EHS and Energy Regulatory Watch October 2024

In October 2024, the EHS and Energy regulatory watch focuses on EPR channels, stored carbon, water billing and medical opinion models in occupational health.

Léa Soler
EHS Consultant
Update : 
12.09.2025
Publication: 
14.11.2024

The list below is an extract from the French and European Official Gazettes concerning the environment, energy and occupational health and safety for October 2024.

Environment

ENVIRONMENT

Changes in data transmission procedures for Extended Producer Responsibility (EPR) channels

Decree of December 12, 2022 concerning data from extended producer responsibility (EPR) channels MODIFIED BY the decree of October 8, 2024 [JORF of October 20, 2024].

As a reminder, producers who have set up an individual system and eco-organizations must send ADEME a certain amount of information each year for each category of products concerned. The Order of December 12, 2022 defines the nature of this information, and the procedures for making it available, for all EPRs.

Changes have been made to the EPR data transmission procedures, as well as to the appendices providing for specific cases for the EPRs in question. First of all, the timetable for data transmission has been revised (deadline now set at May 31, compared with April 30 previously). The fields of application and content of the data to be transmitted are then completed for :

  • Waste collection ;
  • Waste management ;
  • Those relating to the reuse and re-utilization of used products
  • Those to be supplied as part of the transmission to the authority responsible for drawing up and monitoring the Schéma Régional d'Aménagement, de Développement Durable et d'Egalité des Territoires (SRADDET) or the Plan Régional de Prévention et de Gestion des Déchets (PRPGD).

Definition of the criteria and conditions to be met in order to consider the carbon stored in a product as permanently chemically bound.

Commission Delegated Regulation (EU) 2024/2620 of July 30, 2024 supplementing Directive 2003/87/EC of the European Parliament and of the Council as regards the conditions for greenhouse gases to be considered as permanently chemically bound to a product [OJEU, October 4, 2024].

Pursuant to Directive 2023/87 of October 13, 2023 establishing a scheme for greenhouse gas emission allowance trading, this regulation lays down the criteria and conditions to be met for Greenhouse Gases (GHG) to be considered as permanently chemically bound to a product.

As a reminder, the surrender of GHG quotas is not imposed for emissions of GHGs that are deemed to have been captured and used in such a way that they have become permanently chemically bound to a product, so that they cannot enter the atmosphere under normal conditions of use, including any normal activity taking place after the end of the product's life.

Changes to the presentation of water bills

Arrêté du 10 juillet 1996 relatif aux factures de distribution de l'eau et de collecte et de traitement des eaux usées MODIFIE PAR l'arrêté du 2 octobre 2024 [JORF du 30 octobre 2024] (French only)

As a reminder, the reform of water agency fees initiated by the Finance Act for 2024 replaces, as of January 1, 2025, the fees for pollution of domestic origin and for modernization of collection networks with the following fees:

  • Drinking water consumption;
  • For drinking water network performance;
  • For the performance of collective wastewater treatment systems.

In the spirit of consistency, the decree of October 2, 2024 modifies the presentation of water bills to take account of the new charges.

Security

SAFETY

Updated templates for fitness notices, unfitness notices, individual health monitoring certificates and proposed workstation adjustments

Arrêté du 16 octobre 2017 fixant le modèle d'avis d'aptitude, d'avis d'inaptitude, d'attestation de suivi individuel de l'état de santé et de proposition de mesures d'aménagement de poste MODIFIE PAR l'arrêté du 26 septembre 2024 [JORF du 10 octobre 2024]

In order to take into account the changes brought about by law no. 2021-1018 of August 2, 2021 to strengthen occupational health prevention, the order of September 26, 2024 updates the models for aptitude notices, unfitness notices, individual health monitoring attestations and proposals for workstation adjustment measures with four new models.