single site may contain multiple combustion installations with different classification regimes. Technical guidance sheets [https://aida.ineris.fr/taxonomy/term/120] have been published by the Ministry to clarify these classification procedures.
Heading 2921: Evaporative cooling installations using water dispersion in an airflow
Creation of a sub-heading for the classification of heat recovery installations using water dispersion in flue gases emitted into the atmosphere, subject to a single declaration regime.
December 4, 2022: Amendment to the nomenclature – headings 2120 and 2445
These changes came into effect on December 4, 2021. Any requests for grandfathering must be submitted by December 4, 2022.
Heading 2120: Breeding, sale, transit, boarding, keeping, shelters, pounds, etc., for dogs
- Introduction of a registration regime for facilities housing between 51 and 250 dogs. Consequently, facilities subject to authorization are now those with more than 250 animals (compared to 50 previously).
- Dog keeping and shelter facilities are now explicitly mentioned in the heading title.
Heading 2445: Paper and cardboard processing
- Replacement of the authorization regime with registration for paper and cardboard processing activities with a production capacity exceeding 20 tonnes per day.
Illustration credit: 114334797 @Jérôme Rommé