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The list below is an excerpt from French and European official gazettes concerning the environment, energy, and occupational health and safety from December 2025.
ENVIRONMENT
REP 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 sections 4 and 5 of III of Article R. 543-43 of the Environmental Code [JORF of December 18, 2025]
Decree of December 2, 2025, establishing specifications for eco-organizations, individual systems, and coordinating bodies in the extended producer responsibility sector for packaging used to market products consumed or used by professionals [JORF of December 18, 2025]
The first decree aims to define the characteristics of professional packaging, i.e., packaging used to market products consumed or used specifically by professionals, and household packaging, i.e., packaging for products consumed or used by households.
The second decree defines the specifications for eco-organizations, individual systems, and coordinating bodies for eco-organizations in the extendedproducerresponsibility(EPR) sector for professional packaging.
As a reminder, in order to fulfill their obligations under the EPR principle, producers of packaging used to market products consumed or used by professionals must set up an approved individual system or join an accredited eco-organization.
Refrigerants: New procedures for issuing certificates of competence and aptitude
Decree of November 21, 2025, relating to the issuance of certificates of competence to operators as provided for in Article R. 543-99 of the Environmental Code [JORF of December 6, 2025]
Decree of November 21, 2025, relating to the issuance of certificates of competence provided for in Article R. 543-106 of the Environmental Code [JORF of December 10, 2025]
The first decree specifies the procedure for applying for and obtaining a certificate of competence 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 Rankine organic cycles;
- refrigeration units for refrigerated trucks and refrigerated trailers;
- refrigeration units for refrigerated light commercial vehicles, intermodal containers and refrigerated wagons.
The second decree sets out the procedures for applying for and issuing certificates of competence in handling refrigerants or equivalent.
These texts replace the previous decrees of 2008.
As a reminder, operators (companies or professional organizations) handling fluorinated greenhouse gases or equivalents (CO₂, NH₃, hydrocarbons, etc.) in certain refrigeration and air conditioning equipment must obtain a certificate of competence. To be eligible for a certificate of competence, operators' personnel must hold a certificate of aptitude.
Modification of battery sorting and storage conditions
Decree of June 6, 2018 on general requirements applicable to facilities for the transit, collection, sorting, or preparation for reuse of waste covered by 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 of paper, cardboard, plastics, rubber, textiles, wood) or 2716 (non-hazardous non-inert waste) AND Decree of June 6, 2018 on general requirements applicable to facilities for the transit, collection, or sorting of hazardous waste subject to the declaration regime under heading No. 2718 of the nomenclature of facilities classified for environmental protection AMENDED BY Decree of December 1, 2025 amending certain provisions relating to waste management facilities, in particular those relating to 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 [JORF of December 11, 2025]
As a waste management facility, it is necessary to ensure that drums or containers used to store used lithium batteries are designed to prevent water ingress (previously, it was stated that they had to be watertight).
ENERGY
Terms and conditions for applying the new energy audit and energy management system (EMS) requirements
Energy Code Articles R. 233-1 to D. 233-7: Energy performance in businesses AMENDED BY Decree No. 2025-1382 of December 29, 2025 on the transposition of Directive (EU) 2023/1791 on energy efficiency [JORF of December 30, 2025]
Enacted pursuant to Law No. 2025-391 of April 30, 2025, "DDADUE" (transposing the European directive on energy efficiency), this decree specifies the new provisions regarding energy audits and energy management systems.
As a reminder, an energy management system 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 four years in companies whose average annual final energy consumption is greater than or equal to 2.75 GWh and which have not implemented an energy management system.
Modification of the deadlines for applying the obligation relating to automation and control systems, temperature control systems, and insulation of heating and cooling networks
Building and Housing Code Articles R. 175-1 to R. 175-9: Control of technical systems in buildings AND Energy Code Articles R. 241-6: Provisions relating to the insulation of heating and cooling distribution networks AND Energy Code Articles R. 241-31-1: Provisions relating to the local regulation of heating or cooling systems in buildings AMENDED BY Decree No. 2025-1343 of December 26, 2025, amending the dates of application of the obligations concerning automation and control systems for tertiary buildings, temperature control systems for heating and cooling systems, and insulation of heating and cooling distribution networks [JORF of December 27, 2025]
For buildings or parts of buildings in which tertiary activities are carried out, this decree postpones the application date to January 1, 2030 (instead of 2027) for the implementation of:
- an automation and control system for buildings equipped with a heating or air conditioning system with a rated output greater than 70 kW and less than 290 kW;
- a system for regulating the temperature of heating and cooling systems by room or by heating/cooling zone of the indoor temperature with an hourly time step;
- insulation of heating or cooling distribution networks.
SAFETY
Postponement of the deadline for the new radiation protection organization
Labor Code Articles R. 4451-1 to R. 4451-146: Prevention of risks of exposure to ionizing radiation AND Decree No. 2024-1238 of December 30, 2024 on the protection of workers against the risks of ionizing radiation AMENDED BY Decree No. 2025-1347 of December 26, 2025 on the protection of workers against the risks of ionizing radiation [JORF of December 28, 2025]
As a reminder, several changes have been made to the organization of radiation protection and require the publication of decrees in order to be implemented.
In the absence of these orders, this decree postpones the effective dates of several provisions, particularly those concerning the certification of external companies operating in yellow, orange, and red controlled areas, certificates of competence to handle industrial radiology equipment (CAMARI), and the implementation of radiation protection operations.
Developments relating to technical gas and other installations, and periodic inspections in 5th category public buildings
Decree of June 25, 1980 approving the general provisions of the safety regulations against fire and panic risks in establishments open to the public AMENDED BY decree of December 1, 2025 [JORF of December 14, 2025]
The decree of December 1, 2025 strengthens the provisions relating to periodic inspections in category 5 establishments open to the public (ERP), supplements the technical rules for premises with specific risks, hydrocarbon storage facilities, and combustible gas installations to bring them into line with the changes introduced by the decree of February 23, 2025. It also changes the display of emergency response 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, provided there are no changes to the buildings and facilities. When extension or renovation work is undertaken, the ERP regulations apply only to the modified parts.