EHS Energy Regulatory Watch for November 2025

French and European texts concerning the environment, energy, and occupational health and safety from November 2025

Caroline Mardon
EHS Consultant
Update : 
11.12.2025
Publication: 
11.12.2025

The list below is an excerpt from French and European official gazettes concerning the environment, energy, and occupational health and safety in November 2025.

Environment

ENVIRONMENT

Implementation of the Extended Producer Responsibility (EPR) scheme for professional packaging

Environmental Code Articles R. 543-42 to R. 543-74: Packaging AMENDED BY Decree No. 2025-1081 of November 17, 2025 relating to packaging and packaging waste and establishing extended producer responsibility for packaging consumed or used by professionals [JORF of November 18, 2025]

Decree No. 2025-1081 aligns the definitions of packaging, producer, composite packaging, and packaging waste with those in Regulation No. 2025-40 of December 19, 2024, known as the PPWR Regulation. A definition of professional packaging has also been added.

In addition, it specifies the obligations of professional packaging waste holders and producers of such packaging, the conditions for the eco-organization to take back this waste, and the packaging excluded from this EPR.

Preventing plastic pellet loss in the environment throughout the supply chain

Regulation (EU) 2025/2365 of the European Parliament and of the Council of November 12, 2025 on the prevention of plastic pellet loss to reduce microplastic pollution [OJEU of November 26, 2025]

In order to protect the environment and human health, this regulation sets out rules for preventing the loss of plastic pellets throughout the supply chain. It establishes obligations for:

  • economic operators who have handled plastic pellets in the Union in quantities equal to or greater than a threshold of five tons during the previous calendar year;
  • economic operators operating facilities in the Union for the cleaning of tanks and containers for plastic pellets;
  • EU carriers and third-country carriers responsible for transporting plastic pellets within the Union; and
  • to shippers and operators, agents, and captains of seagoing vessels transporting plastic pellets in containers that leave or call at a port in a Member State.

Soil monitoring

Directive (EU) 2025/2360 of the European Parliament and of the Council of November 12, 2025 on soil monitoring and resilience [OJEU of November 26, 2025]

The objectives of this directive are:

  • to establish a robust and consistent soil monitoring framework for all soils throughout the European Union,
  • to reduce soil contamination to levels that are no longer considered harmful to human health and the environment,
  • to continuously improve soil health in the European Union.
  • maintain soils in good health and prevent and treat all aspects of soil degradation, with a view to achieving good soil health by 2050 so that they can provide multiple ecosystem services on a scale sufficient to meet environmental, societal, and economic needs, prevent and mitigate the effects of climate change and biodiversity loss, increase resilience to natural disasters and food security, in particular by reducing land artificialization.

Member States shall transpose this Directive by December 17, 2028, at the latest.

Energy

ENERGY

Changes to the requirements for outdoor parking lots with a surface area of more than 1,500 m² to install shade structures incorporating a renewable energy production process, and changes to the regulatory deadline.

LAW No. 2023-175 of March 10, 2023 on accelerating the production of renewable energies AMENDED BY LAW No. 2025-1129 of November 26, 2025 on simplifying urban planning and housing law [JORF of November 27, 2025]

The requirements relating to the installation of shade structures incorporating a renewable energy production process in outdoor parking lots with an area greater than 1,500 m² have been amended.

In order to meet the requirement to cover at least half of the parking lot's surface area, the owner (or concessionaire, delegatee, or holder of the public domain occupancy permit) may, in particular, install:

- mixed processes involving shade structures incorporating a renewable energy production process covering at least 35% of half the parking lot area and green features contributing to the shading of the remaining area to be covered, thus enabling a combination of technologies.

Operators may also install a renewable energy production system that does not require the installation of shade structures on only part of the area to be covered (previously, this detail was not specified). This system may therefore be installed in whole or in part, provided that it enables production equivalent to that which would result from the installation of shade structures incorporating a renewable energy production process on the unequipped area.

Other changes relate to the postponement of regulatory deadlines and coordination with urban planning documents.

Security

SAFETY

Functional requirements to be met to ensure the safety of persons against fire risks

Building and Housing Code Articles R. 141-1 to R. 141-17:  General rules relating to the safety of persons against fire risks CREATED BY Decree No. 2025-1100 of November 19, 2025, establishing the conditions for the implementation of solutions with equivalent effect relating to fire safety, transferring regulatory provisions concerning fire safety in buildings for professional use (BUP) to the Building and Housing Code and amending certain investigation procedures [JORF of November 20, 2025]

This regulatory section specifies, in particular, the functional requirements, i.e., the technical properties of the building that enable compliance with the general fire safety objectives, possible equivalent solutions, and the content of the fire safety log. These rules concern, in particular, fire protection measures for buildings used for professional purposes, establishments open to the public, and high-rise buildings.  These measures will come into force on July1, 2026. Implementing decrees are expected.

Documents to be included in the safety register for establishments open to the public (ERP)

Building and Housing Code Articles R. 143-1 to R. 143-47: Establishments open to the public AMENDED BY Decree No. 2025-1100 of November 19, 2025 [JORF of November 20, 2025]

The content of the ERP safety register has been modified and expanded. It must now also include:

  • the list of names and positions of persons belonging to the security service (previously, reference was made to the list of personnel responsible for the fire service);
  • the dates of fire drills.

Approval, repair, and initial verification, installation and post-installation inspection, and periodic inspection of tachographs

Decree of October 1, 1981, relating to the approval, initial verification, and post-installation verification of tachographs used in road transport REPEALED AND REPLACED BY Decree of October 27, 2025, relating to tachographs [JORF of November 15, 2025]

This applies to analog (paper disc), digital (electronic), or smart (linked to a satellite navigation system) tachographs installed in vehicles used to transport more than nine passengers (including the driver) and goods vehicles weighing more than 3.5 tons.

This text specifies the requirements relating to the approval, repair, and initial verification, installation, post-installation inspection, and periodic inspection of tachographs.