COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2019 Country Report - FRANCE Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2019: A Europe that protects its citizens and enhances their quality of life
Date: 2019-04-04
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, France, application of EU law, climate change policy, environmental law, environmental protection, governance, green economy, public health, quality of the environment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.4.2019  SWD(2019) 120 final  COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2019    Country Report - FRANCE         Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2019:  A Europe that protects its citizens and enhances their quality of life  {COM(2019) 149 final} - {SWD(2019) 111 final} - {SWD(2019) 112 final} - {SWD(2019) 113 final} - {SWD(2019) 114 final} - {SWD(2019) 115 final} - {SWD(2019) 116 final} - {SWD(2019) 117 final} - {SWD(2019) 118 final} - {SWD(2019) 119 final} - {SWD(2019) 121 final} - {SWD(2019) 122 final} - {SWD(2019) 123 final} - {SWD(2019) 124 final} - {SWD(2019) 125 final} - {SWD(2019) 126 final} - {SWD(2019) 127 final} - {SWD(2019) 128 final} - {SWD(2019) 129 final} - {SWD(2019) 130 final} - {SWD(2019) 131 final} - {SWD(2019) 132 final} - {SWD(2019) 133 final} - {SWD(2019) 134 final} - {SWD(2019) 135 final} - {SWD(2019) 136 final} - {SWD(2019) 137 final} - {SWD(2019) 138 final} - {SWD(2019) 139 final}  
 
 
This report has been written by the staff of the Directorate-General for Environment, European Commission. Comments 
are welcome, please send them to ENV-EIR@ec.europa.eu 

More information on the European Union is available at http://europa.eu. 

Photographs: p. 6 — ©iStock/bluejayphoto; p. 12 — ©iStock/Andrew_Mayovskyy; p. 13 — ©iStock/porojnicu; p. 24 — 
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©European Union, 2019 

Reproduction is authorised provided the source is acknowledged. 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents 

EXECUTIVE SUMMARY ................................................................................................................................... 3 

PART I: THEMATIC AREAS .............................................................................................................................. 5 

1. 

TURNING  THE  EU  A  CIRCULAR,  RESOURCE-EFFICIENT,  GREEN  AND  COMPETITIVE  LOW-CARBON 
ECONOMY ............................................................................................................................................. 5 

Measures towards a circular economy ................................................................................................. 5 
Waste management .............................................................................................................................. 8 
Climate change .................................................................................................................................... 10 

2. 

PROTECTING, CONSERVING AND ENHANCING NATURAL CAPITAL .................................................. 12 

Nature and biodiversity ....................................................................................................................... 12 
Maintaining and restoring ecosystems and their services .................................................................. 14 
Estimating natural capital ................................................................................................................... 14 
Invasive alien species .......................................................................................................................... 15 
Soil protection ..................................................................................................................................... 16 
Marine protection ............................................................................................................................... 17 

3. 

ENSURING CITIZENS' HEALTH AND QUALITY OF LIFE ........................................................................ 18 

Air quality ............................................................................................................................................ 18 
Industrial emissions ............................................................................................................................. 19 
 ................................................................................................................................................. 20 
Noise 
Water quality and management ......................................................................................................... 20 
Chemicals ............................................................................................................................................ 23 
Making cities more sustainable ........................................................................................................... 23 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS ................................................................... 27 

4. 

GREEN  TAXATION,  GREEN  PUBLIC  PROCUREMENT,  ENVIRONMENTAL  FUNDING  AND 
INVESTMENTS ..................................................................................................................................... 27 

Green taxation and environmentally harmful subsidies ..................................................................... 27 
Green public procurement .................................................................................................................. 28 
Environmental funding and investments ............................................................................................ 29 

5. 

STRENGTHENING ENVIRONMENTAL GOVERNANCE ......................................................................... 34 

Information, public participation and access to justice ...................................................................... 34 
Compliance assurance ......................................................................................................................... 35 
Effectiveness of environmental administrations ................................................................................ 36 
International agreements ................................................................................................................... 38 
Sustainable development and the implementation of the UN SDGs .................................................. 39 

2 

 
 
Environmental Implementation Review 2019 – France 

Executive summary 

France and the Environmental Implementation Review 
(EIR) 

The 2017 EIR identified the following main challenges as 
regards the implementation of EU environmental policy 
and law in France: 

 

 

 

improving  air  quality  by  taking  forward-looking, 
rapid  and  effective  action  to  reach  EU-based  air 
pollution limit values; 
taking  the  necessary  measures  to  improve  water 
quality, particularly reducing nitrate pollution; 
effectively  protecting  biodiversity  by  enforcing  the 
applicable law to ensure the protection of habitats 
and species.  

Since  the  2017  EIR,  France  has  not  yet  held  an  EIR 
national  dialogue  to  tackle  the  above  challenges  but 
held  discussions  with  the  Commission  on  nature  or 
access to justice. 

In  2017  the  Commission  launched  the  TAIEX-EIR  Peer-
to-Peer  (EIR  P2P),  a  practical  new  tool  designed  to 
facilitate  peer-to-peer  learning  between  environmental 
authorities.  France  has  taken  part 
in  peer-to-peer 
information sharing on the circular economy, air, nature 
and biodiversity and forests. 

Progress with tackling challenges since the 2017 report 

The 2019 EIR shows that air quality in France continues 
to  give  serious  cause  for  concern,  with  an  estimated 
34 880 premature deaths attributable to fine particulate 
matter  concentrations  and  9 330  to  nitrogen  dioxide 
concentrations.  Although  emissions  of  several  air 
pollutants  and  fine  particulate  matter  have  been 
limit  values  continue  to  be  exceeded. 
reduced, 
Additional efforts are needed to reach the targets set by 
the new National Emissions Ceilings Directive for 2020-
2029. 

France  has  identified  air  quality  as  a  major  challenge 
and adopted an ambitious agenda of planning measures 
to  reduce  emissions,  technical  improvements,  and  tax 
incentives  to  tackle  air  pollution  at  all  levels.  A  legal 
framework to improve air quality is in place. However, it 
will  take  time  for  the  measures  it  covers  to  produce 
tangible  results.  Further  measures  are  needed  to 
accelerate  reductions  in  emissions  of  nitrogen  oxide 
(NOx),  nitrogen  dioxide  (NO2)  and  concentrations  of 
fine  particulate  matter,  transport  emissions  being  a 
particular concern. 

There  has  been  progress  on  water  quality,  notably  as 
regards  bathing  water,  the  collection  and  treatment  of 
urban  waste  water  (although  112  agglomerations  are 

now  non-compliant  with  the  Directive),  and  the 
identification  and  mapping  of  areas  at  risk  of  flooding. 
Nitrate pollution remains a concern, despite the efforts 
made by the French government. 

Nature conservation  has seen some progress, with the 
designation  of  special  conservation  areas  and  the 
definition  of  management  plans.  However,  there  is 
considerable  room  for  improvement.  The  following 
concerns remain: 

 

 

 

implementing  conservation  measures  effectively, 
with appropriate funding, 
better  integrating  nature  protection  into  other 
policies, especially farming and fisheries, 
 hunting.  

innovative  approaches 

France  remains  efficient  in  deploying  EU  funds  and 
integrating 
developing 
environmental considerations into certain sectors so as 
to reduce their impact on the environment. The country 
is  very  active  in  areas  including  the  transition  to  a 
circular  economy,  green  public  procurement  and 
improving environmental protection in cities. 

to 

Examples of good practice 

The  ambitious  roadmap  for  the  circular  economy 
adopted  in  April  2018  sets  out  some  of  the  steps 
that  need  to  be  taken  to  progress  towards  an 
economy based on sustainable design, reuse, repair 
and  recycling.  The  roadmap  is  designed  to  cut 
resource  use  and  consumption  by  30 %  by  2030, 
halve 
the  amount  of  non-hazardous  waste 
landfilled by 2025, introduce an ambitious target of 
100 % plastics recycling by 2025 and create 300 000 
new jobs. 
France  now  has  an  ambitious  biodiversity  plan 
which makes nature protection and preventing the 
loss of biodiversity central to government priorities, 
on the same footing as  combating climate change. 
The  plan  is  designed  to  develop  biodiversity  at 
regional  level,  promote  economic  activities  with 
low  impacts  on  biodiversity,  protect  and  preserve 
nature,  and  develop  an  ambitious  international 
road map for biodiversity. 
The  single  environmental  permit  represents  a 
major simplification. The procedures and decisions 
required for the authorisation of industrial projects 
and  projects  covered  by  the  Water  Act  were 
merged  in  April  2017.  The  single  environmental 
permit  has  simplified  and  streamlined  procedures 
without  lessening  environmental  protection.  It  will 
also 
for  the  project 
promoter.  Whereas  before  the  reform  a  project 

legal  certainty 

improve 

 

 

 

3 

 
Environmental Implementation Review 2019 – France 

could require several environmental permits, it now 
needs just one application , one contact person and 
one environmental permit. The reform should help 
save  time  and  tighten  deadlines  while  protecting 
the 
interests 
the 
applicable legislation. 

covered  by 

fundamental 

4 

 
 
 
Environmental Implementation Review 2019 – France 

Part I: Thematic areas 

1.  Turning the EU a circular, resource-efficient, green and competitive 
low-carbon economy 

Measures towards a circular economy 

The  Circular  Economy  Action  Plan  emphasises  the  need 
to  move  towards  a  life-cycle-driven  ‘circular’  economy, 
reusing  resources  as  much  as  possible  and  bringing 
residual  waste  close  to  zero.  This  can  be  facilitated  by 
developing  and  providing  access  to  innovative  financial 
instruments and funding for eco-innovation. 

Following  the  adoption  of  the  Circular  Economy  Action 
Plan in 2015 and the setting  up of a  related stakeholder 
platform  in  2017,  the  European  Commission  adopted  a 
new  package  of  deliverables  in  January  20181.  This 
included  additional  initiatives  such  as:  (i)  an  EU  strategy 
for plastics; (ii) a  Communication on how to address the 
interplay  between  chemical,  product  and  waste 
legislation; (iii) a report on critical raw materials; and (iv) 
a  framework  to  monitor  progress  towards  a  circular 
economy2. 

figure 

Among these key indicators, the circular (secondary) use 
of  material  in  France  was  19.5 %  in  2016,  the  highest 
Europe’s 
(the  EU-28  average  was  11.7 %). 
However,  France  employs  fewer  people  in  the  circular 
economy  than  the  EU-28  average  (1.52 %  of  total 
employment  in  2016,  compared  with  the  EU-28  average 
of 1.73 %). The index has a consistent difference between 
years  2014  and  2015,  with  a  swift  decrease  from  the 
2014 measurement at 1.78 %. 

The 2017 special Eurobarometer on EU citizens’ attitudes 
towards  the  environment  suggests  that  88 %  of  French 
citizens  are  concerned  about  the  environmental  impact 
of plastic products (the EU-28 average is 87 %). 93 % are 
worried  about  the  impact  of  chemicals  (EU-28  average 
90 %)3. 

France  has  strongly  supported  the  development  of  eco-
industries,  eco-innovation  and  the  circular  economy  in 
recent decades. It has done this through policy initiatives 
and  programmes  to  support  eco-innovation  and  R&D 
programmes, 
including  the  circular  economy.  These 
policy  measures  complement  existing  support  schemes, 

in 

innovation 

including  some  designed  to  promote 
general rather than solely eco-innovation. 
As  regards  resource  productivity4  (how  efficiently  the 
economy  uses  material  resources  to  produce  wealth), 
France  is  performing  well,  with  EUR 2.87/kg  (the  EU 
average  is  2.04)  in  20175.  Figure  1  shows  that  France’s 
resource  productivity  rose  steadily  between  2010  and 
resource 
2016.  Despite 
productivity was the EU’s fifth highest in that year. 
Figure 1: Resource productivity, 2010-20176. 

the  2017  dip,  France’s 

Regional authorities also support eco-innovation and the 
circular economy. 

In April 2018, France published the first circular economy 
roadmap,  designed  to  create  up  to  300 000  new  jobs.  It 
touches upon several areas that are central to achieving a 
more  circular  economy,  including  waste  management, 
eco-design  of  products,  consumption,  financing,  and 
increased stakeholder involvement. 

The  roadmap  is  designed  to  cut  resource  use  and 
consumption  as  a  proportion  of  GDP  by  30 %  by  2030 
(compared to 2010), halve the amount of non-hazardous 
waste landfilled by 2025 (compared to 2010) and recycle 
100 %  of  plastics  by  2025,  an  ambitious  goal.  Extended 
producer responsibility (EPR) schemes will be introduced 
and  producers  will  be  required  to  inform  consumers 

1 European Commission, 2018 Circular Economy Package. 
2 COM(2018) 029. 
3 European Commission, 2017, Special 486 Eurobarometer, ‘Attitudes of 
European citizens towards the environment’. 

4 Resource productivity is defined as the ratio of gross domestic product 
(GDP) to domestic material consumption (DMC). 
5 Eurostat, Resource productivity. 
6 Eurostat, Resource productivity. 

5 

 
 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – France 

about  products’  lifespan,  repairability  in  terms  of  a 
specific new index. 

SMEs and resource efficiency 

Small  and  medium-sized  companies  (SMEs)  in  France 
continue  to  score  in  line  with  the  EU-28  average  as 
regards the environmental aspects of the Small Business 
Act, as shown in Figure 2. 

France  has  more  companies  that  have  taken  resource 
efficiency measures than other countries, but only a few 
are  developing  a  distinctly  green  profile  and  generating 
more  than  half  their  turnover  from  green  products  and 
services. 
Figure 2: Environmental performance of SMEs11  

In  2017,  France  adopted  a  series  of  10  indicators  that 
cover  the  lifecycle  of  the  products.  In  March  2018, 
France’s Ministry for Solidarity and Ecology Transition set 
up  the  Green  Transition  Accelerator  (AcTE),  a  think  tank 
that  brings  together  companies,  training  centres  and 
representatives  of  employers’  organisations  and  trade 
unions.  AcTE  aims  to  promote  green  growth,  support 
innovation,  make  the  circular  economy  a  reality  and 
ensure climate plans are implemented. 

regions, 

complementing 

Policies and action supporting the transition to a circular 
economy transition are becoming increasingly popular in 
the 
action. 
Following  the  2015  reorganisation  of  France’s  regions7, 
14  of  the  18  regions  have  made  support  for  the  circular 
economy  one  of  the  priorities  of  their 
innovation 
strategies8. 

government 

The numbers of EU ecolabel products and EMAS-licensed 
organisations  in  a  given  country  indicate  whether  the 
private sector and national stakeholders support the shift 
towards  a  circular  economy  and  whether  public 
authorities  are  committed  to  supporting  measures  to 
promote  such  an  economy.  By  September  2018,  France 
had  518  licences  covering  4 971  products  registered  in 
the  EU  ecolabel  scheme  out  of  the  EU  total  of  2 167 
licences  covering  71 707  products,  the  third  highest 
figure  after  Spain  and  Italy9.  However,  only  34  French 
organisations  were  registered  in  EMAS  (the  European 
Commission’s  eco-management  and  audit  scheme)  by 
May 201810. 

The  latest  Eurobarometer  on  ‘SMEs,  resource  efficiency 
and  green  markets’12  asked  companies  about  recent 
resource  efficiency  measures  and  those  planned  for  the 
next 2 years and compared responses with the situation 
in  2015.  Only  6 %  of  French  companies  have  taken  no 
resource  efficiency  measure  in  the  2  years  before  the 
survey. 83 % of companies are taking action to minimise 
waste,  while  60-71 %  are  saving  materials,  water  and 
energy.  33 %  of  French  companies  are  taking  action  to 
design  products  that  are  easier  to  maintain  and  repair 
(one  of  the  EU’s  highest  scores).  However,  only  6 %  of 

7 Reorganisation of France’s administrative regions (Nouvelle 
Organisation Territoriale de la REpublique, NOTRe). 
8 Schéma Régional de Développement Economique d’Innovation et 
d’Internationalisation (SRDEII). 
9 European Commission, Ecolabel Facts and Figures. 
10 European Commission, Eco-Management and Audit Scheme. 

11 European Commission, 2018 SBA fact sheet - France, p. 15. 
12 Flash Eurobarometer 456 ‘SMEs, resource efficiency and green 
markets’, January 2018. The 8 dimensions were: save energy; minimise 
waste; save materials; save water; recycle by reusing material 
internally; design products that are easier to maintain, repair or reuse; 
use renewable energy; sell scrap materials to another company. 

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Environmental Implementation Review 2019 – France 

firms have invested in the use of renewables. Companies’ 
future  ambitions  for  action  are  rising  further  from  an 
already  high 
level,  with  the  exception  of  design, 
renewable energy use and internal recycling. 

24 %  of  French  companies  (compared  to  22 %  in  EU-28, 
range 3 %-38 %) relied on external support in their efforts 
to be more resource-efficient. 44 % of French businesses 
mention grants and subsidies as useful help; other forms 
of support are also considered useful. 

A  programme  aiming  at  helping  SMEs  to  save  costs 
through  resource  efficiency  strategies  («  TPE  &  PME 
gagnantes sur tous les coups ») is on-going.  

A  real  momentum  for  actions  on  resource  efficiency 
exists 
in  the  French  business  community  and  pre-
conditions  to  create  impact  from  this  momentum  are 
excellent. 

Eco-innovation 

In  2018,  France  ranked  11th  on  the  2018  European 
Innovation  Scoreboard,  being  the  sixth  fastest-growing 
innovator (an increase of 10.1 % since 2010)13. However, 
its  performance  is  less  outstanding  in  eco-innovation,  in 
which it is ranked 12th among EU countries, according to 
the 2017 eco-innovation index (Figure 3). 
Figure 3: 2017 Eco-innovation index (EU=100)14 

It  has  a  strong  track  record  in  environmental  regulation 
and  support  schemes  targeting  both  public  and  private 
organisations (including individuals). 

the 

3D-printing, 

industries  of 

future 
the 
France  has  made 
(digitalisation, 
energy 
robotics, 
IoT, 
efficiency,  etc.)  a  national  priority  through  the  national 
industrial  policy  (Nouvelle  France  Industrielle  —  NFI).  It 
sets  priorities  for  both  public  and  private  organisations, 
seeking to focus public and private funding on supporting 
the emergence of a set of innovative solutions within the 
next  5  years.  It 
includes  a  specific  focus  on  eco-
innovation and the circular economy, including the use of 
new resources, sustainable cities and green industries. 

Figure 4: France’s eco-innovation performance 

solutions 

France  also  funds  eco-innovation  and  circular  economy 
companies  and 
research  and 
innovation  programmes,  infrastructure  and  institutions 
such  as  the  Environment  and  Energy  Management 
Agency  (ADEME,  Agence  de  l’Environnement  et  de  la 
Maîtrise de l’Energie). 

through 

Despite  these  positive  aspects,  legislative  and  financial 
barriers  prevent  many  companies  from  investing  in  eco-
innovation.  It  appears  to  be  hard  to  change  individual 
behaviour  and 
sustainable 
consumption  patterns.  Banks  are  still  reluctant  to  fund 
breakthrough innovations. 

social  acceptance  of 

As stated above, many local authorities are also involved 
in  supporting  eco-innovation  and  the  circular  economy. 
In  2016,  10  of  the  15  major  cities  made  a  deal  with  the 
government  to  support 
in  energy  and 
environmental transition on the one hand, or smart cities 
and transport on the other 15. 

innovation 

Despite  favourable  legislation  supporting  eco-innovation 
and  entrepreneurship  since  2003,  France  remains  close 
to the European average. 

13 European Commission, European innovation Scoreboard 2018. 
14 Eco-innovation Observatory: 2017 eco-innovation scoreboard. 

15 European Commission, Eco-Innovation Observatory: Eco-innovation 
Country Profiles 2016-2017. 

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Environmental Implementation Review 2019 – France 

Waste management 

Turning waste into a resource is supported by: 
legislation,  which 
implementing  EU  waste 
(i)  fully 
includes  the  waste  hierarchy,  the  need  to  ensure 
separate  collection  of  waste,  the 
landfill  diversion 
targets, etc.; 
 (ii) reducing waste generation and waste generation per 
capita in absolute terms; and  
(iii)  limiting  energy  recovery  to  non-recyclable  materials 
and  phasing  out  landfilling  of  recyclable  or  recoverable 
waste. 

This  section  focuses  on  the  management  of  municipal 
waste  for  which  EU 
law  sets  mandatory  recycling 
targets16. 
Municipal waste generation17 in France has fallen slightly 
in  recent  years  to  513 kg/inhabitant  in  2017.  This  still 
puts  France  5.5 %  above 
the  EU  average  of 
487 kg/inhabitant18. 

Figure 5: Municipal waste by treatment in France, 2010-
201719 

recovery  have  remained  constant  in  absolute  terms 
(which means they have increased as percentages). 

Figure 6 shows that recycling of municipal waste has risen 
steadily since 2010, reaching 43 % by 2017. 

This  progress  in  recent  years  puts  France’s  performance 
close to the EU average. With a recycling rate of 43 % in 
2017 and an improvement of 13 % since 201220, France is 
not  considered  to  be  at  risk  of  missing  the  European 
target  of  recycling  half  of  all  municipal  waste  (according 
to  Eurostat,  the  European  Commission’s  statistics  office, 
methodology)21. However, more efforts will be needed to 
meet  recycling  targets  after  202022.  France  relies  on 
incineration,  with  35 %  of  waste  being  subjected  to 
energy 
landfill  still 
accounts for 21 % of all municipal waste, a figure close to 
the EU average of around 24 % (2017). 
Figure 6: Recycling rate of municipal waste, 2010-201723 

treatment.  Similarly, 

recovery 

Figure 5 shows municipal waste by treatment in terms of 
kilos  per  person.  It  reveals  that  France  is  gradually 
reducing waste disposal and moving towards methods of 
treatment  that  are  higher  up  in  the  waste  hierarchy 
(recycling,  composting).  Only  incineration  and  energy 

16 See Article 11.2 of Directive 2008/98/EC. This Directive was amended 
in 2018 by Directive (EU) 2018/851, and more ambitious recycling 
targets were introduced for the period up to 2035. 
17 Municipal waste is waste collected by or on behalf of municipal 
authorities, or directly by the private sector (business or private non-
profit institutions), not on behalf of municipalities. 
18 Eurostat, Municipal waste and treatment, by type of treatment 
method. 
19 European Commission, Municipal waste by waste operations. 

Despite a number of innovative and far-reaching policies 
(such  as  those  on  EPR)  there  is  still  a  need  for  other 
policies to drive the progress. 

20 Commissariat Général au Developpement Durable: ‘Indicateurs 
nationaux de la transition écologique vers un développement durable 
2015-2020: premier état des lieux, Etudes et documents No 142, mars 
2016, p. 17. 
21 Member States may choose a method other than the one used by 
ESTAT (referred to in this report) to calculate their recycling rates and 
track compliance with the 2020 target of 50 % recycling of municipal 
waste. 
22 Directive (EU) 2018/851, Directive (EU) 2018/852, Directive (EU) 
2018/850 and Directive (EU) 2018/849 amend the previous waste 
legislation and set more ambitious recycling targets for the period up to 
2035. These targets will be taken into consideration to assess progress 
with future environmental implementation Reports. 
22 European Commission, Recycling rate of municipal waste. 
23 European Commission, Recycling rate of municipal waste. 

8 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – France 

collection 

in  France. 

is  plateauing 

A 2016 report by the French Court of Auditors noted that 
separate 
It 
recommends  that  both  waste  producers  and  the 
authorities  take  steps  to  boost  separate  collection.  This 
means that separation and treatment plants will need to 
be  rationalised  and  modernised,  enabling  more  to  be 
done  with  fewer  plants24.  This  issue  is  particularly  acute 
in the outermost regions. 

In August 2015 France adopted the Energy Transition for 
Green Growth Act, which establishes a waste prevention 
target  to  cut  household  waste  production  by  10 %  of 
2010  levels  by  2020.  It  features  a  number  of  measures 
designed  to  build  momentum  towards  this  target  — 
including  a  definition  of  the  legal  concept  of  ‘planned 
obsolescence’,  which  becomes  a  crime;  promotion  of 
deposit  and  return  schemes;  the  obligation  for  food 
retailers  to  donate  unsold  goods  to  charity  so  as  to 
reduce  food  waste;  and  a  ‘resource  use  hierarchy’ 
inspired  by  the  waste  hierarchy,  to  encourage  the 
prevention of waste. 

targets 

The  Act  also  promotes  recycling,  establishing  waste 
recovery 
(55 %  and  65 % 
for  2020-2025 
respectively  of  all  non-hazardous  non-inert  waste),  and 
extends  separate  collection  to  all  organic  waste  before 
2025. In view of action to promote separate collection, it 
also states that mechanical biological treatment (MBT) of 
waste is no longer relevant and excludes  any new public 
financing for MBT installations. 

Following up these considerations, in March 2017 ADEME 
published  a  guidance  document25  detailing  its  views  on 
the  future  of  installations  to  treat  residual  municipal 
waste.  The  document  says  existing  plants  should  be 
converted  to  sorting  separately  collected  waste,  while 
installations  for  biodegradable  waste 
pre-treatment 
should  complement 
replace  separate 
collection. On the other hand, for incineration, treatment 
capacities should not increase and their energy efficiency 
should  improve,  partly  though  phasing  out  installations 
without energy recovery by 2025. 

rather 

than 

In addition, France has recently adopted a decree stating 
that  firms  must  separate  materials  into  paper,  glass, 
plastic,  metal  and  wood.  The  separate  collection  of  bio-
waste has been mandatory for big producers since 2012 
it  to  all 
and  the  Green  Growth  Act  has  extended 
companies.  

The  separate collection of household packaging  waste is 
extended progressively to cover  every type of packaging 
waste  to  be  put  in  a  yellow  bin,  with  the  exception  of 

glass collected separately. By 2022, all households will be 
covered  by  these  new  rules.  A  3,6M€  national  mass-
media  campaign  on  the  benefits  of  recycling  was 
launched on 15 October 2018. The project is co-financed 
by 13 extended producer responsibility schemes, ADEME 
and the Ministry for Ecological Transition.  

France  also  adopted  a  decree  stating  that 
landfill 
capacities should be reduced by 30 % of their 2010 levels 
by  2020,  and  that  they  should  be  halved  by  2025. 
Incineration  is  to  be  reduced  by  a  quarter  by  2020  and 
halved by 202526. 

The decree also stipulates that waste management plans 
must  identify  shared  facilities  for  collecting  and  treating 
bio-waste from households, businesses and farms. 

Although  France  has  taken  various  measures  under  the 
Energy Transition Act to dispense with illegal dump sites 
(by  establishing  a  network  for  collecting  construction 
sector  waste  that  imposes  significant  obligations  on 
building product distributors), the country still has illegal 
dumps.  As  regards  enforcement,  inspections  and  legal 
proceedings  have 
traceability  of 
construction waste. 

improved 

the 

It is becoming urgent to review and adopt regional waste 
management  plans 
in  the  context  of  the  regional 
administration  reform,  as  required  by  the  Waste 
Framework Directive. This should preferably take account 
of  the  revised  Waste  Framework  Directive,  including  its 
more ambitious post-2020 recycling and landfill targets. 

The national focus on EPR schemes to promote recycling 
in particular sectors continues. For instance, there is now 
an EPR scheme for leisure boats. 

2019 priority actions 

 

Improve  and  extend  separate  collection  of  waste. 
Establish  minimum  service  standards  for  separate 
collection  (e.g.  frequency  of  collection,  types  of 
containers,  etc.)  in  municipalities,  to  ensure  high 
recyclable  waste  capture  rates.  Use  economic 
instruments, such as pay-as-you-throw. 

  Urgently  update  and  adopt 

regional  waste 
management  plans;  possibly,  take  into  account  the 
requirements  of  the  revised  Waste  Framework 
Directive. 

24 Les éco-organismes: un dispositif original à consolider (2016), a report 
by the French Court of Auditors. 
25 ADEME, Quel avenir pour le traitement des ordures ménagères 
residuelles?, March 2017. 

26Décret n° 2016-811 du 17 juin 2016 relatif au plan régional de 
prévention et de gestion des déchets. 

9 

                                                                 
                                                                 
Environmental Implementation Review 2019 – France 

Climate change 

The EU has committed to undertaking ambitious climate 
action internationally as well as in the EU, having ratified 
the Paris Climate Agreement on 5 October 2016. The EU 
targets are to reduce greenhouse gas (GHG) emissions by 
20 % by 2020 and by at least 40 % by 2030, compared to 
1990.  As  a  long-term  target,  the  EU  aims  to  reduce  its 
emissions  by  80-95 %  by  2050,  as  part  of  the  efforts 
required by developed countries as a group. Adapting to 
the adverse effects of climate change is vital to alleviate 
its  already  visible  effects  and  improve  preparedness  for 
and resilience to future impacts. 

The EU emissions trading system (EU ETS) covers all large 
greenhouse  gas  emitters  in  the  industry,  power  and 
aviation  sectors  in  the  EU.  The  EU  ETS  applies  in  all 
Member States and has a very high compliance rate. Each 
year,  installations  cover  around  99  %  of  their  emissions 
with the required number of allowances. 

Figure  7:  Change  in  total  greenhouse  gas  emissions 
1990-2017 (1990=100%)27. 

national target under the EU Effort Sharing Decision is to 
reduce  emissions  by  14  %  compared  to  2005.  For  2030, 
France's  national  target  under  the  Effort  Sharing 
Regulation will be to reduce emissions by 37 % compared 
to 2005. 

The  Act  on  Energy  Transition  for  Green  Growth  (loi 
relative  à  la  transition  énergétique  pour  la  croissance 
verte)  is  in  force  and  forms  the  legal  basis  for  the  Low 
Carbon Strategy and the Multiannual Energy Programme. 
In November 2018, the draft Multi-annual Energy Plan for 
2024-2028  (2nd  PPE)  was  adopted.  It  sets  the  main 
trajectory for investments in the field of energy involving 
public intervention in this period. France has developed a 
robust  and  well  elaborated  low  carbon  strategy,  where 
the key element are carbon budgets covering all sectors. 
Sectoral  GHG  reduction  targets  are  defined,  as  well  as 
sectoral policies. The Climate Plan, adopted in July 2017, 
sets  carbon  neutrality  as  the  long  term  objective,  to  be 
met by 2050. 

Figure  8:  Targets  and  emissions  for  France  under  the 
Effort Sharing Decision and Effort Sharing Regulation28. 

For emissions not covered by the EU ETS, Member States 
have  binding  national  targets  under  the  Effort  Sharing 
legislation.  France  had  lower  emissions  than  its  annual 
emission  allocations  (AEAs)  in  each  of  the  years  2013-
2016.  According  to  preliminary  data,  emissions  were 
slightly  lower  than  the  AEA  in  2017.  For  2020,  France's 

27 Annual European Union greenhouse gas inventory 1990–2016 (EEA 
greenhouse gas data viewer). Proxy GHG emission estimates for 
2017Approximated EU greenhouse gas inventory 2017 (European 
Environment Agency). Member States national projections, reviewed by 
the European Environment Agency. 

Transport  represents  almost  a  quarter  of  the  EU’s  GHG 
emissions and is the main cause of air pollution in cities. 
Transport  emissions  in  France  increased  by  1  %  from 
2013 to 2016.  

The  F-gas  Regulation  requires  Member  States  to  run 
training  and  certification  programmes  and  rules  for 
penalties  and  notify  these  measures  to  the  Commission 
by 2017. France has notified both measures.  

28 Proxy GHG emission estimates for 2017Approximated EU greenhouse 
gas inventory 2017 (European Environment Agency). Member States 
national projections, reviewed by the European Environment Agency. 

10 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – France 

Figure 9: Greenhouse gas emissions by sector (Mt. CO2-
eq.). Historical data 1990-2016. Projections 2017-203029. 

summarizing  findings  from  a  comprehensive  national 
consultation process was published in early 2018.  

The  total  revenues  from  the  auctioning  of  emission 
allowances  under  the  EU  ETS  over  the  years  2013-2017 
were EUR 1 295 million. 100 % of the auctioning revenues 
have  been  spent  on  climate  and  energy  purposes  All 
auctioning revenues are earmarked for climate action, more 
specifically to building insolation. 

2019 priority action 

In this report, no priority actions have been included on 
climate action, as the Commission will first need to assess 
the  draft  national  energy  and  climate  plans  which  the 
Member  States  needed  to  send  by  end  of  2018.  These 
plans  should  increase  the  consistency  between  energy 
and climate policies and could therefore become a good 
example  of  how  to  link  sector-specific  policies  on  other 
interlinked  themes  such  as  agriculture-nature-water  and 
transport-air-health.  

The  accounting  of  GHG  emissions  and  removals  from 
forests and agriculture is governed by the Kyoto Protocol. 
A  preliminary  accounting  exercise  for  2013-2016  shows 
net  credits  of,  on  average,  -7.3  Mt  CO2-eq,  which 
corresponds  to  6.4%  of  the  EU-28  accounted  sink  of  -
115.7 Mt CO2-eq.  

The  EU  Strategy  on  adaptation  to  climate  change, 
adopted  in  2013,  aims  to  make  Europe  more  climate-
resilient, by promoting action by Member States, better-
informed  decision  making,  and  promoting  adaptation  in 
key vulnerable sectors. By adopting a coherent approach 
and  providing  for  improved  coordination,  it  seeks  to 
enhance the preparedness and capacity of all governance 
levels to respond to the impacts of climate change.  

tourism, 

In France, the National Adaptation Strategy was adopted 
in  2006  and  the  National  Adaptation  Plan  (PNACC)  in 
2011,  covering  20  thematic  areas:  cross-cutting  actions, 
health,  water,  biodiversity,  natural  hazards,  agriculture, 
forests,  fisheries  and  aquaculture,  energy  and  industry, 
transport  infrastructures,  urban  planning  and  the  built 
environment, 
information,  education  and 
training,  research,  funding  and  insurance,  coastlines, 
international  actions,  and 
mountains,  European  and 
governance.  The  integration  of  adaptation  into  sectorial 
policies 
is  part  of  the  NAP's  specific  actions  and 
measures,  the  monitoring  scheme  looks  at  a  qualitative 
assessment  of  the  status  of  implementation  of  the  230 
measures  in  the  different  sectors.  In  2015  the  final 
evaluation of the NAP concluded that around 80% of the 
actions and 75 % of the measures in  the NAP have been 
in  July  2017 
achieved.  The  Plan  Climat  presented 
announced a revision of the NAP (2e PNACC) and a report 

29 Annual European Union greenhouse gas inventory 1990–2016 (EEA 
greenhouse gas data viewer). Proxy GHG emission estimates for 
2017Approximated EU greenhouse gas inventory 2017 (European 
Environment Agency). Member States national projections, reviewed by 
the European Environment Agency. 

11 

 
                                                                 
 
 
Environmental Implementation Review 2019 – France 

2. Protecting, conserving and enhancing natural capital 

Nature and biodiversity 

in  the  EU  by  2020. 

The  EU  biodiversity  strategy  aims  to  halt  the  loss  of 
biodiversity 
full 
implementation  of  the  Birds  and  Habitats  Directives  to 
achieve  favourable  conservation  status  of  protected 
species and habitats. It also requires that the agricultural 
improve 
and  forest  sectors  help  to  maintain  and 
biodiversity. 

It  requires 

Biodiversity strategy 

for  biodiversity 

is  France’s 
The  national  strategy 
commitment  under 
the  Convention  on  Biological 
Diversity.  The  2011-2020  strategy  is  designed  to  boost 
the  commitment  of  those  involved  in  all  sectors  of 
activity,  at  all  regional  levels,  both  in  mainland  France 
and  overseas.  It  comprises  20  objectives  designed  to 
preserve, improve, promote and restore biodiversity, and 
to ensure sustainable and fair use of natural resources. 

The  French  legislative  and  regulatory  framework  for  the 
protection  of  biodiversity  encompasses  the  Natura  2000 
network  at  European  level  and  various  national  laws, 
ranging  from  the  Law  on  nature  protection,  adopted  in 
1976,  to  the  Law  on  regaining  biodiversity,  nature  and 
landscape,  adopted  in  2016.  France’s  recognition  that 
these  provisions  cannot  prevent  national  biodiversity 
from  declining  rapidly  (as  shown  by  several  recent 
studies) led to the adoption of a new biodiversity plan in 
July  2018.  This  should  speed  up  the  implementation  of 
priority  measures  to  achieve  the  objectives  set  by  the 
national strategy for biodiversity, ongoing until 2020. 

Setting up a coherent network of Natura 2000 sites 

On  the  basis  of  this  latest  assessment,  the  terrestrial 
Natura  2000  network  in  France  is  now  considered  to  be 
close to full completion. The marine network was subject 
to  an  ambitious  wave  of  designation  undertaken  in 
December  2017  beyond  the  territorial  sea  (the  marine 
metropolitan  surface  covered  by  Natura  2000  increased 
from 41 683 km² to 123 540 km² ). 

France  has  1773 Natura  2000  sites,  of  which  1374  fall 
under  the  Habitats  Directive  and  399  under  the  Birds 
Directive. By May 2018, 12.9 % of France’s land area was 
covered by Natura 2000 (EU average: 18.2 %), with Birds 
Directive special protection areas covering about 8 % (EU 
sites  of 
average:  12.4%)  and  Habitats  Directive 
Community  importance  covering  about  9%  (EU  average: 
13.9 %). 

Designating  Natura  2000  sites  and  setting  conservation 
objectives and measures 

France has made substantial progress since the 2017 EIR. 
As  regards  SCI  designation,  France  has  expanded  its 
marine  area  by  173%.  As  regards  the  designation  of 
special  areas  of  conservation,  only 
four  sites  of 
Community interest remain to be designated, while there 
are management plans in place for 91 % of sites. 

Although a  range of species  and habitats have stabilised 
their  overall  conservation  status  –  some  have  even 
improved  it  —  many  are  still  declining  and  endangered. 
Coastal habitats, wetlands, water-related ecosystems and 
agriculture-related  habitats  are  the  main  ecosystems 
under threat. The key threats to biodiversity are: 

 

 
 
 
 

habitat loss and degradation (especially as a result of 
urban  sprawl,  increasingly  intensive  farming,  land 
abandonment, and intensively managed forests), 
pollution, 
over-exploitation (especially fisheries), 
invasive alien species, and 
climate change. 

The lack of integration between nature policy and other 
policy  areas,  especially  in  the  farming  sector,  but  also, 
though  to  a  lesser  extent,  in  urbanisation,  transport, 
energy  and  forestry,  makes  tackling  the  issue  hard, 
particularly in a context of global warming and the spread 
of invasive alien species. 

Beyond  its  legal  obligations  under  the  nature  directives, 
France has launched a range of initiatives in line with the 
EU nature and biodiversity agenda. These include ‘Trame 

12 

 
 
 
Environmental Implementation Review 2019 – France 

verte et bleue’ (‘green and blue trail’), ‘séquence ‘éviter, 
réduire, compenser’ ‘ (a kind of “No Net Loss exercise”), 
and  ‘Grands  Prix  Natura  2000’.  For  Natura  2000,  it  has 
also established a  variety of tools and material designed 
to  streamline  the  approach  on  the  national  territory. 
These include: 

sector-by-sector assessment, 

 
  methodologies  for  mapping  habitats  and  species  at 

 

 
 

site level, 
a national guidance document setting out the Natura 
2000 management plans, 
special Natura 2000 training sessions, and 
day-long  meetings  for  the  sharing  of  technical 
information  (a  national  equivalent  to  the  Natura 
2000 biogeographical process). 

As  regards  Natura  2000,  the  main  challenges  facing 
France are how to: 

 

 

implement  conservation  measures  effectively,  with 
appropriate  financing  from  both  national  and  EU 
funds; 
integrate  nature  conservation  policy  better  with 
other  policy  areas,  especially  farming  and  fisheries. 
The  reorganisation  of  the  French  regions  gives  a 
leading  role  to  the  implementation  of  biodiversity 
protection  and  new  responsibilities  in  managing  EU 
regional funds; 

A  second  challenge  is  to  finalise  the  evaluation  of  the 
nature conservation model to measure to what extent it 
contributed to the Natura 2000 results, especially at site 
level  and  to  create  a  tool  to  link  nature  conservation 
trends and the measures implemented . 

One  of  the  key  aspects  of  the  recently  adopted 
biodiversity  plan  is  protecting  and  restoring  the  natural 
environment.  The  following  measures  should  boost  the 
enforcement of EU law on the natural environment: 

 
 

establishing or extending 20 protected areas, 
establishing a new national park between the regions 
of Champagne-Ardenne and Burgundy, 

13 

 

 

 

 
 

 

a  decree  to  protect  natural  habitats  that  goes 
beyond  existing  laws  on  species  protection  and 
Natura 2000, 
reintroducing  two  bears  into  the  Pyrenees-Atlantic 
region, 
introducing  multi-species  NAPs 
endangered species by 2020, 
a NAP to protect whales, introduced in 2018, 
action  to  rationalise  the  management  of  hunted 
species in accordance with their conservation status, 
and 
action  to  better  integrate  biodiversity  into  forest 
management documents. 

the  most 

for 

Past  experience  shows 
-  through  complaints  and 
infringements  -  that  the  conservation  status  of  some 
protected  species  of  birds  has  been  jeopardised  by 
hunting.  The  following  aspects  need  monitoring  and/or 
further action: 

 

 
 

 

the  continuation  of  traditional  hunting  practices 
using snares, nets, traps or lime; 
illegal hunting; 
specifying  a 
protected under the Birds Directive; 
the hunting of species in decline. 

limited  hunting  period  for  species 

Increasingly intensive farming significantly harms a range 
of  habitats  and  species,  as  shown  by  the  infringement 
case concerning hamsters, an umbrella species for which 
France needs to continue its restoration efforts. Recently 
the Ministry of Agriculture has launched an agro-ecology 
project  at  both  national  and regional  level,  which  brings 
new opportunities. The biodiversity plan includes: 

 

 

a  target  of  15 %  of  the  farming  area  under  organic 
farming by 2022, 
reducing  pesticide  use  during  the  transition  period, 
including phasing out all uses of glyphosate within 5 
years, and 

  more  effective  protection  for  pollinators  (a  ban  on 

active substances similar to neonicotinoids). 

The  rich  and  unique  fauna  and  flora  of  France’s 
Outermost  regions  (ORs)  and  Overseas  countries  and 
territories  (OCTs)  are  not  covered  by  Natura  2000.  But 
the  ORs  have  large  protected  areas  for  marine  and 
terrestrial  ecosystems.  Moreover,  most  of  these  regions 
have  scientific  institutes  focused  on  biodiversity.  The 
European  Parliament  has  adopted  pilot  projects  on 
inventories  of  species  and  habitats  and  on  mapping  and 
assessing ecosystem services. These cover all the ORs and 
OCTs. The BEST initiative30 promotes the conservation of 
biodiversity  and  the  sustainable  use  of  ecosystem 

30 European Commission, Voluntary Scheme for Biodiversity and 
Ecosystem services in Territories of European Overseas. 

 
                                                                 
Environmental Implementation Review 2019 – France 

services  in the ORs and the  OCTs through small projects 
designed to unlock local potential. France contributes to 
a large extent to the Best initiative including on financial 
aspects. 

Progress 
restoring 
in  maintaining  or 
conservation status of species and habitats 

favourable 

The  2017  EIR  referred  to  the  latest  report  on  the 
conservation status of habitats and species; new data will 
be available for the next EIR. 

Improvements in the status of species and habitats have 
recently  been  reported  in  France.  However,  hot  spots 
remain.  More  than  50%  of  bogs,  grasslands,  dunes  and 
coastal  habitats,  and  over  half  of  molluscs  and  fish 
species have an unfavourable (i.e. bad) status. Short-term 
breeding  trends  remain  negative  for  a  quarter  of  bird 
species. 

2019 priority actions 

 

  Assess  the  degree  of  implementation  of  the  Natura 
2000 management plans and the effectiveness of the 
Natura 2000 measures in helping restore or maintain 
habitats  and  species  in  Natura  2000  sites,  thereby 
ensuring favourable conservation status. 
Continue  to  support  a  sustainable  partnership  for 
biodiversity  protection,  sustainable  development 
and  climate  change  adaptation  and  mitigation 
measures in the ORs and the OCTs. 
Protect  habitats  and  species  affected  by  or 
dependent on agricultural management. 

 

Maintaining  and  restoring  ecosystems  and 
their services 

The EU biodiversity strategy aims to maintain and restore 
including  green 
ecosystems  and  their  services  by 
infrastructure  in  spatial  planning  and  restoring  at  least 
15 %  of  degraded  ecosystems  by  2020.  The  EU  green 
infrastructure  strategy  promotes  the  incorporation  of 
green infrastructure into related plans and programmes. 

The EU has provided guidance on the further deployment 
of green and blue infrastructure in France31 and a country 
page  on  the  Biodiversity  Information  System  for  Europe 
(BISE)32. This information will also contribute to the final 
evaluation of the EU Biodiversity Strategy to 2020. 

In France, green infrastructure is implemented in  spatial 
planning  through  the  ‘green  and  blue  trail’33.  The  2016 

the  Grenelle 

Biodiversity  Law  called  on  French  regions  to  develop 
regional  governance  on  biodiversity,  including  measures 
for the ‘green and blue trail’. Water management  policy 
under 
includes  green 
infrastructure  aspects:  restoration  zones  (adaptation  of 
infrastructure,  restoration  of  wetlands  and  natural 
connectivity of rivers) and sustainable land use (purchase 
of wetlands to ensure sustainable management). 

law  also 

II 

several 

The  policy  of  green  infrastructure  is  also  implemented 
(LIFE)  projects.  Regional  nature 
through 
parks (parcs  naturels 
régionaux,  PNR)  have  been 
established throughout France to protect rural areas with 
valuable  landscapes,  natural  areas  and  cultural  heritage. 
Brest  is  a  participant  in  the  Horizon  2020  project ‘Green 
Cities  for  Climate  and  Water  Resilience,  Sustainable 
Economic  Growth,  Healthy  Citizens  and  Environments’ 
(GrowGreen)34.  This  project 
improve 
climate  and  water  resilience  and  social,  environmental 
and economic performance in cities by deploying nature-
based  solutions  to  problems.  Similarly,  Cannes  is  a 
participant  in  another  Horizon  2020  project,  ‘Urban 
Nature  Labs’  (UNaLab)35, designed  to  make  cities  more 
resilient to climate change and water-related challenges. 
The  approach  relies  on  ecological  water  management  in 
urban  areas,  accompanied  by  greening  measures  and 
innovative and inclusive urban design. 

is  designed  to 

Estimating natural capital 

The  EU  biodiversity  strategy  calls  on  Member  States  to 
map  and  assess  the  state  of  ecosystems  and  their 
services 36 in their national territories by 2014, assess the 
economic  value  of  such  services  and  integrate  these 
values  into  accounting  and  reporting  systems  at  EU  and 
national level by 2020. 

France  is  continuing  its  national  ecosystem  assessment 
project  EFESE  (Évaluation  Française  des  Écosystèmes  et 
des  Services  Écosystémiques).  A  report  summarising  the 
assessment is expected in 2019. 

Since  January  2016,  France  has  made  limited  progress 
with 
implementing  Mapping  and  Assessment  of 
Ecosystems and their Services MAES37 (Figure 10), mainly 
because  the  country 
is  already  one  of  the  best 
performers in the EU. 

31 European Commission, The recommendations of the green 
infrastructure strategy review report and the EU Guidance on a 
strategic framework for further supporting the deployment of EU-level 
green and blue infrastructure. 
32 Biodiversity Information System for Europe. 
33 The French Agency for Biodiversity. 

34 EU project, Growgreen. 
35 Horizon 2020 project, ‘Urban Nature Labs’. 
36 Ecosystem services are benefits provided by nature such as food, 
clean water and pollination on which human society depends. 
37The ESMERALDA project is based on 27 implementation questions and 
updated every six months. 

14 

                                                                 
 
 
                                                                 
Environmental Implementation Review 2019 – France 

Figure 10: Implementation of MAES (September 2018) 

are  now  spreading  into  other  EU  countries:  eastern 
baccharis (Baccharis halimifolia) and Asian hornet (Vespa 
velutina).  At  the  same  time,  the  country  is  under  high 
invasion  pressure  of  raccoons  (Procyon 
lotor)  from 
Germany. 

Figure  11:  Number  of  IAS  of  EU  concern,  based  on 
available georeferenced information for France42 

Business  and  biodiversity  platforms,  networks  and 
communities of practice play a key role in promoting and 
facilitating  natural  capital  assessments  (NCAs)  among 
businesses and financial service providers. An example is 
the Natural Capital Coalition’s Natural Capital Protocol38. 
NCAs help private businesses understand and value both 
their  impact  and  the  degree  of  their  dependency  on 
nature,  thereby  contributing  to  the  EU  biodiversity 
strategy. Platforms of this nature have been set up at EU 
level39  and  in  a  number  of  EU  countries,  though  not  all. 
France has some good examples. 

l’environnement’ 

(EpE)40  brings 
‘Entreprises  pour 
together  40  large  international  and  French  companies 
from  different  sectors  which  are  seeking  to  integrate 
their  corporate 
environmental  considerations 
strategies.  The  ‘Plateforme  Entreprises  et  Biodiversité‘ 
(Orée)41  brings  together  public  and  private  stakeholders 
in  Paris  to  share  best  environmental  practices  and  key 
information on biodiversity protection. 

into 

Invasive alien species 

Under  the  EU  biodiversity  strategy,  the  following  are  to 
be achieved by 2020: 
(i) invasive alien species identified; 
(ii) priority species controlled or eradicated; and 
(iii)  pathways  managed  to  prevent  new  invasive  species 
from disrupting European biodiversity.  
This  is  supported  by  the  Invasive  Alien  Species  (IAS) 
Regulation which entered into force on 1 January 2015. 

The  report  on  the  baseline  distribution  (Figure  11),  for 
which  France  reviewed  its  country  and  grid-level  data, 
shows that 25 of the 37 species on the first  EU list  have 
already been observed in the environment  in France; 24 
of  these  are  established.  The  aquatic  environment  is 
particularly strongly affected, with 16 established species. 
The data show how two invasions which started in France 

38 Natural Capital Coalition, Natural Capital Protocol. 
39 Business and Biodiversity, The European Business and Biodiversity 
Campaign aims to promote the business case for biodiversity in the EU 
Member States through workshops, seminars and a cross-media 
communication strategy. 
40 France, Entreprises pour l’environnement (EpE). 
41 France, Platforme Entreprises et Biodiversité (Orée). 

into  force  of  the  EU 

Between  the  entry 
list  and 
18 May 2018,  France  submitted  one  early  detection 
notification for the muntjac  deer (Muntiacus reevesi), as 
required under Article 16(2) of the Invasive Alien Species 
(IAS)  Regulation.  Eradication  measures  have  been 
established, and hunters have been informed. 

The  baseline  distribution  suggests  that  Pallas’  squirrel 
(Callosciurus  erythraeus)  is  still  at  an  early  stage  of 
invasion.  France  is  one  of  the  few  EU  countries  with  a 
local population of this species. It has thus been advised 
to attempt to eradicate the species. 

France  has  notified  the  Commission  of  the  French 
IAS 
authorities 
the 
for 
Regulation,  as  required  by  Article 24(2)  of  the 
IAS 
Regulation. 

implementing 

responsible 

It  has  communicated  to  the  Commission  the  national 
legal  provisions  on  penalties  for 
infringements,  as 
required  by  Article 30(4)  of  the  IAS  Regulation,  and  has 
thus fulfilled its notification obligations. 

France  has  not,  however,  notified  any  lists  of  invasive 
alien  species  of  concern  to  Martinique,  Mayotte, 
Guadeloupe,  French  Guiana,  Réunion  and  Saint  Martin, 
as required under Article 6(4) of the IAS Regulation. 

42 Tsiamis K; Gervasini E; Deriu I; D`amico F; Nunes A; Addamo A; De 
Jesus Cardoso A. Baseline Distribution of Invasive Alien Species of Union 
concern. Ispra (Italy): Publications Office of the European Union; 2017, 
EUR 28596 EN, doi:10.2760/772692. 

15 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – France 

2019 priority action 

  Notify  the  Commission  of  lists  of  invasive  alien 
species  of  concern 
to  Martinique,  Mayotte, 
Guadeloupe,  French  Guiana,  Réunion  and  Saint 
Martin. 

Soil protection 

The  EU  soil  thematic  strategy  underlines  the  need  to 
ensure  a  sustainable  use  of  soils.  This  entails  preventing 
further  soil  degradation  and  preserving  its  functions,  as 
well as restoring degraded soils. The 2011 Roadmap to a 
Resource Efficient Europe states that by 2020, EU policies 
must take into account their direct and indirect impact on 
land use. 

Soil,  a  finite and extremely fragile resource, is becoming 
increasingly degraded in the EU. 

France  set  up  a  scientific  interest  group  on  soil  (GIS  sol) 
17  years  ago.  This  group  manages  a  standardised  soil 
information  system  that  provides  information  on  the 
state  of  the  soil  in  France.  Although  the  group  does  not 
concern  itself  with  contaminated  sites,  information  on 
such sites is available from another national network. 
Figure 12: Proportion of artificial land cover, 2015 43 

43 Eurostat, Land covered by artificial surfaces by NUTS 2 regions. 

16 

The percentage of artificial land cover44 in France (Figure 
12) can be seen as a measure of the relative pressure on 
nature  and  biodiversity  and  of  the  environmental 
pressure  on  people  living  in  urbanised  areas.  A  similar 
measure  is  population  density.  When  both  are  high,  we 
would  expect  it  to  be  challenging  to  protect  natural 
capital  and  ensure  people’s  well-being.  This  means  that 
implementing EU policy and law in this area is a priority. 

At 5.3 %, France ranks above the EU average for artificial 
land  cover,  the  EU-28  average  being  4.1 %.  The 
population density is 105.5/km2, below the EU average of 
11845. 

In  Guadeloupe 
historical 
and  Martinique, 
chlordecone  contamination  is  still  a  major  issue  for 
agriculture,  fisheries  and  aquaculture  activities  and  for 
human health. 

the 

Contamination  can  severely  reduce  soil  quality  and 
threaten  human  health  or  the  environment.  A  recent 
report  of  the  European  Commission46  estimated  that 
potentially  polluting  activities  have  taken  or  are  still 
taking place on approximately 2.8 million sites in the EU. 
At  EU  level,  650 000  of  these  sites  have  been  registered 
in  national  or  regional  inventories.  65 500  contaminated 
remediated.  France  has 
sites  already  have  been 
registered  6 478  sites  where  potentially  polluting 
activities have taken or are taking place, and already has 
remediated or applied aftercare measures on 3 054 sites. 

Soil  erosion  by  water  is  a  natural  process,  which  can  be 
aggravated by climate change and human activities such 
as  inappropriate  farming  practices,  deforestation,  forest 
fires or construction work. High levels of soil erosion can 
reduce  productivity  in  farming.  They  can  also  adversely 
affect  biodiversity  and  ecosystem 
service  across 
boundaries  and  harm  rivers  and  lakes  (more  sediment, 
transport of contaminants).  According to the RUSLE2015 
model47,  France  loses  2.25  tonnes  of  soil  by  water  per 
hectare  every  year  (t ha−a yr−y),  compared  with  the 
European mean of 2.46 t ha−a yr−y; in other words, France 
has a medium level of soil erosion. It is important to note 
that these  figures are the output  of a  model, not  values 

44 Artificial land cover is defined as the total of roofed built-up areas 
(including buildings and greenhouses), artificial non-built-up areas 
(including sealed area features, such as yards, farmyards, cemeteries, 
car parking areas, etc., and linear features, such as streets, roads, 
railways, runways, bridges) and other artificial areas (including bridges 
and viaducts, mobile homes, solar panels, power plants, electrical 
substations, pipelines, water sewage plants, and open dump sites). 
45 Eurostat, Population density by NUTS 3 region. 
46 Ana Paya Perez, Natalia Rodriguez Eugenio (2018), Status of local soil 
contamination in Europe: Revision of the indicator “Progress in the 
management Contaminated Sites in Europe”. 
47 Panagos, P., Borrelli, P., Poesen, J., Ballabio, C., Lugato, E., 
Meusburger, K., Montanarella, L., Alewell, C., The new assessment of 
soil loss by water erosion in Europe, (2015) Environmental Science and 
Policy, 54, pp. 438-447. 

 
                                                                 
                                                                 
Environmental Implementation Review 2019 – France 

measured  in  the  field.  The  actual  soil  loss  rate  can  vary 
considerably  within  a  given  country,  depending  on  local 
conditions. 

Organic  matter  in  soil  plays  an  important  role  in  the 
carbon cycle and in climate change. Soils are the world’s 
second  largest  carbon  sink  after  the  oceans.  France  has 
an average concentration of organic carbon in soil of 26.2 
g/kg  in  the  first  20  cm  of  topsoil  (across  all  land  cover 
types), compared with a European mean of 47 g/kg. 

Marine protection 

Biodiversity aspects are addressed  mostly through a  mix 
of  spatial  protection  measures  and  through  specific 
measures  targeting  certain  habitats  and  species  groups. 
Measures  relating  to  birds, 
for  example,  address 
anthropogenic pressures, such as incidental by-catch, and 
provide for spatial protection measures. 

France  decided  to  implement  the  measures  before  the 
fully 
deadline  of  2021.  Some  measures  are  not 
implemented  but  the  work  is  ongoing..  Overall,  the 
French programme of measures meets the requirements 
of the Marine Framework Directive MSFD in part only. 

EU coastal and marine policy and legislation require that 
by  2020  the  impact  of  pressures  on  marine  waters  be 
reduced  to  achieve  or  maintain  good  environmental 
status (GES) and ensure that  coastal zones are managed 
sustainably. 

While  the  MSFD  does  not  cover  French  overseas 
territories,  France  adopted  in  2016  an  inter-ministerial 
instruction to organise surveillance and better manage all 
of its seas, including in the overseas territories, with the 
aim to protect the marine environment. 

2019 priority actions 

 

 

Provide  more  information  about  its  measures  to 
achieve  GES,  establish  more  measures  that  have  a 
direct impact on pressures and quantify the expected 
reduction of pressure as a result. 
Ensure reporting of the different elements under the 
Marine  Strategy  Framework  Directive  by  the  set 
deadline. 

The Marine Strategy Framework Directive (MSFD)48 aims 
to achieve good environmental status of the EU’s marine 
waters  by  2020.  To  that  end,  Member  States  must 
develop  a  marine  strategy  for  their  marine  waters,  and 
cooperate  with  the  EU  countries  that  share  the  same 
marine (sub)region. 

For  France,  the  Convention  for  the  Protection  of  the 
Marine  Environment  of  the  North-East  Atlantic  (OSPAR 
Convention) and the Convention for the Protection of the 
Marine  Environment  and  the  Coastal  Region  of  the 
Mediterranean (Barcelona Convention) play an important 
contribution  to  achieving  good  environmental  status  as 
required  by  the  Marine  Strategy  Framework.  These 
marine strategies break down into a  number of steps to 
be  developed  and  implemented  over  six-year  periods. 
The  latest  step  required  Member  States  to  set  up  a 
programme of measures and notify it to the Commission 
by  31 March 2016.  The  Commission  assessed  whether 
the measures taken by France were sufficient to achieve 
good environmental status49. 

France’s  measures  are  consistent  with 
its  good 
environmental  status  and  target  definitions,  and  cover 
almost  all  relevant  pressures  in  its  sub  regions.  Good 
environmental  status  and 
relevant  pressures  are 
addressed  through  a  combination  of  measures  that  are 
either direct (e.g. technical measures targeting pressures) 
or indirect (e.g. cross-cutting research measures designed 
to increase knowledge, or communication measures). To 
take  the  example  of  non-indigenous  species,  the 
measures concerned address the risk of introduction, the 
spreading of such species, and the impact  they have, by 
focusing  on  essential  pathways  such  as  aquaculture  and 
ballast water, and on fishing activities. 

48 European Union, Marine Strategy Framework Directive 2008/56/EC 
49 COM(2018) 562 and SWD(2018) 393. 

17 

                                                                 
 
 
Environmental Implementation Review 2019 – France 

3. Ensuring citizens' health and quality of life 

Air quality 

EU clean air  policy and legislation require the  significant 
improvement  of  air  quality  in  the  EU,  moving  the  EU 
closer to the quality recommended by the World Health 
Organisation.  Air  pollution  and  its  impacts  on  human 
health,  ecosystems  and  biodiversity  should  be  further 
reduced with the long-term aim of not exceeding critical 
loads  and  levels.  This  requires  strengthening  efforts  to 
reach  full  compliance  with  EU  air  quality  legislation  and 
defining strategic targets and actions beyond 2020. 

The  EU  has  developed  a  comprehensive  body  of  air 
legislation50,  which  establishes  health-based 
quality 
standards and objectives for a number of air pollutants. 
Emissions of several air pollutants have fallen in France51. 
The reductions between 1990 and 2014 mentioned in the 
previous  EIR  continued  over  2014-2016,  with  sulphur 
oxide  (SOx)  emissions  falling  by  19.09 %,  nitrogen  oxide 
(NOx)  emissions  by  6.53 %,  and  emissions  of  volatile 
organic  compounds  (NMVOCs)  by  3.12 %.  Meanwhile, 
emissions of fine particulate matter PM2.5 rose by 1.73 % 
and emissions of ammonia (NH3) by 1.39 % between 2014 
and  2016  (see  also  Figure  13  on  total  PM2.5  and  NOx 
emissions by sector). 
Figure 13: PM2.5 and NOx emissions by sector in France52 

Ceilings Directive  53 for 2020-2029 and for any year from 
2030.  

To this end, France has adopted in May 2017 a  National 
Plan for Air Pollution Emission Reduction54. 

At the same time, air quality in France continues to give 
cause  for  severe  concern.  For  the  year  2015,  the 
European  Environment  Agency  estimated  that  about 
to 
35 800  premature  deaths  were  attributable 
concentrations  of  fine  particulate  matter55,  1 800  to 
concentrations of ozone56, and 9 700 to concentrations of 
nitrogen dioxide57 58. 

For  2017,  exceedances  related  to  the  annual  limit  value 
for  nitrogen  dioxide  (NO2)  were  registered  in  11  (out  of 
76) air quality zones (including Paris, Marseille and Lyon). 
Exceedances  have  also  been  registered  related  to 
particulate matter (PM10) in 3 (out of 76) air quality zones 
(including  Paris,  Martinique,  Guadaloupe).  Finally,  target 
values  for  concentrations  of  ozone  and  benzo(a)pyrene 
were also exceeded.  

See  also  Figure  14  for  the  numbers  of  air  quality  zones 
that exceed NO2, PM2.5, and PM10 levels.  

Figure  14:  Air  quality  zones  exceeding  EU  air  quality 
standards in 201759 

Despite  these  reductions,  further  efforts  are  needed  to 
reach  the  commitments  to  cut  emissions  from  2005 
levels  that  are  set  out  in  the  new  National  Emissions 

50 European Commission, 2016. Air Quality Standards. 
51 See EIONET Central Data Repository and Air pollutant emissions data 
viewer (NEC Directive). 
52 2016 NECD data submitted by Member State to the EEA. 

53 Directive 2016/2284/EU. 
54 France, National Plan for Air Pollution Emission Reduction . 
55 Particulate matter (PM) is a mixture of aerosol particles (solid and 
liquid) covering a wide range of sizes and chemical compositions. PM10 
(PM2.5) refers to particles with a diameter of 10 (2.5) micrometres or 
less. PM is emitted from many human sources, including combustion. 
56 Low level ozone is produced by photochemical action. 
57 NOx is emitted during fuel combustion e.g. from industrial facilities 
and the road transport sector. NOx is a group of gases comprising 
nitrogen monoxide (NO) and nitrogen dioxide (NO2). 
58 EEA, Air Quality in Europe – 2018 Report, p.64. Please see details in 
this report as regards the underpinning methodology. 
59 EEA, EIONET Central Data Repository. Data reflects the reporting 
situation as of 26 November 2018. 

 Environmental Implementation Review 2019 – France 

 
 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – France 

According  to  a  special  report  by  the  European  Court  of 
Auditors60,  EU  action  to  protect  human  health  from  air 
pollution has not  had the expected impact.  Air pollution 
may be underestimated in some instances because it may 
not always be monitored in the right places. EU countries 
are  required  to  report  both  real-time  and  validated  air 
quality data to the Commission61. 

The  European  Commission  is  following  up  persistent 
breaches of air quality requirements (for PM10 and NO2), 
which  have  severe  negative  effects  on  health  and  the 
environment.  This  is  being  done  through  infringement 
procedures against all the countries concerned, including 
France.  The  Commission  has  decided  to  refer  France  to 
the  European  Court  of  Justice  for  exceeding  NO2  limit 
values 
is  to  take 
appropriate measures to ensure that all regions meet the 
relevant standards. 

(see  COM(2018) 330).  The  aim 

2019 priority actions 

Industrial Emissions Directive62 (IED). 

The  below  overview  of  industrial  activities  regulated  by 
the  IED  is  based  on  the  ‘industrial  emissions  policy 
country profiles’ project63. 

Around 6 400 industrial installations are required to have 
a  permit  based  on  the  IED  industrial  sectors  in  France 
with  the  most  IED  installations.  In  2015,  these  were: 
intensive  rearing  of  poultry  or  pigs  (50 %  of  total),  non-
hazardous  waste  management  (7 %),  and  the  chemicals 
sector (6 %). 

Figure  15:  Number  of  IED  industrial  installations  by 
sector, France (2015)64 

 

 

 

oxide 

(NOx) 

emissions 

Take action to reduce the main sources of emissions, 
in  the  context  of  the  national  air  pollution  control 
programme (NAPCP). 
Cut 
and 
nitrogen 
concentrations of nitrogen dioxide (NO2) faster. This 
will  require,  for  example,  further  reductions 
in 
transport  emissions,  especially  in  urban  areas  (and 
may  require  proportionate  and  targeted  urban 
vehicle  access  restrictions)  and/or  fiscal  incentives 
(alignment and equal treatment of transport fuels). 
Cut  emissions  and  concentration  of  particulate 
matter  (PM2.5  and  PM10);  this  will  require,  for 
example,  further  reductions 
in  emissions  from 
energy  production  and  heat  generation  using  solid 
fuels, or the promotion of clean and efficient district 
heating. 

Industrial emissions 

The  main  objectives  of  EU  policy  on  industrial  emissions 
are to: 
(i) protect air, water and soil; 
(ii) prevent and manage waste; 
(iii) improve energy and resource efficiency; and  
(iv) clean up contaminated sites.  
To  achieve  this,  the  EU  takes  an  integrated  approach  to 
the  prevention  and  control  of  routine  and  accidental 
industrial emissions. The cornerstone of the policy is the 

The  energy sector  was identified as the industrial sector 
responsible  for  the  largest  environmental  burden  as 
regards emissions to air. It produces the largest share of 
emissions  of  heavy  metals  and  other  pollutants:  sulphur 
oxides  (SOx),  nitrogen  oxides  (NOx)  and  polychlorinated 
dibenzodioxins 
and  polychlorinated  dibenzofurans 
(PCDD/F). 

The  sector  labelled  ‘other  activities’  (mostly  intensive 
rearing  of  poultry  or  pigs,  surface  treatment  and  pulp, 
paper  and  wood  products)  is  mainly  responsible  for 
emissions  to  air  of  particulate  matter  (PM2.5),  non-
(NMVOCs), 
methane 
ammonia (NH3), cadmium (Cd) and zinc (Zn). The metals 
sector  also  contributes  significantly  to  heavy  metals  and 
energy-refining, gasification and liquefaction and coke for 
SOx  and  nickel  (Ni).  The  breakdown  is  shown  in  the 
following graph. 

volatile  organic 

compounds 

60 European Court of Auditors, Special report no 23/2018, Air pollution: 
Our health still insufficiently protected, p.41. 
61 Article 5 of Commission Implementing Decision 2011/850/EU of 
12 December 2011 laying down rules for Directives 2004/107/EC and 
2008/50/EC as regards the reciprocal exchange of information and 
reporting on ambient air quality (OJ L 335, 17.12.2011, p. 86) requires 
Member States to provide up-to-date data. 

62 Directive 2010/75/EU covers industrial activities carried out above 
certain thresholds. It covers energy industry, metal production, mineral 
and chemical industry and waste management, as well as a wide range 
of industrial and agricultural sectors (e.g. intensive rearing of pig and 
poultry, pulp and paper production, painting and cleaning). 
63 European Commission, Industrial emissions policy country profile – 
France. 
64 European Commission, Industrial emissions policy country profile – 
France. 

19 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – France 

Figure 16: Emissions to air from IED sectors and all other 
national air emissions, France (2015) 

‘other  activities’  were 

As  regards  emissions  into  water,  the  non-ferrous  metals 
industry,  iron  and  steel,  waste  management,  chemicals 
and 
identified  as  significant 
polluters.  The  waste  management,  chemical  and  metals 
sectors  generate  mainly  hazardous  and  non-hazardous 
waste. The enforcement approach under the IED confers 
on  citizens  a  strong  right  of  access  to  relevant 
information and to participate in the permitting process. 
This enables members of the public, and NGOs, to ensure 
that permits are granted in the appropriate manner and 
that the conditions governing them are respected. 

By  sharing  information  among  EU  countries,  industrial 
associations,  NGOs  and  the  Commission,  the  best 
available  techniques  (BAT),  reference  documents  (the 
so-called  BREFs)  and  BAT  conclusions  ensure  good 
cooperation  with  stakeholders  and  enable  IED  to  be 
better implemented. 

The  Commission  relies  on  and  welcomes  the  efforts  of 
national  competent  authorities  to  implement  the  legally 
binding  BAT  conclusions  and  associated  BAT  emissions 
levels  in  environmental  permits,  resulting  in  substantial 
ongoing pollution reductions. 

Implementing  the  recently  adopted  BAT  associated 
emission  levels  for  large  combustion  plants  will,  for 
example — on average and depending on the situation of 
individual  plants  —  reduce  emissions  of  sulphur  dioxide 
by  between  25 %  and  81 %,  nitrogen  oxide  by  between 
8 % and 56 %, dust by 31 % to 78 % and mercury by 19 % 
to 71 % at EU level. 

The  Commission  has  in  particular  welcomed  the  good 
cooperation  with  the  administration  to  efficiently  solve 
issues  arising  from  late  implementation  of  the  BAT 
conclusion banning the use of the mercury cell technique 
by chlor alkali plants by 11 December 2017. 

However,  pollution  events  are  still  a  reality.  Examples 
include  water  pollution  through  the  disposal  at  sea  of 
bauxite residues in alumina production in Gardanne, and 
air pollution at the Lacq industrial site. 

20 

2019 priority actions 

  Review  permits  to  ensure  they  comply  with  newly 

 

adopted BAT conclusions. 
Step  up  checks  and  enforcement 
compliance with BAT conclusions. 

to  ensure 

Noise 
The  Environmental  Noise  Directive65  provides  for  a 
common  approach  to  avoiding,  preventing  and  reducing 
the harmful effects of exposure to environmental noise. 

Excessive  noise  from  aircrafts,  railways  and  roads  is  one 
of the main causes of health problems in the EU66. 
On  the  basis  of  a  limited  set  of  data67,  environmental 
noise  in  France  is  estimated  to  cause  at  least  900 
premature  deaths  and  5 900  hospital  admissions 
annually. Moreover, about  1 900 000 people  suffer from 
disturbed  sleep.  Implementation  of  the  Environmental 
Noise  Directive has been  significantly delayed.  The most 
recent 
indicates  that  the  only 
obligations met under the Directive are those relating to 
noise  mapping.  There  are  still  no  action  plans  for  a 
majority  of  agglomerations  (extended  built-up  areas), 
some major roads, railways and airports.  

information  analysed 

2019 priority action 

 

Speed up completion of the missing action plans. 

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures  on  transitional,  coastal  and  fresh  waters 
(including  surface  and  ground  waters)  be  significantly 
reduced.  Achieving,  maintaining  or  enhancing  a  good 
status  of  water  bodies  as  defined  by  the  Water 
Framework  Directive  will  ensure  that  EU  citizens  benefit 
from good quality and safe drinking and bathing water. It 
will  further  ensure  that  the  nutrient  cycle  (nitrogen  and 
phosphorus)  is  managed  in  a  more  sustainable  and 
resource-efficient way. 

The  existing  EU  water  legislation68  puts 
in  place  a 
protective  framework  to  ensure  high  standards  for  all 

65 Directive 2002/49/EC. 
66 WHO/JRC, 2011, Burden of disease from environmental noise, 
Fritschi, L., Brown, A.L., Kim, R., Schwela, D., Kephalopoulos, S. (eds), 
World Health Organisation, Regional Office for Europe, Copenhagen, 
Denmark. 
67 European Environment Agency, Noise Fact Sheets 2017. 
68 This includes the Bathing Waters Directive (2006/7/EC), the Urban 
Waste Water Treatment Directive (91/271/EEC) (on discharges of 
municipal and some industrial wastewaters), the Drinking Water 
Directive (98/83/EC) (on potable water quality), the Water Framework 
Directive (2000/60/EC) (on water resources management), the Nitrates 

 
                                                                 
 
Environmental Implementation Review 2019 – France 

unknown chemical status also decreased from 34% down 
to 21%. 

Figure 17: Ecological status or potential of surface water 
bodies in France69 

water  bodies  in  the  EU  and  addresses  specific  pollution 
sources  (for  example,  from  agriculture,  urban  areas  and 
industrial  activities).  It  also  requires  that  the  projected 
impacts  of  climate  change  are 
into  the 
integrated 
instruments  e.g. Flood  Risk 
corresponding  planning 
Management  Plans  and  River  Basin  Management  Plans, 
including  Programmes  of  Measures  which  include  the 
actions  that  Member  States  plan  to  take  in  order  to 
achieve the environmental objectives. 

Water Framework Directive 

France has adopted and reported the second generation 
of  River  Basin  Management  Plans  under  the  Water 
Framework  Directive  and  the  European  Commission  has 
assessed  the  status  and  the  development  since  the 
adoption  of  the  first  River  Basin  Management  Plans, 
including suggested actions in the EIR report 2017. 

arising 

The  most  significant  pressures  on  surface  water  bodies 
in France is from diffuse agricultural sources followed by 
pressures 
of 
channel/bed/riparian  area/shore  and  pressures  from 
urban  waste  water.  For  groundwater  bodies  the  most 
significant  pressure 
is  diffuse  sources  and  water 
abstraction.  

alteration 

physical 

from 

Altered  habitats  due  to  morphological  changes  was  the 
most significant impact on surface water bodies (40% of 
surface  water  bodies)  followed  by  chemical  pollution 
(37%),  nutrient  pollution  (33%),  organic  pollution  (28%) 
and  altered  habitats  due  to  hydrological  changes  (25%). 
The  most  significant  impact  on  groundwater  bodies  was 
from chemical pollution (28% of groundwater bodies) and 
nutrient pollution (24%). 

The ecological status/potential is illustrated in figure 17. 
The  proportion  of  water  bodies  in  less  than  good  status 
has  increased  for  many  water  categories  in  many  River 
Basin  Districts  which  might  be  related  to  the  fact  that 
there  are  less  water  bodies  with  unknown  status  in  all 
categories. There were small increases in the numbers of 
surveillance sites from the first to the second River Basin 
Management Planss in coastal, lake, river and transitional 
waters.  Overall,  the  number  of  operational  monitoring 
sites  decreased  by  about  72%  between  the  two  River 
Basin  management  plans  in  coastal  waters,  rivers  and 
transitional  waters  and  there  was  a  small  increase  in 
operational sites in lakes. 

Between  the  first  and  second  River  Basin  Management 
Plans  there  has  been  increase  in  proportion  of  surface 
water bodies with good chemical status from 43% up to 
63%.  The proportion of  surface  water bodies that  fail to 
achieve  good  chemical  status  decreased  from  23%  to 
16%.  The  proportion  of  surface  water  bodies  with  an 

increased, 

Although the number of groundwater bodies failing poor 
the  overall  area  of 
quatitative  status 
groundwater  bodies 
failing  good  status  decreased 
significantly  by  one  third  from  16%  of  the  total 
groundwater body area in the first to 11.2% in the second 
River Basin Management Plans. 

Most  significant  pressures  are  identified  in  the  River 
Basin  Management  Plans  and  addressed  by  measures 
(Key type of measures) and the most significant progress 
seems to be in the identification of many more significant 
pressures  and  planning  appropriate  measures  for  the 
second  cycle,  as  well  as  performing  gap  analyses, 
although only up to 2021. 

Nitrates Directive 

Diffuse  pollution  from  agriculture  remains  the  most 
widespread significant pressure on water bodies resulting 
in eutrophication and higher water treatment costs. 
According  to  the  Commission’s  latest  report70  on  the 
implementation  of  the  nitrates  Directive,  32.3 %  of 
monitoring  stations  showed  an  overall 
in 
average  nitrate  concentration  in  groundwater  for  2012-
2015  by  comparison  with  2008-2011,  while  35.2 % 
showed  a  decrease.  As  regards  surface  water,  29.2 %  of 
monitoring  stations  showed  a  higher  average  nitrate 
concentration, while 27.3 % of them had a lower one. 

increase 

Directive (91/676/EEC) and the Floods Directive (2007/60/EC). 

69 EEA, WISE dashboard. 
70 European Commission, 2018 Commission report on nitrates. 

21 

                                                                                                         
 
                                                                 
Environmental Implementation Review 2019 – France 

in  groundwater 
The  average  nitrate  concentration 
exceeded  40  mg/L  in  25.3 %  of  monitoring  stations,  and 
50 mg/L in 12.4 % of them. In the case of surface water, 
the  average  concentration  exceeded  40 %  in  3.8 %  of 
stations and 50 % mg/L in 1.2 % of them . 

To comply with the 2013 ruling by the European Court of 
Justice71  on  the  designation  of  zones  vulnerable  to 
nitrates,  France  is  in  the  process  of  designating  the  last 
vulnerable areas. 

Drinking Water Directive 

No new data has been made available on drinking water 
since EIR 2017 72. 

Bathing Water Directive 

As regards bathing water, Figure 18 shows that  in 2017, 
out  of  the  3 379  bodies  of  bathing  water  in  France, 
77.7 %  were  of  excellent  quality,  13.2 %  of  good  quality 
and 3.8 % of sufficient quality (the corresponding figures 
were  76.8 %,  14.3 %  and  4.1 %  in  2016).  In  2017,  80 
bodies of bathing water in France were of poor quality73. 

Detailed information on French bathing water is available 
from  a  national  portal74  and  via  an  interactive  map 
viewer provided by the European Environment Agency75. 
Figure 18: Bathing water quality, 2014 – 2017 76 

Urban Waste Water Treatment Directive  

Overall,  France  has  demonstrated  a  satisfactory  level  of 
compliance with the basic requirements of the Directive 
on  urban  waste  water  treatment.  As  regards  collection 
and  treatment  rates,  100 %  of  waste  water  in  France  is 

collected.  88.5 %  of  the  load  collected  is  subject  to 
secondary  treatment,  while  94.5 %  is  subject  to  more 
stringent  treatment.  112  agglomerations  are  still  non-
compliant with the directive. 
However, the ninth round of reporting77 also showed that 
around 112 agglomerations are now non-compliant  with 
the  Directive.  The  Commission  is  investigating  the  issue 
jointly with France. According to data reported by France 
as  part  of  this  last  round  of  reporting,  investment 
estimated  at  EUR 4 300 million 
is  needed  to  ensure 
adequate  collection  and  treatment  in  the  remaining 
agglomerations78. France has also reported on a number 
of  planned  projects  (28)  but  there  do  not  seem  to  be 
enough  of  them  to  achieve  full  compliance,  as  the 
number  of  agglomerations 
in  breach  (112)  greatly 
outnumber  the  projects.  Moreover,  France  reports  that 
these projects are  expected to be completed by 2021, a 
long time after the last 2005 deadline. 

Floods Directive 

The  Floods  Directive  established  a  framework  for  the 
assessment and management of flood risks, aiming at the 
reduction  of  the  adverse  consequences  associated  with 
significant floods. 

France  has  adopted  and  reported  its  first  Flood  Risk 
Management Plans under the Directive and the European 
Commission conducted an assessment. 

The  Commission’s  assessment  found  that  good  efforts 
were made with positive results in setting objectives and 
devising  measures  focusing  on  prevention,  protection 
and  preparedness.  The  assessment  also  showed  that,  as 
was  the  case  for  other  Member  States,  France’s  Flood 
Risk  Management  Plans  do  not  yet  include  concrete 
enough  measures,  clearly  prioritised,  that  are  linked  to 
the  objectives  set  and  an  as  complete  as  possible 
estimation of the cost of measures with identification of 
specific sources of funding. In addition, there is scope for 
improving  the  integration  of  the  flood  risk  management 
cycle’s successive steps into the Flood Risk Management 
Plans. 

2019 priority actions 

 

 

Take  steps  in  order  to  improve  tackling  nutrient 
pollution, and assess and report the expected effect 
of the measures.  
Implement  measures  to  ensure  there  will  be  no 

71 C-193/12 of 13/06/2013. 
72 Compliance with the Drinking Water Directive microbiological and 
chemical parameters as last reported was very high. 
73 European Environment Agency, 2017. European bathing water quality 
in 2016, p. 17. 
74 France, National bathing water portal. 
75 EEA, State of bathing waters. 
76 European Environment Agency, 2018. European bathing water quality 
in 2017, p. 21. 

77 European Commission, Ninth Report on the Implementation Status 
and the Programmes for Implementation of the Urban Waste Water 
Treatment Directive (COM(2017) 749) and Commission Staff Working 
Document accompanying the report (SWD(2017)445). 
78 European Commission, Ninth Report on the Implementation Status 
and the Programmes for Implementation of the Urban Waste Water 
Treatment Directive (COM(2017) 749) and Commission Staff Working 
Document accompanying the report (SWD(2017)445). 

22 

 
                                                                 
                                                                 
Environmental Implementation Review 2019 – France 

 

future delays concerning agglomerations in breach of 
the urban waste water treatment directive.  
Take  steps  to  improve  the  integration  of  the  flood 
risk  management  cycle’s  successive  steps  into  the 
Flood Risk Management Plan. 

Chemicals 

The  EU  seeks  to  ensure  that  by  2020  chemicals  are 
produced and used in ways that minimise any significant 
adverse  effects  on  human  health  and  the  environment. 
An  EU  strategy  for  a  non-toxic  environment  that  is 
conducive  to  innovation  and  to  developing  sustainable 
substitutes, 
is  being 
prepared. 

including  non-chemical  options, 

EU  chemicals  legislation79  provides  baseline  protection 
for  human  health  and  the  environment  and  ensures 
stability and predictability for economic operators on the 
internal market. 

The  2016  European  Chemicals  Agency  (ECHA)  report  on 
the  operation  of  REACH  and  CLP80  showed  that 
enforcement  activities  are  still  developing.  In  the  Forum 
for  Exchange  of  Information  on  Enforcement,  which 
enables  EU  countries  to  share  their  experience  of 
enforcement,  coordinated  enforcement  projects81  have 
shown  that  enforcement  activities  could  be  made  even 
more  effective,  especially  as 
registration 
obligations  and  safety  data  sheets.  Relatively  high 
instances  of  non-compliance  have  been  found  in  these 
areas. 

regards 

improvements 
is  scope 

While  there  have  been 
in  national 
further 
enforcement  activities,  there 
for 
improvement  as  regards  harmonisation  throughout  the 
EU, including controls on imported goods. It is also clear 
that  enforcement 
in  some  countries, 
is  still  weak 
particularly  as  regards  controls  on  imports  and  supply 
chain  obligations.  Moreover, 
the  architecture  of 
enforcement  capabilities  remains  complex  in  most  EU 
countries.  The  enforcement  projects  also  revealed  some 
differences  among  EU  countries.  For  instance,  some 
systematically  report  higher  compliance  than  the  EU 
average, others lower. 

A 2015 Commission study highlighted the importance of 
harmonising  the  implementation  of  REACH  at  national 
level, in terms of market surveillance and enforcement; it 

79 Principally for chemicals: REACH (Registration, Evaluation, 
Authorisation and Restriction of Chemicals), OJ L 396, 30.12.2006, p. 1.; 
Classification, Labelling and Packaging, the CLP Regulation (OJ L 252, 
31.12.2006, p. 1.), together with legislation on biocidal products and 
plant protection products. 
80 European Chemicals Agency, Report on the Operation of REACH and 
CLP 2016. 
81 ECHA, On the basis of the projects REF-1, REF-2 and REF-3. 

is a critical factor in successfully operating a harmonised 
single market82. 

In March 2018, the Commission published an evaluation 
of  REACH83.  The  evaluation  concludes  that  REACH 
delivers  on  its  objectives,  but  that  progress  made  is 
slower  than  anticipated.  In  addition,  the  registration 
dossiers often are incomplete. The evaluation underlines 
the need to enhance enforcement by all actors, including 
registrants,  downstream  users  and 
in  particular  for 
importers,  to  ensure  a  level  playing  field,  meet  the 
objectives  of  REACH  and  ensure  consistency  with  the 
actions  envisaged  to  improve  environmental  compliance 
and  governance.  Consistent  reporting  of  Member  State 
enforcement  activities  was  considered  important  in  that 
respect. 

labour 

inspectorate, 

The French competent authority on REACH is the Ministry 
for the Ecological and Inclusive Transition of France. The 
French  Environmental  Code  assigns  responsibility  for 
REACH  enforcement 
to  a  number  of  enforcing 
authorities,  especially  the  environmental  inspectorate, 
the 
the  consumer  protection 
authority  and  the  customs  authority.  It  grants  them  the 
powers  they  need  and  sets  out  the  offences  defined  by 
REACH  and  the  penalties  (both  administrative  and 
criminal)  that  can  be  imposed  for  infringing  REACH 
requirements.  An  annual 
circular 
organises  the  work  of  REACH  enforcers.  Each  REACH 
field  of 
enforcement  authority  works 
competence;  for  instance,  the  labour  inspectorate  deals 
with REACH requirements pertaining to workers. The first 
checks  were  carried  out  in  2009.  Currently,  they  focus 
mainly on pre-registration requirements 84. 

interministerial 

its  own 

in 

Making cities more sustainable 

EU policy on the urban environment encourages cities to 
put  policies  in  place  for  sustainable  urban  planning  and 
design.  These  should  include  innovative  approaches  to 
urban  public 
sustainable 
buildings,  energy  efficiency  and  urban  biodiversity 
conservation. 

transport  and  mobility, 

living 

in  Europe 

in  urban  areas 

The  population 
is 
projected  to  rise  to  just  over  80%  by  205085.  The  urban 
the 
environment  poses  particular 
environment  and  human  health,  while  also  providing 
opportunities  and  efficiency  gains 
in  resource  use. 
Municipalities  are  encouraged  to  become  greener 

challenges 

to 

82 European Commission, Monitoring the Impacts of REACH on 
Innovation, Competitiveness and SMEs, 2015. 
83 COM(2018) 116. 
84 ECHA, National Inspectorates – France . 
85 European Commission, Eurostat, Urban Europe, 2016, p.9. 

23 

                                                                 
                                                                 
Environmental Implementation Review 2019 – France 

through  the  Green  Capital  Award86,  the  Green  Leaf 
Award87 and the Green City Tool88. 

Financing greener cities 

to  allocate 
Over  2014-2020,  France  has  planned 
EUR 850 million 
its  European  Regional 
Development Fund (ERDF) allocation) and EUR 62 million 
(2 % of its European Social Fund allocation to sustainable 
urban development)89. 

(10 %  of 

in 

is  a  participant 

France 
the  European  Urban 
Development  Network  (UDN)90,  which  includes  more 
than  500  cities  across  the  EU.  UDN  is  responsible  for 
implementing integrated measures based on sustainable 
urban  development  strategies  financed  by  ERDF  over 
2014-2020. 

Within the UDN initiatives, the ERDF is supporting urban 
innovative  actions  (UIA)  as  a  way  of  testing  new  and 
unproven approaches to urban challenges. The UIA has a 
total  ERDF  budget  of  EUR 372  million  for  2014-20.  Five 
French  cities  (Lille,  Nantes,  Paris,  Sevran  and  Toulouse) 
have  obtained  funding  to  support  a  wide  variety  of 
projects  in  areas  such  as  urban  regeneration,  homeless 
people,  energy  efficiency,  the  circular  economy  or 
mobility. 

Participation in EU urban initiatives and networks 

French municipalities are involved in EU initiatives to do 
with  environmental  protection  and  climate  change  in 
cities. Nantes was  selected as the 2013 European Green 
Capital91,  thanks  to  its  commitment  and  strategy  for 
safeguarding the environment in key areas such as urban 
planning,  transport,  housing,  water,  energy  and  waste 
management. 

Sixteen French municipalities are involved in the URBACT 
initiative  to  support  sustainable  urban  development, 
through 17 thematic networks92. 

Several Horizon 2020 network  projects have also helped 
make French cities more sustainable. CIVITAS includes 14 
municipalities representing France in a common effort to 
achieve cleaner and better transport in cities93. 

French cities are also actively involved in initiatives  such 
as  Eurocities  (a  political  platform  for  major  European 
cities) and the EU Covenant of Mayors. 113 French cities, 
representing  almost  16  million  people,  had  signed  up  to 
the  Covenant  by  June  2018.  Signatories  commit  to 
developing  a  sustainable  energy  and  climate  action  plan 
within  2  years.  80  French  cities  have  already  adopted 
such  a  plan94.  Signatories  endorse  a  shared  vision  for 
2050: 

 
 

 

speeding up decarbonisation of their land, 
improving  their  capacity  to  adapt  to  unavoidable 
climate change, and 
giving  citizens  access  to  secure,  sustainable  and 
affordable energy. 

These urban initiatives and networks may contribute to a 
better  urban  environment.  In  2017,  18 %  of  French  city-
dwellers  said  the  area  where  they  lived  was  affected  by 
pollution,  grime  or  other  environmental  problems 
(19.3 %  in  2016  and  17.8 %  in  2015).  These  figures  are 
below  the  EU-28  average  (20 %  in  2017,  18.9 %  in  2016 
and 9.2 % in 2015)95. 

Nature and cities 

In  France,  22 %  of  the  Natura  2000  network  lies  within 
functional  urban  areas96,  above  the  EU  average  of  15 % 
(see Figure 19). 

includes 

The  biodiversity  plan  recently  adopted  by  France  (on 
4 July 2018)97 
natural 
environment  in  cities.  It  highlights  the  role  played  by 
nature  in  cities  in  helping  to  mitigate  the  urban  heat 
island  effect,  improving  quality  of  life  and  preventing 
floods. The plan aims to achieve the following: 

developing 

the 

 
 
 

one tree per 100 inhabitants, 
a 40 % increase in green areas in cities and 
a 50 % increase in green areas as a proportion of the 
overall surface area in cities by 2020. 

Local  authorities  will  be  encouraged  to  promote 
biodiversity in cities and to support innovative actions. 

86 European Commission, European Green Capital. 
87 European Commission, European Green Leaf Award. 
88 European Commission, Green City Tool. 
89 Agreement between the European Commission and France Accord de 
Partenariat, 2014-2020, France. 
90 European Commission, The Urban Development Network. 
91 Nantes green capital 2013. 

92 URBACT, Associated Networks by country. 
93 European Commission, Horizon 2020 Civitas Project. 
94 Covenant of Mayors for Climate and Energy, Plans & Actions. 
95 European Commission, Eurostat, Pollution, grime or other 
environmental problems by degree of urbanisation. 
96 European Commission, Definition of Functional Urban Areas. 
97 Plan biodiversité 2018. 

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Environmental Implementation Review 2019 – France 

Since 2010, France has had a ‘Capital of Biodiversity’ prize 
to  honour  municipalities  that  improve  and  promote  the 
protection  of  biodiversity  at  local  level  in  urban  areas. 
Participation 
is  open  to  municipalities  of  all  sizes, 
including  small  villages.  In  2017,  Muttersholtz  (Alsace) 
won  the  prize  for  supporting  biodiversity  in  land  use, 
renovation  and  building.  The  theme 
is 
for  2018 
‘ecological design and management of natural areas’98. 

Figure  19:  Proportion  of  Natura  2000  network 
Functional Urban Areas (FUA) 99 

in 

points  in  France  rose  significantly  between  2013  and 
2016.  Between  2014  and  2016,  the  number  of  charging 
points rose from 1 834 to 15 843 units104. 

Figure  20:  Proportion  of  passengers  cars  by  fuel  types, 
2015 

According  to  the  biodiversity  plan,  66 000  hectares  of 
agricultural  soil  or  natural  areas  are  sealed  every  year. 
The  plan  aims  to  reduce  net  soil  sealing  to  zero  and  to 
ensure  that  French  legislation  includes  an  obligation  for 
the local authorities to combat, limit and compensate for 
urban sprawl. 

Urban sprawl 

France  had  a  weighted  urban  proliferation  rate,  at  2.33 
UPU/m2 100 in 2009 compared to a European average (EU-
28+4)  of  1.64  UPU/m2,  having  increased  by  3.1 %  from 
2006 to 2009101. 

Traffic congestion and urban mobility 

The  number  of  passenger  cars  per  1000  inhabitants  has 
been  falling  since  2014.  The  figure  was  498  in  2013;  by 
2016 it had fallen to 479102. 

Road  vehicles  are  up  by  6.5 %  since  2006,  despite  a 
slowdown in registrations over 2016 and 2017. Although 
diesel cars now account  for a  smaller proportion of new 
cars  registered,  62 %  of  passenger  cars  ran  on  diesel  in 
2016103 — the highest rate in Europe. 

However, the number of cars running on alternative fuels 
is  rising.  The  number  of  new  passenger  cars  using 
alternative  fuels  rose  more  than  tenfold  between  2011 
and  2016.  Similarly,  the  number  of  electric  charging 

98 France, ‘Capital of Biodiversity’ prize. 
99 European Commission, The 7th Report on Economic, Social and 
Territorial Cohesion, 2017, p. 121. 
100 Urban Permeation Units measure the size of the built-up area as well 
as its degree of dispersion throughout the region. 
101 EEA, Urban Sprawl in Europe, Annex I, 2014, pp.4-5. 
102 Eurostat, Passenger cars per 1 000 inhabitants. 
103 CGDD, Datalab, Chiffres clés du transport, Édition 2018, Mars 2018. 

Vignette Crit’air 

The  air  quality  certificate  Crit’air 
is  a  tool  for 
improving  air  quality.  It  enables  towns  and  cities  to 
adjust  their  parking  and  traffic  policy  to  encourage 
the  use  of  the  least  polluting  vehicles.  It  allows  to 
ban  the  most  polluting  vehicles  in  certain  areas 
during pollution peaks. 

An  air  quality  certificate  is  mandatory  for  driving  in 
restricted  traffic  areas  (French  low-emission  zones) 
designated  by  the  authorities,  such  as  inside  the 
Paris ring road, or if an emergency scheme has been 
introduced during pollution episodes. The certificate 
also confers certain benefits made available by local 
authorities. 

The  certificate  is  a  round  sticker  displayed  in  a 
prominent  position  on  the  vehicle.  There  are  six 
different  types  of  certificates,  corresponding  to 
different  categories  of  vehicle,  classed  by  air 
pollutant emissions.  

2016  saw  an  increase  in  road  traffic,  with  more  private 
transport of travellers and freight transport, owing to low 
fuel  prices  and  the  economic  recovery.  Greenhouse  gas 
emissions  from  transport,  which  had  been  falling  since 
2004, rose slightly in both 2015 and 2016. Road mortality, 

104 European Commission, Transport in the European Union Current 
Trends and Issues, April 2018. 

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Environmental Implementation Review 2019 – France 

which  had  been  falling  since  2005,  was  up  for  the  third 
year in a row. 

Car  trips  represented  over  80 %  of  passenger-kilometres 
travelled  in  France  in  2015.  This  remains  slightly  below 
the  EU  average  of  81.3 %.  On  the  other  hand,  use  of 
buses  and  coaches  in  France  is  below  the  EU  average, 
while rail passenger transport is higher105. 

The total length of cycle tracks increased from 6900 km in 
2011  to  13700  km  in  2016.  The  total  length  of  the  road 
and  rail  networks  is  almost  stable,  while  the  tram 
network is expanding in big cities108. 

105 European Commission, Transport in the EU, April 2018. 

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Environmental Implementation Review 2019 – France 

Part II: Enabling framework: implementation tools 

4.  Green taxation, green public procurement, environmental funding 
and investments 

Green  taxation  and  environmentally  harmful 
subsidies 

payable for extracting water from a ground source (with 
some exemptions)108. 

incentives, 

Financial 
taxation  and  other  economic 
instruments  are  effective  and  efficient  ways  to  meet 
environmental  policy  objectives.  The  circular  economy 
action  plan  encourages  their  use.  Environmentally 
harmful  subsidies  are  monitored  in  the  context  of  the 
European  Semester  and  the  energy  union  governance 
process. 

France’s  revenue  from  environmentally  relevant  taxes 
remains  close  to  the  EU  average.  Environmental  taxes 
stood at 2.31 % of GDP in 2017 (EU-28 average: 2.4 %), as 
shown  in  Figure  21,  and  energy  taxes  at  1.92 %  of  GDP, 
against  an  EU  average  of  1.84 %.  In  the  same  year,  the 
environmental tax came to 4.77 % of total revenues from 
taxes  and  social  security  contributions  (lower  than  the 
EU-28 average of 5.97 %). 

The labour tax take as a proportion of total tax revenues 
(52 % in 2016) was in line with the EU average, while the 
implicit tax burden on labour was 41.2 %106. Consumption 
taxes  remained  relatively  low  at  24.5 %,  the  lowest  rate 
but  one  among  the  EU-28.  This  suggests  there 
is 
significant potential for shifting taxes  — especially those 
labour  to 
with  an  environmental 
consumption. 

impact  —  from 

The  2018  country  report  prepared  in  the  context  of  the 
European  Semester  acknowledged  France’s  efforts  to 
increase revenue from tax on transport fuel and the fact 
that  environmental  taxation  will  continue  to  rise,  as  the 
carbon tax is set to increase until 2030. However, there is 
in 
no  automatic 
France.  Indexing  excise  duty  levels  to  inflation  may 
prevent an erosion of tax revenues, and it would help to 
maintain the impact of the tax on people’s behaviour107. 

indexation  of  environmental  taxes 

Nevertheless,  there  are  several  instances  where  sound 
fiscal  measures  have  been  implemented  to  protect  the 
environment. The water abstraction charges (Redevances 
pour  prélèvement  sur  la  ressource  en  eau)  are  a  good 
example.  These  have  existed  for  over  50  years  and  are 

Figure  21:  Environmental  tax  revenues  as  %  of  GDP, 
2017109 

Meanwhile, fossil fuel subsidies have been cut  by only a 
limited  amount  over  the  past  decade.  The  main  reason 
for this is the existence of state aid for filling stations and 
funding  for  petroleum  R&D.  Several  tax  exemptions 
persist  that  are  designed  to  keep  national  industry 
competitive. There are also tax refunds on diesel used for 
public, private and freight road transport and on shipping 
and  aviation  fuels110.  These  exemptions  accounted  for 
EUR 4 000  million  in  2016,  while  budgetary  transfers  for 
coal,  electricity  capacity  and  demand-side  response 
exceeded EUR 85 million. 

106 European Commission, Taxation Trends Report, 2017. 
107 European Commission, 2018 European Semester Country Report , p. 
30. 

108 Institute for European Environmental Policy, Case Studies on 
Environmental Fiscal Reform, Water abstraction charges in France 
109 Eurostat, Environmental tax revenues, 2018. 
110 OECD, Inventory of Support Measures for Fossil Fuels, 2018. 

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Environmental Implementation Review 2019 – France 

Some  progress  has  been  made  since  2005  on  reducing 
the ‘diesel differential’ (the difference between the price 
of diesel and that of petrol). The gap between petrol and 
diesel tax rates had  fallen to  15 % by 2018 from 41 % in 
2005111. The excise tax rates levied on petrol and diesel in 
2018  are  EUR  0.6869  per  litre  for  petrol  and  EUR 0.594 
for  diesel)112.  The  2018  finance  law  on  excise  duties  on 
diesel was set to increase the rate by EUR 0.026 per litre 
per  year  between  2018  and  2021  with  the  intention  to 
close  the  taxation  gap  between  diesel  and  petrol  by 
2022113 114, following the increases in 2016 and 2017. 

The  announcement  by  the  government  of  a  plan  to 
increase carbon and diesel taxes as of 2019 has triggered 
a movement of strong social protest led by the so-called 
"gilets jaunes" (yellow vests). Originally motivated by the 
perception  that  the  planned  fuel  tax  hikes  would 
particularly  affect 
further 
exacerbating the negative impact of the recent increases 
of fuel prices on their disposable income. In response to 
the  movement  and  the  ensuing  unrest,  the  government 
decided to cancel the planned increase in fuel taxation.  

low-income  households, 

Tax  treatment  for  company  cars  is  a  cause  for  some 
concern  in  France115.  However,  new  tax  measures  for 
company  cars  are  being  introduced  in  2018:  this  will 
increase  taxation  on  vehicles  with  high  CO2  emissions 
and  limit  the  depreciation  basis  for  cars  that  pollute 
heavily116.  

Company  car  tax  is  based  on  CO2  emissions  and  varies 
from  €2  for  each  gram  emitted  for  vehicles  that  emit 
between  50  and  100  g/km  to  €27  for  vehicles  whose 
emissions exceed 250 g/km117. 

France  has  CO2-based  motor  vehicle  taxes.  Under  the 
bonus-malus  system  in  place,  vehicles  emitting  20  g/km 
or  less  of  CO2  receive  a  bonus  of  EUR 6 000.  Vehicles 
emitting more than 120 g/km, on the other hand, pay a 
malus  of  EUR 50-EUR 10 500,  depending  on  the  level  of 
emissions. Additional bonuses are granted when vehicles 
over  15  years  old  are  scrapped.  The  registration  tax  for 
passenger cars is also based on CO2 emissions118. 

Incentives  to  choose  cars  with  lower  CO2  emissions  in 
2016 included lower annual road taxes, lower road tolls, 
and congestion or low-emission zone charges. Consumers 

111 European Environment Agency 2017, Environmental taxation and EU 
environmental policies, p. 27. 
112 European Commission, Taxes in Europe Database, 2018. 
113 European Commission, European Semester Country Report 2018, p. 
30. 
114 OECD 28th Joint Meeting on Taxation and Environment, 18 May 
2018. 
115 European Commission, Taxation of commercial cars in Belgium, 
2017, p. 3. 
116 FleetEurope, Major changes to company car taxation in Europe. 
117 ACEA, CO2 based motor vehicle taxes in Europe. 
118 ACEA, CO2 based motor vehicle taxes in Europe. 

were encourage to opt for cleaner vehicles or use public 
transport119.  New  vehicles  purchased 
in  France  are 
among the most environmentally friendly in the EU, with 
average  CO2  emissions  of  109.8  grams  per  kilometre, 
below the 2016 EU average of 118 grams120.  

The use of alternative fuels in new passenger cars sold in 
France  has  been  increasing  over  the  past  few  years.  By 
2016,  the  share  of  new  passenger  cars  using  alternative 
fuels was ten times that in 2011121. Most of the increase 
is  attributable  to  battery  electric  vehicles  and  plug-in 
hybrid electric vehicles. 

Green public procurement 

The  EU’s  green  public  procurement  policies  encourage 
Member  States  to  take  further  steps  to  apply  green 
procurement  criteria  to  at  least  50 %  of  public  tenders. 
The European Commission is helping to increase the use 
of  public  procurement  as  a  strategic  tool  to  support 
environmental protection. 

The purchasing power of public procurement amounts to 
around  EUR 1.8  trillion  in  the  EU  (approximately  14%  of 
GDP).  A  substantial  proportion  of  this  money  goes  to 
impact  such  as 
sectors  with  a  high  environmental 
construction  or  transport.  Therefore,  green  public 
procurement  (GPP)  can  help  to  significantly  lower  the 
negative  impact  of  public  spending  on  the  environment 
and  can  help  support  sustainable  innovative  businesses. 
The Commission has proposed EU GPP criteria122. 

The  National  Action  Plan 
for  Sustainable  Public 
Procurement,  France’s  GPP  strategy,  was  adopted  and 
published in March 2015. It aims to increase the extent to 
which  social  and  environmental  aspects  are  taken  into 
consideration  in  public  procurement  (respectively  8,6% 
and 13,4% in 2016 in tenders above EUR 90 000 ex tax). 
The Action plan’s objective is to reach, by 2020, 25% and 
30 % for social and environmental aspects. 

A  European  Parliament  study  shows  that  France  has 
achieved  better  results  than  any  other  EU  country  in 
implementing its  GPP strategy123. However, according to 

119 European Environmental Agency, Appropriate taxes and incentives 
do affect purchases of new cars, 18 May 2018. 
120 European Environment Agency, Average CO2 emissions from new 
passenger cars sold in EU-28 Member States plus Norway, Iceland and 
Switzerland in 2016. 
121 European Commission, Transport in the European Union: Current 
Trends and Issues, 2018, pp.27-28. 
122 In the Communication ‘Public procurement for a better environment’ 
(COM (2008) 400) the Commission recommended the creation of a 
process for setting common GPP criteria. The basic concept of GPP 
relies on having clear, verifiable, justifiable and ambitious 
environmental criteria for products and services, based on a life-cycle 
approach and scientific evidence base. 
123 European Parliament, Green Public Procurement and the Action Plan 
for the Circular Economy, 2017, pp. 79-80. 

28  

                                                                 
                                                                 
Environmental Implementation Review 2019 – France 

With a budget of EUR 454 billion for 2014-2020, the ESIF 
are the EU’s main investment policy tool. 

European  Structural  and 
2020 133 

Investment  Funds,  2014-

interregional  and 

Through  83  national, 
regional 
programmes, France has been allocated EUR 26.73 billion 
from  ESI  Funds  over  2014-2020.  Complemented  by  a 
national  contribution  of  EUR 19.04 billion,  France  has  a 
total budget of EUR 45.77 billion to be invested in various 
areas: 

 
 
 
 

creating jobs and growth 
boosting the shift to a low-carbon economy 
supporting the competitiveness of SMEs 
strengthening  research  and  development 
innovation-friendly business environment129 

in  an 

Figure 22: Breakdown of ESI Funds (2014-2020) 

a French Economic, Social and Environmental Committee 
study,  the  social  and  environmental  progresses  do  not 
reach the policy objectives initially defined124. 

legal  objectives 

concerning:  vehicles, 
There  are 
communication  technology,  sustainably  managed  wood, 
organic  and  sustainably-made  food,  the  development  of 
car  sharing,  and  the  carbon  footprint  of  state-owned 
buildings. 

France  participates  in  the  Interreg  programme  “GPP 
STREAMS”  which  aims  to  improve  the  management, 
implementation  and  monitoring  of  policy  instruments 
that integrate GPP approaches to ensure maximum gains 
in resource efficiency.  

Since 2017, a series of agreements (‘Engagements pour la 
croissance  verte’  —  ECV),  designed  to  develop  greener 
production  patterns  and  to  support  the  implementation 
of  a  circular  economy,  have  been  signed  with  the 
construction  industry  (recycling  or  waste  from  public 
works,  recycling  of  plaster)  and  other  industrial  sectors. 
In the context of the ECVs, France is developing tools to 
help public buyers and building trade professionals move 
towards the circular economy. 

Environmental funding and investments 

European  Structural  and  Investment  Fund  (ESIF)  rules 
oblige  Member  States  to  promote  environment  and 
climate  in  their  funding  strategies  and  programmes  for 
economic, 
rural 
development and maritime policy. 

social  and 

territorial 

cohesion, 

Achieving  sustainability  involves  mobilising  public  and 
private  financing  sources125.  Use  of  the  European 
Structural  and  Investment  Funds  (ESIFs)126  is  essential  if 
countries  are  to  achieve  their  environmental  goals  and 
integrate these into other policy areas. Other instruments 
such  as  Horizon  2020,  the  LIFE  programme127  and  the 
European  Fund  for  Strategic  Investments  (EFSI)128  may 
also  support  the  implementation  and  spread  of  good 
practices. 

According to Eurobarometer 468, 88 % of French people 
support more EU investment in environmental protection 
(the EU-28 average being 85 %). 

124 Conseil economique social et environmental, Commande publique 
responsable: un levier insuffisement exploité, p. 6 ; March 2018. 
125 See, for example, Action plan on financing sustainable growth 
(COM(2018) 97).  
126 i.e. the European Regional Development Fund (ERDF), the Cohesion 
Fund (CF), the European Social Fund (ESF), the European Agricultural 
Fund for Rural Development (EAFRD) and the European Maritime and 
Fisheries Fund (EMFF). The ERDF, the CF and the ESF are referred to as 
the ‘cohesion policy funds’. 
127 European Commission, LIFE programme. 
128 European Investment Bank, European Fund for Strategic 
Investments, 2016. 

ESIF in France will: 

 

 

 

 

 

in  the  farming, 

strengthen  research  and  technological  development 
and innovation, 
support  SMEs  (including  those 
fisheries and maritime sectors), 
promote  employment  and  social  inclusion,  combat 
poverty and support labour mobility, 
 protect the environment by supporting the shift to a 
low-carbon  economy, 
in 
energy efficiency, by developing renewable energies 
and  clean  transport,  and  by  supporting  agricultural 
production  methods  that  are  more  respectful  of 
natural resources, 
through 
support 
integrated  measures 
urban 
development,  and  support  bottom-up  development 
strategies in rural areas. 

the  development  of 

investments 

sustainable 

including 

cities 

for 

Cohesion policy130 

Over  the  2014-2020  programming  period,  France  has 
EUR 8.43 billion through the  ERDF and plans to use over 
EUR 1 044 million  (12 %  of  the  whole  ERDF)  to  support 
direct environmental projects in the following areas: 

129 ESIF country fiche for France. 
130 All the financial allocations given in this section represent only the EU 
contribution (national and private are not covered). 

29  

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – France 

  Protecting and enhancing biodiversity and protecting 

 

nature, EUR 287 million. 
Implementing  measures  to  prevent  and  adapt  to 
climate change, EUR 246 million. 

  Rehabilitating industrial sites and contaminated land, 

EUR 129 million. 

  Managing  household  waste  management  (mainly  in 
the  outermost  regions):  thermal  treatment  and 
incineration, EUR 157 million. 

  Waste  water  treatment  (mainly  in  the  outermost 

regions), EUR 224 million. 

As  regards  integrating  environmental  concerns  in  other 
policy  areas,  France  plans 
support  projects 
contributing indirectly to environmental objectives with a 
total amount of EUR 1 828 million in the following policy 
areas: 

to 

-  Energy:  EUR 1 228 million 

(EUR 423 million 

and 

EUR 805 million 

renewables 
efficiency), 
Sustainable transport: EUR 382 million, 
Sustainable business processes: EUR 165 million, 

- 
- 
-  Sustainable tourism: EUR 53 million. 

for 

for 
energy 

Overall, environmental (direct) and sustainable (indirect) 
investments  represent  34 %  of  France’s  ERDF  allocation 
in 2014-2020. 

the 

and 

2007-2013 

programming 

During 
period, 
EUR 1 008 million  was  allocated  to  direct  environmental 
investments 
indirect 
environmental  investments.  Investment  in  renewable 
energy 
increased 
sources  and  energy  efficiency 
significantly in 2014-2020 (from EUR 670 million in 2007-
2013 to EUR 1 228 million).  

EUR 1 176 million 

to 

indirect 

Reallocations  (the  transfer  of  financial  allocations  from 
one  sector  to  another)  were  positive  in  2007-2013  as 
regards 
investments: 
EUR 119 million  (+11.3 %)  were  reallocated,  mainly  to 
solar energy and energy efficiency. Direct environmental 
investments  remained  stable  overall  (overall,  -1.4 %  of 
funds were reallocated, totalling EUR 14 million). 

environmental 

Rural development 

France  has  EARDF  funding  of  EUR 9 909 million  over 
2014-2020  (before  the  first  modification  and  before 
flexibility between the two pillars of the CAP, reported to 
be 3-3.3 % per year). The budget for agro-environmental-
climate measures represents 10 % of the total EAFRD and 
is  one  of  the  10  lowest  percentage  allocations  (the  EU 
average  being  16.51 %).  However,  agri-environment  and 
climate  measures  receive  the  third  largest  share  of  the 
total  EAFRD  in  France,  and  the  forecast  national  budget 
will  be  doubled  by  comparison  with  the  previous 
programming period, 2007-2013. Taking into account the 
budget  earmarked  for  measures  to  support  organic 

over 

2007-2013 

EUR 180 million/year 

farming (which are now implemented in accordance with 
a  specific  article  of  Regulation  1305/2013),  the  total 
budget  allocated  to  these  measures  is  expected  to  rise 
from 
to 
EUR 360 million/year  during  the  current  programming 
period. Moreover, the 55.87 % rate for priority 4 (one of 
the  EAFRD’s  six  priorities  focused  on  water,  biodiversity 
and  soil  protection),  includes  the  high  contribution  for 
less  favoured  areas  (LFAs)  under  measure  13:  priority  4 
should  be  reduced  to  20 %  without  LFAs.  France  faces 
environmental  pressures  on  air  (especially  ammonia 
emissions 
(by  ensuring 
consistency with the prioritised action framework PAF at 
regional  level)  and  soil  (25 %  of  French  territory  is 
vulnerable  to  landslides).  Irrigation  is  a  significant  drain 
on water resources in southern France. 

farming),  biodiversity 

from 

Figure  23:  ESIF  2014-2020  –  EU  allocation  by  theme, 
France (EUR billions)131 

30  regional  rural  development  plans  allow  for  financing 
measures  to  benefit  the  environment  and  the  climate. 
Approximately  55 %  of  all  funds  assigned  to  these  rural 
funding 
development  plans 
environment  and  climate  measures..  This  represents 
about EUR 15 billion over 2014-2020. In 2018, the budget 
for rural development plans was boosted further with an 
additional  allocation  of  about  EUR 600 million  of  EU 
funds. 

are  earmarked 

for 

As regards agri-environment and climate measures, there 
are  around  70  different  types  of  operations  which  have 

131 European Commission, European Structural and Investment Funds 
Data By Country. 

30  

 
                                                                 
Environmental Implementation Review 2019 – France 

been  designed  to  address  various  environmental  issues 
identified  at  regional  level.  Some  of  these  measures 
contribute  to  the  objective  of  maintaining  or  restoring 
the  good  conservation  status  of  habitats  and  species  of 
Community  interest  in  Natura  2000  sites.  Support  for 
vulnerable habitats and species is prioritised. 

Rural  development  plans  also  support  ambitious 
environmental objectives determined by the authorities, 
such  as  those  relating  to  organic  farming  and  pesticide 
use.  The  French authorities aim to increase the  share of 
organic farming to 15 % of total farmland by 2022 and to 
halve pesticide use by 2025.  Given the challenges posed 
by biodiversity loss (especially the decline of pollinators), 
the  pollution  by  pesticide  of  some  water  bodies  with 
pesticides,  and  strong  demand  on  the  part  of  French 
society, these objectives are strategic. 

In  southern  regions,  where  farming  puts  pressure  on 
water resources, rural development programmes support 
projects  to  reduce  water  needs  and  to  make  irrigation 
systems  more  efficient.  This  is  done  in  accordance  with 
environmental legislation, notably the Water Framework 
Directive, and the objective of achieving a good status of 
water bodies. 

Rural  development  programmes  generally  support  the 
transition  to  a  more  sustainable  model  of  agriculture. 
However,  large  intensive  mono-cropping  areas  remain, 
placing  major 
environment 
(biodiversity,  soil,  water).  Efforts  to  achieve  a  transition 
to  a  fully  sustainable  model  of  farming  need  to  be 
pursued,  especially 
intensive 
production. 

in  the  areas  of  most 

pressures 

the 

on 

As  regards  direct  payments,  farmers  are  required  to 
comply  with  a  number  of  eco-conditionalities  to  protect 
the  environment  and  ecosystems  (biodiversity,  habitats, 
introduction  of  additional 
soil,  water  and  air).  The 
greening  obligations  in  2014  has,  unfortunately  —  as  in 
other  European  countries  —  yielded  only  marginal 
benefits for the environment so far. 

European Maritime and Fisheries Fund (EMFF) 

France  has  EMFF 
(EU 
contribution)  over  2014-2020.  French  funding  priorities 
are as follows132: 

funding  of  EUR 585 million 

-  EU  Priority  1:  EUR 150.9 million  (25.7 %  of  total  EMFF 
allocation) for achieving a better balance between fishery 
activities 
and 
environmental 
sustainability. 

protection 

and 

-  EU  Priority  2:  EUR 88.8 million  (15.1 %)  goes  towards 
meeting  the  objectives  of  the  French  national  strategic 
focus  on 
plan 
protecting and restoring biodiversity. 

for  aquaculture.  Support  will  also 

-  EU  Priority  3:  EUR 122.3 million  (20.8 %)  support  for 
control and data collection. 

- EU Priority 4: EUR 22.6 million (3.8 %) helps to improve 
the territorial cohesion of fisheries and aquaculture. 

-  EU  Priority  5:  EUR 163.2 million  (27.8 %)  goes  towards 
improving  the  marketing,  diversification  and  of  seafood 
products. 

-  EU  Priority  6:  EUR 5.3 million  (0.9  %)  goes  towards 
improving 
the  efficiency  of  maritime  surveillance, 
extending  the  network  of  marine  protected  areas  and 
improving knowledge of the marine environment. 

-  EUR 34.8 million  (5.5 %) 
assistance. 

is  allocated  to  technical 

Artiﬁcial reefs to protect Prado Bay sea beds in 
Marseille 137 

Prado  Bay  has  long  been  the  victim  of  progressive 
silting.  Sand  covered  the  natural  reefs,  endangering 
the  habitats  of  many  animal  and  plant  species.  This 
project  built  some  401  artiﬁcial  reefs  of  up  to  30 m 
deep,  over  an  area  of  220  ha. 
(Total  cost: 
EUR 4 740 000 (EUR 1 814 038 of EU co-ﬁnancing) 

The Connecting Europe Facility (CEF) 

The  CEF  is  a  key  EU  funding  instrument  developed 
investment  towards  European 
specifically  to  direct 
transport,  energy  and  digital  infrastructure  to  address 
identified  missing  links  and  bottlenecks  and  promote 
sustainability. 

By  the  end  of  2017,  France  had  signed  agreements  for 
EUR 2 billion for projects under the CEF133. 

132 European Commission, Summary of French EMFF OP. 
133 European Commission, European Semester Country Report for 
France, 2018, p. 14. 

31  

 
                                                                 
 
Environmental Implementation Review 2019 – France 

Horizon 2020 

France  has  benefited  from  Horizon  2020  funding  since 
the  programme  started  in  2014.  As  of  January  2019, 
2 825  participants  have  been  granted  a  maximum 
amount of EUR 1.09 billion for projects from the Societal 
Challenges work programmes dealing with environmental 
issues134 135.  

In  addition  to  the  abovementioned  work  programmes, 
climate and biodiversity expenditure is present across the 
entire  Horizon  2020.  In  France,  projects  accepted  for 
funding  in  all  Horizon  2020  working  programmes  until 
December  2018  included  EUR  1  billion  destined  to 
climate  action  (26.1 %  of  the  total  Horizon  2020 
contribution  to  the  country)  and  EUR  131  million  for 
biodiversity-related  actions  (3.2 %  of  the  Horizon  2020 
contribution to the country)136. 

LIFE programme 

Since  1992,  when  the  LIFE  programme  was  launched,  a 
total of 354 projects have been co-financed in France137. 
Altogether, they represent a total investment of EUR 789 
million, of which EUR 287 million comes from the EU. Of 
these  projects,  221  have  focused  on  environmental 
innovation  (under  the  LIFE  Environment  and  Resource 
Efficiency  Priority),  118  on  nature  conservation  (under 
the  LIFE  Nature  and  Biodiversity  Priority),  and  seven  on 
information  and  communication.  Under  the  new  LIFE 
programme, the following projects have been co-funded: 
three  on  adapting  to  climate  change,  five  on  mitigating 
climate 
governance  and 
adaptation,  two  preparatory  projects  and  two  technical 
assistance  projects.  One  NGO  operating  grant  has  also 
been co-funded. 

change, 

climate 

three 

strategies 

LIFE  CROAA,  which 
to  bring  alien 

The  EU  allocated  EUR 43 million  to  French  projects  over 
2014-2017138.  The 
involves 
invasive 
implementing 
amphibians 
received  a 
in  France  under  control, 
contribution from the EU of over EUR 2 million139. Under 
the  Resource  Efficiency  strand,  completed  projects  have 
targeted classic issues such as waste management, clean 
technologies  and  waste  water  treatment,  but  also 

134 European Commission own calculations based on CORDA (COmmon 
Research DAta Warehouse). A maximum grant amount is the maximum 
grant amount decided by the Commission. It normally corresponds to 
the requested grant, but it may be lower. 
135 i.e. (ii) Food security, sustainable agriculture and forestry, marine 
and maritime and inland water research and the bioeconomy; (iii) 
Secure, clean and efficient energy; (iv) Smart, green and integrated 
transport; and (v) Climate action, environment, resource efficiency and 
raw materials. 
136 European Commission own calculations based on CORDA (COmmon 
Research DAta Warehouse). 
137European Commission, LIFE programme in France, 2017. 
138 Commission services based on data provided by EASME. 
139 European Commission, LIFE Croaa. 

integrated  environmental  management:  air  quality 
management  and  monitoring,  noise  abatement,  river 
basin  management,  management  of  coastal  areas  and 
sensitive  areas.  More  recently  funded  projects  have 
focused  on  green  construction,  energy  saving,  land-use 
planning  and  eco-design  products.  Most  projects  were 
implemented  by 
firms, 
international  companies,  local  authorities  and  research 
institutions.  Project  durations  ranged  from  20  to  53 
months. 

small  and  medium-sized 

There  are  26  ongoing  projects  in  France.  These  cover  a 
similar spread of themes, as well as some new ones, such 
as:  plastic  waste,  sustainable  construction,  end-of-life 
vehicles,  urban  design,  energy  supply  and  efficiency, 
water  saving,  construction  and  demolition  waste,  life-
cycle assessment and soil decontamination. 

Completed  projects  under 
the  LIFE  Nature  and 
Biodiversity  strand  targeted  over  40  species  —  mainly 
birds,  but  also  freshwater  fish,  reptiles,  mammals  and 
plants  —  and  more  than  20  habitats  —  dry  grasslands, 
rivers,  marshes,  dunes,  lagoons,  forests,  coastal  areas, 
vine-growing  landscapes  and  alluvial  habitats  along  the 
Rhine. NGOs and park authorities accounted for over half 
of  project  beneficiaries.  Other  types  of  beneficiary 
included development  agencies, a  research institute and 
local  and  regional  authorities.  Project  durations  ranged 
from 43 to 72 months. 

innovative  actions  to 

21  of  these  projects  are  currently  under  way  in  France. 
They  deal  with  conserving  and  restoring  species  and 
habitats. One Nature project aims to restore biodiversity 
and  conserve  remarkable  military  sites  in  the  southeast 
of  France,  supporting  bat,  gull  and  raptor  species  within 
four  Natura  2000  sites.  There  are 
four  ongoing 
biodiversity projects. One aims to test the relevance and 
effectiveness  of 
improve  the 
viability  of  hamster  populations  in  Alsace.  Another  is 
seeking  to  halt  the  decline  of  endemic  petrels  on  La 
Réunion.  A  third  project  aims  to  preserve  unique  semi-
xerophilic  forest  habitats  on  La  Réunion  and  to  re-
establish  the  connectivity  between  restored  and  relict 
plots.  The  fourth  is  designed  to  conserve  the  critically 
endangered  giant  pearl  mussel  in  France,  specifically  in 
the  Charente,  Vienne  and  Creuse  rivers,  where  up  to 
98 % of the world’s giant pearl mussel population can be 
found. 

Three  projects  have  been  co-financed  under  the 
Governance  and  Information  strand.  The  European 
Week for Waste Reduction, was coordinated by France in 
partnership with four organisations from three other EU 
countries  (Belgium,  Spain  and  Portugal).  Some  22 
pioneering public authorities from 10 European countries 
took part in the project. The Waste Reduction Week was 
designed  to  inform  the  public  about  the  simple  actions 

32  

                                                                 
Environmental Implementation Review 2019 – France 

they  can  take  in  everyday  life  to  help  curb  waste.  The 
events were a huge success. 

European Investment Bank (EIB) 

Since its inception, the EIB has invested EUR 133 billion in 
the French economy in France — half of it supplied over 
the last decade — through the funding of 1 400 projects 
across the country140. 

In  2018  alone,  the  EIB  Group  (the  European  Investment 
Bank  and  the  European  Investment  Fund)141  loaned 
French businesses and public institutions EUR 7.17 billion. 
Figure  24  shows  that  more  than  EUR 2.5 billion  (35 %  of 
the  total)  was  invested  directly  in  environment-related 
projects. 
Figure 24: EIB loans to France in 2018142 

Consequently, France received greater support for energy 
efficiency  projects  in  public  and  private  buildings  and 
clean  transport  and  renewable  energy  projects.  The 
renewable energy projects were financed through energy 
efficiency  and  renewable  energy  investment  funds  and 
risk-sharing agreements with commercial banks. 

European Fund for Strategic Investments  

The  EFSI  is  an  initiative  to  help  overcome  the  current 
investment  gap  in  the  EU.  It  aims  to  mobilise  EUR 500 
billion by 2020 for all Member States. As of January 2019, 
it  has  mobilised  EUR 11.6  billion  in  France,  and  the 
secondary investment triggered by this is expected to be 
EUR 60.6 billion143. 

In  2017,  EUR 4.7 billion  in  EFSI  financing  was  approved 
for  56  interventions  in  France.  In  the  same  year,  48 
projects with total financing  of nearly EUR 3 billion were 
signed, 
additional 
investment. 

EUR 13.5 billion 

unlocking 

of 

‘green’ shipping finance contract was signed with Brittany 
Ferries  (for  an  amount  of  EUR 50 million)  for  the 
construction  of  their  first  ferry  powered  by  liquefied 
natural gas. This ferry will serve on the Caen-Ouistreham 
(France) to Portsmouth (UK) route from April 2019. 

National environmental financing 

came 

amount 

(EUR 21 billion) 

France spent EUR 42 billion on environmental protection 
(including  private  and  public  financing)  in  2016.  Half  of 
this 
from  public 
expenditure.  52 %  of  public  spending  was  allocated  to 
waste  management  activities 
(the  annual  average 
percentage of environmental spending allocated to waste 
management  in the EU is 49.7 %). EUR 4 254 million was 
allocated  to  wastewater  management  (20 %  of  the  total 
amount)  and  EUR 1 575 million  went  towards  pollution 
abatement  (7.4 %  of  the  total).  8 %  of  the  total  amount 
was  allocated 
the 
landscape  (EUR 1 690 million).  Between  2012  and  2016, 
the  public  funding  for  environmental  protection  was 
EUR 107.8 billion, the highest amount in the EU 144. 

to  protecting  biodiversity  and 

is 

to  ensure 

for  France 

As it has been mentioned through the report, one of the 
main  challenges 
that 
environmental financing remains at an adequate level to 
tackle  the  main  issues  affecting  the  country.  Existent 
financial gaps in areas such as green infrastructure, urban 
wastewater  and  waste  amanegement  are  delaying  the 
correct  implementation  of  EU  environmental  law  and 
financial  resources  to 
policies.  Therefore,  ensuring 
reduce the implementation gap should be considered as 
a priority for the country. 

2019 priority actions 

 

 

tourism)  and 

Strengthen  the  integration  of  biodiversity  concerns 
into  other  policies  (in  particular  in  agriculture,  but 
also  in  forestry,  urban  and  infrastructure  planning 
the  encourage  cooperation 
and 
between  the  people  and  organisations  involved  in 
these policy areas.  
Ensure  appropriate  investments  from  national  and 
other relevant sources to renew existing urban waste 
water infrastructures so as to avoid any future non-
compliance. 

  Mobilise  investment,  including  through  EU  funds,  in 
waste  prevention,  separate  collection  and  recycling, 
as well as reducing air pollution. 

EFSI supports a number of new sectors including culture, 
cybersecurity  and  the  maritime  sector.  The  EIB’s  first 

140 EIB Group activity in France in 2017. 
141 The EIB Group includes EIB and EFSI investments and loans. 
142 EIB, France and the EIB, 2018. 
143 European Investment Bank, EFSI project map. 

144 Eurostat, General Government Expenditure by function, 2018. 

33  

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – France 

5. Strengthening environmental governance 

Information, public participation and access to 
justice 

Citizens  can  more  effectively  protect  the  environment  if 
they  can  rely  on  the  three  pillars  of  the  Aarhus 
Convention: 
(i) access to information; 
(ii) public participation in decision-making; and 
(iii) access to justice in environmental matters. 

It is of crucial importance to public authorities, the public 
and  business  that  environmental  information  is  shared 
efficiently  and  effectively145.  Public  participation  allows 
authorities  to  make  decisions  that  take  public  concerns 
into account. Access to justice is a set of guarantees that 
allows  citizens  and  NGOs  to  use  national  courts  to 
protect the environment146. It includes the right to bring 
legal challenges (legal standing)147. 

Environmental information 

information, 

France  has  an  abundance  of  publicly  available 
information  and  data  for  all  policy  areas,  including  the 
environment.  The  ‘State  of  the  Environment’  report  is 
published  online  every  4  years.  Many  public  bodies 
including  through  a  couple  of 
provide 
portals which aim to offer centralised access points148 — 
however,  these  generally  do  not  contain  all  necessary 
information. There are big differences between individual 
information 
environmental  areas 
available.  A  large  amount  of  information  is  available  for 
some areas and for others it is difficult to find anything at 
all.  The  national  geoportal  is  a  very  comprehensive 
information,  providing  many  view  and 
source  of 
download  services  and  analytical  tools.  The  geoportal 
also  hosts  France’s  INSPIRE  portal  which  also  contains  a 
significant amount of data and allows all of the basic data 
to be downloaded free of charge. 

in  the  amount  of 

France’s  implementation  of  the  INSPIRE  Directive  leaves 
Its  performance  has  been 
room  for 

improvement. 

145 The Aarhus Convention, the Access to Environmental Information 
Directive, 2003/4/EC and the INSPIRE Directive, 2007/2 together create 
a legal foundation for the sharing of environmental information 
between public authorities and with the public. This EIR focuses on 
INSPIRE. 
146 The guarantees are explained in Commission Notice on access to 
justice in environmental matters, OJ L 275, 18.8.2017 and a related 
Citizen’s Guide. 
147 This EIR looks at how well Member States explain access to justice 
rights to the public, and at legal standing and other major barriers to 
bringing cases on nature and air pollution. 
148 France, The ‘State of the Environment’ report.  

reviewed based on its 2016 implementation report149 and 
its  most  recent  monitoring  data  from  2017150.  France  is 
considered to have made good progress on coordination, 
data  set  identification,  documentation  of  data  and  data 
access through services. Additional efforts are needed to 
improve the conditions for data reuse. France also needs 
to  make  additional  efforts  to  prioritise  environmental 
datasets 
implementation  of  environmental 
legislation.  In  particular,  it  needs  to  prioritise  data  sets 
identified as high-value spatial data sets151. 

the 

in 

Figure  25:  Access  to  spatial  data  through  view  and 
download services in France (2017)  

Public participation 

(Code  de 

l’Environnement)  entitled 

In  France,  Title  II  of  the  first  book  of  the  Environmental 
Code 
‘Citizen 
information  and  participation’  152  contains  the  main 
legislative  measures  related  to  public  participation.  The 
measures  were  updated  by  Ordonnance  n°  2016-488  of 
21 April 2016153, which  established a  new Chapter III bis 
entitled  “Local  consultation  for  projects  with  potential 
environmental  impact”  154  and  by  Ordonnance  n°2016-
1060  of  3  August  2016,  which  reformed  the  procedures 
of  public  participation  in  the  field  of  environment.  They 
were completed  in 2017 as a follow up to the report by 
the  National  Ecological  Transition  Council  entitled 
‘Environmental 
decide’ 
(Démocratie environmentale debattre et decider)155.  

democracy: 

debate 

and 

149 INSPIRE FR country sheet 2017. 
150 INSPIRE monitoring dashboard. 
151 European Commission, List of high value spatial data sets. 
152 France, Citizen information and participation. 
153 France, Ordonnance No 2016-488. 
154 France, Consultation locale sur les projets susceptibles d’avoir une 
influence sur l’environnement. 
155 France, Démocratie environmentale debattre et decider. 

34 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – France 

The  Ministry  for  an  Ecological  and  Solidary  Transition, 
created  the  ‘Charter  for  public  participation’  (La  charte 
de  la  participation  du  public)156  with  the  help  of  expert 
committees.  The  Charter  includes  a  practical  handbook, 
written  in  plain  language  that  gives  guidance  on  best 
practices 
in  environmental 
projects.  Citizens,  associations  and  project  holders  can 
join the Charter, thereby expressing their commitment to 
implement its principles. 

for  public  participation 

The guidelines on ‘Consult to better regulate’ (Consulter 
pour mieux réglementer) in France are considered to be a 
good  practice  in  the  context  of  the  Commission’s  policy 
on better regulation157.  

The Eurobarometer  figures  from 2017  show that people 
in  France  agree  strongly  (85 %  of  respondents)  that  an 
individual can play a role in protecting the environment. 
This is an improvement compared with 2014. 

Access to justice 

justice 

in  environmental 
Information  on  access  to 
matters  can  be  found  on  the  website  of  the  Ministry  of 
Justice158. The website covers the legal provisions, but  it 
does  not  include  information  on  how  an  individual  or 
NGO can exercise their right to access justice. 

The French system of legal standing is based on whether 
the  litigant  has  interests  that  are  affected  and  is  liberal. 
There  are  no  significant  barriers  to  NGOs  being  able  to 
bring  challenges  on  nature  and  air  cases.  For  example, 
following  a  legal  challenge  by  an  NGO,  by  its  ruling  of 
11 July  2017  (No 394254),  the  Council  of  State  ordered 
the French government to adopt new and more effective 
air quality plans. An obstacle to access to justice in France 
is  the  high  cost  of  hiring  expert  lawyers  specialised  in 
environmental matters, especially as their involvement is 
is 
in  certain  courts.  However, 
mandatory 
available under certain conditions. 

legal  aid 

2019 priority actions 

 

Improve  access  to  spatial  data  and  services  by 
making  stronger  links  between  the  central  INSPIRE 
website and regional portals. Identify and document 
all  spatial  datasets  required  for  the  implementation 
law159.  Make  the  data  and 
of  environmental 
documentation  at  least  accessible  ‘as  is’  to  other 
public  authorities  and  the  public  through  the  digital 
services set out in the INSPIRE Directive. 

  Better  inform  the  public  about  their  right  to  access 
justice,  notably  in  relation  to  air  pollution  and 
nature. 

156 France, Charte de la participation du public. 
157 France, The guidelines on ‘Consult to better regulate’. 
158 And more information on the Council of State (Conseil d’Etat). 
159 European Commission, INSPIRE. 

Compliance assurance 

to  ensure 

Environmental compliance assurance covers all the work 
undertaken  by  public  authorities 
that 
industries,  farmers  and  others  fulfil  their  obligations  to 
protect  water,  air  and  nature,  and  manage  waste160.  It 
includes  support  measures  provided  by  the  authorities, 
such as: 
(i) compliance promotion161;  
(ii) inspections and other checks that they carry out, i.e. 
compliance monitoring162; and  
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement163.  
Citizen  science  and  complaints  enable  authorities  to 
liability164 
focus  their  efforts  better.  Environmental 
ensures that the polluter pays to fix any damage. 

Compliance promotion and monitoring 

compliance 

areas  with 

Whether and how well online information is provided to 
farmers  on  how  to  comply  with  obligations  on  nitrates 
and  nature  is  an  indicator  of  how  actively  authorities 
promote 
serious 
in 
implementation  gaps.  In  France,  online  information  on 
farmers’ obligations regarding nitrates is available on the 
Ministry of Agriculture’s website and its regional offices. 
Among  other  examples,  a  document  by  the  Direction 
régionale  de  l'Environnement,  de  l'Aménagement  et  du 
(DREAL)  Grand  Est  provides  detailed 
Logement 
information  on  who  is  concerned  and  how  they  can 
comply  with  the  eight  requirements  that  include:  (i)  a 
period  during  which  the  spreading  of  fertilisers 
is 
prohibited;  (ii)  storage  of  livestock  manure;  and  (iii) 
making sure that soil is covered with crops to avoid loss 
of  nutrients165.  Very  little  information  is  available  online 
on  land  owners’  obligations  to  fulfil  their  obligations  for 
Natura  2000  sites  in  accordance  with  the  Birds  and 
Habitats Directives. 

industrial 

Major 
installations  can  present  serious 
pollution  risks.  Public  authorities  are  required  to  have 
installations  and  to  make 
plans  to 
individual  inspection  reports  available  to  the  public166. 
The  website  of  the  Inspection  of  Classified  Installations 

inspect  these 

160 The concept is explained in detail in the Communication on ‘EU 
actions to improve environmental compliance and governance’ 
COM(2018) 10 and the related Commission Staff Working Document, 
SWD(2018)10. 
161 This EIR focuses on the help given to farmers to comply with nature 
and nitrates legislation. 
162 This EIR focuses on inspections of major industrial installations. 
163This EIR focuses on the availability of enforcement data and 
coordination between authorities to tackle environmental crime. 
164 The Environmental Liability Directive, 2004/35, creates the 
framework. 
165 France, Fiche by DREAL Grand Est. 
166 Article 23, Industrial Emissions Directive, 2010/75/EU. 

35 

                                                                 
                                                                 
Environmental Implementation Review 2019 – France 

unit  (Inspections  des  Installations  Classées)  has  general 
information on the planning of inspections. 

Citizen science and complaint handling 

Engaging  the  general  public  through  citizen  science,  can 
promote knowledge about the environment and help the 
authorities in their work. No online information could be 
found about the use of citizen science in France. 

The  availability  of  clear  online  information  on  how  to 
make  a  complaint  is  an  indicator  of  how  responsive 
authorities are to complaints from the public. For lodging 
complaints  on  offences  related  to  waste  and  industrial 
sites,  France  provides  online  forms  (formulaires  de 
reclamation) on DREAL’s websites and on the Inspection 
of Classified Installations’ website167. However, there is a 
lack  of  similar  online  information  on  how  to  lodge 
complaints on nature-related offences. 

Enforcement 

information  on  the  number  of 

identifies  problems,  a  range  of 
When  monitoring 
responses  may  be  appropriate.  The 
Inspection  of 
Classified  Installations’  website  publishes  reports  with 
general 
installations 
inspected,  the  number  of  visits  and  the  number  of 
administrative  sanctions  for  cases  of  non-compliance168 
intermittently.  Information  at  regional  level  is  a  mixed 
picture.  For  example,  DREAL  Centre’s  annual  reports 
have  almost  no  information  on  inspections169  whereas 
DREAL  Grand  Est  provides  key  details170.  There  is  no 
published information on responses to cross-compliance 
breaches  on  nitrates  and  nature.  However,  statistics  on 
environmental crimes are published171. 

is  especially  challenging. 

Tackling  waste,  wildlife  crimes  and  other  environmental 
offences 
It  requires  close 
cooperation  and  coordination  arrangements  between 
inspectors, customs authorities, police and prosecutors. 
The  Central  Office  for  Coordinating  Environmental  and 
Public  Health  Crime  (OCLAESP)172,  a  national  office 
the 
located  within 
the  Gendarmerie,  coordinates 
enforcement  of 
these  crimes  across  enforcement 
agencies,  including  Customs  and  the  National  Hunting 
and Wildlife Agency (ONCFS). 

Environmental liability  

The  Environmental  Liability  Directive  (ELD)  establishes  a 
framework  based  on  the  ‘polluter  pays’  principle  to 

167 France, IPPC website. 
168 France, IPPC brochure. 
169 France, DREAL Centre’s annual reports. 
170 France, DREAL Grand Est. 
171 France, statistics on environmental crimes, p. 1. 
172 France, OCLAESP. 

focused  on  gathering  better 

prevent  and  remedy  environmental  damage.  The  2017 
EIR 
information  on 
environmental  damage,  on  financial  security  and  on 
establishing  guidance.  The  Commission  is  still  collecting 
evidence on the progress made. 

2019 priority actions 

 

 

 

to 

monitoring 

information 
compliance, 

Provide  better 
the  public  on 
and 
encouraging 
enforcement. At the very least, this should entail: (i) 
ensuring  online  information  on  how  to  comply  with 
obligations  on  nitrates  and  nature  is  available  to 
French farmers; and (ii) providing online information 
to citizens to make it  easier for them to file nature-
related complaints. 
Publish  more 
information  on  the  outcomes  of 
administrative enforcement action and of the follow-
up  to  detected  cross-compliance  breaches  on 
nitrates and nature. 
Improve  financial  security  for  liabilities  and  ELD-
guidance  and  publish  information  on  environmental 
damage. 

Effectiveness of environmental 
administrations 

in 

involved 

implementing 

Those 
environmental 
legislation at EU, national, regional and local levels need 
to have the knowledge, tools and capacity to ensure that 
the  legislation  and  the  governance  of  the  enforcement 
process brings about the intended benefits. 

Administrative capacity and quality 

Central, regional and local administrations must have the 
ability  to  carry  out  their  own  tasks  and  work  effectively 
with  each  other  within  a  system  of  multi-level 
governance. 
TAIEX-EIR Peer 2 Peer events173 

The  EIR  P2P  programme  facilitates  the  exchange  of 
the  national  environmental 
experiences  between 
authorities  that  implement  environmental  policy  and 
legislation.  France  has  taken  an  active  part 
in  the 
programme since September 2018. For example, experts 
from France and the Netherlands shared best practice in 
March  2018  on  establishing  a  public-private  voluntary 
agreement  on  ‘green’  purchasing  and  Dutch  experts 
shared  their  experience  of  the  ‘circular  procurement’ 
green deal in the Netherlands. 

Experts  from  France  also  participated  in  April  2018  in  a 
EIR  P2P  workshop  in  Lisbon  on  Monitoring  air pollution 
impacts on ecosystems along with experts from Portugal, 

173 European Commission, TAIEX Peer 2 Peer. 

36 

                                                                 
                                                                 
Environmental Implementation Review 2019 – France 

Spain,  France, 
Denmark.  

Italy,  Croatia,  the  Netherlands  and 

At another meeting in Prague in June 2018, experts from 
France  and  Germany  shared  experiences  on  controlling 
and  reducing  emissions  from  cars  and  on  measures  to 
upgrade the car fleet with their peers from the Czech and 
the Slovakian governments. 

In addition, a study visit has been organised in September 
2018,  where  experts  from  the  government  of  Castilla  y 
León  in  Spain  visited  the  French  region  of  Auvergne-
Rhône-Alpes  for  the  French  and  Spanish  authorities  to 
exchange knowledge on managing wolf populations. 

from 

competent 

Finally,  experts 
authority 
the 
responsible  for  overseeing  the  EU  Timber  Regulation 
(EUTR)  participated  in  June  2018  in  a  EIR  P2P  workshop 
to  strengthen  cooperation  among 
the  competent 
authorities  from  eight  Mediterranean  EU  countries.  The 
aim  was  to  improve  and  harmonise  the  implementation 
of  the  EUTR  in  the  Mediterranean  region.  Experts  from 
the  Netherlands  and  Denmark  shared  their  experiences 
from  the  Nordic-Baltic  network  of  EUTR  competent 
authorities. 

Coordination and integration 

environmental 

As  mentioned  in  the  2017  EIR,  the  transposition  of  the 
revised 
(EIA) 
Directive174  provides  an  opportunity  for  countries  to 
streamline their regulatory framework on environmental 
assessments.  France  transposed  the  Directive  by  the 
deadline of May 2017.  

assessment 

impact 

in  environmental  assessments 

The  Commission  encourages  the  streamlining  of  the 
environmental  assessments  to  reduce  duplication  and 
avoid  overlaps 
for 
projects.  Streamlining  helps  to  reduce  unnecessary 
It  also  accelerates  decision-
administrative  burden. 
making,  without  compromising  the  quality  of  the 
environmental 
the 
transposition  of  the  revised  EIA  Directive,  France 
introducing 
streamlined  administrative  procedure  by 
common  or  coordinated  procedures  for  environmental 
evaluation.  

assessment 

procedure. 

In 

From  1  March  2017,  France  has  introduced  a  single 
environmental  permit  for  projects  as  part  of  the 
government’s 
initiative  to  modernise  environmental 
regulations.  The  single  environmental  permit  simplifies 
and  streamlines  the  procedures  and  allows  a  better 
overview of all environmental aspects of a project.  

The  single  environmental  permit  applies  to:  (i)  projects 
that  implement  the  legislation  on  industrial  installations 
de 
(‘Installations 

Protection 

Classées 

pour 

la 

174 Directive 2014/52/EU. 

37 

l’Environnement,  ICPE’);  and  (ii)  relevant  projects  that 
implement the French Water Act (‘Loi sur l’eau’). Projects 
that  are  likely  to  include  measures  to  avoid,  reduce  or 
offset harmful effects on the environment do not need a 
permit but they do require an environmental assessment. 

The  permit  covers  a  number  of  areas  for  which  main 
decisions are required from the State. These are: 
 

environmental  legislation  (Natura  2000,  protected 
species and derogations and waste processing), 
forestry, 
energy, 
patrimony, 
transport, 
defence.  

 
 
 
 
 

In  France,  the  environmental  authorisation  procedure  is 
coordinated  with  other  relevant  procedures,  especially 
those required under its urban legislation. For wind farm 
projects,  the  environmental  authorisation  exempts  from 
obtaining  the  construction  permit.  Greater  flexibility  is 
also being introduced in the renewable energy sector (i.e. 
photovoltaics). 

The permit application is submitted to a single contact — 
the prefect (‘préfet’), a local representative of the State. 
The procedure has been reduced to three stages (review, 
public  inquiry  and  decision)  and  there  are  simplified 
formalities  and  requirements 
for  a  single  permit. 
Complex  projects  can  benefit  from  a  special  system 
whereby  permits  are  granted  in  several  stages.  The 
streamlined approach also aims to shorten the delays in 
procedures,  for  example  by  reducing  the  average  time 
taken for authorisation to be granted from 12-15 months 
to 9 months.  

that  project  developers  may  now 

France  also  introduced  changes  to  the  litigation  system 
so 
the 
authorisation to the administrative court within 2 months 
of its publication and third parties  within 4  month of its 
publication  (compared  with  the  previous  period  of  12 
months  after  publication  and  6  months  after  entry  into 
force fixed in general law).  

refer 

Following a grievous complaint by a third party, the judge 
may  conduct  the  procedure  or  completely  or  partially 
annul the authorisation, depending on the law applicable 
at the time of the judgment (except for planning rules for 
which  the  judge  must  take  account  of  the  law  that 
In  case  of 
applied  at  the  time  of  the  decision). 
the  environmental 
modification  of 
the  project, 
to  amendment  by 
authorisation  may  be  subject 
supplementary order of the prefect. 

France  adopted  a  new  act  in March  2018  which  states 
that  if  the  environmental  authority  has  comments  on  a 
project, the project developer should respond in writing 
and these written comments should be made public.  

                                                                 
Environmental Implementation Review 2019 – France 

Following a case law from the Conseil d’Etat, a decree is 
expected  to  be  adopted,  requiring  that  the  opinion  on 
the  EIA  for  all  regional-level  projects  be  given  by  the 
regional 
independent 
the 
environmental  authority  (MRAe)  and  not  by  the  prefect 
who could also be the authority delivering the consent.  

national 

bodies 

of 

Adaptability, 
(eGovernment) 

reform 

dynamics 

and 

innovation 

French  public  authorities  are  increasingly  adopting  and 
using  electronic  services  that  enable  them  to  interact 
with  the  public  online.  The  country  performance  was  in 
line  with  the  EU  average  in  2018.  For  Digital  Public 
Services,  the  country  has  a  score  of  0.58/1  based  on 
Europe's  Digital  Progress  Report  2018,  EU28  average 
being 0.57/1175. The situation has slightly improved since 
the year 2016, mainly in terms of open data. 

The Public Action Programme 2022, launched in October 
2017  by  the  Prime  Minister,  gives  priority  to  the  digital 
transformation  of  administrations,  with  the  objective  of 
100% of dematerialised public services by 2022.  

A  fund  for  the  transformation  of  public  action  was 
installed at the end of 2017 and endowed with EUR 700 
million over the next five years, including EUR 200 million 
for 2018. 

In the DESI Report 2018, France had a score of 59 out of 
100 on digital public services, slightly higher than the EU 
average176.Enabling financing and efficient use of funds 

The  French  authorities  have  a  long  experience  in  the 
management of EU funding and no major problems arise 
in this respect.  

2019 priority action 

 

France can further improve its overall environmental 
citizen 
governance 
engagement,  compliance  and  enforcement,  as  well 
as administrative capacity and coordination). 

transparency, 

(such 

as 

International agreements 

The  EU  Treaties  require  EU  environmental  policy  to 
promote measures at the international level to deal with 
regional or worldwide environmental problems. 

The EU is committed to strengthening environmental law 
and its implementation globally. It therefore continues to 
support  the  Global  Pact  for  the  Environment  process, 
which  was  launched  by  the  United  Nations  General 

175 European Commission, DESI country profile France, 2018, p. 10.DESI 
country profile France, 2018, p. 10. 
176 European Commission, Digital Economy and Society Index Report 
2018, Digital Public Services. 

38 

Assembly  in  May  2018177.  The  EIR  is  one  of  the  tools  to 
ensure  that  the  Member  States  set  a  good  example  by 
respecting  European  Union  environmental  policies  and 
laws and international agreements.  

France  has  signed  but  not  yet  ratified  the  Protocol  on 
Strategic  Environmental  Assessment  to  the  Espoo 
Convention,  the  Offshore  Protocol  to  the  Barcelona 
Convention and the Nagoya Protocol178. 

Forests:  EU  Timber  Regulation  (EUTR)179/Forest  Law 
Enforcement,  Governance 
(FLEGT) 
Regulation180 

Trade 

and 

In  France,  checks  are  conducted  more  frequently  in 
regions  with  higher  numbers  of  operators.  Between 
March  2015  and  February  2017,  France  carried  out  a 
total  of  30  planned  checks  for  domestic  timber,  and  all 
320  checks  planned  for  imported  timber.  However,  the 
number  of  checks  is  quite  low  when  compared  to  the 
estimated  5  000  French  operators  that  place  domestic 
timber  on  the  EU  market  and  the  14  000  that  import 
timber.  French  competent  authorities  only  conducted 
one check on traders181.  

In  France,  in  addition  to  financial  penalties  (which  may 
not  exceed  EUR 1  million),  a  possible  penalty  for 
infringements of due diligence, prohibition or traceability 
is to suspend the authorisation to trade. So far, sanctions 
have  mainly  been  for  breaches  of  the  due  diligence 
requirement.  These  sanctions  have  taken  the  form  of 
notices  of  remedial  actions.  Infringement  cases  are  still 
under way.  

collaborated  with 

On  cooperation  (Article 12  of  the  EUTR),  France  reports 
to  have 
various  government 
institutions  as  well  as  with  other  EU  competent 
authorities  and 
institutions.  Furthermore,  France 
participates  in  the  Mediterranean  network  on  EUTR 
implementation.  

Genetic  resources:  Nagoya  Protocol  on  Access  to 
Genetic Resources and the Fair and Equitable Sharing of 
Benefits Arising (ABS)182  

In  line  with  the  provisions  of  the  EU  Access  and  Benefit 
Sharing  (the  ABS  Regulation),  which  transposes  the 
the  Nagoya 
required  compliance  measures  under 

177 UN General Assembly Resolution 72/277 and Organizational session 
of the ad hoc open-ended working group.  
178 Protocol on Access to Genetic Resources and the Fair and Equitable 
Sharing of Benefits Arising from their Utilisation to the Convention on 
Biological Diversity. 
179 Regulation (EU) No 995/2010. 
180 Regulation (EC) No 2173/2005. 
181Traders were checked by 19 countries, with numbers of checks 
ranging from 1 (Denmark, France, Luxembourg) to 747 (Cyprus). 12 out 
of 19 countries conducted between 1 and 65 checks. 
182 Regulation (EU) No 511/2014. 

                                                                 
                                                                 
Environmental Implementation Review 2019 – France 

Protocol  into  EU  law,  France  has  appointed  competent 
authorities  for  genetic  resources.  It  has  also  applied  the 
Regulation’s sanctions for infringements. So far, it has not 
submitted  a  due  diligence  declaration  or  applied  any 
penalties.  Moreover,  France  has  not  delivered  on  its 
reporting obligations under the EU ABS Regulation. 

that stronger efforts will be made to  include sustainable 
development  in  the  work  of  all  public  institutions.  Each 
Minister has nominated one or more senior  civil servant 
to  prepare  their  administration’s  contribution  to  the 
NSDS,  coordinate  the  preparation  of  the  corresponding 
action plans and monitor their implementation. 

is  also  developing  an  action  plan  for  the 
France 
it 
Sustainable  Development  Goals  (SDGs).  However, 
remains  to  be  seen  whether  the  plan  will  include  a 
mechanism for integrating SDGs into policy making. 

The  110  statistical  indicators  developed  by  the  National 
Institute  of  Statistics  and  Economic  Studies  to  monitor 
progress in implementing the SDGs could help to inform 
decision-making.  France  presented  a  voluntary  national 
review  of  its  implementation  of  the  SDGs  at  a  UN  high-
level  political  forum  on  sustainable  development  in  July 
2016. It was one of the first  four EU countries to do so. 
An update is planned for 2019. 

International  wildlife 
the  Convention  on 
trade: 
International  Trade  in  Endangered  Species  of  Wild 
Fauna and Flora (CITES)183 

In  line  with  the  Convention  on  International  Trade  in 
Endangered  Species  of  Wild  Fauna  and  Flora  (CITES), 
France  has  established  relevant  national  authorities  for 
the  international  wildlife  trade  and  regularly  processes 
requests for import, export, re-export, and intra-EU trade 
documents 

Reports  on  seizures  of  illegal  wildlife  shipments,  (in 
particular  those  reported  every  6  months  to  TRAFFIC 
(Trade Records Analysis of Flora and Fauna in Commerce) 
under  its  contract  with  the  Commission,  and  those 
exchanged through the European Union Trade in Wildlife 
Information  eXchange  (EU-TWIX)  -  platform),  show  the 
extent of the customs authorities’ activity. 

To  ensure  the  2016  EU  wildlife  action  plan  is  fully 
implemented,  France  has  developed  best  practice 
procedures  on  how  to  handle  wildlife  trade  offences 
along  the  enforcement  chain.  France  also  provides 
financial  support  to  national  and  regional  development 
programs  outside  of  the  EU,  e.g.  the  African  elephant 
Fund184. 

Sustainable 
implementation of the UN SDGs 

development 

and 

the 

Sustainable development links environmental, social and 
economic policies in a coherent framework and therefore 
legislation  and 
helps  to 
policies. 

implement  environmental 

France adopted its first national sustainable development 
strategy  (NSDS)  in  2003.  The  second  (2010-2013)  NSDS 
was  adopted 
in  July  2010,  following  the  national 
environment roundtable. An interministerial delegate for 
sustainable development working under the authority of 
the Prime Minister and Ministry of Environment, Energy 
and  Sea  affairs,  coordinates  the  work  at  national  level. 
The 
is  also  Commissioner 
interministerial  delegate 
General for Sustainable Development. 

in  the 
Sustainable  development  has  been 
French  Constitution  since  March  2005  when  the 
Environmental  Charter  was  adopted.  This  guarantees 

included 

183 The Convention on International Trade in Endangered Species of 
Wild Fauna and Flora (CITES). 
184 UN, African Elephant Fund. 

39