HSEES Deadlines Reminder for October 2025

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

Marie Faucon
Consultante HSE
Mise à jour : 
23.10.2025
Publication : 
23.10.2025
Table of Contents
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Please note: This article concerns French legislation. The requirements described may not apply in other countries.

October 1, 2025: Individual health monitoring for employees who may be assigned to a position requiring an operating permit or electrical authorization

As of October 1, 2025, reinforced individual monitoring (SIR) is abolished for workers requiring operating permits and electrical authorizations.

It is replaced by a certificate confirming the absence of medical contraindication, valid for 5 years and issued by the occupational physician, for the issuance of:

-        the operating permit;

-        the electrical authorization for live work or operations near bare live parts

Note that fitness certificates issued under SIR prior to October 1st 2025 will serve as the newly provided certificate for a period of five years from their issuance.

To learn more: https://www.tennaxia.com/en/blog/retraits-de-la-liste-des-travailleurs-soumis-a-suivi-individuel-renforce-de-letat-de-sante

October 1, 2025: New criteria for energy audits and energy management systems (EMS)

The new criteria are established based on energy consumption and no longer on the size, turnover, or balance sheet of companies.

Companies whose average annual final energy consumption is greater than or equal to 2.75 GWh and have not implemented an EMS are subject to conducting energy audits.

Companies whose average annual final energy consumption is greater than or equal to 23.6 GWh are subject to implementing an EMS.

To learn more: https://www.tennaxia.com/en/blog/nouveau-perimetre-des-audits-energetiques-et-du-sme

https://www.tennaxia.com/en/blog/les-enjeux-energetiques-des-centres-de-donnees-data-centers

31/10/2025: Measurement of atmospheric PFAS emissions for ICPE 2770 and 3520-b

PFAS (*) analyses in atmospheric emissions are mandatory for certain classified facilities in the waste sector.

(*) any substance containing at least one fully fluorinated methyl carbon atom (CF3-) or methylene (-CF2-), without any bound H/Cl/Br/I atoms.

This sampling and analysis campaign must:

  • be carried out by laboratories or organizations accredited by COFRAC at each channeled atmospheric emission point resulting from the thermal treatment of waste from the facility before any dilution with other effluents;
  • be carried out under conditions representative of the facility's normal operation;
  • cover 49 PFAS substances as well as hydrogen fluoride (HF) and the main associated peripheral parameters (flow rate, oxygen content, temperature, pressure, and water vapor content).

Note that the obligation to carry out the sampling and analysis campaign does not apply if it is demonstrated that the composition of the waste streams entering the facility is stable over time, and that the incoming waste does not contain PFAS substances.

The measurement campaign is mandatory as of October 1, 2025, for classified facilities 2770 (*) and/or 3520-b, regardless of their capacity, with the exception of household waste incineration units that would be classified under heading 2770 and/or 3520-b solely for the purpose of treating infectious healthcare waste,

(*) Thermal treatment facility for hazardous waste, excluding facilities referred to in headings 2792 and 2793 and combustion facilities consuming only waste meeting the definition of biomass as per heading 2910

(**) Incineration or co-incineration of hazardous waste with a capacity exceeding 10 tonnes per day