COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022 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 2022: Turning the tide through environmental compliance
Date: 2022-09-08
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, France, application of EU law, biodiversity, circular economy, climate change policy, environmental law, governance, pollution control measures, waste management

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.9.2022  SWD(2022) 257 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022       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 2022: Turning the tide through environmental compliance {COM(2022) 438 final} - {SWD(2022) 252 final} - {SWD(2022) 253 final} - {SWD(2022) 254 final} - {SWD(2022) 255 final} - {SWD(2022) 256 final} - {SWD(2022) 258 final} - {SWD(2022) 259 final} - {SWD(2022) 260 final} - {SWD(2022) 261 final} - {SWD(2022) 262 final} - {SWD(2022) 263 final} - {SWD(2022) 264 final} - {SWD(2022) 265 final} - {SWD(2022) 266 final} - {SWD(2022) 267 final} - {SWD(2022) 268 final} - {SWD(2022) 269 final} - {SWD(2022) 270 final} - {SWD(2022) 271 final} - {SWD(2022) 272 final} - {SWD(2022) 273 final} - {SWD(2022) 274 final} - {SWD(2022) 275 final} - {SWD(2022) 276 final} - {SWD(2022) 277 final} - {SWD(2022) 278 final}  
 
 
 
 
 
 
 
 
 
France  1 

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 

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Environmental Implementation Review 2022 – France 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
©European Union, 2022 

Reproduction is authorised provided the source is acknowledged. 

France  2 

Environmental Implementation Review 2022 – France 

 
 
 
France  3 

TABLE OF CONTENTS 

EXECUTIVE SUMMARY ........................................................................................................................................... 4 

PART I: THEMATIC AREAS ...................................................................................................................................... 4 

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ............................................................................................................. 4 
Measures towards a circular economy ................................................................................................................ 4 
Waste management ............................................................................................................................................. 6 
2. BIODIVERSITY AND NATURAL CAPITAL ............................................................................................................................. 9 
Nature protection and restoration ....................................................................................................................... 9 
Marine ecosystems............................................................................................................................................. 15 
Ecosystem assessment and accounting ............................................................................................................. 17 
3. ZERO POLLUTION ..................................................................................................................................................... 19 
Clean air ............................................................................................................................................................. 19 
Industrial emissions ............................................................................................................................................ 20 
Preventing major industrial accidents – Seveso ................................................................................................. 23 
Noise .................................................................................................................................................................. 24 
Water quality and management ........................................................................................................................ 25 
Chemicals ........................................................................................................................................................... 28 
4. CLIMATE ACTION ..................................................................................................................................................... 31 
Key national climate policies and strategies ...................................................................................................... 31 
Effort sharing target ........................................................................................................................................... 31 
Key sectoral developments ................................................................................................................................. 32 
Use of revenues from the auctioning of EU ETS allowances .............................................................................. 33 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS .............................................................................. 34 

5. FINANCING ............................................................................................................................................................. 34 
Environmental investment needs in the European Union .................................................................................. 34 
EU environmental funding 2014-2020 ............................................................................................................... 36 
EU environmental funding 2021-2027 ............................................................................................................... 37 
National environmental protection expenditure ................................................................................................ 39 
Green budget tools ............................................................................................................................................. 40 
Overall environmental financing compared to needs ........................................................................................ 43 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 44 
Information, public participation and access to justice...................................................................................... 44 
Compliance assurance ........................................................................................................................................ 45 
Effectiveness of environmental administrations ................................................................................................ 47 
Reforms through the Commission’s TSI .............................................................................................................. 48 
Taiex peer-to-peer projects ................................................................................................................................ 48 

Environmental Implementation Review 2022 – France 

 
France  4 

Executive summary

In  previous  environmental  implementation  reviews 
(EIRs), the Commission identified three main challenges 
for France’s implementation of EU environmental policy 
and law. These three challenges were to: 

 

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

 

For the Natura 2000 network, special protection areas 
(SPAs) still need to be classified. The conservation status 
of  habitats  and  species  of  EU  interest  must  also  be 
improved  by  fully 
implementing  the  Natura  2000 
network  and  setting  out  conservation  objectives  and 
respective  measures.  To  protect  ecosystems,  the 
regions need to cooperate more so that their different 
marine  strategies  are  consistent  with  each  other. 
Protecting  species  remains  a  major  issue  with  three 
infringement procedures currently pending. 

Air quality and air pollution in France continue to be a 
serious cause for concern. Although emissions of many 
air  pollutants  and  fine  particulate  matters  have  been 
reduced,  limit  values  continue  to  be  exceeded  for 
certain  pollutants.  France  is  subject  to  two  ongoing 
infringement cases on nitrogen dioxide (NO2) and PM10 
and additional efforts are needed to reach the targets 
set by the new National Emissions Ceilings Directive for 
2020-2029. Although the laws to improve air quality are 
now in place, it will take time for the planned measures 
to  produce  tangible  results,  in  particular  for  ammonia 
(NH3).  Access  to  environmental  information  has  been 
identified  as  an  issue,  especially  information  about 
major 
(Seveso 
installations).  On  noise  pollution,  there  is  an  urgent 
need to  finalise  action plans  for noise management  in 
urban areas and around major roads. 

accidents  prevention 

industrial 

On water management, although there has been some 
progress  tackling  water  pollution  and  the  industrial 
release  of  heavy  metals,  the  number  of  water  bodies 
that have not yet reached good ecological and chemical 
status is still significant. Nitrates pollution, mainly from 
agriculture,  remains  a  serious  concern  to  be  tackled  – 
there  is  an  ongoing  infringement  on  exceedances  of 
nitrates  concentration  in  drinking  water.  In  addition, 
France  has,  over  the  years,  encountered  difficulties  in 
fulfilling  its  obligations  under  the  Urban  Waste  Water 
Treatment  Directive  and  is  currently  subject  to  an 
infringement case. 

There has been some progress on waste management, 
with  an  improvement  in  municipal  recycling  rates. 
However, more efforts are necessary to  meet with EU 
recycling  targets  for  2025  and  2030.  Moreover,  waste 
management plans must be put in place that are fully in 
line  with  the  revised  Waste  Framework  Directive. 
Adopting  adequate  implementing  legislation  is  also 
necessary to ensure the compliance of France's recovery 
and resilience plan (RRP), which supports measures to 
accelerate the transition to  a circular economy (under 
the framework of the anti-waste and circular economy 
law). 

EU  financing  continues  to  substantially  support  the 
environmental  implementation  gap.  France  is  due  to 
receive  EUR  39.4  billion  from  the  Recovery  and 
Resilience  Facility  (RRF)  (2021-2026)  in  grants,  out  of 
which  20.2  will  serve  green  transition  matters.  It  will 
also  receive  EUR  17.9  billion  from  the  cohesion  policy 
(2021-2027, including JTF), out of which 2.8 billion will 
serve climate and environment matters. France’s overall 
environmental financing for investments is estimated to 
have  been  an  annual  0.78%  of  GDP  in  2014-2020  on 
average. The overall environmental investment needs in 
2021-2027  are  at  least  annual  0.82%  of  France’s  GDP. 
This suggests an environmental investment gap of over 
0.05% of GDP that should be addressed by focusing on 
the country’s environmental implementation priorities, 
with  the 
for 
environmental compliance and sustainability.

likely  need  to 

financing 

increase 

Environmental Implementation Review 2022 – France 

 
 
 
France  4 

Part I: Thematic areas 

1. Circular economy and waste management 

Measures towards a circular economy 

Figure 1: Circular material use rate (%), 2010-20202 

The  new  Circular  Economy  Action  Plan  adopted  in 
March  2020  is  one  of  the  main  building  blocks  of  the 
European Green Deal.  The EU’s transition to a  circular 
economy will reduce pressure on natural resources and 
will  create  sustainable  growth  and  jobs.  It  is  also  a 
prerequisite to achieve the EU’s 2050 climate neutrality 
target  and  to  halt  biodiversity  loss.  The  Action  Plan 
announces  initiatives  along  the  entire  life  cycle  of 
products,  aiming  to  reduce  the  EU's  consumption 
footprint  and  to  double  the  EU's  circular  material  use 
rate  by  2030.  It  targets  how  products  are  designed, 
promotes  circular  economy  processes,  encourages 
sustainable consumption, and aims to ensure that waste 
is prevented and the resources used are kept in the EU 
economy for as long as possible. 

The circular material use-rate is a good indicator of an 
economy’s circularity, as it includes all the materials that 
are fed back into our economy. Large differences in the 
circularity rate exist between countries. To help achieve 
the  goal  in  the  EU  circular  economy  action  plan  of 
doubling  the  EU’s  circular  material  use-rate  by  2030, 
ambitious  measures  targeting  the  whole  product  life 
cycle are needed at Member State level. Such measures 
range  from  sustainable  product  design  that  makes  it 
reparability, 
possible 
upgradability  and  recyclability  of  products,  to  other 
measures  like:  (i)  ‘remanufacturing’1;  (ii)  increasing 
circularity  in  production  processes;  (iii)  recycling;  (iv) 
boosting eco-innovation; and (v) increasing the uptake 
of green public procurement. 

the  durability, 

increase 

to 

France’s  circular  (secondary)  use  of  materialrose  to 
22.2% in 2020 compared to 17.8% in 2014. It constantly 
remained above the EU average of  11.2% in 2014 and 
12.8%  in  2020.  France  is  increasing  its  use  of  this 
material faster than the EU average – the gap widened 
between France and the EU average between 2010 and 
2020. 

Resource  productivity  expresses  how  efficiently  the 
economy  uses  material  resources  to  produce  wealth. 
Improving  resource  productivity  can  help  to  minimise 
negative  impacts  on  the  environment  and  reduce 
dependency on volatile raw material markets. As shown 
in Figure 2, with EUR 3.13 generated per kg of material 
consumed  in  2020,  resource  productivity  in  France  is 
well  above  the  EU  average  of  EUR  2.09  per  kg.  This 
positive  performance 
is  further  supported  by  a 
continuous  increase  in  France’s  resource  productivity 
over the last decade. 

1 A standardised industrial process that takes place within industrial or 
factory  settings,  in  which  cores  are  restored  to  original  as-new 
condition and performance or better. 

2 Eurostat, Circular Economy Monitoring Framework. 

Environmental Implementation Review 2022 – France 

 
                                                                 
 
 
 
Figure 2: Resource productivity 2010-20203 

Circular economy strategies 

The  Commission  encourages  Member  States  to  adopt 
and 
implement  national/regional  circular  economy 
strategies covering the whole life cycle of products. This 
is because such strategies are one of the most effective 
ways  to  progress  towards  a  more  circular  economy. 
Since  the  launch  of  the  European  Circular  Economy 
Stakeholder  Platform  in  2017,  national,  regional  and 
local authorities have used the platform to  share their 
strategies and roadmaps and presented best  practices 
on  recycling  of  primary  and/or  secondary  raw 
materials4. 

At  national 
level,  France  has  set  a  timeline  and 
objectives in its roadmap for the circular economy 5. To 
fulfil the vision set out in the roadmap, France adopted 
the  first  ever  law  against  waste  and  for  the  circular 
economy in 2020 (‘AGEC law’ - Loi n° 2020-105)6. With 
this  law,  France  has  put  in  place  rules  on  planned 
obsolescence, 
a 
reparability index), extending producers’ responsibility, 
and measures on single-use plastics and the destruction 
of  unsold  food  and  non-food  products.  The  law  is 
organised around five objectives: (i) phasing out single-
use  plastics;  (ii)  improving  information  to  consumers; 
(iii) promoting reuse and combatting waste; (iv) fighting 
improving  circular 
planned  obsolescence;  and  (v) 

(including 

durability 

product 

France  5 

and  products.  Many 

implementing 
production 
measures  (décrets)  have  already  been  adopted,  and 
others are still in preparation. 

France  does  not  have  specific  sectoral  strategies  on 
textiles, plastics, and construction. However, the AGEC 
Law directly targets these sectors with clear objectives 
and  concrete  measures.  These  include  achieving  zero 
disposable  plastics  by  2040,  creating  an  extended 
producer  responsibility  scheme  for  the  building  sector 
and  planning  the  gradual  setting  up  of  mandatory 
product  environmental  labelling,  notably  in  the  textile 
sector. 

France plans reforms under Component 2 (ecology and 
biodiversity) of its RRP. The country proposes to publish 
decrees  to  implement  the  law  on  circular  economy. 
the  producer 
These  measures  will: 
responsibility scheme for construction and public works 
material  waste;  (ii)  set  minimum  rates  of  recycled 
material that must be used in production; and (iii) set a 
proportional amount of reusable packaging that has to 
be placed on the market7. 

(i)  extend 

Overall, France is advancing on implementing the AGEC 
Law, which can be considered a good practice in terms 
of innovative legislation. 

Eco-innovation 

A  successful  transition  to  a  circular  economy  requires 
social and technological innovation. This is because the 
full  potential  of  the  circular  economy  can  only  be 
reached when it is implemented across all value chains. 
Eco-innovation  is  an  important  enabling  factor  for  the 
circular  economy.  New  approaches  to  product  design 
and  new  business  models  can  help  produce  systemic 
creating  new  business 
circularity 
opportunities. 

innovations, 

France ranked seventh in the list of EU countries, with a 
in  the  2021  Eco-Innovation 
total  score  of  127 
Scoreboard,  and  it  performs  as  an  eco-innovation 
leader. The country performs above the EU average in 
three  of  the  five  components  of  the  2021  Eco-
Innovation Index, except for eco-innovation outputs and 
socio-economic outcomes. 

3 Eurostat, Resource productivity. 
4 Good Practices | European Circular Economy Stakeholder Platform 
(europa.eu). 
5  France  Ministry  of  Ecological  Transition,  Roadmap  for  the  Circular 
Economy, April 2018 - FREC anglais.pdf (ecologie.gouv.fr). 
6 AGEC Law, October 2019 (ecologie.gouv.fr). 

7  Commission staff  working  document,  Analysis  of  the  recovery  and 
resilience plan of France Accompanying the document Proposal for a 
Council implementing  decision on the approval of  the assessment of 
the recovery and resilience plan for France (COM(2021) 351 final), p. 
30. 

Environmental Implementation Review 2022 – France 

 
 
 
                                                                 
 
Figure 3: Eco-innovation performance8 

Green public procurement 

Green  public  procurement  can  help  drive  the  demand 
for  sustainable  products.  The  national  action  plan  for 
sustainable  public  procurement,  called  France’s  green 
public  procurement  strategy  for  2015-2020,  was 
adopted  and  published  in  March  2015.  It  aims  to 
increase the extent to which social and environmental 
criteria  are 
in  public 
procurement.  In  addition,  the  plan  aims  at  integrating 
the  United  Nations’  (UN)  Sustainable  Development 
Goals thus giving it an international dimension9. Several 
French sectoral laws also set green public procurement 
obligations,  in  particular  promoting  the  use  of  reused 
and  recycled  materials,  avoiding  the  use  of  single-use 
plastic items and considering deforestation risks10. 

into  consideration 

taken 

EU Ecolabel and the EU eco-management and audit 
scheme (EMAS) 

The  number  of  EU  Ecolabel  products  and  EMAS-
licensed11  organisations  in  a  given  country  provides 

France  6 

some  indication  of  the  extent  to  which  the  private 
sector  and  stakeholders  in  that  country  are  actively 
engaged in the transition to a circular economy. It also 
shows  how  committed  public  authorities  are  to 
instruments  designed  to  promote  the 
supporting 
circular economy. 

As  of  September  2021,  France  had  8  347  products 
registered in the EU Ecolabel scheme (out of 83 590 in 
the EU).  This  makes France the country with the  third 
highest number of products after Spain and Italy. France 
had registered 327 licences out of a total of 2 057 in the 
EU.  The  trend  for  products  is  very  positive  (having 
increased from 4 971 products in 2018), but the number 
of  licences  has  fallen  (compared  to  the  518  licences 
registered in September 2018)12. 

As  of  October  2021,  France  had  30  organisations 
registered in EMAS13, a  further decrease from the low 
number in 20180. 

Waste management 

Turning waste into a resource is supported by: 
(i)  fully  implementing  EU  waste  legislation,  which 
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; 
(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 
waste14,  for  which  EU  law  sets  mandatory  recycling 
targets. 

Preventing  products  and  materials  from  becoming 
waste for as long as possible is the most efficient way to 
improve  resource  efficiency  and  to  reduce  the 
environmental impact of waste. Waste prevention and 
reuse are the most preferred options and are therefore 
at  the  top  of  the  ‘waste  hierarchy’.  The  amount  of 
municipal  waste  generated  is  a  good  indicator  of  the 
effectiveness of waste prevention measures. 

8  European  Commission  -  Directorate-General  for  Environment  (DG 
ENV), Eco-innovation Observatory, Eco-innovation index. 
9  Plan  national  d'action  pour  les  achats  publics  durables  2015-2020 
(ecologie.gouv.fr). 
10 A public stakeholder consultation took place between 15 June 2021 
and 6 July 2021 : Plan national pour des achats durables 2021 - 2025 - 
Consultations publiques (developpement-durable.gouv.fr). 
11  EMAS  is the  Commission’s  eco-management  and audit  scheme,  a 
programme  that  encourages  organisations  to  behave  in  a  more 

environmentally  sustainable  way.  EMAS  –  Environment  -  European 
Commission (europa.eu). 
12 European Commission, Ecolabel Facts and Figures. 
13  Eco-management  and  audit  scheme,  European  Commission,  June 
2021. 
14 Municipal waste consists of mixed waste and separately collected 
waste from households and from other sources, where such waste is 
similar in nature and composition to waste from households. This does 
not  affect  the  allocation  of  responsibilities  for  waste  management 
between the public and private sectors. 

Environmental Implementation Review 2022 – France 

 
 
 
 
                                                                 
 
in  France  decreased 
Municipal  waste  generation 
between  2010  and  2014  and  started  increasing  again 
from 2015 until 2020 (see Figure 4). Given that France’s 
economic  growth  (GDP)  continuously  grew  between 
2014  and  2018,  municipal  waste  generation  was 
coupled to economic growth from 2014 onwards. 

Figure 4: Municipal waste by treatment in France, 
2010-202015 

France  7 

  reduce food waste in food distribution and catering 
by 50% by 2025 compared to 2015, and reduce it in 
consumption,  production,  processing  and  catering 
by 50% by 2030 compared to 2015. 

  end the marketing of single-use plastic packaging by 

2040. 

As  shown  in  Figure  4,  municipal  waste  by  treatment 
(measured in kilos per person) has an increasing share 
of material recycling over time  and a decreasing share 
of landfill/disposal. Managing waste efficiently remains 
a major challenge for France. 

France has made some progress over the past decade in 
improving  its  recycling  rate  and  diverting  municipal 
waste  from  landfill.  The  recycling  rate  for  municipal 
waste in 2020was 42%, a slight decrease from 44.1% in 
since  2017.  The  recycling  rate  stands  below  the  EU 
average of 48.1%. 

Figure 5: Recycling rate of municipal waste, 2010-
2020917 

After a downward trend, municipal waste16 generation 
in France has started to increase again in recent years. 
It rose to 555 kg per capita in 2019, but decreased to 535 
kg per capita in 2020. The recent increase from 2015 can 
be  attributed  to  an  increase  in  the  population  and  in 
household  spending.  Overall,  the  average  annual 
municipal waste generation of 535 kg per capita is above 
the EU average of 505 kg per capita. 

The AGEC Law as of 10 February 2020 sets the following 
waste prevention targets: 

  reduce  household  and  similar  waste  produced  per 

person by 15% in 2030 compared to 2010; 

  reduce the amount of waste produced by economic 
activities  per  unit  of  value  (in  particular  from  the 
building  and  public  works  sector)  by  5%  in  2030 
compared to 2010; 

  reuse and recycle the equivalent of 5% of household 

waste tonnage in 2030; 

  achieve a  share of reused packaging placed on the 

market of 5% in 2023 and 10% in 2027; 

Figure  5  shows  that  France  may  need  to  step  up 
investment in recycling to meet the EU 2020 and 2025 
recycling targets. 

The Commission is currently finalising its analysis of the 
progress on the recommendations from the 2018 Early 
Warning reports, as a well as progress in achieving the 
2020 and 2025 municipal waste recycling targets of 50% 
and  55% respectively. This report  will be presented at 
the end of 2022. The Commission's 2018 Early Warning 

15 Eurostat, Municipal waste by waste operation, april 2022. 
16  Municipal  waste  consists  of  (a)  mixed  waste  and  separately 
collected  waste  from  households,  including  paper  and  cardboard, 
glass, metals, plastics, bio-waste, wood, textiles, packaging, electrical 
waste and electronic equipment, waste batteries and accumulators, 
and  bulky  waste,  including  mattresses  and  furniture;  and  (b)  mixed 

waste and waste collected separately from other sources, where such 
waste  is  similar  in  nature  and  composition  to  households  waste. 
(Directive 2008/98/EC, Art. 3(2)(b)). 
17 Eurostat, Recycling rate of municipal rate, april 2022. 

Environmental Implementation Review 2022 – France 

 
 
 
 
                                                                 
 
 
 
report did not list France as one of the countries at risk 
of missing the EU 2020 target of recycling18. 

Implementation of the 2018 waste legislative package  

By  5  July  2020,  Member  States  had  to  bring  their 
national laws in line with amendments included in the 
revised Waste Framework Directive, the Packaging and 
Packaging Waste Directive and the Landfill Directive19. 

In July 2021, France had still not done this for any of the 
waste  laws,  and  so  the  Commission  sent  a  formal 
request  to  France  to  fully  turn  the  updated  EU  waste 
rules  into  national 
in  the 
meantime,  notified  the  Commission  that  it has  turned 
the  waste  package  into  national  law.  A  conformity 
assessment is now ongoing. 

legislation.  France  has, 

Waste  management  plans  and  waste  prevention 
programmes are critical for a sound implementation of 
EU  waste  legislation.  They  set  out  key  rules  and 
investment to ensure compliance with existing and new 
legal  requirements  (e.g.  waste  prevention,  separate 
collection  for  specific  types  of  waste,  recycling  and 
landfill targets). 

Four  regions  have  not  submitted  their  revised  waste 
management  plans  /  waste  prevention  programmes20. 
The  other  regions  submitted  the  revised  plans  and 
infringement 
programmes,  but  gaps  remain.  An 
procedure  addressing  this  gap  is  pending,  and  the 
Commission  is  closely  monitoring  the  adoption  of  the 
missing regional plans. 

France  8 

According  to  the  Ministry  of  Ecological  Transition, 
France  produces  10  million  tonnes  of  food  waste  per 
year,  equivalent  to  30  kg  per  person.  A  French  study 
shows  that  most  food  waste  is  thrown  away  by 
consumers  (33%),  followed  by  food  producers  (32%), 
processors (21%) and retailers (14%)21. 

The second National Pact to Combat Food Waste (2017) 
covers 2017-202022. Its main objective is to improve the 
food waste  measures of the  national food programme 
and the national waste prevention programme initially 
planned 
together 
stakeholders from across the food production chain and 
aims to reduce food waste by 50% by 202524. 

2019-202323. 

It  brings 

for 

Given  the  limited  progress  since  the  2019  EIR,  and  in 
light  of  the  2022  Early  Warning  Report,  the  priority 
actions are proposed again. 

2022 priority actions 

 

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

  Ensure  waste  management  plans  are  in  place  and 
are  in  line  with  the  revised  Waste  Framework 
Directive. 

for  re-use/recycling 

18 Report on the implementation of EU waste legislation, including the 
early  warning  report  for  Member  States at  risk  of  missing  the  2020 
preparation 
target  on  municipal  waste, 
COM(2018)  656  final,  EUR-Lex  -  52018DC0656  -  EN  -  EUR-Lex 
(europa.eu). 
19  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. 

20 Corsica, Guyanne, Mayotte and La Reunion. 
21 European Food Loss and Waste Prevention Hub (europa.eu) 
22  An  assessment  of  the  2017-2020  National  Pact  is  available  in 
French :  https://agriculture.gouv.fr/pacte-national-de-lutte-contre-
le-gaspillage-alimentaire-les-partenaires-sengagent. 
23 Programme national pour l'alimentation 2019-2023 : territoires en 
action | Ministère de l'Agriculture et de l'Alimentation 
24  Ministry  of  Ecological  Transition,  available  in  French :  Gaspillage 
alimentaire | Ministère de la Transition écologique (ecologie.gouv.fr). 

Environmental Implementation Review 2022 – France 

 
 
                                                                 
 
 
 
 
France  9 

2. Biodiversity and natural capital

The 2030 EU biodiversity strategy adopted in May 2020 
aims to put the EU’s biodiversity on a path to recovery 
and sets out new targets and governance mechanisms to 
achieve healthy and resilient ecosystems. 
In particular, the strategy sets out ambitious targets to: 
(i) protect a minimum of 30% of the EU’s land area and 
30% of its sea area and integrate ecological corridors, as 
part of a true trans-European nature network; 
(ii) strictly protect at least a third of the EU’s protected 
areas, including all remaining EU primary and old-growth 
forests; 
(iii) effectively manage all protected areas, defining clear 
conservation  objectives  and  measures,  and  monitoring 
them appropriately. 
The strategy also sets out an EU nature restoration plan 
–  a  series  of  concrete  commitments  and  actions  to 
restore degraded ecosystems across the EU by 2030, and 
manage them sustainably, addressing the key drivers of 
biodiversity loss. 

France  has  just  launched  a  consultation  on  its  third 
national  biodiversity  strategy.  On  19  November  2021, 
France adopted a national strategy for marine and land 
protected  areas,  which  aims  to  protect  30%  of  the 
national territory from 2022, 33% of which under strong 
protection. 

Nature protection and restoration  

The EU’s Birds and Habitats Directives are key legislative 
tools  to  deliver  on  the  targets  in  the  EU’s  biodiversity 
strategy  for 2030 and are the cornerstone of European 
legislation aimed at conserving the EU’s wildlife, natural 
habitats and ecosystems25. 

Natura  200026,  the  largest  coordinated  network  of 
protected  areas  in  the  world,  is  the  key  instrument  to 
achieve  the  objectives 
in  the  Birds  and  Habitats 
Directives.  These  objectives  are:  (i)  to  ensure  the  long-

25  These  should  be  strengthened  by  the  Nature  Restoration  Law, 
according to the new EU biodiversity strategy. 
26  Natura  2000  comprises  sites  of  community  importance  (SCIs) 
designated under  the  Habitats Directive  as  well  as  special  protection 
areas  (SPAs)  classified  under  the  Birds  Directive.  Figures  of  coverage 
and no-coverage do not add up to 100% due to the fact that some SCIs 
and  SPAs  overlap.  Special  Areas  of  Conservation  (SACs)  are  SCIs 
designated by Member States. 
27 SCIs are designated under the Habitats Directive whereas SPAs are 
designated  under  the  Birds  Directive.  Figures  of  coverage  and  non-
coverage do not add up  to 100% due to the fact that some SCIs and 
SPAs overlap. Special areas of conservation (SACs) are SCIs designated 
by Member States. 

term  protection,  conservation  and  survival  of  Europe's 
most valuable and threatened species and habitats; and 
(ii)  to  maintain  or  restore  the  favourable  conservation 
status  of  these  species  and  habitats.  Key  milestones 
towards meeting the objectives of the Birds and Habitats 
Directives  are:  (i)  the  setting  up  of  a  coherent  Natura 
2000 network; (ii) the designation of sites of community 
importance  (SCIs)  as  special  areas  of  conservation 
(SACs)27; and (iii) the setting of site-specific conservation 
objectives and measures for all Natura 2000 sites. 

Setting up a coherent network of Natura 2000 sites 

France  hosts  130  habitat  types28  and  291  species29 
covered  under  the  Habitats  Directive.  The  country  also 
hosts  populations  of  145  bird  taxa  listed  in  the  Birds 
Directive Annex I30. 

By 2021, 12.9% of the national land area of France was 
covered  by  Natura  2000  (EU-27  average:  18.5%).  SPAs 
classified  under  the  Birds  Directive  were  covering  8% 
(EU-27  average:  12.8%),  and  SCIs  under  the  Habitats 
Directive  were  covering  8.9%  (EU  average:  14.2%)  of 
French territory. 

The  assessment  of  the  SPAs  shows  insufficiencies  for 
migratory  birds  (e.g  turtle  dove)  and  in  marine  coastal 
areas. Therefore, France has still to complete its Natura 
2000  network,  in  particular  the  marine  network.  A 
dialogue on assessing gaps is ongoing with France. 

France legally protects 27.6% of its terrestrial areas (EU-
27  average:  26.4%)  and  37,7  %  of  marine  areas  (EU-27 
average: 10.7%)31 – this includes Natura 2000 and other 
nationally  designated  protected  areas.  France  strictly 
protects  1.5% of the EU’s protected areas, as classified 
under the International Union for Conservation of Nature 
(categories 1A and 1B). 

28 European Environment Agency, Article 17 dashboard, Annex I total, 
2019. 
29  European  Environment  Agency,  Article  17  dashboard,  Annex  II  + 
Annex IV excluding those in Annex II + Annex V excluding those in Annex 
II, 2019. This counting only takes into account species and habitats for 
which assessment of conservation status was requested. 
30 European Environment Agency, Article 12 dashboard, Annex I, 2020. 
This counting only takes into account birds taxa for which information 
was requested. 
31  European  Environment  Agency,  Protected  areas,  terrestrial 
protected  area  percentage  (2021)  and  marine  protected  area 
percentage (2019), March 2022. 

Environmental Implementation Review 2022 – France 

 
 
                                                                 
 
 
Figure 6: Marine and terrestrial protected area 
coverage, 202132 

Designating special areas of conservation (SACs) and 
setting conservation objectives and measures 

France  10 

Only 21 SCIs out of 1 377 have not yet been designated 
as SACs. Site-specific conservation objectives have been 
set  for  1  176  SCIs  and  set  out  in  comprehensive 
management plans for 1 292 SCIs. 

The  French  implementation  of  Natura  2000  has  the 
following strengths: (i) the network of facilitators; (ii) the 
high  number  of  sites  with  management  plans;  (iii)  the 
way  the  effectiveness  of  the  network  is  assessed;  (iv) 
financing  efforts;  (v)  the  bottom-up  approach;  (vi)  the 
involvement  of  local  authorities  and  representatives  of 
different interest groups; (vii) the stability and expertise 
of the different bodies working on biodiversity, and who 
are based around the sites themselves. However, it still 
faces the following gaps: (i) the lack of diversification of 
funding  sources;  (ii)  the  under  use  of  the  LIFE 
programme; (iii) no management at sea; (iv) Natura 2000 
is not as visible as French protection policy tools; and (v) 
there is not enough ecological connection between the 
sites. 

France  also  does  not  do  enough  to  prevent  damage 
caused  by  agricultural,  forestry  and  fishing  practices 
(Article 6(2) of the  Habitats Directive). An infringement 
case is open because there are no measures to prevent 
by-catch  of  marine  species 
in  Natura  2000  sites 
(unwanted  fish  and  other  marine  creatures  trapped  by 
commercial  fishing  nets  when  fishing  for  a  different 
species). The quality of the objectives and measures for 
sites  is  not  always  sufficient,  and  they  are  not  always 
tailored  to  the  ecological  needs  of  the  designated 
habitats  and  species  –  this  creates  uncertainties  when 
evaluating plans and projects (under Article 6(3)). 

Progress in maintaining or restoring favourable 
conservation status of species and habitats 

To measure the performance of Member States, Article 
17  of  the  Habitats  Directive  and  Article  12  of  the  Birds 
Directive  require  reporting  on  the  progress  made 
towards  maintaining  or  restoring 
favourable 
conservation status of species and habitats34. 

the 

According  to  the  report  submitted  by  France  on  the 
conservation  status  of  habitats  and  species  covered  by 
Article  17  of  the  Habitats  Directive,  between  2013  and 
in  good 
2018,  the  share  of  habitats  and  species 
conservation status was 20.2% and 28.06% respectively. 
This is slightly less than in the previous reporting period 

34 Conservation status and trends of habitats and species — European 
Environment Agency (europa.eu). 

Figure 7: Nature 2000 terrestrial protected area 
coverage, 202133 

32  EU  Biodiversity  Strategy  Dashboard,  indicators  A1.1.1  and  A1.2.1, 
February 2022. 
33  European  Environment  Agency,  Natura  2000  Barometer,  February 
2022. 

Environmental Implementation Review 2022 – France 

 
 
 
 
 
 
                                                                 
 
(2007-2012)  when  the  share  was  22.56%  and  29.83%. 
While 17% of French forest area is protected under the 
EU  nature  directives,  less  than  18%  of  forest  habitats 
types have a favourable conservation status35. On birds, 
43% of breeding species showed a short-term increase in 
their numbers or had a stable population (this was 67% 
for wintering species). 

At  the  same  time,  the  share  of  habitats 
in  bad 
conservation status had slightly  decreased to  34 % and 
the share of assessed species in bad conservation status 
had slightly increased to 25%. The main pressure comes 
from  agriculture, 
forestry,  and  the  development, 
construction and use of infrastructure. 

Figure 8: Assessments on conservation status for 
habitats for the 2007-2012 and 2013-2018 reporting 
periods36 

35  European  Environment  Agency,  State  of  Nature  in  the  EU:  Results 
from reporting under the nature directives 2013-2018, 2021. 
36  European  Environment  Agency,  Conservation  status  and  trends  of 
habitats and species, December 2021. Please note when comparing the 
figures shown for 2007-2012 and 2013-2018 that these differences may 
also be affected by changes of methods or better data availability. 

France  11 

Figure 9: Assessments on conservation status for 
species for the 2007-2012 and 2013-2018 reporting 
periods37 

As  the  results  of  the  biogeographical  assessment  show 
(in Figures 8 and 9), there is no evidence that species and 
habitats conservation status is improving. 

Species protection 

France can do more for species protection. For example, 
the  country  has  not  taken  the  necessary  steps  to 
preserve, maintain and re-establish habitats with enough 
diversity and area for turtle doves, as required under the 
Birds  Directive.  Furthermore,  despite  the  size  of  the 
turtle  dove  breeding  population,  no  protected  areas 
(SPAs)  had  been  designated  within  the  Natura  2000 
network  and  no  specific  measures  have  been  taken  to 
conserve this species. Lastly, hunting of turtle dove does 
not comply with the ‘wise use’ principle for the species, 
because  hunting 
is  not  sufficiently  monitored  and 
hunting quotas are authorised at unsustainable levels. As 
a result, the Commission has launched an infringement 
procedure, which is still at the reasoned opinion stage. 

France  has  started  adaptive  harvest  management  for 
four huntable bird species, but there are still 20 hunted 
species  in  bad  conservation  status.  France  has  also 
authorised  several  methods  to  capture  birds  (such  as 
glue  for  thrushes  and  nets  and  traps  for  skylarks  and 
pigeons), that are not selective and are forbidden under 
the Birds Directive. Furthermore, hunting Greylag geese 
(Anser  anser)  after  they  have  started  migrating  to 

37 Conservation status and trends of habitats and species — European 
Environment Agency (europa.eu). 

Environmental Implementation Review 2022 – France 

 
 
 
 
                                                                 
 
 
 
breeding  grounds  is  widespread  and  authorised.  This 
practice, which is prohibited under the Birds Directive, is 
a cause of concern. The Commission sent a request for 
further  information  in  July  2019,  but  France  has  not 
taken  the  action  required  to  make  these  hunting  and 
capture  practices  comply  with  EU  law.  As  a  result,  the 
Commission  formally  requested  France  to  stop  illegal 
hunting and review capture methods for birds38. 

France has also been urged to take measures to reduce 
by-catch.  An  infringement  procedure  was  launched  in 
July  2020  for  failing  to  adopt  and  implement  the 
measures  needed  to  protect  cetaceans  and  seabirds 
within and outside designated Natura 2000 areas, as well 
as to limit incidental catches. This breaches several of the 
Birds  and  Habitats  Directives’  rules  on  managing  sites 
and protecting species. In addition, France has not taken 
action  on  acoustic  devices  that  deter  certain  creatures 
from approaching fishing vessels. 

Managing  large  carnivores,  in  particular  wolves  and 
brown bears, remains a sensitive point. Action is needed 
as their numbers are stabilising or increasing, resulting in 
renewed controversy in some parts of the country. 

Species  are  also  under  pressure  from  agricultural  and 
forest practices. 

Bringing nature back to agricultural land and restoring 
soil ecosystems 

Agricultural land 

The biodiversity strategy works alongside the new farm 
to fork strategy and the new common agricultural policy 
(CAP)  to  support  and  achieve  the  transition  to  fully 
sustainable agriculture. 
The biodiversity and farm to fork strategies have set four 
important targets for 2030: 
- a 50% reduction in the overall use of – and risk from – 
chemical pesticides; 
-  a  50%  reduction  in  the  use  of  more  hazardous 
pesticides; 
-  a  50%  reduction  in  losses  of  nutrients  from  fertilisers 
while  ensuring  there  is  no  deterioration  of  soil  fertility 
(which  will  result  in  a  20%  reduction  in  the  use  of 
fertilisers); 
- bring back at least 10% of agricultural area under high-
diversity  landscape  features  and  increase  areas  under 
organic farming to at least 25%. 

38 July infringements package: key decisions (europa.eu). 
39 Statistics | Eurostat (europa.eu) 
40 Eurostat, Area under organic farming, online data code: SDG_02_40, 
February 2022. 
41 SWD (2020) 379 final - available in French. 
42  These  objectives  relate  to  the  use  of  pesticides  and  the  risks 
associated  with  them,  the  sale  of  antimicrobials,  nutrient  losses,  the 

France  12 

As shown in Figure 10 France has an estimated 8.71% of 
land  under  organic farming,  which is  slightly below  the 
EU average of 9.07%39. 

Figure 10: Share of total utilised agricultural area 
occupied by organic farming per Member State, 202040 

Following its analysis of France’s CAP strategic plan41, the 
Commission made the following recommendations: 

  promote  the  development  of  a  smart,  resilient  and 
diversified agricultural sector, ensuring food security; 
  strengthen  environmental  protection  and  climate 
action,  and  contribute  to  the  eu's  climate  and 
environmental objectives; 

  strengthen  the  socio-economic  dimension  of  rural 

areas, and respond to societal concerns; 

  boost  knowledge,  innovation  and  digitalisation  in 

agriculture and rural areas. 

The Commission also invited France to allocate national 
targets specific to the Green Deal42 objectives in its CAP 
strategic  plan  that  take  the  country’s  specific  situation 
and  the  recommendations  above  into  account.  This  is 
also included in the farm to fork strategy. 

The farmland bird index43 has declined from 76.4 in 2013 
to 63.8 in 2018. 

Soil protection 

Soil  is  a  finite  and  extremely  fragile  resource.  It  is 
increasingly degrading in the EU. 
EU 
The 

strategy, 

adopted 

new 

soil 

on 

area devoted to organic farming, high-diversity topographical features, 
and the access to high-speed internet. 
43 Farmland bird index - FBI | Eurostat (europa.eu). 

Environmental Implementation Review 2022 – France 

 
                                                                 
 
 
 
importance  of  soil 
17 November 2021,  stresses  the 
protection,  of  sustainable  soil  management  and  of 
restoring  degraded  soils  to  achieve  the  Green  Deal 
objectives as well as land-degradation neutrality by 2030.  
This entails: 
(i) preventing further soil degradation; 
(ii) making sustainable soil management the new normal;  
(iii) taking action for ecosystem restoration. 

One factor  in the degradation  of soil ecosystems  is the 
area  of  soil  that  is  sealed  or  artificialised44.  The  land 
taken45 per year in 2012-2018 can be seen as a measure 
of one significant pressure on nature and biodiversity – 
land  use  change.  At  the  same  time,  land  use  change 
constitutes an environmental pressure on people living 
in urbanised areas. 

Despite a reduction in the last decade (land take was over 
1000  km2/year  in  the  EU-28  between  2000  and  2006), 
land take in the EU-28 still amounted to 539 km2/year in 
2012-2018 . The concept of ‘net land take’ combines land 
take  with  the  return  of  land  to  non-artificial  land 
categories  (re-cultivation).  While  some  land  was  re-
cultivated in the EU-28 in 2000-2018, 11 times more land 
was taken than returned. 

In 2012-2018, France ranked above the EU average with 
a  net  land  take  of  143.6  m2/km2  (EU-27  average:  83.8 
m2/km2)46. 

France  13 

Figure 11: Land take and re-cultivation in EU27 
(m2/km2), 2012-201847 

However,  France  has  not  yet  committed  to  set  land 
degradation neutrality targets under the UN Convention 
to Combat Desertification (UNCCD)48. 

Forests and timber 

The EU forest strategy for 2030, adopted in July 2021, is 
part  of  the  ‘Fit  for  55’  package.  The  strategy  promotes 
the many services that forests provide. Its key objective 
is to ensure healthy, diverse and resilient EU forests that 
contribute significantly to the strengthened biodiversity 
and climate ambitions.  
Forests are important carbon sinks and conserving them 
is vital if the EU is to achieve climate neutrality by 2050. 

Out  of  the  27%  of  EU  forest  area  protected  under  the 
Habitats  Directive,  less  than  15%  of  the  assessments 
show  a  favourable  conservation  status49.  The  share  of 
forested areas in the EU with a bad conservation status 
increased from 27% in 2015 to 31% in 2018. 

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 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 ‘Land taken’ means land that is sealed or artificialized. 

46 Land take  in Europe — European Environment Agency (europa.eu) 
Figure 6. 
47 European Environment Agency, Land take in Europe, December 2021. 
48  United  Nations  Convention  to  Combat  Desertification  includes  the 
land degradation neutrality (LDN) target, See: The LDN Target Setting 
Programme | UNCCD. 
49 European Environment Agency, State of Nature in the EU. 

Environmental Implementation Review 2022 – France 

 
 
                                                                 
 
 
 
In  France,  forests  cover  28.23%  of  the  country50  and 
more than 75% of the assessments reveal a bad to poor 
conservation status51. 

Figure 12: Conservation status of forests protected 
under the Habitats Directive in the EU-27, 2013-201852 

(EUTR)53 
The  European  Union  Timber  Regulation 
prohibits  the  placing  on  the  EU  market  of  illegally 
harvested timber. In line with the EUTR, Member States’ 
competent  authorities  must  conduct  regular  checks  on 
operators  and  traders,  and  apply  penalties  for  non-
compliance.  With  the  amendment  of  Article  20  of  the 
EUTR,  reporting  every  2  years  has  been  changed  to 
annual reporting and covers the calendar year as of 2019. 

From March 2017 to February 2019, France carried out 
30 checks on domestic timber operators54. It also carried 
out 73 checks on operators importing timber. Over the 
reporting  period,  it  is  estimated  that  France  had  5  000 
operators  placing  domestic  timber  types  on  the  single 
market,  and  14  000  operators  placing  imported  timber 
types on the single market. 

A proposal for the Regulation on the making available on 
the  EU  market  and  export  of  products  associated  with 
deforestation  and  forest  degradation  (Deforestation 
Regulation)  was  adopted  on  17  November  2021.  This 
followed a  request  from the  Council in 2019 to table a 
legislative  proposal  to  address  the  problem  and  a 
European  Parliament  resolution  recommending  the 

50  European  Environment  Agency,  Forest  information  system  for 
Europe. 
51 COM SWD (2021) 652. 
52  European  Environment  Agency,  Conservation  status  and  trend  in 
conservation status by habitat group - forests, January 2022. 
53 Regulation (EU) No 995/2010. 
54 COM (2020) 629 final. 
55  Regulation  (EU)  No  995/2010  of  the  European  Parliament  and  the 
Council  of  17  November  2021  on the  making  available  on  the  Union 
market as well as export from the Union of certain commodities and 

France  14 

Commission to come forward with legislation to halt and 
reverse  EU-driven  global  deforestation55  56.  The  new 
Deforestation  Regulation  will  repeal  and  replace  the 
EUTR,  and  it  will  essentially  integrate  and  improve  the 
existing system to check the legality of timber. 

Invasive alien species (IAS) 

IAS  are  a  key  cause  of  biodiversity  loss  in  the  EU 
(alongside changes in land and sea use, overexploitation, 
climate change and pollution).  
Besides  inflicting  major  damage  on  nature  and  the 
economy,  many  IAS  also  facilitate  the  outbreak  and 
spread of infectious diseases, posing a threat to humans 
and wildlife.  
The  implementation  of  the  EU  Invasive  Alien  Species 
Regulation  and  other  relevant 
legislation  must  be 
stepped up.  
The  biodiversity  strategy  for  2030  aims  to  manage 
recognised  invasive  alien  species  and  decrease  the 
number of ‘red list’ species they threaten by 5050%. 

The core of Regulation (EU) 1143/2014 on IAS57 (the IAS 
Regulation) is the list of IAS of Union concern. 

The total number of IAS of Union concern is currently 66, 
of which: 30 are animal species; 36 are plant species; 41 
are  primarily  terrestrial  species;  23  are  primarily 
freshwater species; 1 is a brackish-water species; and 1 is 
a marine species. 

According to a 2021 review58 of the application of the IAS 
Regulation, implementation of the Regulation is already 
starting  to  deliver  on  its  objectives.  These  objectives 
include a consistent framework for addressing IAS at EU 
level and increased awareness of the IAS problem. At the 
same  time,  the  review  identified  some  challenges  and 
areas  for  improvement.  Given  that  the  deadlines  for 
implementing  the  different  rules  of  the  IAS  Regulation 
were between July 2016 and July 2019, it is  to early to 
draw  conclusions  on  many  aspects  of  the  Regulation’s 
implementation. 

The review also shows that of the 66 species on the EU 
list, 44 have been observed in the environment in France. 
The geographical spread can be seen in Figure 13. 

706 

final 

Annexes 

COM(2021) 

products  associated  with  deforestation  and  forest  degradation  and 
repealing, COM_2021_706_1_EN_ACT_part1_v6 (1).pdf. 
56 
1 
COM_2021_706_1_EN_annexe_proposition_part1_v4 (1).pdf. 
57 Regulation (EU) No 1143/2014. 
58  Report  from  the  Commission  to  the  European  Parliament  and  the 
Council  on  the  review  of  the  application  of  Regulation  (EU)  No 
1143/2014  of  the  European  Parliament  and  of  the  Council  of  22 
October 2014 on the prevention and management of the introduction 
and spread of invasive alien species, COM(2021) 628 final, 13.10.2021. 

to 

2, 

Environmental Implementation Review 2022 – France 

 
 
 
 
                                                                 
 
Figure 13: Number of IAS of EU concern, based on 
available georeferenced information for France, 2021 

  Take  the  necessary  steps  to  fully  comply  with  the 
requirements  specified  in  Article  13  of  the  IAS 
Regulation. 

Marine ecosystems 

France  15 

The  EU  Biodiversity  Strategy 
for  2030  aims  to 
substantially  reduce  the  negative  impacts  on  sensitive 
species  and  habitats  in  marine  ecosystems  and  to 
achieve good environmental status as well as eliminate 
or 
incidental  catches  of  protected, 
endangered, threatened and sensitive species to a level 
that allows species recovery and conservation51.  

reduce 

the 

The  Marine  Strategy  Framework  Directive  (MSFD) 
requires Member States to achieve good environmental 
status  (GES)  for  their  marine  waters.  To  that  end, 
Member States must draw up marine strategies for their 
marine  waters,  and  cooperate  with  Member  States 
sharing  the  same  marine  region  or  subregion.  These 
marine  strategies  comprise  different  steps  to  be 
developed and implemented over 6-year cycles. 

The MSFD also required Member States to draw up a set 
of  GES  characteristics  for  each  qualitative  descriptor59 
(Article  9)  and  to  provide  an initial  assessment  of  their 
marine  waters  (Article  8)  by  15  October  2018.  The 
Commission  then  assesses  whether  this  constitutes  an 
appropriate framework to meet the requirements of the 
Directive. 

The Commission assessed France’s 2018 determinations 
of  GES  for  each  of  the  MSFD’s  11  descriptors60  and 
determined how adequate they were  in relation to the 
Commission  Decision  on  criteria  and  methodological 
standards  for  GES  in  marine  waters61.  A  good  or  very 
good score in the Commission assessment indicates that 
the national determinations of GES are well aligned with 
the requirements of the Commission GES Decision, and 
provide 
national 
and 
environmental objectives to be achieved for their marine 
waters. 

quantitative 

qualitative 

An infringement case is ongoing against France because 
it had failed to establish and implement any action plan 
fulfilling  the  requirements  under  Article  13  of  the  IAS 
Regulation by 13 July 2019. 

France  has  been  very  late 
in  complying  with  the 
obligation  to  adopt  the  list  of  IAS  in  the  outermost 
regions (the last list was only adopted in 2021). 

The results of the biogeographical assessment show that 
no  progress  has  been  made  to  maintain  or  restore 
favourable  conservation  status  of  species  and  habitats 
compared to the 2019 EIR. 

2022 priority actions 

  Address the SACs and the conservation status by: (i) 
completing  Natura  2000  designation  (especially  at 
sea); (ii) better define theconservation objectives in 
the  Natura  2000  sites;  and  (iii)  comply  with  the 
Natura 2000 rules against deterioration. 
Improve protection of species, especially cetaceans, 
huntable  birds  and  farmland  birds,  and 
large 
carnivores. 

 

59  The  Marine  Strategy  Framework  Directive’s  descriptors  are  eleven 
qualitative descriptors stes out in Annex I of the Directive and which 
describe  what  the  environment  will  look  like  when  GES  has  been 
achieved. These descriptors help Member States interpret what Good 
Environmental Status (GES) under the MSFD means in practice. 

60  Annex  I  of  Directive  2008/56/EC  establishing  a  framework  for 
community action in the field of marine environmental policy (Marine 
Strategy Framework Directive), OJ L 164, 25.6.2008, p. 19–40. 
61  This  assessment  was  made  in  relation  to  the  Commission  GES 
Decision, Commission Decision No 2017/848, pp. 43-74. 

Environmental Implementation Review 2022 – France 

 
 
 
 
 
                                                                 
 
 
Figure 14: Level of adequacy of GES determination by 
France (ANS, MWE, ABI and ACS regions) with criteria 
set under the Commission GES Decision – Article 9 
(2018 reporting exercise)62 

France  16 

good or very good. The national determination of GES 
by France is coherent for 5 out of 11 descriptors. 

  ACS-NE  Atlantic 

(Celtic  Sea):  5  out  of  11 
determinations of GES were assessed as good or very 
good. The national determination of GES by France is 
coherent for 5 out of 11 descriptors. 

The  MSFD  also  requires  Member  States  to  make  an 
assessment of the current environmental status of their 
marine waters in relation to the determination of GES. A 
good  or  very  good  score  indicates  that  the  Member 
States  have  good  capabilities  to  assess  their  marine 
environment in line with the requirements set out in the 
Commission GES Decision. 

Figure 15: Level of adequacy of national assessment of 
France’s marine environment (ANS, MWE, ABI and ACS 
regions) with criteria set under the Commission GES 
Decision – Article 8 (2018 reporting exercise)63 

France has four marine sub-regions. 

  ANS-NE Atlantic (Great North Sea): in this marine sub-
region,  6  out  of  11  determinations  of  GES  were 
assessed  as  good  or  very  good.  The  national 
determination of GES by France is coherent for 6 out 
of 11 descriptors. 

  MWE-Mediterranean (Western Mediterranean Sea): 
6 out of 11 determinations of GES were assessed as 
good or very good. The national determination of GES 
by France is coherent for 6 out of 11 descriptors. 
  ABI-NE  Atlantic  (Bay  of  Biscay  and  Iberian  Coast):  5 
out  of  11  determinations  of  GES  were  assessed  as 

62 Assessment carried out by the Commission of the data reported by 
Member States, January 2022. Please note that only two sub-sections 
of descriptor D1 are displayed (D1-M Mammals and D1-B Birds). For the 

analysis,  these  two  sub-sections  were  considered  as  a  whole  after 
averaging them. 
63 See previous footnote. 

Environmental Implementation Review 2022 – France 

 
 
 
 
                                                                 
 
 
 
 
 
In ANS-NE Atlantic (Great North Sea), 9 descriptors out of 
11  were  scored  as  good  or  very  good.  France’s 
assessment  of its marine environment  is coherent  with 
requirements  set  out  under  the  Commission  GES 
Decision for 9 out of 11 descriptors. 

In MWE-Mediterranean (Western Mediterranean Sea), 9 
descriptors out of 11 were scored as good or very good. 
France’s  assessment  of 
is 
coherent  with  requirements  set  under  the  Commission 
GES Decision for 9 out of 11 descriptors. 

its  marine  environment 

In  ABI-NE  Atlantic  (Bay  of  Biscay  and  Iberian  Coast),  8 
descriptors out of 11 were scored as good or very good. 
France’s  assessment  of 
is 
coherent  with  requirements  set  under  the  Commission 
GES Decision for 8 out of 11 descriptors. 

its  marine  environment 

In  ACS-NE  Atlantic  (Celtic  Sea),  7  descriptors  out  of  11 
were scored as good or very good. France’s assessment 
of its marine environment is coherent with requirements 
set under the Commission GES Decision for  7 out of 11 
descriptors. 

In the 2019 EIR, the Commission suggested that France: 
(i)  provides  more  information  about  its  measures  to 
achieve GES; (ii) draws up more measures with a direct 
impact  on  pressures;  and  (iii)  quantifies  the  expected 
reduction  of  pressure  as  a  result.  The  Commission  also 
recommended  that  France  should  ensure  reporting  of 
the  different  parts  of  the  Marine  Strategy  Framework 
Directive. 

Furthermore, in March 2022, the Commission published 
a  Communication  with  recommendations  for  Member 
States.  The  Commission’s  assessment  concludes  that 
Member  States  need  to  step  up  their  efforts  to 
determine  the  GES  and  the  use  of  the  criteria  and 
methodological standards according to the Commission 
GES  Decision.  The  above  considerations  form  the  basis 
for the 2022 priority actions. 

2022 priority actions 

  Ratify  the  Protocol  for  the  Protection  of  the 
Mediterranean  Sea  against  Pollution  Resulting  from 
the  Exploration  and  Exploitation  of  the  Continental 
Shelf  and  the  Seabed  and  its  Subsoil  (Offshore 
Protocol to the Barcelona Convention). 
Implement  the  Commission’s  recommendations  on 
preparing marine strategies, including assessing, and 
determining  good  environmental  status  and  setting 
environmental targets. 

 

France  17 

  Ensure  regional  cooperation  with  Member  States 
sharing  the  same  marine  sub-region  to  address 
predominant pressures. 

Ecosystem assessment and accounting 

The  EU  biodiversity  strategy  for  2030  calls  on  Member 
States to better integrate biodiversity considerations into 
public and business decision making at all levels and to 
develop  natural  capital  accounting.  The  EU  needs  a 
better performing biodiversity observation network and 
more  consistent 
the  condition  of 
reporting  on 
ecosystems. 

The  biodiversity  information  system  for  europe  (BISE) 
provides  information  on  progress  by  Member  States  in 
ecosystem  assessment  and  accounting64.  The  French 
national  ecosystem  assessment 
is  a  science-policy-
society  platform  (Evaluation  française  des  écosystèmes 
et  des  services  écosystémiques  or  EFESE)  led  by  the 
Ministry of Ecological Transition.  In a first phase (2012-
2018),  an  overall  assessment  of  the  six  major  French 
ecosystems was published. A final report was published 
in October 202065. EFESE also has its own social network 
that allows interaction within the community involved in 
ecosystem assessments in France66. 

in  ecosystem  mapping  and 
To  assess  progress 
assessment, the Commission sends out a  questionnaire 
twice  a  year  containing  27  implementation  questions. 
France has provided updated information, and progress 
has  been  recorded  since  January  2016  (see  Figure  16). 
This  assessment 
implementation 
is  based  on  27 
questions and updated every six months. 

Figure 16: ESMERALDA MAES barometer, January 2016 
- March 202167 

To assess progress on the implementation of ecosystem 
accounting,  the  Commission  conducts  a  survey  of 
Member  States  every  x  year  by  sending  out  a  survey 

64 https://biodiversity.europa.eu/countries/ 
65 French national ecosystem assessment (available in French). 
66 EFESE programme webpage. 

67 European Commission, Joint Research Centre, Publication Office, EU 
Ecosystem assessment: summary for policymakers, p. 80, May 2021. 

Environmental Implementation Review 2022 – France 

 
 
                                                                 
 
 
 
 
France  18 

containing 13 questions (see Figure 17). In the ecosystem 
accounting  barometer,  France  is  in  the  group  of  less 
advanced countries and ranks third. 

Figure 17: Ecosystem accounting barometer, 
September 202168 

indicators  for 

integrating  ecosystem 
appropriate 
extent,  condition  and  services  (including  some 
monetary values) into national accounts. 

  Continue  supporting  the  development  of  national 
including 
business  and  biodiversity  platforms, 
natural-capital  accounting  systems  to  monitor  and 
value the impact of business on biodiversity. 

In  France,  there  is  a  lot  of  interest  in  biophysical  and 
economic  accounts.  A  methodological  framework  has 
been developed by the government to create the marine 
ecosystem  extent,  condition  and  monetary  asset 
accounts.  A  national  forest  ecosystem  monetary  asset 
account  has  been  developed  and  a  cultural  ecosystem 
supply and use account in monetary terms has also been 
developed  at  local  level.  In  addition,  a  theoretical 
framework is under development to calculate the unpaid 
ecological cost of an ecosystem. 

Data  gaps  in  France  mainly  concern:  (i)  marine  and 
coastal habitats; and (ii) the overseas territories. The first 
suffers  from  infrequent  and  inconsistent  data  affecting 
both  extent  and  condition  accounts,  while  the  second 
lacks data overall except for coral reefs. The account for 
unpaid  ecological  cost  still  needs  conceptual  and 
technical refinements to become operational. 

the  MSFD69,  while 

As  highlighted  in  the  Commission’s  report  on  the 
implementation  of 
regional 
cooperation  has  improved  since  the  adoption  of  the 
MSFD, more cooperation is needed so that the regional 
marine  strategies  are  consistent  with  each  other,  as 
required by the Directive. 

2022 priority actions 

  Continue supporting the mapping and assessment of 
ecosystems and their services, and the development 
of ecosystem accounting This should be done through 

68  MAIA  Portal,  Mapping  and  assessment  for  Integrated  Ecosystem 
Accounting (EU Horizon 2020 project), 2022. MAIA uses the System of 
Environmental  Economic  Accounting  –  Experimental  Ecosystem 
Accounting  (SEEA-EEA)  as  the  methodological  basis  for  ecosystem 

accounting. The SEEA EA is an integrated and comprehensive statistical 
framework,  which  is  based  on  five  core  accounts:  ecosystem  extent, 
condition, services and monetary ecosystem asset. 
69 COM(2020)259. 

Environmental Implementation Review 2022 – France 

 
 
 
 
 
                                                                 
 
 
 
France  19 

3. Zero pollution

Clean air 

its 

EU  clean-air  policies  and  legislation  need  to  significantly 
improve air quality in the EU, moving the EU closer to the 
quality recommended by the WHO and curbing emissions 
of key air pollutants. 
Air  pollution  and 
impacts  on  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 
clean-air  legislation  and  defining  strategic  targets  and 
actions for 2030 and beyond. 
The 2030 zero-pollution action-plan targets are to reduce 
the health impacts of air pollution by 55% and to reduce 
the  EU  ecosystems  threatened  by  air  pollution  by  25%, 
compared to 2005. 

The EU has developed a comprehensive suite of clean air 
legislation, which sets health-based air quality standards70 
and emissions reduction commitments by Member State 
for a number of air pollutants71. 

At the same time, air quality in France continues to give 
cause  for  serious  concern.  The  latest  available  annual 
estimates  (for  2019)  by  the  European  Environment 
Agency72  point  to  France  suffering  about  29  800 
premature  deaths  (or  354  100  years  of  life  lost  (YLL)) 
attributable to fine particulate matter concentrations73,2 
050 premature deaths each year (25 800 YLL) attributable 
to ozone concentration  74  and 4970 premature deaths  a 
year  (59  100  YLL)  attributable  to  nitrogen  dioxide 
concentrations75 76. 

The  emissions  of  several  air  pollutants  have  decreased 
significantly in France in recent years, while GDP growth 
has continued (see Figure 18). According to the latest air 
pollutant emission projections as submitted under Article 
10(2)  of  the  National  Emission  Reduction  Commitments 
Directive  (NECD)77,  France  projects  that  it  will  reach 
emissions  reduction  commitments  for  all  air  pollutants 
covered under the Directive for 2020-2029 and for most 
pollutants for 2030 onwards. The projections however do 
not show reaching emissions reduction commitments for 
NH3 for  2030 onwards. Latest data  submitted by France, 
before the Commission’s review, indicate that the country 

70 European Commission, 2016. Air Quality Standards. 
71 European Commission, Reduction of National Emissions. 
72 European Environment Agency, Air Quality in Europe – 2021 Report. 
Please  see  details 
in  this  report  as  regards  the  underpinning 
methodology, p.106. 
73  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. 
74 Low-level ozone is produced by photochemical action on pollution. 

complied with the emission reduction commitments for all 
pollutants in 2020. 

France  submitted 
programme to the Commission on 9 October 2019. 

its  national  air  pollution  control 

Figure 18: Emission trends of main pollutants/ GDP 
2005-2019 in France78 

75 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). 
76  Please  note  that  these  figures  refer  to  the  impacts  of  individual 
pollutants, and to avoid double-counting cannot be added up to derive a 
sum. 
77 Directive 2016/2284/EU. 
78 European Environment Agency. 

Environmental Implementation Review 2022 – France 

 
                                                                 
 
 
Figure 19: PM2.5 and NOx emissions by sector in France, 
201979 

In  2020,  exceedances  above  the  limit  values  set  by  the 
Ambient Air Quality Directive were registered for nitrogen 
dioxide (NO2) in two air quality zones and of sulfur dioxide 
(SO2)  in  one  zone.  Furthermore,  for  several  air  quality 
zones,  the  target  values  for  ozone  concentrations  have 
also not been met80. 

Persistent  breaches  of  air  quality  requirements,  which 
have severe negative effects on health and environment, 
are being followed up closely by the Commission through 

France  20 

infringement  procedures  (mainly  for  PM10  and  NO2 
exceedances)  covering  all  Member  States  concerned, 
including France. 

For exceedances of NO2 limit values, the Court of Justice 
of  the  European  Union  (CJEU)  delivered  a  judgment81 
confirming non-compliance with Directive 2008/50/EC in 
12 air quality zones and urban areas (agglomérations)82. In 
December  202083,  France  was  urged  to  execute  this 
judgment  by  taking  and  implementing  all  the  required 
measures to remedy the situation in order to ensure that 
the period of exceedance would be as short as possible. If 
France fails to do so, the Commission may refer the case 
back to the CJEU and propose financial penalties. 

For  exceedances  of  PM10  limit  values,  the  Commission 
decided84 to refer France to the CJEU in October 2020. The 
aim  of  this  legal  action  is  to  put  in  place  appropriate 
measures  that  are  implemented  swiftly,  bringing  all  air 
quality zones into compliance with EU standards. 

2022 priority actions 

  As part of its national air pollution control programme 
(NAPCP),  take  action  to  reduce  emissions  from  the 
main emission sources. 

  Ensure  full  compliance  with  EU  air  quality  standards 
and  maintain  downward  emissions  trends  for  air 
pollutants to reduce adverse air pollution impacts on 
health and the economy, with a view to reaching WHO 
guideline values in the future. 

  Acclerate  ratification  of  the  amended  Gothenburg 
Protocol  under  the  UN  Economic  Commission  for 
Europe Air Convention. 

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;  
(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 

79 European Environment Agency. 
80 European Environment Agency, Eionet Central Data Repository. 
81 C-636/18; COM vs France. 
82 These zones and urban areas are: Marseille, Toulon, Paris, Clermont-
Ferrand, Montpellier, Toulouse, Reims, Grenoble, Strasbourg, Lyon, Nice 

and the former Vallée de l'Arve Rhône-Alpes (now two distinct zones : 
Vallée de l'Arve and Vallée du Rhône). 
83 December_infringements_package__key_decisions_.pdf 
84 See previous footnote. 

Environmental Implementation Review 2022 – France 

 
 
 
 
                                                                 
 
 
France  21 

Figure 20: Number of IED industrial installations per 
sector in France, 201888 

Industrial  Emissions  Directive  (IED)85.  The  Commission 
tabled a proposal  in April  202286. The revision seeks to 
improve the Directive’s contribution to the zero-pollution 
objective, as well as its consistency with climate, energy 
and circular-economy policies. 

The overview of industrial activities regulated by the IED 
below  is  based  on  data  reported  to  the  EU  registry 
(2018)87. 

industrial 

In  France,  around  6 850 
installations  are 
required  to  have  a  permit  based  on  the  IED.  This 
represents  an  increase  of  about  450  installations  since 
2015, mainly in the waste management sector and in the 
intensive  rearing  of  poultry  and  pigs.  The  distribution  of 
installations is shown in Figure 19. 

The  industrial  sectors  in  France  with  the  most  IED 
installations  in  2018  were:  (i)  the  intensive  rearing  of 
poultry and pigs (48%); (ii) the waste management sector, 
including  landfills  (15%);  (iii)  the  food  and  drink  sector 
(12%); (iv) the production and processing of metals (9%); 
and (v) the chemical sector (7%). 

The industrial sectors identified as contributing the largest 
burden to the environment for emissions to air were: 

 

 

 

the  energy  sector  for  sulfur  oxides  (SOx),  nitrogen 
oxides (NOx), nickel (Ni) and mercury (Hg); 
the production and processing of metals (in particular 
iron  and  steel)  for  lead  (Pb),  arsenic  (As);  cadmium 
(Cd), chromium (Cr); 
the waste management  sector for Particulate Matter 
(PM2.5) and dioxins (PCDD/F); 
 
intensive rearing of poultry or pigs for Ammonia (NH3); 
  surface treatment and the food, drink and milk sector 
for  non  methane  volatile  organic  compounds 
(NMVOCs). 

The breakdown is shown in the Figure 21. 

In particular, in 2017, two installations for producing and 
processing ferrous metals (ArcelorMittal in Dunkirk and in 
Fos-sur-Mer) were among the top 30 European Pollutant 

parallel to the revision of Regulation (EC) No 166/2006 on the European 
Pollutant Release and Transfer Register (E-PRTR). 
87 European Environment Agency, European Industrial Emissions Portal. 
88  European  Environment  Agency,  EU  Registry,  European  Industrial 
Emissions Portal (data retrieved on 3 November 2021). 

85  Directive  2010/75/EU  covers  industrial  activities  carried  out  above 
certain thresholds. It covers the energy industry, metal production, the 
mineral and chemical industry, waste management, and a wide range of 
industrial  and  agricultural  sectors  (e.g.  intensive  rearing  of  pigs  and 
poultry, pulp and paper production, painting and cleaning). 
86  European  Commission,  proposal  for  a  revision  of  the  Industrial 
Emissions Directive, 4 April 2022. The revision of the IED is performed in 

Environmental Implementation Review 2022 – France 

 
 
                                                                 
 
 
 
France  22 

Release and Transfer Register (E-PRTR) facilities with the 
highest absolute damage costs from emissions of the main 
air pollutants and greenhouse gases89. 

Figure 22: Relative releases to water from industry in 
France, 201891 

Figure  21: Emissions to air from IED sectors and rest of 
national total air emissions in France, 201890 

The  EU  approach  to  enforcement  under  the  IED  creates 
strong  rights  for  the  public  to  have  access  to  relevant 
information  and  to  participate  in  the  permitting  process 
for potentially polluting installations. This empowers the 
public and NGOs to ensure that permits are appropriately 
granted and the conditions of these permits are complied 
with.  As  part  of  environmental  inspection,  competent 
authorities carry out site visits to IED installations to take 
samples and to gather necessary information. In line with 
Article  23(4)  of  the  IED,  site  visits  must  be  carried  out 
between once a year and once every 3 years, depending 
on the environmental risks posed by the installations. In 
2018  France  carried  out  4  222  site  visits.  The  largest 
number of visits were to the waste sector (25% of visits), 
the  intensive  rearing  of  poultry  or  pigs  (23%)  and  the 
chemical sector (17%).  

The  environmental  burdens  for  industrial  emissions  to 
water mainly result from: (i) the chemical sector and the 
metal  sector  for  heavy  metals;  (ii)  from  the  chemical 
sector for total nitrogen; (iii) production of pulp and paper 
for  total  organic  carbon  (TOC);  (iv)  the  food  and  drink 
sector for total phosphorus. 

The  breakdown,  based  on  E-PRTR  data,  is  presented  in 
Figure 22. 

89 European Environment Agency, Costs of air pollution from European 
industrial facilities 2008–2017. Eionet Report - ETC/ATNI 2020/4, 2021. 
The ranking is based on the approach accounting for the value of a life 
year (VOLY), table 41, p.125 and table 44, p.141. 
90  European  Environment  Agency,  LRTAP,  Air  pollutant  emissions  data 
viewer (Gothenburg Protocol, LRTAP Convention) 1990-2019. 

91 European Environment Agency, E-PRTR, European Industrial Emissions 
Portal. The heavy metals are presented both as a weighted sum of eco 
toxicity and human toxicity factors to illustrate both the ecological and 
human impact (based on USEtox). 

Environmental Implementation Review 2022 – France 

 
 
 
 
 
                                                                 
 
 
Figure 23: Number of inspections of IED installations in 
France in 201892 

The  development  of  best  available  techniques  (BAT) 
reference  documents  (BREFs)  and  BAT  conclusions 
ensures  good  collaboration  between  stakeholders  and 
enables better implementation of the IED93. Since the last 
EIR report, the Commission adopted BAT conclusions for: 
(i)  waste  incineration;  (ii)  for  the  food,  drink  and  milk 
industries;  (iii)  surface  treatment  using  organic  solvents 
including  wood  and  wood  products  preservation  with 
chemicals. 

The  Commission  relies  on  the  efforts  of  national 
competent  authorities  to  implement  the  legally  binding 
BAT  conclusions  and  associated  BAT  emission  levels  in 
environmental permits. This should result in considerable 
and continuous reductions in pollution. 

In  2019,  France  received  priority  actions  to:  (i)  review 
permits to comply with newly adopted BAT  conclusions; 
and (ii) strengthen monitoring and enforcement to ensure 
compliance  with  BAT  conclusions.  These  actions  have 
been  followed  up  by  the  Commission  through  the 
reporting  by  France  to  the  EU  registry.  The  Commission 
also followed no non-compliant permits reported in 2018. 

2022 priority action 

  Address  pollution 

from  metal  production  and 

processing. 

Preventing major industrial accidents – Seveso 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to: 
(i)  control  major  accident  hazards  involving  dangerous 

France  23 

substances, especially chemicals; 
(ii)  limit  the  consequences  of  such  accidents  for  human 
health and the environment; 
(iii)  continuously  improve  prevention,  preparedness  and 
response to major accidents. 
The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso-III Directive)94. 

The below overview of industrial plants regulated by  the 
Seveso III Directive (‘Seveso establishments’), is based on 
data  reported  to  the  eSPIRS  database  (2018)95  and  the 
France  report  on  the  implementation  of  the  Seveso  III 
Directive for 2015-201896. 

In  France,  of  the  1  295  Seveso  establishments,  617  are 
categorised  as  lower-tier  establishments  and  678  as 
upper-tier establishments (UTEs), based on the quantity of 
hazardous  substances  likely  to  be  present  in  them.  The 
UTEs  are  subject  to  more  stringent  requirements.  The 
change 
is 
presented in Figure 24. 

in  the  number  of  Seveso  establishments 

Figure 24: Number of Seveso establishments in France, 
2011, 2014 and 201897 

Many  Seveso  establishments  are  required  to  draw  up 
external emergency plans (EEPs). These EEPs are essential 
to allow proper preparation and effective implementation 
of the necessary actions to protect the environment and 
the population should a major industrial accident occur at 
them.  According  to  France,  an  EEP  is  required  for  641 
UTEs. In 2018, 619 UTEs had an EEP, and 532 of these EEPs 
had  been  tested  over  the  last  3  years.  The  summary  of 
EEPs in France is shown in Figure 25. 

92  European  Environment  Agency,  EU  registry,  European  Industrial 
Emissions Portal. 
93 European Commission, BAT reference documents. 
94 Directive 2012/18/EU on the control of major-accident hazards 
involving dangerous substances. 
95 European Commission, Seveso Plants Information Retrieval System. 

96 As provided for under Article 21(2) of the Seveso III Directive. 
97 European Commission, Assessment and summary of Member States’ 
implementation  reports  for 
Implementing  Decision  2014/896/EU 
(implementing  Directive  2012/18/EU  on  the  control  of  major  accident 
hazards involving dangerous substances), 2022. 

Environmental Implementation Review 2022 – France 

 
 
 
 
 
                                                                 
 
 
 
Figure 25: Situation regarding EEPs in France, 201898 

The  following  types  of  information  are  permanently 
available for 100% of the Seveso establishments in France: 
(i) information to the public referred to in Annex V of the 
Seveso  III  Directive  especially  about  how  the  public 
concerned will be warned if there is a major accident; (ii) 
information about appropriate behaviour in the event of a 
major accident; and (iii) information contraining the date 
of the last site visit. 

The  share  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  were  actively  made 
available  to  the  public  in  recent  years  are  presented  in 
Figure 26. 

Figure 26: Share of UTEs for which information on safety 
measures and requisite behaviours were actively made 
available to the public in France – 2011, 2014 and 201899 

France  24 

turned  into  national  legislation  has  been  assessed,  and 
there  is  currently  an  ongoing  infringement  case  on  the 
information  that  should  be made  available  to  the  public 
and howthe public should be consulted. 

2022 priority action 

  Strengthen  monitoring  and  enforcement  to  ensure 
compliance  with  Seveso  III  Directive  rules,  especially 
on EEPS and information to the public. 

Noise 

The  Environmental  Noise  Directive100  provides  for  a 
common  approach  to  avoid,  prevent  and  reduce  the 
harmful  effects  of  exposure  to  environmental  noise, 
although  it  does  not  set  noise  limits  as  such.  The  main 
instruments  it  uses  in  this  respect  are  strategic  noise 
mapping  and  planning.    A  relevant  2030  zero  pollution 
action  plan  target  is  a  reduction  by  30%  of  the  share  of 
people chronically disturbed by transport noise compared 
to 2017.  

Excessive noise from aircraft, railways and roads is one of 
the main causes of environmental health‐related issues in 
the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress101. 

is  estimated  to  cause  at 

In France, based on a limited set of data102, environmental 
noise 
least  around  1500 
premature  deaths  and  7500  cases  of  ischemic  heart 
disease  annually103.  Moreover,  some  1.2  million  people 
suffer  from  disturbed  sleep.  The  overall  noise  exposure 
was  15.5  million  people  in  2012,  the  latest  year  with 
almost complete data. 

On the basis of the latest full set of information analysed, 
noise  mapping  of  urban  areas,  roads  and  railways  is 
complete.  In  the  2019  EIR,  France  received  a  priority 
action  to  complete  noise  action  plans,  where  there  has 
been  limited  progress  as  detailed  above.However,  the 
country still lacks action plans for many urban areas and 
major  roads.  The  noise  maps  and  action  plans,  to  be 
adopted  after  a  public  consultation,  should 
include 
measures to keep noise at low levels or reduce it. 

The conformity on how the Seveso III Directive has been 

98 See previous footnote. 
99 See previous footnote. 
100 Directive 2002/49/EC 
101 WHO 2018, Environmental Noise Guidelines for the European Region. 
102  For  further  information:  European  Environment  Agency,  Noise  Fact 
Sheets 2021. 
103  These  figures  are  an  estimation  by  the  European  Environmental 
Agency  based  on:  (i)  the  data  reported  by  Member  States  on  noise 

exposure  covered  by  Directive  2002/49/EC;  (ii)  ETC/ATNI,  2021,  Noise 
indicators under the Environmental Noise Directive 2021: Methodology 
for  estimating  missing  data,  ETC/ATNI  Report  No  2021/06,  European 
Topic Centre on Air Pollution, Transport, Noise and Industrial Pollution; 
and (iii) the methodology for health impact calculations, ETC/ACM, 2018, 
Implications of environmental noise on health and wellbeing in Europe, 
Eionet  Report  ETC/ACM  No  2018/10,  European  Topic  Centre  on  Air 
Pollution and Climate Change Mitigation. 

Environmental Implementation Review 2022 – France 

 
 
 
 
 
 
                                                                 
 
 
 
2022 priority action 

  Complete action plans for noise management in urban 

areas and around major roads. 

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. 

Water Framework Directive 

is 

(WFD)104 

the 
The  Water  Framework  Directive 
cornerstone of EU water policy in the 21st century105. The 
legislation106  set  the 
WFD  and  other  water-related 
framework 
integrated  water 
sustainable  and 
management, which aims at a high level of protection of 
water resources, prevention of further deterioration and 
restoration to good status. 

for 

By  March 2022, all  Member  States  had to  report on  the 
third  round  of  river  basin  management  plans  (RBMP). 
France has done it on time. Member States were required 
under the WFD to draw up river basin management plans 
for all river basins on their territory. The Commission will 
now  assess  the  reported  status  of  river  basins  and 
progress  made  in  these  river  basins,  checking  how  the 
findings identified in the Commission’s assessment of the 
second round of RBMPs107 have been addressed. 

which 

Report108, 

The  Commission  published  in  December  2021  the  6th 
Implementation 
assesses 
implementation of the WFD and the Floods Directive. This 
report includes an interim assessment on progress of the 
implementation  of  the  programmes  of  measures  and 
monitoring  of  new  priority  substances.  The  assessment 
report for France109 showed that all 14 river basin districts 
(RBDs)  had  implemented  numerous  measures  since  the 
in  2015. 
adoption  of  the  programme  of  measures 

France  25 

Furthermore,  all  French  RBDs  have  reported  decreasing 
gaps  from  2015  to  2021.  There  were  also  no  indicators 
that show increases in the gap to meet the objectives for 
any  RBD.  The  reported  information  on  key  types  of 
measures makes it possible to clarify the main pressures 
targeted  by  each  type  of  measure  for  all  French  RBDs. 
However,  only  indicator  values  have  been  presented  for 
2018; – no quantitative values were provided for 2021 and 
2027, thus a trend analysis was not possible. 

Based on the second round of  RBMP reporting and data 
published  in  2020110, only  44.2% of  all  French  surface 
water  bodies  have  reached  good  ecological  status  (with 
only 0.4% of surface water bodies having unknown status), 
and 62.9% have good chemical status (with 21.2% having 
unknown status). For groundwater, 30.9% of groundwater 
bodies failed to achieve good chemical status, and 10.2% 
are in poor quantitative status. 

Figure  27  illustrates  the proportion  of  surface  water 
bodies in France and other European countries that failed 
to achieve good ecological status. 

Figure 27: Proportion of surface water bodies (rivers, 
lakes, transitional waters and coastal waters) in less 
than good ecological status per river basin district111 

Figure 28 presents the percentage of surface water bodies 
in France and other European countries failing to achieve 
good  chemical  status.  For  France,  this  is  15.9%  if  one 

104 The Water Framework Directive (2000/60/EC). 
105 The EU Water Policy. 
106  This 
includes  the  Groundwater  Directive  (2006/118/EC),  the 
Environmental  Quality  Standards  Directive  (2008/105/EC),  the  Floods 
Directive  (2007/60/EC),  the  Bathing  Water  Directive  (2006/7/EC),  the 
Urban Waste Water Treatment Directive (91/271/EEC), the new Drinking 
Water  Directive  (2020/2184/EC),  the  Nitrates  Directive  (91/676/EEC), 
the  Marine  Strategy  Framework  Directive  (2008/56/EC),  the  Industrial 
Emissions Directive (2010/75/EU), and the new Regulation on minimum 
requirements for water reuse (2020/741). 

107  Detailed  information  can  be  found  in  the  5th  Report  from  the 
Commission on the implementation of the Water Framework Directive 
and the Floods Directive, as well as in the 2019 EIR. 
108 See the 6th Implementation Report of the WFD and Floods Directive. 
109  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Member  States’  progress  in  Programmes  of  Measures 
during  the  second  planning  cycle  of  the  Water  Framework  Directive. 
Member State: France, 2022. 
110 WISE Freshwater (europa.eu). 
111 European Environment Agency, 2021. 

Environmental Implementation Review 2022 – France 

 
 
                                                                 
 
 
 
France  26 

includes water bodies failing due to substances behaving 
as ubiquitous PBTs (uPBTs – persistent, bio-accumulative, 
and  toxic).  Without  uPBTs,  3%  of  French  surface  water 
bodies fail to achieve good chemical status (with 21% of 
surface water bodies having unknown chemical status). 

Figure 28: Percentage of surface water bodies not 
achieving good chemical status112 

000  m3/year  (surface  water)  are  not  subject  to  any 
authorisation  or  declaration.  However,  the  competent 
authority  may  impose  any  measures  necessary  on  such 
abstractions 
in  order  to  prevent,  stop,  or  repair 
environmental damage whenever an incident or accident 
endangers  the  quality,  circulation  or  conservation  of 
water. 

Figure 29: Water abstraction by sector in France115 

Under  the  IED,France  showed  a  significant  decrease 
(81.8%)  over  the  last  decade  in  the  industrial  release  of 
heavy metals like Cd, Hg, Ni and Pb. It also saw a massive 
89.9%  decline  in  TOC  released  to  water  over  the  same 
period113. 

The  total  water  abstracted  annually  (corresponding  to 
2019  as  the  baseline  year)  in France  from  surface  and 
is  27  691.47  hm3  (European 
groundwater  sources 
Environment  Agency,  2022).  The  percentage  for  water 
abstraction per sector is 8.79% for agriculture, 19.14% for 
public  water  supply,  65.77%  for  electricity,  6.17%  for 
manufacturing  and  0.12%  for  mining  and  quarrying  (see 
Figure  29).  France  uses  a  register  to  monitor  water 
abstractions114.  The  register  of  protected  areas  covers 
drinking  water  abstraction  zones  of  >10m3/day  or 
supplying over 50 people, as well as zones identified for 
such a usage in future. Abstraction permits indicate their 
validity  duration,  and  single  abstraction  permits  (for 
agricultural irrigation in areas with a chronic lack of water 
in  relation  to  needs)  are  valid  for  up  to  15  years. 
Abstractions below 1 000 m3/year (groundwater) and 10 

In France, the water exploitation index plus (WEI+)116 was 
6.14% 
the  20% 
that is generally considered to indicate water scarcity. 

in  2017,  which 

than 

less 

is 

Figure  30  presents  the  WEI+  index  in France and  other 
European countries. France is ranked 10th in the EU on the 
WEI+ (with 1st indicating a country that has a high WEI+ 
and therefore a country with water-scarcity problems). 

Figure 30: Water exploitation index plus (WEI+) in the 
EU, 2017117 

112  European  Environment  Agency,  Water  bodies  Status  -  December 
2019. 
113 European Environment Agency, June 2021. 
114  Water  abstraction  registry  –  available  in  French:  Accueil  |  BNPE 
(eaufrance.fr). 
115  European  Environment  Agency,  Water  abstraction  by  source  and 
economic sector in Europe, 2022. 

116 The water exploitation index plus (WEI+) is a measure of total fresh 
water  use  as  a  percentage  of  the  renewable  fresh  water  resources 
(groundwater and surface water) at a given time and place. It quantifies 
how much water is abstracted and how much water is returned to the 
environment after use. 
117 European Environment Agency, Water exploitation index plus, 2022. 

Environmental Implementation Review 2022 – France 

 
 
 
 
                                                                 
 
 
 
 
 
 
Floods Directive 

Figure 31: Bathing water quality in Europe in the 2020 
season125 

France  27 

As  mentioned  earlier,  the  Commission  published 
in 
December  2021  the  6th  Implementation  Report,  which 
assesses  the  implementation  of  both  the  WFD  and  the 
Floods Directive. The report includes a review and update 
of  the  preliminary  flood  risk  assessments  drawn  up  by 
Member States during the second cycle (2016-2021). The 
report118 showed that a detailed review of past floods had 
been  carried  out,  and  a  common  methodology  was 
developed  at  national  level  and  applied  in  all  units  of 
management  in  a  relatively  uniform  way.  However,  it  is 
future  developments  are 
unclear  how 
considered. 

long-term 

The Commission will assess the progress made by France 
since  the  adoption  of  the  first  flood  risk  management 
plans and publish a report on this, as it did in 2019. 

Drinking Water Directive 

Figure 32: France, Bathing water quality 2017-2020126 

On the Drinking Water Directive119, no new assessment of 
the  quality  of  drinking  water  is  available  since  the  2019 
EIR. The quality of drinking water in France has not been 
indicated  as  an  area  of  concern.  However,  in  October 
2020, 
infringement 
procedure  against  France  because  the  limit  values  for 
nitrates have not been respected for several distribution 
units120. 

the  Commission 

launched  an 

The  recast  Directive121 entered  into  force  on  12  January 
2021, and Member States have until 12 January 2023 to 
turn it into national legislation. France will have to comply 
with these revised quality standards. 

Bathing Water Directive 

In 2020, 77.5% of French bathing waters were of excellent 
quality (see Figure 31)122. Detailed information on bathing 
waters  is  available  from  a  national  portal123  and  via  an 
interactive map of the European Environment Agency124. 
The trend between 2017 and 2020 is shown in Figure 32. 

Nitrates Directive 

According  to  the  last  implementation  report  on  the 
Nitrates  Directive127,  which 
2012-2015, 
groundwater  quality  in  France  has  slightly  improved 
the  previous  reporting  period.  The 
compared 

covers 

to 

118  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Second  Cycle  Preliminary  Flood  Risk  Assessments  and 
Identification of Areas of Potential Significant Flood Risk under the Floods 
Directive: Member State: France, 2022. 
119 OJ L 330, 5.12.1998, p. 32. 
120 October_infringements_package_key_decisions. 
121 OJ L 435, 23.12.2020, p. 1. 
122 European Environment Agency, 2021. French_bathingwater_country 
reports_2021. 
123 Ministère chargé de la santé - Bathing water quality (sante.gouv.fr). 

124  European  Environment  Agency,  State  of  bathing  waters  in  2020  — 
European Environment Agency (europa.eu). 
125 European Environment Agency, Bathing Water Quality in 2020, 2022. 
126  European  Environment  Agency,  European  Bathing  Water  Quality  in 
2017, 2018, 2019, 2020. 
127 Commission Report on the implementation of the Nitrates Directive 
for the period 2016-2019 - Staff Working Document accompanying the 
report  on  the  implementation  of  the  Nitrates  Directive  for  the  period 
2016-2019. 

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France  28 

percentage of stations reaching or exceeding 40 or 50 mg 
nitrate per litre that decreased from 23.91% to 21.4% and 
from 20.4% to 17.9% respectively. The situation on nitrate 
concentrations in surface water is rather good and stable, 
and  some  improvements  were  recorded  in  reducing  the 
eutrophication of surface water. 

An  infringement  procedure  is  ongoing  on  the  levels  of 
nitrates in French drinking water128. 

Urban Waste Water Treatment Directive 

In  recent  years,  France  had  difficulties  in  meeting  its 
obligations  under  the  Urban  Waste  Water  Treatment 
Directive  (UWWTD).  The  overall  compliance rate is  90%, 
which  is higher than the EU average in 2018129. 100% of 
urban waste water in France is collected, and 68.7% meets 
the requirements for biological treatment130. 

Figure 33: Proportion of urban waste water that meets 
all requirements of the UWWTD (collection, biological 
treatment, biological treatment with nitrogen and/or 
phosphorus removal) in compliant urban areas of the 
UWWTD (‘compliance rate’)131 

is not subject to the appropriate level of treatment before 
being discharged, and (ii) even if the appropriate level is 
applied,  treated  waste  water  does  not  meet  the 
Directive's requirements. Fifteen of these urban areas also 
fail  to  meet  additional  requirements  of  the  Directive  on 
protecting nutrient-sensitive areas. The French authorities 
have  shared  monitoring  data  that  aims  to  show 
compliance with the Directive for some of the urban areas 
identified  as  non-compliant.  However,  the 
initially 
remaining  deficiencies  and  gaps  led  the  Commission  to 
conclude that the French authorities have failed to comply 
for these urban areas. 

2022 priority actions 

  Assess new physical modifications  to water bodies in 
line with Article  4(7) of the  WFD.  These assessments 
should  consider  alternative  options  and  propose 
suitable mitigation measures. 

  Further improve water quality, in particular water that 
is polluted by nitrates in groundwater from agriculture. 
  Better  coordinate  implementation  of  water,  marine 

and nature policies. 

  Fully  implement  the  UWWTD  for  all  urban  areas,  by 

building up the necessary infrastructure. 

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 
effects on human health and the environment. In October 
2020, the Commission published its chemicals strategy for 
sustainability  -  'Towards  a  Toxic-Free  Environment'132 
which  led  to  some  systemic  changes  in  EU  chemicals 
legislation. The strategy is part of the EU's zero-pollution 
ambition  –  a  key  commitment  of  the  European  Green 
Deal. 

legislation133 provides  baseline 
The  EU’s  chemicals 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating within the single market. 

Since 2007, the Commission has gathered information on 
the  enforcement  of  the  Regulation  on  the  Registration, 
Evaluation,  Authorisation  and  Restriction  of Chemicals 
(‘the  REACH  Regulation’)  and 
the  Regulation  on 
Classification, Labelling and Packaging (‘CLP Regulation’). 
In  December  2020,  the  Commission  assessed  Member 
States’ reports of these Regulations134, in line with Article 

improvements 

In  recent  years,  there  have  been 
in 
compliance  with  the  UWWTD,  for  which  the  use  of  EU 
these 
funding  has  been  essential.  But  despite 
improvments,  the  incomplete  implementation  of  the 
Directive  has  led  to  several  rulings  of  the  CJEU  against 
France. 

In June 2021, the Commission decided to refer France to 
the  CJEU  for  failure  to  comply  with  the  requirements  of 
the  Urban  Waste  Water  Treatment  Directive  France 
should have been fully compliant with these requirements 
since  2005.  However,  more  than  100  urban  areas  with 
populations of over 2000 people are not campliant. This is 
because: (i) urban waste water entering collecting systems 

128 See footnote 129. 
129 WISE. 
130 See previous footnote. 
131 European Commission, WISE Freshwater, 2021. 

132 COM(2020) 667 final. 
133 REACH: OJ L 396, 30.12.2006, p.1. - CLP: OJ L 252, 31.12.2006, p.1. 
134 European Commission, Final Report, on the operation of REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu). 

Environmental Implementation Review 2022 – France 

 
 
 
 
 
                                                                 
 
 
France  29 

them out will meet three times a year to share good 
practices. 

Every  year,  the  Directorate-General  for  Competition, 
Consumer  Affairs  and  Fraud  Control  inspects  between  1 
000 and 1 300 sites and carries out between 180 and 200 
samples  for  the  REACH  and  CLP  regulations.  Chemical 
inspectors are  part  of  a  network that meets regularly. A 
review  of  the  network’s  activities  is  published  internally 
every  year.  As  a  rule,  any  infringement  of  the  REACH 
Regulation  is  categorised  as  a  serious  or  very  serious 
environmental administrative offence. If the infringement 
is serious enough, the competent authority may decide to 
impose  further  penalties  in  addition  to  a  fine.  The 
authority may also, where necessary, order the temporary 
seizure of assets and documents. 

In France, 20 specialised inspectors are allocated to REACH 
and CLP enforcement138. There were almost 4 000 REACH 
checks in the reporting period (2019), while the percentage 
of non-compliance cases out of the total number of REACH 
and CLP checks is almost in line with the EU average139. Most 
REACH checks are proactive ones (i.e. inspections), compared 
with 
investigations 
following  complaints,  accidents  and  referrals)127.  The 
percentage  of  non-compliance  cases  out  of  the  total 
number of checks is the same as the EU average. 

reactive/non-routine 

checks 

(i.e. 

117(1)  of  the  REACH  Regulation  and  Article  46(2)  of  the 
CLP  Regulation.  According  to  the  latest  available  data, 
national enforcement structures have not changed much 
in  recent  years.  However,  it  is  apparent  from  the  latest 
report in 2020 that there are still many disparities in the 
implementation  of  the  REACH  and  CLP  Regulations,  and 
notably  in  the  area  of 
law  enforcement.  Recorded 
compliance  levels  in  Member  States  seem  to  be  quite 
stable over time, but with a slight worsening trend, which 
is  likely  due  to:  (i)  enforcement  authorities  being  more 
effective in detecting non-compliant products/companies; 
and (ii) more non-compliant products being put on the EU 
market. 

In August 2021, the Commission published a  measurable 
assessment  of  the  enforcement135  of  REACH  Regulation 
and CLP Regulations using a set of indicators on different 
aspects of enforcement. 

Responsibility  for  checking  compliance  with  REACH  in 
France lies with the authorities136 listed below. 

  Ministry  of Ecological  Transition (Directorate-General 

for Risk Prevention and Local Services). 

  Ministry of Labour (Directorate-General for Labour and 

Local Services). 

  Ministry  of  Economy 

for 
Competition  Policy,  Consumer  Affairs  and  Fraud 
Control and Local Services). 

(Directorate-General 

  Ministry of Public Action and Accounts  (Directorate--
General Of Customs and Excise and Local Services). 

France  has  devised  and  fully  implemented  both  REACH 
and  CLP  enforcement  strategies137  with  the  features 
described below. 

  Each national enforcement authority develops its own 

strategy. 

  WEI+  strategies  can  be  on  REACH-EN-FORCE  or  pilot 

projects. 

  Annual  planning  and  evaluation  –  strategies  are 

revised based on an annual evaluation. 

  From 2016 onwards, 5% of inspections of installations 
classified  for  environmentalprotection  (installations 
classées pour la protection de l’environnement – ICPEs) 
will  include  a  chemical  products  check  and  200 
specialised  inspections.  These  inspections  cover  all 
(registration, 
aspects 
supply 
authorisation, 
information 
restrictions 
dissemination). The inspectors responsible for carrying 

chain 
and 

the 

of 

135  European  Commission,  REACH  and  CLP  enforcement:  EU  level 
enforcement indicators. 
136 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 69. 
137 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 76. 
138 European Commission, Final Report, on the operation of REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 74. 

139 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 87- p. 
88. 

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Figure 34: Percentage of non-compliance cases out of 
the total number of REACH and CLP checks during 2019 
per Member State and compared to the EU average140 

France  30 

2022 priority action 

  Upgrade  administrative  capacities  in  implementation 
and enforcement towards a policy of zero tolerance to 
instances of non-compliance. 

140 European Commission, Final Report, on the operation of REACH and 
CLP, pp.87-88, 2022. 

Environmental Implementation Review 2022 – France 

 
 
 
                                                                 
France  31 

4. Climate action

In  line  with  the  Paris  Agreement  and  as  part  of  the 
European Green Deal, the European Climate Law sets the 
EU  target  of  reaching  climate  neutrality  by  2050  and 
reducing greenhouse gas (GHG) emissions by 55% by 2030 
compared  to  1990.  The  law  also  limits  the  contribution 
that  carbon  removals  can  make  towards  emission 
reductions in 2030 to ensure a sufficient mitigation effort.  
The  EU  and  its  Member  States  submitted  updated 
Nationally Determined Contribution (NDC) to the UNFCCC 
in December 2020.  
The EU is working across all sectors and policies to cut GHG 
emissions  and  make  the  transition  to  a  climate-neutral 
and  sustainable  economy,  as  well  as  addressing  the 
unavoidable consequences of climate change.  
EU  climate  legislation  incentivises  emissions  reductions 
from power generation, industry, transport, the maritime 
sector and fluorinated gases (F-gases) used in products.  
For  road  transport,  EU  legislation  requires  the  GHG 
intensity  of  vehicle  fuels  to  be  cut  by  6%  by  2020 
compared  to  2010141  and  sets  binding  GHG  emission 
standards for different vehicle categories 142. 
Under the F-gas Regulation, the EU’s F-gas emissions will 
be cut by two thirds by 2030 compared with 2014 levels. 
From 2021, emissions and removals of GHGs from LULUCF 
have been included in the EU emission-reduction efforts.  
The  EU  adaptation  policy  is  an  integral  part  of  the 
European  Green  Deal.  From  2021,  Member  States  are 
required to report on their national adaptation policies143, 
as  the  EU  Climate  Law  recognises  adaptation  as  a  key 
component  of  the  long-term  global  response  to  climate 
change. Member States will be required to adopt national 
strategies, and the EU will regularly assess progress as part 
of its overall governance on climate action.  The updated 
EU adaptation strategy, published in February 2021, sets 
out how the EU can adapt to the unavoidable impacts of 
climate change and become climate resilient by 2050. 

Key national climate policies and strategies 

France has an integrated national energy and climate plan 
for  2021-2030.  The  work  is  consistent  with  the  national 
low carbon strategy. The national objective is to become 
climate-neutral  by  2050.  In  addition  to  setting  out 
economy-wide  greenhouse  gas  emission 
reduction 
targets, the long-term strategy sets carbon budget. These 
targets  were  first  introduced  in  the  climate  plan  (2017) 
and  enshrined  in  the  Climate  and  Resilience  Law,  thus 
making  the  strategy  and  the  carbon  budgets  legally 
enforceable.  Greenhouse  gas  emissions  are  decreasing 

but further effort will be needed to match the increased 
ambition  of  the  European  Green  Deal  and  the  2050 
climate neutrality target  set  at national  and EU level.  As 
highlighted in the 2020 annual report of the High Council 
for  Climate,  emissions  reduction  in  general  continues  to 
be too slow in France, which puts respecting the nationally 
determined carbon budgets at risk. 

In  its  RRP,  France  allocates  46%  of  the  funds  to  climate 
objectives and outlines crucial investments to further the 
green transition. 

The  first  national  adaptation  strategy  was  published  in 
2006.  In  2011,  France  adopted  the  national  adaptation 
plan  to  climate  change  for  2011-2015.  A  consultation 
process  in  2016  led  to  the  preparation  of  the  second 
national adaptation plan for 2018-2022. The 2006 strategy 
was  considered  to  be  still  relevant  according  to  those 
consulted. 

Between  1990  and  2020,  greenhouse  gas  emissions  in 
France decreased by 27%, less than the EU average, in part 
due to its already significantly decarbonised power sector. 

Figure  35:  Total  greenhouse  gas  emissions 
international aviation) in France, 1990-2020 

(incl. 

Effort sharing target 

For emissions not covered by the  EU's emissions trading 
scheme  (ETS),  Member  States  have  binding  national 
targets under the Effort Sharing legislation144145. Under EU 
legislation, France has a target to reduce greenhouse gas 
emissions  in  the  non-ETS  sectors  (buildings,  road  and 

141  The Fuel  Quality  Directive (Directive 98/70/EC)  sets  strict  quality 
requirements for fuels used in road transport in the EU to protect human 
health and the environment, and to make road travel across the EU safer. 
142 Directive 98/70/EC. 

143 Article 29 of Regulation (EU) 2018/1999. 
144 Regulation (EU) 2018/842 
145 Effort sharing 2021-2030: targets and flexibilities (europa.eu) 

Environmental Implementation Review 2022 – France 

 
                                                                 
 
domestic maritime transport, agriculture, waste and small 
industries) by 14% by 2020 and by 37% by 2030 compared 
to  2005.  France  overachieved  its  2020  target.  Emissions 
decreased  in  all  sectors  concerned,  apart  from  road 
transport. In its national energy and climate plan, France 
intends  to  reduce  emissions  below  its  current  Effort 
Sharing target for 2030 of -37%. 

Figure 36: Emissions and targets under the Effort 
Sharing Decision/ Effort Sharing Regulation in France, 
2020 and 2030 as percentage change from 2005 

Figure 37: Emissions, annual emission allocations (AEAs) 
and accumulated surplus/ deficit of AEAs under the 
Effort Sharing Decision in France, 2013-2020 

Key sectoral developments 

In road transport, the greenhouse gas intensity of vehicle 
fuels in France decreased by 4,5% from 2010 to 2019. The 
country  needs  to  act  swiftly  to  meet  the  current  EU 

in 

the 

146  The  sectors 
following 
Intergovernmental  Panel  on  Climate  Change  (IPCC)  sectors:  Energy 
supply:  1A1,  1B  and  1C;  Energy  use  in  manufacturing  industries:  1A2; 
Industrial  processes and  product  use:  2;  Transport:  1A3;  Other  energy 

figure  correspond 

the 

to 

France  32 

reduction target of a 6% decrease by 2020 (compared to 
2010).  There  are  several  types  of  action  that  Member 
States  can  take  in  this  regard,  for  example:  (i)  further 
expanding  the  use  of  electricity  in  road  transport;  (ii) 
supporting the use of biofuels, and advanced biofuels  in 
particular; 
the  development  and 
deployment  of  renewable  fuels  of  non-biological  origin; 
and  (iv)  reducing  upstream  emissions  before  refining 
processes. 

incentivising 

(iii) 

Road transport in 2019 in France represented 27% of the 
country’s  total  greenhouse  gas  emissions.  Emissions  of 
greenhouse gases from road transport have decreased by 
7%  compared  to  2005.  France  intends  to  accelerate  the 
electrification  of  transport,  the  use  of  alternative  fuels, 
including hydrogen, and the development of batteries. 

On  agriculture,  the  non-CO2  greehouse  gas  emissions, 
such  as  methane  emissions  from  livestock,  continue  to 
stagnate rather than decrease, and the sector is still not 
ready to start making significant emissions reductions. 

Figure  38  :  Greenhouse  gas  emissions  by  sector  in 
France146  –  historical  emissions  1990-2020,  projections 
2021-2030147 

To  reduce  emissions  in  the  buildings  sector,  energy 
performance remains the biggest challenge. 

In  the land use, land use change and forestry  (LULUCF) 
sector, France  expects  to see increasing net  removals  of 
CO2  equivalent  by  2030.  Reported  quantities  under  the 
Kyoto  Protocol  for  France  show  net  removals  of,  on 
average, -46.4 Mt CO2-eq in 2013- 2019. France therefore 
contributes 13.5% to the  EU-27's annual average carbon 

use:  1A4,  1A5  and  6;  Agriculture:  3;  Waste:  5;  International  aviation: 
1.D.1.a. 
147 European Environment Agency, Total GHG trends and projections. 

Environmental Implementation Review 2022 – France 

 
 
 
 
                                                                 
 
 
France  33 

up to a ceiling of EUR 420 million a year. The remainder is 
not  reserved  but  goes  to  the  general  budget,  which 
includes climate and energy investments. 

2022 priority actions 

  Make transport more sustainable. 
  Simplify  the  rules  to  carry  out  renewable  energy 
projects  because  deployment  of  renewable  energy  
infrastructure is progressing too slowly. 

  Ensure that  the agriculture sector is on a  low-carbon 

pathway. 

‘sink’ of -344.9 Mt CO2-eq. Using a separate measurement 
scheme, carbon accounting for the same period shows net 
average  annual  credits  (i.e.  the  equivalent  of  carbon 
removals) of  -0.8 Mt  CO2-eq, which  corresponds to 0.7% 
of  the  EU-27  accounted  sink  of  -115.0 Mt  CO2-eq. 
Reported  net  removals  show  a  decreasing  trend  from 
2013  to  2015,  which  levelled  off  after  that.  Accounted 
quantities  show  the  same  pattern,  but 
is  more 
accentuated, with net credits in 2013, 2014 and 2016 and 
net debits in all other years. France is one of 14 Member 
States  that  show  net  debits  for  at  least  one  year  in  this 
preliminary accounting exercise. 

it 

France’s net land use and forestry sink have considerably 
decreased  due  to  climate  change  impacts,  increase  of 
wood harvests and continued land sealing.  France needs 
to implement additional measures and changes in its land 
management practices. 

Figure 39: Reported and accounted emissions and 
removals from LULUCF in France148 

Use of revenues from the auctioning of EU ETS 
allowances 

from 

revenues 

the  auctioning  of  emission 
Total 
allowances in France under the EU ETS in 2012-2021 were 
EUR 5.1 billion. In France, the auctioning revenues co-fund 
energy efficiency improvements for low-income housing, 

148  The  differences  between  reported  and  accounted  emissions  from 
LULUCF under the Kyoto Protocol are described in the Explanatory note 
on LULUCF – accounted and reported quantities under the Kyoto Protocol. 

Environmental Implementation Review 2022 – France 

 
 
 
 
                                                                 
 
 
 
 
 
 
France  34 

Part II: Enabling framework: Implementation tools 

5. Financing

Environmental investment needs in the 
European Union 

Financing  environmental  measures  is  essential  for  their 
success.  Although  most  financing  comes  from  national 
sources, various EU funds contribute significantly, helping 
to close the financing gaps. 
Post-2020,  environmental  implementation  will  also  be 
supported by the EU’s  COVID-19 Recovery Fund (via the 
RRF) and the ‘do no significant harm’ principle which runs 
across the EU budget. The renewed commitments made 
at  COP26  (Glasgow,  October-November  2021)  and  the 
Biodiversity  Convention  (April-May  2022)149  will  also  be 
reflected in the EU budget. 

Overall environmental investment gaps (EU27) 

The EU’s investment needs for the green transition cover 
a  range  of  interlinked  areas.  The  additional  investment 
needs  over  the  baselines  (i.e.  the  gap  between  what  is 
needed and what is forecast to be invested if no additional 
action  is  taken)  for  climate,  energy  and  transport  were 
estimated in 2021 at EUR 390 billion a year (EU-27)150 with 
a  further  EUR  130  billion  a  year  to  deliver  the  EU's  core 
environmental  objectives151.  The  cost  of 
slimate 
adaptation  can  also  be  significant  and  are  estimated  to 
reach a total of EUR 35-62 billion (narrower scope) or EUR 
158-518 billion (wider scope) a year152. Those investment 
needs reflect the implementation objectives to 2020 and 
to 2030 (except for climate adaptation, the costs of which 
are expected to last over a longer time horizon). 

A  preliminary  update  of  the  EU’s  core  environmental 
investment  gap  is  provided  in  Table  1153.  Almost  40%  of 
the  environmental  investment  needs  relate  to  dealing 
with pollution, which accounts for almost 65% of the total 
gap if combined with water management. The investment 
gap  in  circular  economy  and  waste  is  estimated  to  be 
between EUR 13-28 billion a year, depending on the level 

149  The  Convention  on  Biological  Diversity  (cbd.int);  Post-2020  Global 
Biodiversity Framework | IUCN. 
150 SWD(2021)621, accompanying proposal COM(2021)557 to amend the 
REDII Directive (EU) 2018/2001. 
151 SWD(2020) 98 final/2. 
152  SWD(2018)292.  Impact  assessment  accompanying  the  Proposal  for 
the LIFE Regulation (COM(2018)385). 
153  With  decreases  due  to  Brexit  and  some  reconciliation  among  the 
objectives. 
154 European Commission, DG Environment, ‘Study supporting EU green 
investment  needs  analysis’  (ongoing,  2021-2023)  and DG  Environment 

of  circularity 
financing gap is estimated at around EUR 20 billion. 

implemented.  The  annual  biodiversity 

Table 1: Estimated breakdown of the EU’s 
environmental investment needs, by environmental 
objective, 2021-2030 (per year)154 

Estimated investment gap (EU-27, 
p.a.)  

Environmental 
objective 

Pollution  prevention 
& control 

Water management & 
industries 

Circular  economy  & 
waste 

EUR billion 

42.8 

26.6 

13.0 

& 

21.5 

6.2 

& 

Biodiversity 
ecosystems155 

Research, 
Development 
Innovation 

Total 

% 

39% 

24% 

12% 

20% 

6% 

110.1 

100% 

Environmental investment needs in France 

There is a clear shift of investment priorities in France to 
support  climate  policies.  Climate  investment  priorities 
address  the  needs  or  ‘investment  gaps’  in  a  wide  set  of 
economic  sectors  such  as  the  energy  renovation  of 
housing, e-mobility, and transportation infrastructures. 

In  2020,  France’s,  climate-related  investments  increased 
by 10% and amounted to EUR 45 billion compared to 2019. 
Despite this increase, an obvious investment gap remains 
to meet the objectives set out in the national low-carbon 
strategy  and  the  multiannual  energy  programming.  By 

internal analysis ‘Environmental Investment needs and financing in the 
EU’s green transition’, July 2020. 
155  To  meet  the  needs  of  the  2030  biodiversity  strategy  (Natura  2000, 
green infrastructure), at least EUR 20 billion a year should be unlocked 
for  nature  (COM/2020/380  final),  while  fully  covering  the  strategy 
(including restoration) may require EUR 30-35 billion, indicating a gap of 
EUR 10-20 billion a year compared to current baseline expenditure. 

Environmental Implementation Review 2022 – France 

 
                                                                 
 
 
2023, an additional EUR 13-15 billion in public and private 
investment  is  needed  per  year  for  France  to  be  able  to 
bridge the gap156. 

Pollution prevention and control 

The  EU’s  first  Clean  Air  Outlook157  under  the  clean  air 
programme  estimated  that,  to  reach  the  emissions 
reduction  requirements  (ERRs)  in  the  NECD  by  2030158, 
total  air  pollution  control  costs  for  France  would  be 
equivalent to EUR 9 billion  a year. This includes EUR 5.1 
billion  for  capital  investment  (assuming  France  achieves 
the 2030 climate and energy targets)159. 

The  second  Clean  Air  Outlook  suggests160  that  the 
EU would  largely  achieve  the  reductions  of  air  pollutant 
emissions  that  correspond  to  the  obligations  under  the 
NECD for 2030 if: (i) all relevant legislation adopted up to 
2018  is  implemented  (including  all  air  pollution  and  the 
2030  climate  and  energy  targets  set  in  2018);  and  (ii) 
the  measures 
Member  States  also 
announced 
in  their  national  air  pollution  control 
programmes.  The  only  exception  is  for  ammonia  for  15 
Member States, excluding France. 

implemented 

Compared  to  2018  emission  levels,  France  and  14  other 
Member States will need to reduce their NOx emissions by 
more than 30% compared to 2018. 

Water management 

France  has  made  good  progress  in  complying  with  the 
Urban  Waste  Water  Treatment  Directive  (UWWTD)  by 
satisfactorily  implementing  the  required  measures  to 
achieve good status. In France, 70-100% of the objectives 
have  been  met  for  312  river  basis  district  (RBDs).161  The 
OECD estimates that France spent approximately EUR 16 
billion  on  water  supply  and  waste  water  every  year 
between 2011 and 2015 (total expenditure)162. Until2030, 
the  additional  cumulative  investment  need  for  France 
over  its  baselines  was  estimated  at  EUR  20.5  billion 

156 I4CE, Landscape of Climate Finance  in France, Landscape of climate 
finance in France, I4CE, 2021. 
157 International Institute for Applied Systems Analysis (IIASA), Progress 
towards the achievement of the EU's air quality and emissions objectives, 
2018. 
158  Covering  the  reductions  of  and  the  emission  ceilings  for  five 
atmospheric  pollutants,  SOx,  NOx,  PM2.5,  NH3  and  VOC,  by  2030, 
compared  to  2005.  Requirements  are  based  on  Directive  (EU) 
2016/2284. 
159 Directive (EU) 2016/2284. 
160 COM(2021) 3 Final and Report Annex. 
161 Implementation of the Water Framework Directive (2000/60/EC), the 
Environmental  Quality  Standards  Directive  (2008/105/EC  amended  by 
Directive  2013/39/EU)  and  the  Floods  Directive  (2007/60/EC):  Report-
implementation-WaterFrameworkDirective.pdf. 
162  OECD,  Financing  a  Water  Secure  Future,  2022.  Country  Fact  Sheet 
France, Country Fact Sheet France, p. 4. 

France  35 

(around EUR 2.1 billion a year), with over 90% of that for 
waste water. Moreover, the recent 6th Water Framework 
Directive  and  Floods  Directive  Implementation  Report163 
and the financial - economic study164 accompanying it, are 
also a relevant source of information in this domain. 

Waste and the circular economy 

According to a Commission study165, if France is to meet 
its  recycling  targets  for  municipal  waste  and  packaging 
waste,  it  still  needs  to  invest  an  additional  EUR  3  514 
billion (around EUR 500 million a year) over its baselines 
reprocessors, 
in  2021-2027 in:  collection, 
biowaste  treatment,  waste  sorting  facilities,  and  waste 
registry  digitalisation. This  does  not 
the 
investment necessary in other key waste streams (plastics, 
textile,  furniture)  or  the  investment  needed  to  increase 
circularity and waste prevention across the economy. 

recycling 

include 

Biodiversity and ecosystems 

Prioritised  action  frameworks  (PAFs)  adopted  by  the 
Member  States  under  Article  8  of  the  Habitats  Directive 
present: (i) the conservation priorities for the Natura 2000 
network  and  its  supporting  green  infrastructure;  (ii)  the 
costs  of  these  conservation  priorities;  and  (iii)  planned 
funding  sources  for  biodiversity  and  ecosystems  in  the 
period corresponding to the current multiannual financial 
framework  (MFF)  for  2021-2027.  For  France,  the  total 
identified  needs  amount  to  EUR  651.4  million  a  year166. 
This  excludes  additional  costs 
the 
biodiversity strategy to 2030, including those for increased 
protection and restoration. 

implement 

to 

A  recent  study  from  the  French  Treasury  (DG  Trésor) 
shows that 44% of the country’s economic value added is 
strongly or very strongly dependent on natural capital. The 
study’s  conclusions  will  help 
international 
decisions for the post-2020 global biodiversity framework 
and COP15167. 

inform 

163 WFD and Floods Directive Implementation Reports – DG Environment 
– European Commission. 
164  European  Commission,  Directorate-General 
for  Environment, 
Economic data related to the implementation of the WFD and the Floods 
Directive and the financing of measures, Final report. Publications Office, 
2021. 
165 European Commission, Study on investment needs in the waste sector 
and on the financing of municipal waste management in Member States, 
2019. 
166  The  N2K  Group,  Strengthening  investments  in  Natura  2000  and 
improving synergies with EU funding instruments report to the European 
Commission, 2021. 
167 Post-2020 Global Biodiversity Framework | IUCN. 

Environmental Implementation Review 2022 – France 

 
 
 
                                                                 
 
 
EU environmental funding 2014-2020 

The MFF for 2014-2020 allocated almost EUR 960 billion 
(in commitments, 2011 prices)168 for the EU to spend over 
this period. The commitment in the 2014-2022 MFF to the 
green transition included a 20% climate spending target. It 
also included funding opportunities for the environment, 
in  particular,  under  the  European  Structural  and 
Investment (ESI) Funds169. The 2014-2020 MFF budget was 
subsequently  topped  up  with  over  EUR  50  billion  (in 
current prices) from the REACT-EU programme (Recovery 
Assistance for Cohesion and the Territories of Europe) for 
cohesion policy action against COVID-19170. 

France  received  EUR  35.11  billion  from  the  ESI  Funds  in 
2014-2020 to invest in job creation and a sustainable and 
healthy  European  economy  and  environment.  The 
planned  direct  environmental  investment  amounted  to 
EUR 2.21 billion with further EUR 967.5 million identified 
as  indirect  environmental  investment  value,  totaling  to 
EUR 3.18 billion. Figure 41 gives an overview of (planned) 
individual ESI Funds earmarked for France (EU amounts, 
without national amounts). 

France  36 

Figure 40: ESI Funds allocated to France, including 
environmental investments,, 2014-2020171 

Table 2:  Direct  and indirect  environmental investments 
under the ESI Funds in France, 2014-2020172 

Instrument 

Under Cohesion policy (ERDF) 
Direct environmental investments 
water 
waste 
biodiversity and nature 
land rehabilitation 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 
other energy173 
sustainable transport 
sustainable tourism 
business development, R&I 

Under EAFRD/rural development 

Allocations  
for the environment  
(EUR million) 

1 945.6 
1 030.5 
220.0 
119.2 
264.1 
139.4 
287.9 
915.1 
168.2 
319.1 
11.9 
293.8 
55.3 
66.7 

1 074.9 

168 Council Regulation (EU, Euratom) No 1311/2013. 
169  The  European  Structural  and  Investment  (ESI)  Funds  include  the 
European Regional Development Fund (ERDF), the Cohesion Fund (CF), 
the  European  Social  Fund  (ESF)  with  the  Youth  Employment  Initiative 
(YEI), the European Agricultural Fund for Rural Development (EAFRD) and 
the European Maritime and Fisheries Fund (EMFF). 
170 Regulation (EU) 2020/2221. 
171  European  Commission,  DG  Environment  –  Data  analysis,  DG 
Environment  analysis  based  on  ESI Funds Open  Data  Portal 
(cohesiondata.ec.europa.eu), Integration  of  environmental  concerns  in 
Cohesion 
(EU)  No 
1303/2013,Regulation  (EU)  2021/1060 and Implementing  Regulation 
(EU) No 215/2014. Cut-off date for data: December 2021. Environmental 
investments  here  are  captured  via  the  combined  use of  intervention 
fields 
No 
1303/2013 and Regulation  (EU)  2021/1060 allowing for  a  more  precise 
identification and valuation of relevant environmental investments. N.B. 

2017), Regulation 

coefficients 

Regulation 

(COWI, 

under 

Funds 

Policy 

(EU) 

and 

may 

differ 

Indirect  environmental  investments  are  valued  using  the  Annex  I 
environmental  coefficients  of  the Regulation 
(EU)  2021/1060 (as 
opposed to full value). 
172 European Commission, DG Environment - Data analysis. The values of 
environmental investments identified here in the specific environmental 
areas 
values 
at cohesiondata.ec.europa.eu, e.g. for clean  air or biodiversity,  due  to 
two factors: the set of environmental coefficients used and the range of 
funds assessed. DG Environment’s analysis covered the full range of ESI 
Funds. 
173  Intelligent  energy  distribution  systems  (smart  grids)  and  high 
efficiency co-generation and district heating, based on intervention field 
53  and  54  respectively  (with  40%  environmental  coefficients)  of 
Regulation (EU) 2021/1060, Annex I. 

tracking 

from 

the 

Environmental Implementation Review 2022 – France 

 
 
 
                                                                 
 
 
  
Direct environmental investments 
water 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 

Under EMFF 
Direct environmental investments 
environment  protection  &  resource 
efficiency 
Direct environmental investments 
business development, R&I 

Under ESI Funds total  
Direct environmental investments 
Indirect environmental investments 

1 023.7 
181.2 
842.5 
51.2 
23.3 
27.9 

160.4 
159.2 
159.2 

1.2 
1.2 

3 180.9 
2 213.4 
967.5 

Funding for the environment from the ESI Funds has also 
been  supplemented  by  other  EU  funding  programmes 
available  to  all  Member  States  such  as  the  LIFE 
programme, Horizon 2020, or European Investment Bank 
(EIB) financing. This amounts to an estimated total of EUR 
5.7 billion of EU financing for France in 2014-2020. 

is  entirely  dedicated 

The  LIFE  programme174 
to 
finances 
environmental  and  climate  objectives. 
demonstration  and  best-practice  actions  for  green 
solutions to be deployed. In  2014-2020,  France received 
EU  support  for  41  LIFE  projects  (for  nature  and 
environment) worth EUR 126.2 million (out of 1 028 EU-27 
LIFE  projects  with  a  total  EU  contribution  of  EUR  1.74 
billion)175. 

It 

In  2014-2020,  Horizon  2020  allocated  about  EUR  156.9 
million  to  France  for  the  environment  which  is  2.1%  for 
environment  out  of  France’s  total  allocation176.  The 
Horizon  2020  funds  directed  at  French  environmental 
projects  focused,  in  particular,  on  the  circular  economy, 
climate action, natural resources and ecosystems. 

From the European Fund for Strategic Investments (EFSI), 
France 
for  direct 
environmental  investments  and  EUR  150.2  million  for 
indirect  environmental  investments  France,  therefore, 

received  EUR  826.0  million 

France  37 

received  a  total  of  EUR 976.2  million  for  environmental 
investments out of its total allocation of EUR 9.6 billion177. 

investments 

From the EIB, France received EUR 1.35 billion for direct 
for  water, 
environmental 
sewerage  and  waste.  Total  EIB  loans  for  the  country 
amounted to EUR 53.03 billion178. France ranks third in in 
the amount of total EIB lending it received in this period. 

specifically 

In 2020, the EIB provided EUR 24.2 billion in funding across 
Europe to fight climate change, 37% of its total financing. 
It is also provided EUR 1.8 billion (3% of its financing) for 
broader environmental lending179. 

EU environmental funding 2021-2027 

The 2020 European Green Deal investment plan calls for 
EUR 1 trillion in green investments (public and private) to 
be made across the EU by 2030. The 2021-2027 MFF and 
the NextGenerationEU spending programme will mobilise 
EUR  2.018  trillion  (in  current  prices)  to  support  the 
recovery from COVID-19 and the EU’s long-term priorities, 
including  environmental  protection180.  Following  the 
Green  Deal’s181  pledge  to 
‘do  no  harm’  and  the 
Interinstitutional  Agreement  on  the  2021-2027  MFF182, 
30% of the EU budget  in 2021-2027 will support  climate 
efforts,  while  biodiversity  will  receive  7.5%  of  the  EU 
budget  as  of  2024  and  10%  as  of  2026.  Reaching  the 
biodiversity  targets  requires  increased  programming  of 
financial  resources,  specifically  under  the  2021-2027 
cohesion policy and the 2023-2027 CAP. 

Sustainable  finance  significantly  increases  transparency 
on environmental sustainability (a goal promoted by the 
EU  Taxonomy)183. 
It  also  strengthens  non-financial 
reporting  requirements  and  facilitates  the  issuance  of 
green  bonds  (by  developing  the  EU  Green  Bond 
Standard184).  Reinforced  by  the  renewed  sustainable 
finance  will 
finance  strategy 
increase 
the 
flows 
environment. The new strategy on adaptation to climate 
change186  can  help  close  the  insurance  protection  gap, 
which currently leaves many risks from uninsured climate-
related events187. The EIB will align 50% of its lending for 

(2020)185,  sustainable 

climate  and 

investment 

to 

174 European Commission, LIFE Programme. 
175 LIFE (europa.eu). 
176 Source: https://sc5.easme-web.eu/. 
177 Approved and signed EFSI financing – EIB, 2015-2020. 
178 EIB loans in EU countries in 2014-2020. Source: EIB Open Data Portal: 
https://www.eib.org/en/infocentre/eib-open-data.htm 
179  EIB  2020  Activity  Report.  The  EIB  Group  jointly  works  with  the 
European Commission in implementing several programmes that finance 
environmental implementation: InvestEU, the successor of EFSI, Pillar II 
and  III  of  the  Just  Transition  Mechanism.  The  EIB  Group  is  a  key 
implementing partner for InvestEU with responsibility for managing 75% 
of the overall budgetary capacity of the mandate. 
180  European  Commission,  2021-2027 
NextGenerationEU. 

long-term  EU  budget  & 

181 COM/2019/640 final. 
182 Interinstitutional Agreement, OJ L 433I. 
183 

https://ec.europa.eu/info/business-economy-euro/banking-and-

finance/sustainable-finance/eu-taxonomy-sustainable-activities_en 
184 EU Green Bond Standard - 2021/0191 (COD). 
185 COM (2021) 390 Final - European Commission, Strategy for Financing 
the Transition to a Sustainable Economy. 
186 COM(2021) 82 final. 
187 The strategy would support improved coverage of the insurance gap 
including through the natural catastrophe markets as reflected with the 
EIOPA  (European  Insurance  and  Occupational  Pensions  Authority) 
dashboard on the insurance protection gap for natural catastrophes. See: 

Environmental Implementation Review 2022 – France 

 
 
 
                                                                 
 
France  38 

gone  beyond  the  37%  climate  expenditure  target,  the 
minimum level required under the RRF197. 

Some  examples  of  how  RRF  funding  will  be  used  are 
described below. 

  Under  Component  1  of  the  RRP,  the  renovation  of 
buildings includes investment in the energy efficiency 
of  public  buildings  and  other  buildings  (private 
residential  buildings,  social  housing  and  small  and 
medium-sized companies). It also provides for drawing 
up environmental rules for constructing new buildings. 
  Component 3 (Infrastructure and Green mobility) aims 
to  reduce  traffic  congestion  and  air  pollution. 
Investment 
industrialising  electric 
(i) 
batteries  for  the  transport  sector;  (ii)  renewing  the 
local  public  transport  fleets  with  clean  vehicles;  and 
(iii)  promoting  the  shift  to  clean  urban  modes  of 
transport (e.g. metros, cycle lanes, tramways). 

includes: 

  As  part  of  a  green  budget,  a  standardised  and 
comprehensive  information  framework  showing  the 
environmental impact of the  government budget will 
be  proposed  to  the  French  Parliament  and  civil 
society198. 

Payments from the RRF will be made in the form of grants 
to  2026  for  the  nine  components  of  the  recovery  and 
resilience plan94. The plan: (i) ensures direct action at local 
level for the green transition; (ii) protects or restores the 
environment; and (iii) complies with the ‘do no significant 
harm principle’199. 

climate and environmental projects by 2025188, with a EUR 
250 billion contribution to the Green Deal investment plan 
by 2027. 

Table 3 gives an overview of the EU funds earmarked for 
France  in  2021-2027.  These  funds  are  supplemented  by 
other  EU  funding  programmes  available  to  all  Member 
States. 

Table 3: Key EU funds allocated to France (current 
prices), 2021-2027 

Instrument 

Country funding allocation 
(million EUR) 

Cohesion policy 

Total: 16 852.8 189 

9 070.4 

6 674.8 

1 107.6190 

1 030.1 191 

7 297.2193 

567.1194 

ERDF 

ESF+ 

ETC (ERDF) 

Just Transition Fund 

EAFRD/rural 
development  

under  2023-2027  CAP 
strategic plans192 

European  Maritime, 
and 
Fisheries 
Aquaculture 
Fund 
(EMFAF) 

Recovery 
and 
Resilience Facility (RRF)  

2021-2026195  

39 400196 (grants) 

Figure 41: Climate expenditure in RRPs, 2021-2026200 

In  France,  programming  for  most  EU  funds  (cohesion 
policy funds, EAFRD and the European Maritime, Fisheries 
and Aquaculture Fund) is ongoing. However, negotiations 
have been concluded under the RRF. 

As  part  of  the  EU’s  recovery  package,  France  requested 
EUR 39.4 billion in grants through the RRF. 46% of the RRF 
funding  to  France  is  for  measures  that  contribute  to 
climate and environmental objectives. This is in line with 
the average expenditure of 45.3% for climate measures in 
the RRPs accross the EU Member States. France has also 

The pilot dashboard on insurance protection gap for natural catastrophes 
| Eiopa (europa.eu). 
188 EIB Climate Bank Roadmap 2021-2025, November 2020. 
189  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
190 
Interreg 
transnational, ETC cross-border cooperation and ETC outermost. 
191  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
192 European Commission, CAP strategic plans. 
193 Regulation (EU) 2021/2115, Annex XI. 

initial  allocations  per  Member  State 

including  ETC 

194 Regulation (EU) 2021/1139, Annex V. 
195  The  actual  reforms  and  investments  under  the  RRF  have  to  be 
implemented up until 31 December 2026. 
196 Council Implementing Decision, FIN 523. 
197 NextGenerationEU - Recovery and Resilience plans (ngeutracker.org). 
198 French recovery and resilience plan measure (C3,R2). 
199 European Commission, Technical Guidance on the DNSH Principle. 
200 European Commission. The contributions to climate objectives have 
been calculated using Annex VI of the RRF Regulation (EU) 2021/241. 

Environmental Implementation Review 2022 – France 

 
 
 
 
                                                                 
 
 
France  39 

Under NextGenerationEU, the Commission will issue up to 
EUR 250 billion of EU green bonds (one third of all bonds 
issued  under  NextGenerationEU)  until  2026  that  will 
comply  with  the  general  spirit  of  the  ‘do  no  significant 
harm’  principle.  However,  this  EUR 250  billion  in  green 
bonds  will  not  be  subject  to  the  currently  developed 
delegated acts related to the EU Taxonomy. They will not 
fully align with the proposed EU standard for green bonds. 

environmental  protection  in  2020.  In  2014-2020,  this 
totalled  around  EUR  376  billion 
in  environmental 
investment in the EU-27, and EUR 68.3 billion for France. 

Figure 42: Direct and indirect environmental protection 
investments in the EU27 (EUR million and % of GDP), 
2018209 

In addition to EU funds earmarked specifically for France 
in 2021-2027, there are also funding programmes that can 
been  accessed  at  EU  level  and  are  open  to  all  Member 
States.  These  include  the  LIFE  programme  (EUR  5.4 
(EUR  95.5  billion)201,  the 
billion),  Horizon  Europe 
Connecting Europe Facility202 (EUR 33.7 billion)203 and the 
funds to be mobilised via InvestEU204. These other sources 
of funding will also support the green transition, including 
through 
for 
environmental  protection  (Horizon  Europe)205,  clean 
transport  and  energy  (the  Connecting  Europe  Facility)206 
and sustainable infrastructure (InvestEU)207. 

innovation 

activities 

research 

and 

National environmental protection 
expenditure 

Total national expenditure on environmental protection ( 
including all relevant current and capital expenditure)208 in 
the EU-27 was EUR 272.6 billion in 2020, representing 2% 
of  the  EU-27  GDP.  This  percentage  has  remained  quite 
stable over time. Although the largest  absolute amounts 
of expenditure are concentrated in a few countries, most 
countries  spend  between  1-2%  of  their  GDP  on 
environmental protection, with France  spending 1.9% of 
its GDP. 

By institutional sector, around 60% of France’s investment 
in  environmental  protection  (capital  expenditure)  came 
from the general government, 18%  came from specialist 
producers  (of  environmental  protection  services,  e.g. 
waste  and  water  companies),  and  25%  came  from 
businesses not specialised in environmental protection. At 
EU  level,  the  spread  is  more  balanced:  37%  comes  from 
governments,  33%  from  specialist  producers,  and  30% 
from  businesses  not  specialised 
in  environmental 
protection. 

Of  this  spending,  the  EU-27’s  capital  expenditure  on 
environmental  protection  (i.e.  investment)  amounted  to 
EUR 56.3 billion in 2018, failing to EUR 54.5 billion in 2020, 
representing  around  0.4%  of  EU-27  GDP.  Most  Member 
States  invested  0.2-0.5%  of  their  GDP  in  environmental 
in 
protection.  France 

invested  0.4%  of 

its  GDP 

201  European  Commission,  Multiannual  financial  framework  2021-2027 
(in commitments) - Current prices. 
202 The CEF (Transport) also includes EUR 11.3 billion transferred from the 
Cohesion Fund. 30% of the transferred amount will be made available, 
on a competitive  basis,  to  all  Member  States eligible  for  the  Cohesion 
Fund.  The  remaining  70%  will  respect  the  national  envelopes  until  31 
December 2023. Any amount under national envelopes that is unspent 
by that date will support all the Cohesion Fund’s Member States. 
203 Regulation (EU) 2021/1153. 
204  The  InvestEU  Fund  is  set  to  mobilise  over  EUR 372  billion  of 
investment through an EU budget guarantee of EUR 26.2 billion to back 
the  investment  of  financial  partners  such  as  the  European  Investment 
Bank (EIB) Group and others. 
205 European Commission, Horizon Europe. 

level, 

including  final  consumption, 

206 European Commission, Connecting Europe Facility. 
207 European Union, InvestEU. 
208  At  economy 
intermediate 
consumption and  capital  expenditure  of  households,  corporations  and 
governments related to environmental protection goods and services. It 
international 
excludes  EU  funds,  although 
expenditure  beyond  strictly  domestic  expenditure.  Data  source: 
Environmental Protection Expenditure Accounts (EPEA), Eurostat. EPEA 
accounts are based on the CEPA 2000 classification, excluding climate, 
energy and circular economy. 
209 Eurostat, Environmental Protection Expenditure Account, 2021. 

include  some 

it  may 

Environmental Implementation Review 2022 – France 

 
 
 
                                                                 
 
 
 
 
Figure 43: EU-27 Member States’ environmental 
protection investments (Capex) by institutional sectors 
(Total economy = 100%), 2018210 

France  40 

bonds  taxonomy,  which  is  broadly  similar  to  the  EU 
Taxonomy213. 

France  has  been  active  on  the  green  bond  market  and 
issued  more  than  EUR  32.4  billion  in  bonds  in  2020.  In 
March 2021, the French government issued green bonds 
with  a  maturity  of  23  years.  This  followed  on  from  the 
issuance  of  EUR  9.7  billion  of  sovereign  green  bonds  in 
2017 and issuances of bonds led by three French regions 
in 2012. The issuances of green bonds in 2021 amounted 
to EUR 7 billion. Overall, France contributed to the EU-27’s 
total  2020  green  bond  issuance  with  a  value  of  EUR  25 
billion  and  is  third  in  the  global  green  bond  market 
ranking. 

Figure 44: Annual EU green bond issuance in 2020 (EUR 
billion)214 

A  breakdown  of  investment  by  environmental  topic  is 
partially  available,  but  only  at  the  level  of  institutional 
sectors  (instead  of  at  economy  level),  due  to  different 
reporting patterns across the sectors. 

to  waste  management  and  10% 

At  France’s  general  government  level  in  2018,  56%  of 
environmental  protection  investments  went  to  waste 
water,  18% 
to 
biodiversity.  For  the  country’s  specialist  producers  of 
environmental  protection  services,  around  half  of  the 
investments were in waste water and over a third in waste 
management. For businesses not involved in the specialist 
production  of  environmental  protection 
services, 
investment shares included 22% in air protection, 39% in 
water and soil protection, and 18% in environmental R&D. 

In  2020,  the  total  annual  issuance  of  green  bonds 
(including some non-EU countries)211 was USD 156 billion 
(EUR 137 billion), up from USD 117 billion (EUR 105 billion) 
in 2019. Looking only at EU-27 Member States, green bond 
issuance in 2020 was EUR 124 billion212. In 2014-2020, 83% 
of the green bonds issued by European countries served 
objectives  in  energy,  buildings  or  transport,  while  8% 
supported water and waste, with a further 6% supporting 
sustainable land use, with links to ecosystem conservation 
and  restoration.  These  data  are  based  on  the  climate 

Green budget tools 

Green taxation and tax reform 

France’s  revenue  from  environmentally-related  taxes  in 
absolute  amounts  was  one  of  the  highest  in  the  EU  in 
2020.  However,  when  compared  to  GDP  (2.18%),  it  was 
slightly  below  the  EU  average  (2.24%)  (see  Figure  46). 
Within  this,  energy  taxes  accounted  for  84%,  while  the 
share of transport taxes (10.8%) remained  below the EU 
average (19%). Pollution and resource taxes accounted for 

210 Eurostat, Environmental Protection Expenditure Accounts (env_epe). 
211  Green  bonds  were  created  to  fund  projects  that  have  positive 
environmental  and/or  climate  benefits.  Most  green  bonds  issued  are 
green ‘use of proceeds’ or asset-linked bonds. The very first green bond 
was  issued  in  2007  with  a  AAA-rated  issuance  from  multilateral 
institutions, the European Investment Bank (EIB) and the World Bank. 

212  Climate  Bonds  Taxonomy.  USD  value  is  converted  via  Eurostat’s 
annual average EUR/USD exchange rates. 
213 Interactive Data Platform at www.climatebonds.net. Climate Bonds. 
Taxonomy: https://www.climatebonds.net/standard/taxonomy. 
214 Climate Bonds Initiative, 2022. 

Environmental Implementation Review 2022 – France 

 
 
 
                                                                 
 
 
 
5.3% of total environmental tax revenue, which was above 
the EU-average of 3.6%. 

Environmentally-harmful subsidies 

France  41 

incentives 

investments 

Addressing  and 
removing  environmentally-harmful 
subsidies  (EHS)  is  a  further  step  towards  wider  fiscal 
reforms220. Fossil fuel subsidies are costly for government 
budgets and undermine the green transition.  They often 
work  against 
in  green 
for 
technologies,  and  do  not  contribute  to  levelling  the 
playing  field.  Fossil  fuel  subsidies  vary  around  EUR  55 
billion in the EU since 2015. As a share of GDP, this ranges 
from  1.2%  in  Hungary  to  less  than  0.1%  in  Luxembourg 
(the EU average is 0.4%). Despite positive developments in 
some Member States (Latvia, Lithuania, Sweden, Greece 
and  Ireland),  energy  subsidies,  especially  fossil  fuel 
subsidies,  continue  to  adversely  affect  reaching  climate 
neutrality and the broader Green Deal objectives, such as 
better air quality and health. 

In France, the trend was similar with an overall increase in 
fossil  fuel  subsidies221.  Based  on  the  EU‘s  Energy  Union 
data, France‘s total fossil fuel subsidies amounted to EUR 
11.5  billion  in  2019,  representing  0.48%  of  GDP,  slightly 
above the EU average. 

In 2020, the EU-27’s total amount of fossil fuel subsidies 
fell to EUR 52 billion due to reduced consumption caused 
by  COVID-19  restrictions.  However,  without  action  by 
Member States, these subsidies are likely to rebound as 
economic activity picks up222. 

Figure  46  shows  further  details  on  fossil  fuel  subsidy 
trends  in  France,  based  on  OECD  data.  This  data  shows 
fossil fuel subsidies amounting to 0.34% of GDP in 2020, 
with  petroleum  products  representing 
largest 
component. 

the 

Figure 45: Environmental taxes in the EU-27, 2020215 

simultaneously 

The  2019  European  Green  Deal  underlines  that  well-
designed  tax  reforms  can  boost  economic  growth  and 
resilience,  foster  a  fairer  society  and  promote  a  just 
transition. Tax reforms can contribute to this sending the 
right price signals and incentives to economic actors. The 
Green  Deal  creates  the  context  for  broad-based  tax 
reforms, the removal of fossil fuel subsidies, and a shift in 
the  tax  burden  from  labour  to  pollution.  It  achieves  this 
while 
social 
taking 
considerations216. The Green Deal promotes the ‘polluter 
pays  principle’217  which  stipulates  that  polluters  should 
bear the cost of measures to prevent, control and remedy 
pollution. The polluter pays principle is facilitated by the 
Commission’s  Technical Support Instrument (TSI) project 
on  greening  taxes,  in  which  France  participates218.  In 
France, taxes on fertilisers and intensive agriculture have 
been 
economic 
instruments219. 

account  of 

highlighted 

polluter 

pays 

as 

215 Eurostat, Environmental taxes accounts (env_eta). 
216 COM (2019/640 final), p.17. 
217 Article 191(2) of the Treaty on the Functioning of the European Union: 
states that ‘Union policy on the environment (…) shall be based on the 
precautionary  principle  and  on  the  principles  that  preventive  action 
should  be  taken,  that  environmental  damage  should  as  a  priority  be 
rectified at source and that the polluter should pay’. 
218  European  Commission,  Greening  taxes-  applying  polluter  pays 
principle in practice. 

219  European  Commission,  Green  taxation  and  other  economic 
instruments, 2021. 
220 European Commission, Study on Assessing the Environmental Fisccal 
Reform Potential for the EU28, January 2016 Eunomia EFR Final Report 
MAIN REPORT.pdf (europa.eu). 
221  European  Commission,  2020  Report  on  State  of  the  Energy  Union, 
COM(2020) 950 final, Annex 2. 
222 State of the Energy Union report, COM(2021) 950 and Annex. 

Environmental Implementation Review 2022 – France 

 
 
 
 
 
                                                                 
 
Figure 46: Trends in natural gas, petroleum products, 
electricity and coal subsidies in France223 

% GDP 

2013  2014  2015  2016  2017  2018 

2019 

2020 

Electricity 

0.00 

0.00 

0.00 

0.00 

0.01 

0.01 

0.01 

0.01 

Natural gas 

0.02 

0.01 

0.01 

0.02 

0.02 

0.04 

0.04 

0.04 

Petroleum  

0.19 

0.19 

0.20 

0.22 

0.24 

0.27 

0.29 

0.28 

Coal 

0.00 

0.00 

0.00 

0.00 

0.00 

0.01 

0.01 

0.01 

‘polluter  pays  principle’ 
law  enshrined 

is  a  principle  of  EU 
The 
environmental 
in  Article  191  of  the 
European  Treaties224.  The  principle  means  that  polluters 
bear  the  costs  of  their  pollution  including  the  cost  of 
measures taken to prevent, control and remedy pollution 
and  the  costs  it  has  on  society.  The  European  Court  of 
Auditors  believes  that,  while  the  principle  is  generally 
reflected in the EU’s environmental policies, its coverage 
is not fully satisfactory. In addition, the principle is applied 
unevenly across sectors and Member States225. 

Examples  of  subsidies  and  taxation  measures:  In  2015, 
France introduced a carbon tax on energy products, with 
certain  exemptions  to  protect  energy  intensive  sectors 
from the increase in excise tax rates on fossil fuels (see EIR 
2019).  On  environmental  taxation,  France  has  made 

223 OECD, Fossil Fuel SubsidyTracker. 
224 Article 191(2) of the Treaty on the Functioning of the European Union 
states that ‘Union policy on the environment (…) shall be based on the 
precautionary  principle  and  on  the  principles  that  preventive  action 
should  be  taken,  that  environmental  damage  should  as  a  priority  be 
rectified at source and that the polluter should pay’. 
225 European Court of Auditors, Special Report 12/2021: The Polluter Pays 
Principle: Inconsistent application across EU environmental policies and 
actions. 
226 
Tax_benefits_purchase_incentives_European_Union_2021.pdf 
(acea.auto). 
227 Heat Fund – Policies - IEA. 
228 Com_351_swd_en.pdf (europa.eu). 
229  Tagging  is  explained  in  European  Commission,  Green  budgeting 
practices in the EU: a first review , 2021 (p.7). 

Electric_vehicles-

France  42 

progress  with  recent  tax  benefits  for  buying  electric 
cars226.  France  put  in  place  feed-in  tariffs  to  accelerate 
investment  in  biomass,  geothermal,  ocean,  and  waste 
projects227.  The  recovery  and  resilience  plan  does  not 
include  measures  or  reforms  to  remove  harmful  fuel 
subsidies  or  increase  environmental  taxation228.  At  the 
COP  26  climate  summit  in  Glasgow  (November  2021), 
France  signed  the  declaration,  which  brings  forward  the 
country’s target to end overseas fossil fuel funding from 
2035 to 2022. 

Current green budgeting practices  

‘Green  budgeting’  encompasses  various  climate  and 
environmental  tagging229  and  tracking  practices 
in 
budgets. Some Member States already use certain green 
budgeting practices230. Green budgeting helps identify and 
track green  expenditure and  green revenues to increase 
transparency on how green budgetary policies are. This is 
aimed  at  improving  policy  coherence  and  supporting 
green  policies  (including  climate  and  environmental 
objectives)231. 

The Commission has also drawn up climate-proofing and 
sustainability-proofing guidance as tools to assess project 
eligibility and a project’s compliance with environmental 
legislation  and  criteria232.  The  Commission  developed  a 
green budgeting reference framework233 and launched a 
TSI project  on  green budgeting in 2021 to  help Member 
States  develop  national  green  budgeting  frameworks  to 
improve  policy  coherence  and  support  the  green 
transition. France participated in the Commission’s green 
budgeting project, which started in 2021. 

In France, the green budgeting framework is based on six 
environmental  strands,  which  are  aligned  with  the 
objectives of the EU Taxonomy 234 in annexes to its Budget 
Law, France reported EUR 35 billion in green expenditure 
compared to EUR 109 billion planned for 2020235. 

230 European Commission, Green Budgeting Practices in the EU: A First 
Review, 2021. 
231 European Commission, Green Budgeting Reference Framework. 
232 European Commission, Technical guidance on sustainability proofing 
for the InvestEU Fund. 
233 European Commission, Green Budgeting Reference Framework, based 
on  the  review  of  the  OECD  Paris  Collaborative  on  Green  Budgeting 
initiative, 2017. 
234 The six environmental objectives of the EU Taxonomy: climate change 
mitigation,  climate  change  adaptation,  water  resource  management, 
circular  economy  and  waste  management,  pollution  abatement, 
biodiversity and landscape protection. 
235 D1_France Green Budgeting.pdf (financeministersforclimate.org) 

Environmental Implementation Review 2022 – France 

 
 
 
                                                                 
 
 
Overall financing compared to the needs 

The EU’s overall financing for environmental investments 
is estimated to have been 0.6-0.7% of GDP in 2014-2020, 
comprising  both  major  EU  funds  and  national  financing. 
This  ranged  from  0.3%  (Ireland)  to  1.91%  (Bulgaria), 
depending  on  the  level  of  environmental  challenges  in 
different  Member  States.  The  overall  EU  environmental 
investment  needs  in  2021-2027  are  estimated  to  range 
between  0.9-1.5%  of  the  projected  GDP  in  that  period, 
suggesting an overall environmental financing gap of 0.6-
0.8%  of  GDP  (EU  level),  comared  to  previous  financing 
levels236. 

Figure  47:  Total  environmental  financing  (2014-2020) 
and  estimated  needs  (2020-2030)  in  the  EU27  (%  of 
GDP)237 

France  43 

investments 

is 
France’s  financing  for  environmental 
estimated to have been 0.78% of GDP in 2014-2020 (above 
the  EU  average),  almost  exclusively  relying  on  national 
financing  sources.  The  country’s  overall  environmental 
investment needs in 2021-2027 are estimated to be over 
0.82% of France’s GDP (with partial cover, including data 
with 
an 
environmental financing gap of at least 0.05% of GDP. This 
is  likely  to  be  higher  when  taking  into  account  needs 
currently estimated at EU level only (e.g. water protection, 
circularity, biodiversity strategy) . The gap will have to be 
addressed 
increased 
through  other  means  e.g. 
mobilisation of financing. 

breakdowns). 

suggests 

country 

This 

2022 priority actions 

  Subsidies  policy:  Remove  (direct  or  indirect)  energy 
subsidies  and  other  forms  of  support  when  they 
adversely  impact  reaching  climate  neutrality  and  the 
broader Green Deal objectives. 

  Fiscal  reforms:  Shift the tax burden  to  green  taxes, 
provide incentives to change long-term behaviour in all 
sectors  of  the  economy,  and  complete  the  green 
budgeting initiative, expanding the scope of budgetary 
fields covered in the budget bill. 

  Green funding: Address green funding needs in a more 
targeted  way  e.g.  based  on  budget  tracking  and 
sustainable  private  finance  flows.  Use  EU  blending 
mechanisms  and  green  bonds  to  meet  long-term 
investment needs. 

236  DG  Environment  data  analysis.  EU  financing  sources  covered:  ESI 
Funds  (ERDF,  CF,  ESF,  YEI,  EAFRD,  EMFF),  Horizon 2020,  LIFE,  EFSI  (EU 
amount),  EIB  loans.  National  financing:  total  national  environmental 
protection  capital  expenditure  (investments)  -  source:  Eurostat  EPEA 

dataset.  Cut-off  date  for  data:  end  2021.  N.B.  Total  financing  may  be 
higher,  in  particular  through  further  indirect  investments,  requiring 
further analysis in the future. 
237 Eurostat, ESI Funds Open Data, 2021. 

Environmental Implementation Review 2022 – France 

 
 
 
                                                                 
 
 
6. Environmental governance

France  44 

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; 
(iii) access to justice in environmental matters.  
It is of crucial importance to public authorities, the public 
and businesses that environmental information is shared 
efficiently  and  effectively238.  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  environment239.  It  includes  the  right  to  bring  legal 
challenges (‘legal standing’)240. 

Environmental information  

This  section  focuses  on  France’s  implementation  of  the 
INSPIRE Directive. The INSPIRE Directive aims at setting up 
infrastructure  for  sharing  
a  European  spatial  data 
environmental  spatial 
information  between  public 
authorities  across  Europe.  It  is  hoped  that  this  will  help 
policy-making  across  boundaries  and  facilitate  public 
access  to  this  information.  Geographic  information  is 
needed  for  good  governance  at  all  levels  and  should  be 
readily and transparently available. 

France’s implementation of the INSPIRE Directive could be 
improved.  France’s  performance  has  been  reviewed 
based  on  the  country's  2021  country  fiche241.  Slow 
progress  has  been  made  in  data  identification,  and 
implementation  levels  have  improved.  However,  more 
efforts are needed to: 

i.  make the data more widely accessible, and 
ii.  prioritise  environmental  datasets  in  implementation, 
identified  as  high-value  spatial 
environmental 

implementing 

especially  those 
datasets 
legislation242. 

for 

the 

and 

(Directive 2003/4/EC) 

238  The  Aarhus  Convention,  the  Access  to  Environmental  Information 
Directive 
INSPIRE  Directive 
(Directive 2007/2/EC)  together  create  a  legal  foundation  for  sharing 
environmental  information  between  public  authorities  and  with  the 
public. This EIR focuses on the INSPIRE Directive's implementation.  
239 These guarantees are explained in the Commission Notice on access 
to  justice  in  environmental  matters,  OJL  275,  18.8.2017  and  a  related 
Citizen's Guide. 
240  This  EIR  focuses  on  the  means  implemented  by  Member  States  to 
guarantee  rights  of  access  to  justice,  legal  standing  and  to  overcome 
other major barriers to bringing cases on nature and air pollution. 

Table 4: Country dashboard on the implementation of 
the INSPIRE Directive , 2016-2020243 

2016 

2020 

Legend 

■  Implementation  of 
this  provision  is  well 
advanced  or  (nearly) 
completed. 
Outstanding 
issues 
are minor and can  be 
easily. 
addressed 
Percentage: >89% 

■  Implementation  of 
this  provision  has 
started  and  made 
some  or  substantial 
progress but is still not 
close  to  be  complete. 
Percentage: 31–89% 

■  Implementation  of 
this provision is falling 
significantly  behind. 
Serious  efforts  are 
to  close 
necessary 
implementation  gap. 
Percentage: <31% 

Effective  coordination  and  data 
sharing 

Ensure effective 
coordination 

sharing 

Data 
without 
obstacle 

INSPIRE 
indicators 

■ 

■ 

■ 

■ 

performance 

i. Conformity of 
metadata 

■ 

ii.  Conformity 
of  spatial  data 
sets244 

■ 

■ 

■ 

iii.  Accessibility 
of  spatial  data 
through 
sets 
view 
and 
download 
services 

iv.  Conformity 
of 
network 
services 

■ 

■ 

■ 

■ 

France must further improve access to its environmental 
information.  The  Commission  opened  an  infringement 
procedure 
in  2020  because  delays  for  the  redress 
procedure were excessive. 

Public participation 

In March 2018, the Ministry of Environmental and Social 
‘projets-
Transition 

launched  a  platform 

called 

241 https://inspire.ec.europa.eu/INSPIRE-in-your-Country/FR. 
242 European Commission, List of high value spatial data sets. 
243 INSPIRE knowledge base. 
244  In  2016,  the  deadlines  for  implementation  of  the  spatial  data 
interoperability:  23  November  2017  for  Annex  I  data  and  21  October 
2020 for Annex II and III data. In many cases, this conformity indicator 
will never  reach 100% conformity as most countries provide as-is data 
sets in addition to the INSPIRE harmonised data sets. 

Environmental Implementation Review 2022 – France 

 
 
                                                                 
  
  
 
 
It 

to 

aims 

transparency  and  public  access 

improve 
environnement.gouv.fr’. 
environmental 
to 
information  about  projects  that  have  a  significant 
environmental 
impact 
and 
assessment245. For  each project, the platform  provides  a 
detailed description, the impact study, various documents 
from the public consultation file, and, in due course, the 
administrative documents authorising the project. 

require 

impact 

an 

in 
However,  no  statistics  on  public  participation 
environmental  projects  are  available  on  the  platform  or 
anywhere else. 

France  45 

and  it  is  accessible  for  the  members  of  the  public  and 
NGOs. 

There 
is  no  specific  website  available  to  access 
environmental justice. This is because environmental law 
does not  have  any dedicated courts, and the courts and 
the  Ministry  of  Justice  provide  information  without 
distinguishing environmental matters. 

In  2019,  the  Commission  proposed  priority  actions  to 
France on access to justice, in particular, to better inform 
the public about their rights to environmental justice. It is 
concluded that there has been limited progress made. 

Access to justice 

2022 priority actions 

in  a 

Appeals  by  organisations  in  defence  of  their  statutory 
purpose  are  admitted 
flexible  manner  by 
administrative judges. Because of the principle of specialty 
of  legal  persons,  standing  is  assessed  based  on  the 
its 
organisation’s  corporate  purpose  as  defined  by 
statutes.  To  assess  legal  standing  (the  right  to  bring 
challenges),  the  judge  compares  the  content  of  the 
contested administrative decision with the organisation's 
corporate purpose.  An appeal by  an organisation is only 
admissible, therefore, if the contested decision adversely 
affects  the  collective 
interest  that  the  organisation 
defends. 

The  screening  decision  for  environmental  plans  and 
programmes  can  be  challenged  by  the  petitioner. 
However,  under  Article  R.  122-18  of  the  Environmental 
Code, such a judicial appeal against the screening decision 
must be preceded by an administrative appeal ( “recours 
administratif préalable obligatoire” or RAPO). 

It  cannot  be  challenged  by  the  public  or  an  NGO.  The 
Council of State (Conseil d’État) decided that a decision to 
exempt  a  plan  from  SEA  cannot  be  challenged  directly. 
However,  such  a  decision  can  be  contested  when 
challenging the final plan. 

Government  decrees  can  be  challenged  directly  before 
the Conseil d’Etat. Access to the judge is widely accepted. 
Anyone  with  an  interest  in  maintaining  or  annulling  the 
contested  decision  may  take  part.  Associative  approval 
under the Environmental Code makes admissibility easier 
but is not a prerequisite. To appeal a government decree, 
it is not necessary to have legal representation. It can be 
concluded  that  there 
is  a  system  of  regular  and 
substantive supervision of regulatory legally binding acts 

  Collect  and  publish  data  to  assess  whether  France’s 
efforts  to  increase  public  participation  are  achieving 
their objectives. 

to 

in  particular  by  referring  to 

  Better inform the public about their access  to justice 
rights, 
judicial  and 
administrative portals and to Commission eJustice fact 
sheets  on  access 
in  environmental 
matters246. 
Improve access to environmental information. 

 
  Ratify  the  Protocol  on  Strategic  Environmental 
Assessment 
on 
the  UNECE 
Environmental Impact Assessment in a Transboundary 
Context (Kiev Protocol). 

Convention 

justice 

to 

  Ratify  the  First  Amendment  to  the  Convention  on 
Environmental Impact Assessment in a Transboundary 
Context  (the  Epsoo  Convention)  –  Sofia,  27  February 
2001. 

environmental 

  Make  spatial  data  more  widely  accessible  and 
prioritise 
the 
implementation  of  the  INSPIRE  Directive,  especially 
those identified as having high-value for implementing 
environmental legislation. 

datasets 

in 

Compliance assurance 

Environmental compliance assurance covers all the work 
undertaken by public authorities to ensure that industries, 
farmers and others fulfil their obligations to protect water, 
air and nature, and manage waste247. 
It includes support measures provided by the authorities 
such as: 
(i) compliance promotion248; 

245 Website: https://www.projets-environnement.gouv.fr/pages/home/ 
246 
https://e-
justice.europa.eu/content_access_to_justice_in_environmental_matter
s-300-en.do 

247 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. 
248 This EIR focuses on the help given to farmers to comply with nature 
legislation and nitrates legislation. 

 Environmental Implementation Review 2022 – France 

 
 
                                                                 
 
 
France  46 

(ii) inspections and other checks that they carry out, i.e. 
compliance monitoring249; 
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement250. 
Citizen science and complaints enable authorities to focus 
their efforts better. Environmental liability251 ensures that 
the polluter pays to remedy any damage. 

complaints will be handled257. Inspection reports are not 
published.  The  Ministry  of  Ecological  Transition 
occasionally  publishes  reports  summarising  inspection 
activities of ICPEs, with different national data (number of 
inspectors,  number  of  inspection  visits).  However,  the 
Ministry’s  website  only  has  reports  for  2014,  2015  and 
2018.  Some  regional  reports  are  also  published  by  the 
DREALs concerned258. 

Compliance promotion and monitoring 

The French Biodiversity Agency has an extensive website 
with  detailed  technical  information  on  protected  sites 
with some information for non-specialists. The Ministry of 
Agriculture and Food also provides information on Natura 
2000 sites, and the website of the chambers of agriculture 
has  tools  to  help  farmers  with  biodiversity  matters 
(diagnostics, training, etc.)252. In addition, the Agricultural 
Biodiversity  Observatory  (Observatoire  Agricole  de  la 
Biodiversité  or  OAB)253, 
is  a  participatory  science 
programme  that  provides  farmers  with  biodiversity 
observation  protocols  to  help  them  gain  a  better 
understanding  of  biodiversity  in  agriculture.  Since  the 
2019  EIR,  France  has  made  more  online  information 
available  on  farmers’  obligations  to  protect  biodiversity 
and how to meet them. 

régionales 

l'Environnement, 

France  has  a  network  of  regional  environment  offices 
(Directions 
de 
de 
l'Aménagement  et  du  Logement,  or  DREALs),  which  has 
websites  explaining  how  to  respect  rules  on  nitrates  254. 
The website of the chambers of agriculture also provides 
information  on  the  Nitrates  Directive,  with  tools  and 
technical resources to help farmers255. 

Every year, the Ministry of Ecological Transition publishes 
an  outline  of  priority  actions  for  inspecting  installations 
classified for environmental protection (ICPEs). The latest 
outline  was  published  on  22  December  2022256.  Some 
DREALs  publish  information  on  their  annual  inspection 
objectives, such as the number of visits planned and how 

249 This EIR focuses on inspections of major industrial installations. 
250  This  EIR  focuses  on  the  availability  of  enforcement  data  and  co-
ordination between authorities to tackle environmental crime. 
251  The  Environmental  Liability  Directive,  2004/35,  creates  the 
framework. 
252  https://chambres-agriculture.fr/agriculteur-et-politiques/politiques-
environnementales/biodiversite/, 
https://chambres-
agriculture.fr/exploitation-agricole/gerer-son-entreprise-
agricole/favoriser-la-biodiversite/ 
253  Observatoire  Agricole  de  la  Biodiversité  (observatoire-agricole-
biodiversite.fr). 
254  See  nitrates  information  on  DREAL  for  the  Nouvelle  Aquitaine 
Region website: 
http://www.nouvelle-aquitaine.developpement-
durable.gouv.fr/nitrates-r1132.html. 
255  https://chambres-agriculture.fr/agriculteur-et-politiques/politiques-
environnementales/directive-nitrates/ 
256 See Instruction du gouvernement du 22 décembre 2021 relative aux 
actions nationales de l’inspection des installations classées pour l’année 
2022: https://www.legifrance.gouv.fr/download/pdf/circ?id=45258. 

Complaint handling and citizen science 

DREAL websites provide a form for filing complaints about 
ICPEs259. The form contains instructions on how to file the 
complaint. The National Commission on Ethics and Alerts 
in Public Health and the Environment  also has a website 
that  lets  stakeholders,  and  the  public  in  some  cases,  to 
submit information on, for example, threats and harm to 
public  health  and  the  environment.  However,  the 
websites  of  many  other  public  environmental  bodies  do 
not contain information on how to submit complaints and 
do  not  direct  users  to  the  DREAL  websites.  There  is  no 
information available to the public on how they can report 
concerns about breaches of environmental legislation and 
how  the  government  handles  such  complaints.  No  data 
are  published  on  the  number  of  complaints  from  the 
public or how they are managed. 

France provides the public with good opportunities to get 
involved in policymaking. The Vie-publique.fr website has 
a  page dedicated to current  policy consultations. France 
organised a Citizen’s Convention on Climate from 2019 to 
2021,  during  which  a  panel  of  citizens  was  tasked  with 
drawing up a series of measures to reduce greenhouse gas 
emissions260. Individual local authorities have also taken a 
launched  a 
similar  approach,  e.g.  Seine-Saint-Denis 
citizens'  convention  on  climate  and  biodiversity 
in 
2020 
The 
September 
Environmental  Report  for  France262  shows  a  growing 
number  of  people  engaging  in  participatory  science 

government’s 

2021261. 

257  See,  for  example,  DREAL  for  Centre-Val  De  Loire  Inspection  Des 
Installations  Classées  Pour  La  Protection  De  L'environnement 
Présentation Du Bilan Régional 2018 Et Des Objectifs 2019. 
258 
https://www.ecologie.gouv.fr/sites/default/files/Dossier%20de%20pres
se_Les%20risques%20industriels_Une%20mission%20de%20protection
%20pour%20les%20populations%20et%20l%27environnement_Bilan%
202018.pdf 
259 See, for example, the website of the DREAL for the Hauts-de-France 
region: 
https://www.hauts-de-france.developpement-
durable.gouv.fr/?Le-formulaire-de-depot-de-plainte. 
260 https://www.conventioncitoyennepourleclimat.fr/en/ 
261 
https://www.environnement-
magazine.fr/politiques/article/2021/09/20/136165/est-ensemble-tient-
premiere-convention-citoyenne-locale-pour-climat-biodiversite 
262 
numerique/bilan-environnemental/ 

https://www.statistiques.developpement-durable.gouv.fr/edition-

See 

 Environmental Implementation Review 2022 – France 

 
                                                                 
 
programmes on biodiversity – the number of participants 
increased from 20 000 in 2011 to nearly 90 000 in 2018. 

publish  information  on  environmental  damage.  Since 
2019,  France  has  made  no  progress  on 
these 
recommendations. 

France  47 

Enforcement 

The Ministry of Justice published a study in 2021 on the 
criminal  justice  system’s  treatment  of  environmental 
litigation between 2015 and 2019263. This study provides 
detailed data on environmental crime involving: (i) water, 
air,  and  natural  spaces  protection;  (ii)  fauna  and  flora 
protection;  and  (iii)  prevention  of  pollution  and  risks 
(including  waste,  natural  and  technological  risks).  In 
October  2019,  the  Ministry  of  Ecological  Transition  and 
Solidarity  and  the  Ministry  of  Justice  published  a  report 
assessing  the  relationship  between 
justice  and  the 
environment  in  France264,  which  includes  statistics  on 
environmental criminal cases. 

The  Central  Office  for  Coordinating  Environmental  and 
Public  Health  Crime  (Office  central  de  lutte  contre  les 
atteintes  à  l’environnement  et  à  la  santé  publique,  or 
OCLAESP),  a  national  office  within  the  police  force 
(Gendarmerie nationale), coordinates waste, wildlife, and 
other environmental crime enforcement. It does so across 
enforcement agencies, including the customs services and 
the Biodiversity Agency (Office français de la biodiversité). 
There is also a 2015 government circular with guidance on 
criminal policy  for environmental offences. This sets out 
ways  to  collaborate  with  decentralised  administrations 
and public institutions in charge of environmental policing 
(administrative  and  judicial),  under  the  authority  of  the 
public prosecutor's office. 

Environmental Liability Directive (ELD) 

ARIA (Analyse, Recherche et Information sur les Accidents) 
is a French public database that provides  information on 
incidents, accidents or near misses that have affected, or 
could  have  affected,  public  health  or  safety  or  the 
environment265.  However,  it  is  not  clear  which  of  those 
situations  relate  to  ELD  cases.  Detailed  information  on 
financial  securities  does  not  seem  to  be  available. 
Environmental insurance for liabilities under the ELD and 
other environmental legislation is available in France. 

2022 priority actions 

 

  Ensure  that  websites  of  national  and  regional 
authorities with environmental responsibilities include 
clear  information  on  how  the  public  can  report 
breaches or file complaints. 
Improve  cooperation  systems  between  professionals 
combating environmental crimes. 
Improve information to the public on the availability of 
financial securities to meet the costs of environmental 
damage. 

 

Effectiveness of environmental 
administrations 

Those involved in implementing 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 bring about the intended benefits. 

Administrative capacity and quality 

France is a unitary state with a hierarchy of administrative 
divisions – regions, departments, and municipalities. The 
Ministry  of  Ecological  Transition  is  the  central  national 
authority. The Ministry’s policies are implemented directly 
by the Ministry’s services in the regions and departments. 

France  ranks  fifth  out  of  180  countries  in  the  2020 
Environmental Performance Index266. Overall, France has 
a good record in implementing EU environmental laws and 
has ambitious  environmental policies in place.  However, 
serious challenges remain to tackle air pollution, preserve 
species,  as  well  as  improve  waste  management  (with 
suitable plans), sanitation (UWWTD) and drinking water. 

Coordination and integration 

The 2019 EIR recommended that France:: (i) improve ELD 
guidance  and  financial  security  for  liabilities;  and  (ii) 

As  mentioned  in  the  2017  EIR,  turning  the  revised 
(EIA 
Environmental 

Impact  Assessment  Directive 

263  Document  available  at  http://www.justice.gouv.fr/statistiques-
10054/infostats-justice-10057/le-traitement-du-contentieux-de-
lenvironnement-33897.html. 
264  Report  available  at  https://www.vie-publique.fr/rapport/273078-
une-justice-pour-l-environnement. 

265  https://www.aria.developpement-durable.gouv.fr/le-barpi/la-base-
de-donnees-aria/; 
https://www.data.gouv.fr/en/datasets/analyse-
recherche-et-information-sur-les-accidents/ 
266  Environmental  Performance  Index  |  Environmental  Performance 
Index (yale.edu) 

 Environmental Implementation Review 2022 – France 

 
 
 
                                                                 
 
 
 
Directive)267 into national law provides an opportunity to 
streamline  the  regulatory  framework  on  environmental 
assessments. Despite a delay, France has now turned the 
revised Directive into national law. 

The Commission encourages streamlining environmental 
assessments to reduce duplication and avoid overlaps in 
environmental  assessments  applicable 
to  projects. 
Moreover,  streamlining  helps  to  reduce  unnecessary 
administrative  burden  and  accelerates  decision-making, 
provided it is done  without  compromising the quality of 
the  environmental  assessment  procedure268.  France  had 
already 
environmental 
assessments under the EIA and Habitats Directives before 
the revision of the EIA Directive. Coordinated procedures 
have  been  decided  upon  for  the  EIA  Directive,  the  WFD 
and the IED. 

streamlining 

introduced 

A  good  practice  that  can  be  highlighted  is  the  single 
environmental permitting platform. This was developed to 
help  implement  the  single  environmental  permitting 
system,  which  simplifies,  standardises  and  describes 
different environmental permits. 

France  48 

Reforms through the Commission’s technical 
support instrument (TSI) 

Besides  EU  funding  programmes,  the  Commission  also 
the  green 
supports  environmental  measures  and 
transition by granting technical assistance such as TSI. 

TSI 

supported 

 The  Commission’s 
French 
environmental  project  in  2021:  ’Ecological  transition  of 
public services and application to the Ministry of Culture’. 
The Commission encourages France to use this tool more 
often in the coming years. 

one 

TAIEX EIR peer-to-peer projects 

The TAIEX-EIR peer-to-peer tool269 was launched in 2017 
by  the  Commission  to  facilitate  peer-to-peer  learning 
between environmental authorities. 

In 2019, France benefited from a study visit in Germany on 
environmental 
impact  assessments.  In  2022,  France 
participated in two multicountry workshops on ammonia-
reducing technology and measures  on  zero pollution for 
air, water and soil. 

267 Directive 2014/52/EU of the European Parliament and of the Council 
of 16 April 2014 amending Directive 2011/92/EU on the assessment of 
the effects of certain public and private projects on the environment. 
268 The Commission issued a guidance document in 2016 on setting up 
coordinated and/or joint procedures that are simultaneously subject to 

assessments  under  the  EIA  Directive,  Habitats  Directive,  Water 
Framework  Directive,  and the  Industrial  Emissions  Directive,  OJ  C  273, 
27.7.2016, p. 1. 
269  TAIEX  -  Environmental  Implementation  Review  -  PEER  2  PEER  - 
Environment - European Commission (europa.eu). 

 Environmental Implementation Review 2022 – France