September 2023 HSEES deadlines reminder

September 2023 marks several key EHS deadlines: inventory and analysis of PFAS substances for ICPEs and declaration of energy consumption on OPERAT.

Marie Faucon
EHS Consultant
Update : 
12.09.2025
Publication: 
21.09.2023

09/28/2023: Deadline for inventories of PFAS substances used, produced, treated or discharged, as well as PFAS substances produced by degradation for ICPEs subject to authorization.

Per- and polyfluoroalkylated substances, also known as PFAS, degrade very little after use or release into the environment.

ICPEs subject to authorization must draw up an inventory of PFAS substances used, produced, treated or released, as well as PFAS substances produced by degradation. If such substances have been used, produced, treated or released before June 28, 2023, they are also included in the list, together with the date on which they are likely to have been released.

Find out more: PFAS Substances: a closer look at obligations

09/28/2023: Deadline for the first PFAS analysis campaign for ICPEs subject to authorization under one of the headings 2660, 2661, 2760, 2790, 3410, 3420, 3440, 3450, 4713

ICPEs subject to authorization under headings 2660, 2661, 2760, 2790, 3410, 3420, 3440, 3450, 4713 must carry out a PFAS substance analysis campaign every month, for 3 consecutive months. The first campaign must be carried out before September 28, 2023.

Find out more: PFAS Substances: a closer look at obligations

30/09/2023: Deadline for declaring consumption for 2022 on the OPERAT platform if concerned by the Eco Energie Tertiaire scheme (tertiary sector decree).

Every year, before September 30, those subject to the Eco Energie Tertiaire (or "tertiary decree") scheme must declare their consumption for the previous year on the OPERAT platform.

Find out more: Tertiary Decree: what you need to know