HSEES October 2026 deadline checklist

Energy audits, PFAS restrictions, and hedgerow protection: October 2026 brings several HSE regulatory deadlines. Discover the key dates and obligations your company needs to prepare for.

Marie Faucon
Consultante HSE
Publication : 
19.10.2026
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🔎 Key takeaways

  • Hedgerows : starting October 1st, any destruction must be declared via the single portal and offset by replanting; certain work is prohibited during nesting season.
  • Energy audit : new entities subject to the requirement that consume at least 2.75 GWh/year and do not have an EMS must complete their first audit by October 11, 2026.
  • Firefighting foams : as of October 23, the use of foams containing at least 1 mg/L of PFAS triggers new obligations, including labeling requirements.
  • Atmospheric emissions : certain incineration facilities (ICPE) 2771 and 3520-a ≥ 15 t/h must measure 49 PFAS in their emissions before October 31, 2026.

Please note: This article concerns French legislation. The requirements described may not apply in other countries.

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10/01/2026: Unified hedgerow regulations

A unified regulatory framework for hedgerow management is being implemented. It introduces new rules for businesses and project developers:

  • hedgerow destruction or maintenance work is prohibited during the bird nesting season, as defined by prefectural decree;
  • any hedgerow destruction must be declared via the unified hedgerow portal. The administration may subject the project to authorization. The applicant must minimize the extent of the destruction and compensate for it through replanting, ensuring that the new vegetation eventually provides functions at least equivalent to those of the destroyed hedgerow.

Note that for overseas departments and regions, these provisions come into force on September 1st , 2028.

10/11/2026: Deadline for energy audits for newly subject entities

Companies may be subject to energy audits or energy management systems based on their average annual final energy consumption.

Companies with an average annual final energy consumption of 2.75 GWh or more that have not implemented an Energy Management System (EMS) are required to conduct energy audits.

Companies with an average annual final energy consumption of 23.6 GWh or more are required to implement an EMS.

Legal entities newly subject to these requirements must complete their first energy audit no later than October 11, 2026. 

To learn more, read our dedicated article: New scope for energy audits and EMS

10/23/2026: Usage restrictions for PFAS in firefighting foams

As of October 23, 2026, the use of PFAS substances in firefighting foams at a concentration equal to or greater than 1 mg/L for the sum of all PFAS will trigger compliance with new measures. Labeling requirements, in particular, will apply.

To learn more, read our dedicated article: Prohibition on the use of PFAS substances in firefighting foams

10/31/2026: PFAS atmospheric emission measurements for certain ICPE 2771 and 3520-a facilities

Analysis of PFAS (*) in atmospheric emissions is mandatory for certain classified waste management facilities.

(*) any substance containing at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom, with no H/Cl/Br/I atoms attached.

The measurement campaign is mandatory by October 31, 2026, for incineration facilities classified under 2771 and/or 3520-a with a capacity of 15 t/h or more.

This sampling and analysis campaign must:

  • be carried out by laboratories or organizations accredited by COFRAC at each ducted atmospheric emission point resulting from the thermal treatment of waste at the facility, prior to any dilution with other effluents;
  • be carried out under conditions representative of the facility's normal operations;
  • 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).

Please note that the obligation to carry out the sampling and analysis campaign does not apply if it can be 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.

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