Is a section of your ICPE classification affected?

This article details the changes to the ICPE nomenclature, notably for headings 2915, 2925, 2930 and 2940, and the elimination of certain double classifications with IED headings.

Marie Faucon
EHS Consultant
Update : 
12.09.2025
Publication: 
10.09.2020
Contents
Example H2
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The ICPE nomenclature changes regularly. Perhaps a section of your ICPE classification has recently been modified?

We offer you an update on the main changes introduced by decree no. 2019-1096 of October 28, 2019 [1] and decree no. 2020-559 of May 12, 2020 [2] concerning headings 2925, 2915, 2930 and 2940, as well as the elimination of double classification with headings 3000.

Note: the new 1978 heading, concerning the use of organic solvents, has already been covered by our experts.

Heading 2925 (Battery charging workshops)

1) What wattage should be taken into account?

It is now specified that the maximum current power usable for the charging operation is understood as the cumulative deliverable charging power of all workshop infrastructures. In other words, all the charging power available on site must be added together.

2) How are new technologies taken into account?

This section has been amended to take account of the development of new technologies associated with battery charging, based on the use of lithium (e.g. lithium-ion batteries) and the associated fire hazards.

It has therefore been restructured to distinguish the case where the charging operation produces hydrogen from the situation where the charging operation does not produce hydrogen. A new declaration system has been created for electric accumulators whose charging operation does not produce hydrogen, when the maximum current power usable for this operation exceeds 600 kW, with the exception of charging infrastructures for electric vehicles open to the public (sub-heading 2925-2).

Heading 2915 (Heating processes using combustible organic substances as heat transfer fluids)

The authorization system has been replaced by the registration system. Heating processes where the operating temperature of the heat transfer fluid is equal to or higher than its flash point AND where the total quantity of fluid present in the installation (at 25°C) exceeds 1,000 l (subheading 2915-1) are now subject to registration.

An order dated May 12, 2020 [3] defines the general requirements applicable to facilities covered by heading 2915 under the registration regime. It applies to facilities registered on or after May 15, 2020. However, it does not apply to existing classified facilities already subject to a prefectoral authorization order on May 15, 2020.

Heading 2930 (Repair and maintenance workshops for motor vehicles and engines)

For both sub-headings, the authorization system has been replaced by the registration system. The following are now subject to registration:

  • repair and maintenance workshops for motor vehicles and engines with a surface area of over 5,000 m² (subheading 2930-1)
  • installations for applying, baking and drying varnish, paint and primer on motor vehicles and machines, where the maximum quantity of products likely to be used exceeds 100 kg/d (subheading 2930-2).

For subheading 2930-2, classification as a declaration with periodic inspection can no longer be based on the annual quantity of solvents contained in the products likely to be used. To be subject to the DC regime, installations must be likely to use a quantity of products greater than 10 kg/d but less than or equal to 100 kg/d.

A decree dated May 12, 2020 [4] defines the general requirements applicable to facilities covered by heading 2930 under the registration regime. It applies to new facilities registered on or after May 15, 2020, as well as to existing facilities duly authorized under the conditions specified in Appendix I. In the event of an extension requiring a new registration, all articles are applicable to the entire facility, with the exception of articles 2.1 (layout rules), 4.2 (fire behavior), 4.3 (accessibility) and 6.4 (chimney height), which are only applicable to the constructive part of the extension.

Heading 2940 (Application, coating, lacquering, laminating, impregnating, baking, drying of varnish, paint, primer, glue, coating, etc.).

The authorization system has been replaced by the registration system. The following are now subject to registration:

  • plants that process liquid-based products using a "dip" process (including electrophoresis), and where the maximum quantity of products likely to be present in the plant exceeds 1,000 l (subheading 2940-1);
  • plants that use liquid-based products by any process other than "dipping" (spraying, coating, other processes) and where the maximum quantity of products likely to be used exceeds 100 kg/day (subheading 2940-2);
  • plants using powders based on organic resins, where the maximum quantity of products likely to be used exceeds 200 kg/day (subheading 2940-3).

In addition, coating, lacquering, laminating and impregnation activities are now clearly mentioned, and the list of exclusions (initially partial) is detailed.

The rule for weighting the quantities of products used in the plant has been updated:

  • quantities of products based on flammable liquids with hazard statements H224, H225 or H226 (no longer 1st category - flash point below 55°C) or halogenated liquids are assigned a coefficient 1 ;
  • quantities of liquid-based products with a flash point between 60°C and 93°C (no longer 2nd category - flash point greater than or equal to 55°C) or containing less than 10% organic solvents at the time of use are assigned a coefficient 1/2.

An order dated May 12, 2020 [5] defines the general requirements applicable to facilities covered by heading 2940 under the registration regime. It applies to new facilities registered on or after May 15, 2020, as well as to duly authorized existing facilities, under the conditions specified in Appendix I. In the event of an extension requiring a new registration, all articles apply to the entire facility, with the exception of articles 2.1 (layout rules), 4.2 (fire behavior), 4.3 (accessibility), 4.4 (smoke extraction) and 6.4 (chimney height), which apply only to the constructive part of the extension.

Which double classifications with IED headings have been eliminated?

The following headings have been modified to exclude from their scope installations that are otherwise subject to authorization under headings 3000 (IED):

  • 2102 (pig breeding, sales, transit, etc.), excluding 3660 (intensive breeding).
  • 2111 (poultry farming, sales, transit, etc.), excluding 3660 (intensive farming).
  • 2210 (slaughter of animals), excluding 3641 (operation of slaughterhouses).
  • 2260 (crushing, grinding, screening, shredding), excluding 3610 (manufacture of pulp, paper, cardboard, wood panels), 3620 (textile pre-treatment or dyeing), 3660 (intensive livestock farming).

What should I do if one of these sections concerns me?

We recommend :

  • analyze the impact of these changes on your ICPE classification
  • and, if necessary, inform the administration of the change in situation (request for prior rights for a declared site) before May 15, 2021 for headings 2915, 2930 and 2940, and before October 31, 2020 for the other headings.

[1] Decree no. 2019-1096 of October 28, 2019 modifying the nomenclature of classified installations for environmental protection [JORF of October 30, 2019].

[2] Decree no. 2020-559 of May 12, 2020 modifying the nomenclature of classified installations for environmental protection [JORF of May 14, 2020].

[3] Arrêté du 12 mai 2020 relatif aux prescriptions générales applicables aux installations relevant du régime de l'enregistrement au titre de la rubrique n° 2915 (Procédés de chauffage utilisant comme fluide caloporteur des corps organiques combustibles, lorsque la température d'utilisation est égale ou supérieure au point éclair des fluides) de la nomenclature des installations classées pour la protection de l'environnement [JORF du 14 mai 2020]

[4] Arrêté du 12 mai 2020 relatif aux prescriptions générales applicables aux installations relevant du régime de l'enregistrement au titre de la rubrique n° 2930 (Ateliers de réparation et d'entretien de véhicules et engins à moteur, y compris les activités de carrosserie et de tôle) de la nomenclature des installations classées pour la protection de l'environnement [JORF du 14 mai 2020]

[5] Arrêté du 12 mai 2020 relatif aux prescriptions générales applicables aux installations relevant du régime de l'enregistrement au titre de la rubrique n° 2940 (Application, revêtement, laquage, stratification, impégnation, cuisson, séchage de vernis, peinture, apprêt, colle, enduit, etc., sur support quelconque) de la nomenclature des installations classées pour la protection de l'environnement [JORF du 14 mai 2020]

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