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The list below is an excerpt from publications in the French and European official journals concerning environment, energy, and occupational health and safety from December 2025.
ENVIRONMENT
EPR for professional packaging: Publication of the scope decree and specifications
Decree of December 2, 2025, relating to packaging for products used by households and/or professionals and falling under points 4 and 5 of Section III of Article R. 543-43 of the Environmental Code [Official Journal of December 18, 2025]
Decree of December 2, 2025, establishing the specifications for eco-organizations, individual schemes, and coordinating bodies for the Extended Producer Responsibility scheme for packaging used to market products consumed or used by professionals [Official Journal of December 18, 2025]
The first decree aims to define the characteristics of professional packaging, i.e., packaging used to market products specifically consumed or used by professionals, and household packaging, i.e., packaging for products consumed or used by households.
The second decree defines for the Extended Producer Responsibility scheme for producers (EPR) of professional packaging, the specifications for eco-organizations, individual schemes, and coordinating bodies for eco-organizations.
As a reminder, to fulfill their obligations under the EPR principle, producers of packaging used to market products consumed or used by professionals must implement an approved individual scheme or join an approved eco-organization.
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Refrigerant Fluids: New Procedures for Issuing Capacity and Aptitude Certificates
Order of November 21, 2025, concerning the issuance of capacity certificates to operators as provided for in Article R. 543-99 of the Environmental Code [Official Journal of December 6, 2025]
Order of November 21, 2025, concerning the issuance of aptitude certificates as provided for in Article R. 543-106 of the Environmental Code [Official Journal of December 10, 2025]
The first order specifies the procedure for requesting and obtaining a capacity certificate for handling fluorinated and natural refrigerants. This applies to companies responsible for working on the following refrigeration equipment:
- fixed refrigeration equipment;
- fixed air conditioning and heat pump equipment;
- fixed organic Rankine cycles;
- refrigeration units for refrigerated trucks and trailers;
- refrigeration units for refrigerated light commercial vehicles, intermodal containers, and refrigerated railcars.
The second order sets out the procedures for requesting and issuing aptitude certificates for handling refrigerant fluids or equivalent.
These orders replace the previous orders from 2008.
As a reminder, operators (companies or professional organizations) carrying out activities involving the handling of fluorinated greenhouse gases or equivalent (CO2, NH3, hydrocarbons, etc.) on certain refrigeration and air conditioning equipment must obtain a capacity certificate. To qualify for a capacity certificate, operators' personnel must hold an aptitude certificate.
Changes to Battery Sorting and Storage Conditions
Order of June 6, 2018, concerning the general requirements applicable to facilities for transit, grouping, sorting, or preparation for reuse of waste subject to the declaration regime under heading no. 2711 (waste electrical and electronic equipment), 2713 (non-hazardous metals or metal waste, non-hazardous metal alloys or metal alloy waste), 2714 (non-hazardous waste from paper, cardboard, plastics, rubber, textiles, wood), or 2716 (non-hazardous non-inert waste) AND Order of June 6, 2018, concerning the general requirements applicable to facilities for transit, grouping, or sorting of hazardous waste subject to the declaration regime under heading no. 2718 of the nomenclature of classified facilities for environmental protection AMENDED BY order of December 1, 2025, modifying certain provisions relating to waste management facilities, particularly concerning accident prevention in the waste sector within facilities subject to declaration and registration under headings 2711, 2713, 2714, 2716, and 2718 of the ICPE nomenclature [Official Journal of December 11, 2025]
As a waste management facility, it is necessary to ensure that drums or storage containers for used lithium batteries are designed to prevent water entry (previously, it was stated that they had to be watertight).
ENERGY
Terms of application for new energy audit and energy management system (EMS) obligations
Energy Code Articles R. 233-1 to D. 233-7: Energy performance in businesses AMENDED BY Decree No. 2025-1382 of December 29, 2025, concerning the transposition of Directive (EU) 2023/1791 on energy efficiency [Official Journal of December 30, 2025]
Issued pursuant to Law No. 2025-391 of April 30, 2025, "DDADUE" (transposing the European directive on energy efficiency), this decree specifies new provisions regarding energy audits and EMS.
As a reminder, an EMS must be implemented and certified in companies whose average annual final energy consumption is greater than or equal to 23.6 GWh. An energy audit must be carried out by a competent auditor every 4 years in companies whose average annual final energy consumption is greater than or equal to 2.75 GWh and which have not implemented an EMS.
Amendment of application deadlines for obligations related to automation and control systems, temperature control systems, and insulation of heating and cooling networks
Construction and Housing Code Articles R. 175-1 to R. 175-9: Management of building technical systems AND Energy Code Articles R. 241-6: Provisions concerning the insulation of heating and cooling distribution networks AND Energy Code Articles R. 241-31-1: Provisions concerning the local regulation of heating or cooling installations in premises AMENDED BY Decree No. 2025-1343 of December 26, 2025, amending the application dates for obligations concerning building automation and control systems in tertiary buildings, temperature control systems for heating and cooling systems, and insulation of heat and cold distribution networks [Official Journal of December 27, 2025]
For buildings or parts of buildings used for tertiary activities, this decree postpones the application date to no later than January 1, 2030 (instead of 2027) for the implementation of:
- a building automation and control system for buildings equipped with a heating or air conditioning system with a nominal useful output greater than 70 kW and less than 290 kW;
- a temperature control system for heating and cooling systems per room or per heating/cooling zone for indoor temperature with an hourly time step;
- thermal insulation of heat or cold distribution networks.
SECURITY
Postponement of the deadline for the new radiation protection organization
Labor Code Articles R. 4451-1 to R. 4451-146: Prevention of risks from exposure to ionizing radiation AND Decree No. 2024-1238 of December 30, 2024, concerning the protection of workers against risks from ionizing radiation AMENDED BY Decree No. 2025-1347 of December 26, 2025, concerning the protection of workers against risks from ionizing radiation [Official Journal of December 28, 2025]
As a reminder, several modifications have been made to the organization of radiation protection and require the publication of ministerial orders for their implementation.
Due to the absence of these ministerial orders, this decree shifts the effective dates of several provisions, particularly regarding the certification of external companies operating in yellow, orange, and red controlled zones, certificates of aptitude for handling industrial radiology equipment (CAMARI), and the implementation of operational radiation protection.
Changes related to technical gas and other installations, and periodic inspections in 5th category Public Access Buildings
Decree of June 25, 1980, approving the general provisions of the safety regulations against fire and panic risks in public access buildings, MODIFIED BY the decree of December 1, 2025 [Official Journal of the French Republic of December 14, 2025]
The decree of December 1, 2025, strengthens the provisions related to periodic inspections in 5th category public access buildings (ERP), completes the technical rules for rooms with specific risks, hydrocarbon storage, and combustible gas installations to align with the changes introduced by the decree of February 23, 2025. It also updates the display of intervention plans.
As a reminder, with the exception of administrative rules concerning maintenance and/or technical inspections, the ERP regulations and their amendments do not apply to existing establishments unless there are changes to the buildings and installations. When expansion or development work is undertaken, the ERP regulations apply only to the modified parts.