Reminder of HSEES deadlines for January 2026

Don't miss out on the new environmental, health, safety, energy and security regulations that could affect you!

Marie Faucon
EHS Consultant
Update : 
15.01.2026
Publication: 
15.01.2026
Contents
Example H2
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01/01/2026: ICPE - Digitization of the transmission of accident/incident reports and associated accident/incident reports

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.

01/01/2026: New model for the 8-flow certificate

As a reminder, textile waste is one of the eight waste streams subject to mandatory sorting and recovery since 2025. Operators of waste recovery facilities and intermediaries involved in the collection, transport, trading, or brokering of waste must issue a certificate each year, before March 31, to the producers or holders of waste who have transferred this waste to them.

The certificate template now includes textile waste.

https://www.tennaxia.com/blog/tri-des-dechets-non-dangereux-quelles-sont-vos-obligations

01/01/2026: New EPR scheme for professional packaging

From a strictly regulatory standpoint, the new EPR (*) system for commercial packaging came into effect on January1, 2026.

(*) extended producer responsibility

However, according to the Minister for Ecological Transition, it will not be operational until July1, 2026.

Thus, producers of packaged products or packaging will have to either join an eco-organization or set up an individual system.

For more information: https://www.tennaxia.com/blog/dechets-point-sur-la-responsabilite-elargie-du-producteur

01/01/2026: Contract with an eco-organization or an approved individual system for battery waste management operators

Waste management operators can now only manage battery waste if they have contracts in place for the management of this waste with approved eco-organizations or with individual systems for the relevant battery category.

The exemptions to this obligation are as follows:

  • collection, transit, or consolidation operators;
  • distributors;
  • mechanics;
  • actors carrying out research and development activities aimed at testing, improving recyclability, or developing technical solutions for recycling battery waste, with regard to battery waste on which such activities are carried out,

provided that they deliver the waste to a treatment operator who has itself entered into a contract either with an approved eco-organization or with a producer who has set up an approved individual system.

01/01/2026: Monitoring and detector network for authorized ICPE sites

For facilities for which the complete application for authorization (*) was submitted before September 1, 2022, the work identified as necessary to comply with the following provisions had to be completed before January 1, 2026:

(*) subject to the decree of October 4, 2010 (note: excluding classified facilities subject to sections 2101 or 3660)

· The operator must install a network of detectors in areas identified as potential sources of fire or explosion in the hazard study, which could lead to one or more identified hazardous phenomena causing irreversible effects beyond the site boundaries, as well as in premises housing equipment used to protect the facilities.

· The operator keeps the design and sizing documentation for the detector network available. It keeps an up-to-date list of these detectors and their functionality, and determines and implements maintenance operations designed to maintain their effectiveness over time. The operator complies with the operating and maintenance conditions defined by the manufacturer of these detectors. The triggering of detectors and any corrective or preventive actions taken shall be recorded.

· For facilities where one or more hazardous phenomena identified in the hazard study lead to irreversible effects, within the meaning of the aforementioned order of September 29, 2005, which extend beyond the boundaries of the site, the associated detector networks shall have a relay system with alarm transmission to the operator at all times, via relay to the control room, the guard post, or via remote monitoring. In the case of a remotely monitored installation, intervention following the triggering of an alarm by one of the detectors shall be carried out within a maximum of thirty minutes by a person who is competent, trained, and authorized to implement the initial response measures.

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01/01/2026: Uses of ICPE sites requiring authorization

For facilities for which the complete application for authorization (*) was submitted before September 1, 2022, the work identified as necessary to comply with the following provisions had to be completed before January 1, 2026:

(*) subject to the decree of October 4, 2010 (note: excluding classified facilities subject to sections 2101 or 3660)

· The operator shall ensure the continuous supply or availability of utilities that enable the facilities to operate within their safety margins or that are necessary to power safety barriers or risk control measures contributing to the safe shutdown or emergency shutdown of the facilities.

· The operator defines the conditions and procedures for maintaining the safety of the facilities in these situations and, where applicable, the conditions under which the facilities are shut down. These conditions and procedures are formalized in a procedure.

· Safety barriers or risk control measures are maintained in service or automatically placed in a safe position in the event of a failure of the main control power supply.

01/01/2026: Provisions relating to the fire risk of flammable liquid storage facilities

Many provisions relating to fire risk in regulations concerning the storage of flammable liquids (*) will come into force on January1, 2026, for existing facilities.

Examples: firefighting strategy, availability of firefighting equipment, staff training

(*) Order of October 3, 2010 relating to the storage of flammable liquids in manufactured above-ground tanks, operated within a facility classified for environmental protection subject to authorization, and Decree of September 24, 2020 relating to the storage of flammable liquids in mobile containers, operated within a facility classified for environmental protection subject to authorization.

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01/01/2026: Provisions for warehouses subject to heading 1510 (storage of combustible products)

The operator of a facility 1510:

· must provide the prefect before January 1, 2026, for facilities subject to declaration (*), with a study to determine the distances corresponding to thermal effects in the event of a fire of 8 kW/m²;

· Do not store flammable liquids in fusible containers for Category 2 liquids that are not miscible with water in containers with a unit volume greater than 30 L and Category 2 liquids that are miscible with water in containers with a unit volume greater than 230 L in covered storage (with some exceptions).

(*) As a reminder, the deadline was January1, 2023, for facilities requiring registration and authorization.

01/01/2026: ICPE - Format for communicating hazard mapping in hazard studies

The required hazard studies must now include maps delineating the following zones by type of effect, aggregated by intensity:

  • overpressure effects of probability classes A, B, C, and D;
  • overpressure effects of probability class E;
  • toxic effects of probability classes A, B, C, and D;
  • toxic effects of probability class E;
  • thermal effects of probability classes A, B, C, and D;
  • thermal effects of probability class E.

These maps are provided in a georeferenced electronic format so that they can be used directly by government departments.

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01/01/2026: Establishments open to the public (ERP): display of the emergency plan & rules for gas installations

Various provisions of the ERP regulation now apply to public buildings:

· The display of the emergency response plan to facilitate rescue operations now applies to all category 5 public buildings, and no longer only to those located on upper floors or in basements.

· Technical regulations for gas installations such as heating, refrigeration, domestic hot water production, etc. (*)

(*) As a reminder, with the exception of administrative rules concerning maintenance and/or technical inspections, the ERP regulations and their amendments do not apply to existing establishments, provided there are no changes to the buildings and facilities. When extension or renovation work is undertaken, the ERP regulations apply only to the modified parts.

01/01/2026: Strengthening firefighting efforts in the waste sector

Fire safety provisions will come into effect on January 1, 2026, for the following ICPE facilities:

· Facility authorized under headings 2710 (collection of waste brought in by the original producer of such waste), 2712 (storage, depollution, dismantling, or cutting up of end-of-life vehicles or various end-of-life means of transport), 2718 (transit, consolidation, or sorting of hazardous waste), 2790 (treatment of hazardous waste) and 2791 (treatment of non-hazardous waste);

· facility subject to declaration under heading 2718 (transit, consolidation, or sorting of hazardous waste);

· Facility subject to declaration under heading No. 2711 (waste electrical and electronic equipment), 2713 (non-hazardous metals or metal waste, non-hazardous metal alloys or metal alloy waste), 2714 (non-hazardous waste of paper, cardboard, plastics, rubber, textiles, wood) or 2716 (non-hazardous non-inert waste);

· facilities for the storage, decontamination, dismantling, or cutting up of waste from pleasure boats or sports boats subject to registration under heading 2712-3.

These provisions stem from recent regulatory changes aimed at strengthening fire risk prevention in the waste sector.

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01/01/2026: Specific training for the SIR of employees exposed to ionizing radiation

Health professionals (occupational physicians, etc.) working in occupational health and safety services (SPST) and agricultural occupational health services (SSTA) must have completed training in order to provide enhanced individual monitoring (SIR) of workers exposed to ionizing radiation. The training includes specific training on this subject and, if necessary, additional modules for monitoring employees in special situations. It is renewed every five years or, alternatively, carried out continuously throughout the year, with a minimum of seven hours of continuing education.

Please note that as of July 1, 2026, SPSTs and SSTAs must hold an additional certification valid for five years.

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01/01/2026: New biocides

Practicing professionals:

  • Any entity acting as a decision-maker, purchaser, or distributor of type 2, 3, and 4 biocidal products must obtain the "certibiocide désinfectant" certificate before January 1, 2026.
  • a professional user, distributor or purchaser of type 21 biocidal products must obtain the "certibiocide other products" or "certibiocide pests" certificate before January 1, 2026.

Type 2: Disinfectants and algaecides not intended for direct application to humans or animals

Type 3: For veterinary hygiene

Type 4: Surfaces in contact with foodstuffs and animal feed

Type 21: Anti-fouling products

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01/01/2026: New organization for occupational risk prevention in mines and quarries

In any mining or quarrying operation or group of operations, the employer must set up one or more functional structures, under his authority, to advise him on occupational health and safety matters.

The functional structure must, after consulting with the works council, equip itself with adequate resources in terms of equipment and skilled employees to carry out occupational risk protection and prevention activities, as provided for in the Labor Code.
The employer shall assign to this functional structure:

  • one competent employee at least one day per month for every ten employees;
  • in a mine or group of mines and in quarries employing more than two hundred employees, at least one competent full-time employee.

In quarries, the employer has the choice of:

  • either use the functional structure mentioned above and under the conditions specified above,
  • or, after consulting the CSE, to call upon the services of an occupational risk prevention specialist who works in quarries and has the necessary professional qualifications.

As a reminder, previously, all quarry operators were required to either set up a functional occupational health and safety structure or call on the services of an approved external prevention organization. Until February 28, 2026, employers or operators of quarries may use an approved external prevention organization. Approvals valid on January 1, 2026, will remain valid until February 28, 2026.

January 22, 2026: Signage for smoking areas

Signs indicating smoking areas (*) established before July 22, 2025, and compliant with the decree of December 1, 2010, shall be deemed invalid after January 22, 2026.

It must be replaced by the rate set by the decree of July 21, 2025.

(*) smoking areas (does not apply to outdoor areas)