March HSEES deadlines reminder

In March 2024, a number of HSEES regulatory obligations expire: HFO leak tests, PFAS analyses, GEREP declarations and waste and biowaste certificates.

Marie Faucon
EHS Consultant
Update : 
12.09.2025
Publication: 
08.03.2024

11/03/2024: Leak testing and leak detection for HFO refrigerants

HFOs (unsaturated hydro(chloro)fluorocarbons) are refrigerants with low global warming potential and are often used to replace HCFCs and HFCs. HFOs include R-1234yf and R-1234ze.

The new F-GAS III regulation requires leak testing for the following equipment containing more than 1 kg or more of non-foamed unsaturated HFOs:

  • stationary refrigeration, air conditioning and heat pump equipment ;
  • fixed fire protection equipment ;
  • organic Rankine cycles ;
  • electrical switching devices ;
  • refrigerated trucks and trailers.

The frequency of these checks depends on the HFO load.

In addition, fixed refrigeration, air conditioning, heat pump and fire protection equipment must have a leak detection system whenever the HFO charge exceeds 100 kg.

28/03/2024: Deadline for the first PFAS analysis campaign for ICPEs subject to authorization under one of the headings 2791, 3510, 3531, 3532, 3540, 3560 or headings not mentioned.

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

ICPEs subject to authorization for headings 2791, 3510, 3531, 3532, 3540, 3560 or headings not mentioned in the Order of June 20, 2023 must carry out a PFAS substance analysis campaign every month, for 3 consecutive months.

For more information: https: //hse-reglementaire.com/substances-pfas-zoom-sur-les-obligations-dinventaire-et-danalyses-des-substances-presentes-dans-les-icpe-soumises-a-autorisation/

03/31/2024: GEREP declaration for 2023

The GEREP declaration for reference year N must be completed on the dedicated website by March 31 N+1 at the latest for plants subject to the GEREP declaration (and not covered by the greenhouse gas Emissions Trading Scheme (ETS)).

To find out more about the GEREP declaration: Terms and conditions of the annual GEREP declaration of pollutant emissions - https://hse-reglementaire.com/

03/31/2024: Deadline for bio-waste recovery certificate

Before March 31st each year, collection and recovery service providers must send producers or holders of biowaste who entrusted them with waste the previous year, a certificate stating the quantities expressed in tons, the nature of the waste they collected separately for recovery the previous year, and the final recovery destination.

To find out more about bio-waste sorting and collection obligations: Source separation of bio-waste: everyone concerned - EHS Réglementaire - https://hse-reglementaire.com/

03/31/2024: Deadline for 7-stream waste certification

Operators of waste recovery facilities and intermediaries involved in waste collection, transport, trading or brokerage are required to send an attestation each year, by March 31, to waste producers or holders who have sold them waste paper, metal, plastic, glass, wood, mineral fractions and gypsum ("7-stream" waste).

This certificate must mention the quantities expressed in tons, the nature of the waste entrusted to them in the previous year for recovery or disposal, and the final recovery destination (type of facility and new geographical location).

03/31/2024: Technical certification required for agents involved in explosives detection by dog

The end of the transitional period during which canine-detection missions can be carried out by agents holding only a professional card allowing them to exercise the activity of human surveillance and guarding had been postponed to March 31, 2024 (as opposed to December 31, 2023 initially).