The 1510 classification is changing: what impact will this have on covered warehouses?

As part of the Lubrizol action plan, the 1510 heading governing covered warehouses has been updated. Find out about the new classification thresholds and more stringent requirements.

Marie Faucon
EHS Consultant
Update : 
12.09.2025
Publication: 
11.01.2021
Contents
Example H2
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One year after the Lubrizol accident, regulations are being tightened in terms of industrial risk prevention and accident management. These changes are part of the government's Lubrizol action plan, which aims to provide feedback on the major accident that occurred in Rouen on September 26, 2019. What are the main measures affecting warehouses classified under heading 1510? This concerns the storage of combustible materials and products in covered warehouses. Sites not classified under this heading may be newly classified.

What is a combustible material or product?

Combustible materials or products are materials or products, including waste, that are not classified as incombustible.

Non-combustible: materials or products made exclusively of materials classified A1 or A2-s1-d0 as defined by the Order of November 21, 2002, or materials or products qualified as non-combustible following tests carried out in accordance with a protocol recognized by the Ministry of the Environment.

Examples of combustible materials involved: packaging, pallets, plastic film, textiles, cardboard, etc.

Who is now concerned by the 1510 heading?

Heading 1510 on covered warehouses now covers facilities with a roof (new), dedicated to the storage of combustible materials or products in quantities exceeding 500 tonnes (unchanged), exceeding the classification thresholds, unless these facilities are :

  • warehouses used for the storage of materials, products or substances classified under a single heading of this nomenclature (*)
  • or buildings intended exclusively for the storage of motor vehicles and their trailers (unchanged)
  • or establishments open to the public (ERP) (unchanged)
  • or exclusively refrigerated warehouses (**)

(*) New: a warehouse is considered to be used for the storage of products classified under a single nomenclature heading when the total quantity of other combustible materials or products present in the warehouse is less than or equal to 500 tonnes.

Please note: storage facilities classified under headings 4XXX or under headings 1511, 1530, 1532, 2160, 2662, 2663 may now be covered by heading 1510, depending on the quantity of combustible materials/products, whereas previously these storage facilities were not necessarily classified under heading 1510.

(**) New definition: a warehouse is exclusively refrigerated when the quantity of combustible materials or products other than the materials or products kept in the refrigerated warehouse (temperature and/or humidity conditions regulated and maintained at a temperature of 18°C or less, depending on the product's specific conservation criteria) is less than or equal to 500 tons.

How to classify: an upcoming application guide

The French Ministry of the Environment has announced a first update of the 1510 application guide, to be released shortly. This update will explain the procedures for classifying warehouses under heading 1510.

It will help to answer the following questions: how should different warehouses be classified? several buildings? dispersed warehouses? ... should WIP be taken into account?

What changes have been made to the classification thresholds?

A new criterion to take into account

Warehouse construction projects subject to systematic environmental assessment (*) are now subject to authorization, whatever their volume.

* concerns works and constructions creating a footprint greater than or equal to 40,000 m² in an area other than :

  • urban zones known as "zones U" where a local urban development plan applies;
  • sectors where construction is authorized, when a carte communale is applicable;
  • the urbanized parts of the commune, in the absence of an applicable local urban plan or carte communale.

What about volumes?

The authorization system has been made more flexible. The lower threshold for this system has been raised from 300,000m3 to 900,000m3 (warehouse volume).

As a result, the registration system has been extended. The upper threshold of this regime has been raised from 300,000m3 to 900,000m3 ( warehouse volume).

The declaration system remains unchanged, and still covers volumes of 5,000m3 or more but less than 50,000m3 ( warehouse volume) .

The double classification with heading 1510 has been abolished for certain storage facilities.

As long as they are carried out within a warehouse classified under heading 1510, storage activities :

  • paper/cardboard or combustible materials (heading 1530) ;
  • wood (heading 1532) ;
  • plastics (heading 2662) ;
  • tires and products in which at least 50% of the total unit mass is composed of polymers (heading 2663);

are no longer to be classified under their respective headings, but must be integrated and encompassed under heading 1510.

Fire prevention and management

The decree of April 11, 2017 ("AMPG 1510") sets out the general requirements applicable to covered warehouses subject to authorization, declaration or registration under heading 1510, and has been amended to reinforce fire prevention and management requirements.

The main changes :

  • Detailed statement of materials stored for facilities subject to registration or authorization (January1, 2022)
  • Obligation to make available elements of risk visit reports that relate to recommendations arising from the risk analysis carried out by the insurer (from January 1, 2021)
  • Compliance with storage heights for liquid hazardous materials (by January 1, 2023 or 2026 depending on the case)
  • Compliance with distances between the external walls of warehouse cells and external storage likely to encourage the outbreak of fire (by January 1, 2025).
  • Creation of a fire defense plan (December 31, 2023)
  • Proof of availability of personnel or organization and equipment (January 1, 2022).
  • Updating of the Internal Operations Plan (POI) (if existing) with the means and methods planned for restoring and cleaning up the environment after an accident, and the forecast arrangements for ensuring continuity of water supply in the event of the fire lasting longer than 2 hours (January 1, 2022).
  • Carry out a study of thermal effects, with compensatory measures (sprinklers, 2-hour firewall) put in place where necessary for certain existing facilities.
  • Addition of specific provisions for refrigeration cells and chambers
  • New inspection points for notifiable installations

Conclusion

As part of the Lubrizol action plan, regulations applicable to the storage of combustible materials and products in covered warehouses have been significantly tightened.

We recommend :

  • until the application guide is updated, list the combustible materials stored in warehouses on your site, including the associated tonnage and warehouse volume;
  • once the guide has been published, to determine your possible classification under heading 1510 based on the classification procedures indicated in the guide;
  • in the event of classification under heading 1510 :
    • apply for grandfathering rights before January1, 2022
    • identify and apply the applicable requirements of AMPG 1510

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Photo credit: Marcin Jozwiak