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The list below is an extract from French and European official journals concerning environment, energy, and occupational health and safety for May 2025.
ENVIRONMENT
Update to the list of battery-related waste
Commission Decision No 2000/532/EC of 3 May 2000 replacing Decision 94/3/EC establishing a list of waste AMENDED BY Commission Delegated Decision (EU) 2025/934 of 5 March 2025 amending Decision 2000/532/EC to update the list of waste with regard to battery-related waste [JORF of 2 May 2025]
Commission Delegated Decision (EU) 2025/934 of 5 March 2025 amends this decision to update the list of waste with regard to battery-related waste. This list is updated to align with Regulation (EU) 2023/1542 of 12 July 2023 on batteries and waste batteries.
As of 9 November 2026, it is therefore necessary to ensure:
- Use the correct waste codes for battery waste in waste registers and, where applicable, on waste tracking forms;
- Establish waste tracking forms when waste is newly classified as hazardous.
Clarifications provided regarding the party responsible for the obligation to equip certain car parks with canopies incorporating a renewable energy production process, the terms for possible deferral, and the calculation of the car park's surface area
LAW No 2023-175 of 10 March 2023 on accelerating the production of renewable energy: Articles 4, 28 and 40 AMENDED BY LAW No 2025-391 of 30 April 2025 [JORF of 2 May 2025]
Law No 2025-391 of 30 April 2025 provides clarifications regarding compliance with the obligation to equip car parks larger than 1,500 m² with canopies incorporating a renewable energy production process. Thus:
- This obligation, initially borne by the parking facility manager, is now transferred to the owner (except in cases of public service concessions or public domain use authorizations where it is newly specified that it applies to the concessionaire, delegatee, or authorization holder).
- The commitment contract required to benefit from the deferral of the regulatory deadline to January 1st 2028 for parking facilities larger than 10,000 m² can be submitted no later than December 31, 2025 (instead of December 31, 2024), and the purchase order concluded before June 30, 2026 (instead of December 31, 2025). This deferral option allowed compliance with the APER law by January 1,st 2028 instead of July 1,st 2026.
- Surfaces corresponding to traffic lanes and paths specifically used by heavy goods vehicles with a gross vehicle weight exceeding 7.5 tonnes are deducted from the area of outdoor parking facilities used to calculate the area that must be equipped with canopies integrating a renewable energy production system.
- Finally, a clarification has been provided for the conclusion or renewal of a concession or delegation. If this occurs after July 1, 2026 (instead of after July 1, 2028), the obligation to equip 50% of the parking facility's area comes into effect on July 1, 2028.
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Amendment of the lists of woods and forests classified as fire-risk areas and forest massifs at lower risk within the framework of legal brush clearing obligations
Order of February 6, 2024, classifying woods and forests exposed to fire risk under Articles L. 132-1 and L. 133-1 of the Forestry Code, AMENDED BY Order of May 20, 2025 [JORF of May 31, 2025]
As a reminder, this order lists woods and forests located in departments particularly exposed to fire risk (Article 3), as well as woods and forests individually classified when the department is not mentioned (Annex 1).
Finally, the text lists excluded woods and forests that are nevertheless located in departments particularly exposed to fire risk:
- forest massifs are smaller than 0.5 hectares in a single block,
- the other forest areas with lower fire risk (annex 2).
The decree of May 20, 2025, replaces the annexes used to determine the applicability of legal brush-clearing obligations.
Regarding annex 1, many woods and forests are added in the following departments: Cher, Côtes d’Armor, Eure, Eure-et-Loir, Finistère, Indre, Jura, Loir-et-Cher, Loiret, Maine-et-Loire, Morbihan, and Sarthe.
Regarding annex 2, many woods and forests are newly excluded in the following departments: Alpes-de-Haute-Provence, Hautes-Alpes, Drôme, and Hérault.
ENERGY
Modification of the criteria for applicability to energy audits, implementation of an energy management system, and new cost-benefit analysis obligation for large-scale projects
Energy Code Articles L. 233-1 to L. 233-5: Energy Performance in Businesses (Book II, Title III, Chapter III) AMENDED BY Law No. 2025-391 of April 30, 2025, enacting various provisions for adaptation to European Union law concerning economic, financial, environmental, energy, transport, health, and free movement of persons [Official Journal of May 2, 2025]
Law No. 2025-391 of April 30, 2025, known as the "DDADUE Law," amends the criteria for the applicability of a management system or an energy audit to legal entities registered with the trade and companies register, as well as to certain non-commercial private legal entities.
Henceforth, the new criteria are established based on the average annual final energy consumption of these companies and no longer based on balance sheet, turnover, or workforce. Thus, small and medium-sized enterprises (SMEs) may be subject to the implementation of an energy management system (EMS) or the performance of an energy audit, depending on their consumption.
Henceforth:
- The implementation of an EMS is mandatory for legal entities registered with the trade and companies register, as well as for certain private legal entities whose average annual final energy consumption is greater than or equal to 23.6 GWh ;
- Energy audits of activities carried out in France are mandatory for the same entities when they have not implemented an EMS and their average annual final energy consumption exceeds 2.75 GWh. These audits must be conducted every 4 years.
This requirement entails new obligations (action plan to be published in the company's annual report, submission of information relating to the implementation of these obligations to the administration, declaration of annual final energy consumption when it exceeds 2.75 GWh).
Furthermore, every operator is required to carry out a prior cost-benefit analysis of the economic feasibility of improving the energy efficiency of heat and cold supply when it concerns a major creation or modification project involving:
- A thermal electricity generation facility with a capacity exceeding 10 MW;
- An industrial facility with a capacity exceeding 8 MW;
- A service facility with a capacity exceeding 7 MW;
- A data center with a capacity exceeding 1 MW.
Energy Performance of Public Bodies
Energy Code Articles L. 235-1 to L. 235-4: Energy performance of public bodies (Book II, Title III, Chapter V) CREATED BY Law No. 2025-391 of April 30, 2025 [JORF of May 2, 2025]
Law No. 2025-391 of April 30, 2025, creates new obligations regarding the energy performance of public bodies. Public bodies subject to these provisions include the State, State operators, local authorities and their groupings, as well as public or private entities meeting certain criteria.
As of the 1st October 2025, they are now required to meet:
- A cumulative final energy consumption reduction target of at least 1.9% per year compared to their 2021 consumption and the submission of data related to this annual energy consumption;
- A building renovation target of at least 3% per year with the achievement of a high level of energy performance defined by decree and the communication, every two years, of data related to renovations.
- The submission, every two years, of data related to the energy performance of buildings. This can be combined with the submission of data for the two previous obligations.
Regarding the first obligation, however, adjustments are provided for certain categories, particularly local authorities with fewer than 50,000 and 5,000 inhabitants, their associations, and public establishments.
SAFETY
Update of models for fitness-for-work notices, unfitness-for-work notices, individual health monitoring certificates, and proposed workplace adjustment measures for agricultural workers, including seasonal workers and employees of temporary employment agencies or employer groups
Decree of December 20, 2017, establishing the model for fitness-for-work notices, unfitness-for-work notices, individual health monitoring certificates, and proposed workplace adjustment measures MODIFIED BY Decree of May 5, 2025, amending the decree of December 20, 2017, establishing the model for fitness-for-work notices, unfitness-for-work notices, individual health monitoring certificates, and proposed workplace adjustment measures [JORF of May 14, 2025]
To take into account the changes introduced by Law No. 2021-1018 of August 2, 2021, to strengthen occupational health prevention, the decree of May 5, 2025, updates the models for fitness-for-work notices, unfitness-for-work notices, individual health monitoring certificates, and proposed workplace adjustment measures for workers covered by the agricultural scheme, including seasonal workers, employees of temporary employment agencies, or employer groups.