January 2026 HSEES Deadlines Reminder

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

Marie Faucon
Consultante HSE
Publication : 
15.01.2026
Table of Contents
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Please note: This article concerns French legislation. The requirements described may not apply in other countries.

01/01/2026: ICPE - Electronic submission of accident/incident declarations and associated accident/incident reports

ICPE operators must now submit on the platform https://entreprendre.service-public.gouv.fr/vosdroits/R71939

  • the declaration of accidents or incidents occurring due to the operation of the facility, likely to jeopardize protected interests;
  • the accident or incident report. Note: The following must be submitted in non-electronic format:
  • information related to defense-related facilities;
  • information that could compromise confidential interests.

01/01/2026: New template for the 8-stream certificate

As a reminder, textile waste is part of the 8-stream waste subject to sorting and recovery obligations since 2025. Operators of waste recovery facilities and intermediaries involved in waste collection, transport, trading, or brokerage must issue a certificate annually, before March 31, to waste producers or holders who have transferred this waste to them.

The certificate template now includes textile waste.

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

01/01/2026: New EPR scheme for Professional Packaging

From a strictly regulatory perspective, the new EPR scheme (*) for professional packaging came into force on January 1st January 2026.

(*) extended producer responsibility

However, it will only become operational from the 1st July 2026, according to the Minister for Ecological Transition.

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

To learn more: https://www.tennaxia.com/en/blog/dechets-point-sur-la-responsabilite-elargie-du-producteur

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

Battery waste management operators can now only manage battery waste if they have contracts concluded for the management of such waste with approved eco-organizations or with individual schemes for the battery category concerned.

Exemptions from this obligation are as follows:

  • collection, transit, or grouping operators;
  • distributors;
  • mechanics;
  • actors carrying out research and development activities aimed at testing, improving recyclability, or developing technical solutions for battery waste recycling, concerning the battery waste on which such activities are performed,

provided that the latter hand over the waste to a treatment operator who has himself concluded a contract either with an approved eco-organization or with a producer who has set up an approved individual scheme.

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

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

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

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

· The operator must make available the design and sizing documentation for the detector network. They must keep an up-to-date list of these detectors, including their functionality, and define and implement maintenance operations to ensure their long-term effectiveness. The operator must comply with the operating and maintenance conditions defined by the manufacturer of these detectors. The triggering of detectors and the corrective or preventive actions taken must be recorded.

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

January 1, 2026: Utilities for authorized ICPE sites

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

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

· The operator must continuously ensure the supply or availability of utilities that allow facilities to operate within their safety domain or that are necessary for powering safety barriers or risk control measures contributing to the safe shutdown or emergency stop of facilities.

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

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

January 1, 2026: Provisions relating to fire risk for flammable liquid storage

Many provisions concerning fire risk from decrees related to the storage of flammable liquids (*) come into force on January 1st 2026 for existing facilities.

Examples: fire-fighting strategy, availability of fire-fighting resources, staff training

(*) Decree of October 3, 2010, concerning the storage of manufactured above-ground flammable liquid tanks, operated within an authorized classified facility for environmental protection, and Decree of September 24, 2020, concerning the storage of flammable liquids in mobile containers, operated within an authorized classified facility for environmental protection.

January 1, 2026: Provisions for warehouses subject to heading 1510 (storage of combustible products)

The operator of a 1510 installation:

· must provide the prefect with a study by January 1, 2026, for declared installations (*), to determine the distances corresponding to thermal effects in the event of an 8 kW/m² fire;

· must not store flammable liquids of category 2 immiscible with water in fusible containers with a unit volume greater than 30 L, or category 2 miscible with water in containers with a unit volume greater than 230 L in covered storage (except for specific exemptions)

(*) as a reminder, the deadline was January 1st 2023 for registered and authorized installations

January 1, 2026: ICPE - Communication format for hazardous phenomena mapping in danger studies

Required danger studies must now include mapping delineating zones by type of effect, aggregated by intensity, as follows:

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

These mappings must be provided in a georeferenced electronic format so that they can be directly used by administrative services.

January 1, 2026: Public access buildings (ERP): display of intervention plan & rules for gas installations

Various provisions of the ERP regulations now concern ERPs:

· the display of the intervention plan, aimed at facilitating emergency response, now applies to all Category 5 ERPs 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, … (*)

(*) 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, in the absence of changes to buildings and installations. When expansion or development work is undertaken, the ERP regulations apply only to the modified parts.

01/01/2026: Enhanced fire prevention in the waste sector

Fire prevention provisions come into force on January 1, 2026 for the following ICPE installations:

· installations requiring authorization under headings 2710 (collection of waste brought by the initial producer of such waste), 2712 (storage, depollution, dismantling or cutting of end-of-life vehicles or various end-of-life transport means), 2718 (transit, regrouping or sorting of hazardous waste), 2790 (treatment of hazardous waste) and 2791 (treatment of non-hazardous waste);

· installations requiring declaration under heading 2718 (transit, regrouping or sorting of hazardous waste);

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

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

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

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

Health professionals (occupational physicians, etc.) from occupational health and prevention services (SPST) and agricultural occupational health services (SSTA) must have completed training to ensure the reinforced 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 particular situations. It is renewed every 5 years or, alternatively, carried out continuously throughout the year, with a minimum of 7 hours of continuous training.

It should be noted that as of July 1, 2026, SPSTs and SSTAs must hold an additional accreditation valid for 5 years.

01/01/2026: New biocidal product certificates

Professionals carrying out:

  • an activity as a decision-maker, purchaser or distributor of biocidal products types 2, 3 and 4 must obtain the "disinfectant biocidal product certificate" before January 1, 2026
  • an activity as a professional user or distributor or purchaser of biocidal products type 21 must obtain the "other biocidal products certificate" or "pest control biocidal product 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 food and animal feed

Type 21: Antifouling products

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

In any mine or quarry operation or group of operations, the employer must establish one or more functional structures, under their authority, to advise them on occupational safety and health.

The functional structure must, after consulting the CSE, acquire adequate resources in terms of equipment and competent employees to handle occupational risk protection and prevention activities, as stipulated by the Labor Code.
The employer assigns to this functional structure:

  • a competent employee for at least one day per month per ten employees;
  • in a mine operation or group of mine operations and in quarries where more than two hundred employees are employed, at least one full-time competent employee.

In quarries, the employer has the choice to:

  • either use the functional structure mentioned above and under the conditions specified above,
  • or, after consulting the CSE, use an occupational risk prevention specialist working in quarries and possessing professional qualifications.

As a reminder, previously, any quarry operator had to either create a functional structure for occupational safety and health or use an approved external prevention organization. Until February 28, 2026, in quarries, the employer or operator may use an approved external prevention organization. Accreditations valid on January 1, 2026, remain valid until February 28, 2026.

22/01/2026: Signage for smoking areas

Signage for smoking areas (*) established before July 22, 2025, and compliant with the decree of December 1, 2010, will be considered obsolete after January 22, 2026.

It must be replaced by the signage stipulated in the decree of July 21, 2025.

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