COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2025 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 2025 Environmental Implementation Review for prosperity and security
Date: 2025-07-07
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, 7.7.2025  SWD(2025) 309 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2025        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 2025 Environmental Implementation Review for prosperity and security {COM(2025) 420 final} - {SWD(2025) 300 final} - {SWD(2025) 301 final} - {SWD(2025) 302 final} - {SWD(2025) 303 final} - {SWD(2025) 304 final} - {SWD(2025) 305 final} - {SWD(2025) 306 final} - {SWD(2025) 307 final} - {SWD(2025) 308 final} - {SWD(2025) 310 final} - {SWD(2025) 311 final} - {SWD(2025) 312 final} - {SWD(2025) 313 final} - {SWD(2025) 314 final} - {SWD(2025) 315 final} - {SWD(2025) 316 final} - {SWD(2025) 317 final} - {SWD(2025) 318 final} - {SWD(2025) 319 final} - {SWD(2025) 320 final} - {SWD(2025) 321 final} - {SWD(2025) 322 final} - {SWD(2025) 323 final} - {SWD(2025) 324 final} - {SWD(2025) 325 final} - {SWD(2025) 326 final}  
 
 
Contents 

EXECUTIVE SUMMARY ........................................................................................................................................... 2 

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

1. Circular economy and waste management ........................................................................................................ 5 
Transitioning to a circular economy ......................................................................................................................... 5 
Waste management.................................................................................................................................................. 7 

2. Biodiversity and natural capital ....................................................................................................................... 13 
Global and EU biodiversity frameworks.................................................................................................................. 13 
Nature protection and restoration – Natura 2000 ................................................................................................. 13 
Recovery of species................................................................................................................................................. 15 
Recovery of ecosystems .......................................................................................................................................... 16 
Prevention and management of invasive alien species .......................................................................................... 20 
Ecosystem assessment and accounting .................................................................................................................. 21 

3. Zero pollution .................................................................................................................................................. 23 
Clean air .................................................................................................................................................................. 23 
Industrial emissions ................................................................................................................................................ 24 
Major industrial accidents prevention – Seveso ..................................................................................................... 27 
Mercury Regulation ................................................................................................................................................ 28 
Noise ....................................................................................................................................................................... 29 
Water quality and management ............................................................................................................................. 29 
Chemicals ................................................................................................................................................................ 34 

4. Climate action .................................................................................................................................................. 37 
The EU emissions trading system ........................................................................................................................... 37 
Effort sharing .......................................................................................................................................................... 38 
Land use, land-use change and forestry ................................................................................................................. 39 
Adaptation to climate change ................................................................................................................................. 39 

PART II: ENABLING FRAMEWORK – IMPLEMENTATION TOOLS ............................................................................ 40 

5. Financing .......................................................................................................................................................... 40 
Climate finance landmarks ..................................................................................................................................... 40 
Environmental financing and investments ............................................................................................................. 41 
Public financial management .................................................................................................................................. 45 

6. Environmental governance .............................................................................................................................. 49 
Information, public participation and access to justice .......................................................................................... 49 
Compliance assurance ............................................................................................................................................ 51 
EU-supported environmental capacity building ..................................................................................................... 53 

 
 
 
 
 
France  2 

Executive summary

In  May  2016,  the  European  Commission  launched  the 
Environmental Implementation Review “EIR”, a regular 
reporting  tool  based  on  analysis,  dialogue  and 
collaboration  with  EU  Member  States  to  improve  the 
implementation of the existing EU environmental policy 
and  legislation (1).  Following  previous  cycles  in  2017, 
2019 and 2022, this report assesses the progress made 
while  describing  the  main  outstanding  challenges  and 
opportunities 
legal 
implementation in France. The purpose of this report is 
to  provide 
implementation 
performance and to highlight the most effective ways to 
address  the  implementation  gaps  that  impact  human 
health and the environment and hamper the economic 
development  and competitiveness of the country. The 
report  relies  on  detailed  sectoral 
implementation 
reports  collected  or  issued  by  the  Commission  under 
specific environmental legislation. 

information  on 

environmental 

regarding 

the 

The main challenges set out below have been selected 
from Part I of this report, ‘Thematic areas’, taking into 
consideration  factors  such  as  the  gravity  of  the 
environmental implementation, in light of the impact on 
the quality of life of the citizens, the distance to target 
and financial implications. 

France is well on track with regard to its transition to a 
in  terms  of  secondary  use  of 
circular  economy, 
materials,  resource  productivity  and  EU  Ecolabel 
promotion. Green procurement  environmental criteria 
also  increased  significantly,  a  success  praised  in  late 
2024 by the French Court of Auditors. On a less positive 
note,  waste  management  remains  a  challenge,  one 
shared by many other Member States. France is at risk 
of not reaching the 2025 target for reuse and recycling 
of  municipal  waste,  which  led  to  the  launch  of  an 
infringement case in July 2024.  

The  protection  of  biodiversity  and  natural  capital 
remains  an  issue  of  particular  concern,  despite  the 
ambition of the national biodiversity strategy for 2030, 
and despite France's international commitments. There 
are  gaps  between  France's  ambition  and  effective 
measures. Some gaps have led to infringement cases. As 
in  many  other  Member  States,  intensive  agriculture 
practices  and  land  artificialisation  put  pressure  on 
support 
ecosystems.  Measures 

adopted 

to 

reforestation, although appropriate to combat climate 
change  and  damage  to  the  health  of  forests,  did  not 
sufficiently account for biodiversity considerations. On a 
positive  note,  France  is  doing  well  in  fighting  invasive 
alien species. 

With regard to pollution, progress is being made on air 
quality,  though  actions  to  reduce  pollutants  are  still 
needed. 
is  also 
Industrial  accidents  prevention 
improving,  despite  an  ongoing  infringement  case  on 
citizens’  information  and  involvement  in  this  area.  In 
July 2024, the Commission referred France to the Court 
of  Justice  of  the  European  Union  (CJEU)  for  failure  to 
comply  with  the  requirements  of  the  Noise  Directive, 
with regard to missing action plans for agglomerations 
and major roads. In the field of water quality, France is 
facing  challenges  that  are  common  to  many  Member 
States, as evidenced by the Commission's assessment of 
the third cycle of river basin management plans and the 
second  cycle  of  flood  management  plans.  Specifically, 
there 
improve  river  continuity  and 
ecological flows and to reduce pollution from pesticides 
and  nutrients  released  by  intensive  agriculture.  In  the 
same vein, the Commission decided to refer  France to 
the  CJEU  for  nitrates  pollution  in  drinking  water.  The 
assessment  of  per-  and  polyfluoroalkyl  substances 
(PFAS) in drinking water will apply from 2026. Finally, in 
2024, the CJEU found that France failed to comply with 
treatment  and  monitoring  obligations 
for  urban 
wastewater in 78 areas, impacting more than 6 million 
inhabitants.  With  regard  to  climate  protection,  the 
Commission  launched  an  infringement  case  against 
France on 25 January 2024 for failure to fully transpose 
the Emissions Trading System Directive. 

is  a  need  to 

In terms of funding for the ecological transition, France 
performs well on green budgeting practices. The phase-
out  of  environmentally  harmful  subsidies  remains  a 
structural concern, exacerbated by the energy crisis. The 
investment  need  to  enable 
overall  environmental 
France  to  meet 
is 
estimated  to  be  EUR 63.8 billion  per  year.  The 
investment gap amounts to EUR 21.1 billion per year. 

its  environmental  objectives 

Finally, to improve governance, more data is needed on 
the duration of environmental impact assessments.

(1) 

Communication  from  the  Commission  to  the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions – Delivering the 
benefits  of  EU  environmental  policies  through  a  regular 

environmental  implementation  review,  COM(2016) 316 
final  of  27 May  2016,  http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2016%3A316%3AFIN. 

2025 Environmental Implementation Review – France 

 
 
 
Part I: Thematic areas 

1. Circular economy and waste management 

Transitioning to a circular economy 

Figure 1: CMUR (%), 2013–2023 

France  5 

Advancing the transition to a circular economy in the EU 
will reduce the environmental and climate impact of our 
industrial systems by reducing input materials, keeping 
products  and  materials  in  the  loop  for  longer  and 
reducing  waste  generation,  thus  decoupling  economic 
growth from resource consumption. A circular economy 
has considerable potential to increase competitiveness 
and job creation and will also promote innovation and 
provide access to new markets. With the 2020 circular 
economy action plan (CEAP) (2) measures either in place 
or  going  through  the  legislative  process,  EU  Member 
States  will  now  have  to  focus  on  a  swift  and  effective 
implementation. 

The 2020 CEAP launched the legislative process for a set 
of initiatives that will now have to be implemented by 
national  governments  across  the  EU.  These  initiatives 
were  all 
life-cycle 
introduced  following  a  holistic 
approach,  with  measures  addressing  the  different 
stages of a product’s life cycle, from design through use 
to end of life. 

In the CEAP, the EU sets as its overarching objective the 
doubling  of  its  circular  material  use  rate  (CMUR)  by 
2030. 

The CMUR is a measure of one aspect of circularity: the 
share  of  the  total  amount  of  material  used  in  the 
economy  that  is  accounted  for  by  recycled  waste.  A 
higher  CMUR  value  means  that  more  secondary 
materials were used as a  substitute for raw  materials, 
thus reducing the environmental impacts of extracting 
primary material. 

France’s circular use of material is and has been higher 
than the EU average, at 17.6 % of total material use in 
2023, against the EU average of 11.8 % (Figure 1). The 
rate  has  been  comparatively  stable  for  more  than  a 
decade, with a slight increase since 2013. 

25

20

15

10

5

0

2013

2015

2017

2019

2021

2023

France

EU-27

Source: Eurostat, ‘Circular material use rate’, env_ac_cur, last updated 
13 November 
2024, 
accessed 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_c
ur. 

10 December 

2024, 

Resource  productivity  measures  the  total  amount  of 
materials directly used by an economy in relation to gross 
domestic product (GDP). Improving resource productivity 
impacts  on  the 
can  help  to  minimise  negative 
environment  and  reduce  dependency  on  volatile  raw 
material markets. 

France’s resource productivity has been steadily higher 
than the EU average, having generated EUR 3.16 per kg 
of  material  consumed  in  2023  compared  with  the  EU 
average of EUR 2.23 per kg (Figure 2). 

Figure 2: Resource productivity (EUR/kg), 2013–2023 

4,0

3,0

2,0

1,0

0,0

2013

2015

2017

2019

2021

2023

France

EU-27

NB:  The  unit  of  measurement  used  is  EUR/kg  chain-linked  volume 
last  updated 
(2015).  Source:  Eurostat, 
7 August 
2024, 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_r
p. 

‘Resource  productivity’, 
accessed 

10 December 

2024, 

(2) 

Communication from the Commission to the European 
Parliament, the Council, the European Economic and Social 
Committee and the Committee of the Regions – A new circular 
economy action plan for a cleaner and more competitive 

Europe, COM(2020) 98 final of 11 March 2020, https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A98%3AFIN. 

2025 Environmental Implementation Review – France 

 
 
 
 
Policies and measures 

In  parallel  with  European  initiatives  under  the  CEAP, 
Member States are encouraged to adopt and implement 
circular  strategies  at  the  national,  regional  and  city 
levels.  These  should  be  tailored  to  each  national  and 
local  reality,  to  harness  the  proximity  economy’s 
potential (3), while following the principles of a holistic 
whole-value-chain approach. 

Since  the  launch  of  the  online  European  Circular 
Economy  Stakeholder  Platform  in  2017 (4),  national, 
regional and local authorities have used the platform to 
share their strategies, roadmaps and good practices, for 
example  alternative  business  models  and  innovative 
technologies. 

France adopted a circular economy roadmap in 2018 (5) 
and a waste management plan in 2019 (6). The roadmap 
is set to reduce resource use and consumption by 30 % 
by 2030 (compared with 2010), to reduce landfilling of 
non-hazardous waste by 50 % by 2025 (compared with 
2010) and to reach an ambitious 100 % recycling rate of 
plastics  by  2025.  On  this  basis  and  following  progress 
stemming  from  the  national  recovery  and  resilience 
plan (RRP) (7), various initiatives are being rolled out to 
enable  the  circular  economy  transition, 
including 
extended  producer  responsibility  (EPR)  schemes  for  a 
wide  set  of  sectors.  Eco-design  targets  are  being 
expanded to more sectors  

France’s climate policy also includes a circular economy 
angle.  The  Climate  and  Resilience  Law (8)  adopted  in 
August  2021  includes  many  references  and  measures 
for  example, 
related 
sustainable  public  procurement  and  environmental 
information  on  product 
though 
criticisms have been expressed about the haute valeur 
environnementale labelling9. 

the  circular  economy, 

for  consumers, 

to 

To  further  integrate  the  ecological  transition  into  all 
sectors  of  public  action,  in  2022  France  introduced  an 
ecological  planning  process.  This  approach  allows  for 
coordinated  action  and  is  based  on  the  rolling-out  of 
action plans focusing on specific policy areas. A number 

(3) 

(4) 

(5)

European Commission, ‘Proximity and social economy 
ecosystem’, European Commission website, https://single-
market-economy.ec.europa.eu/sectors/proximity-and-social-
economy_en. 
Circular Economy Stakeholder Platform 
(https://circulareconomy.europa.eu/platform/en/strategies). 

https://www.ecologie.gouv.fr/sites/default/files/docume

nts/FREC%20-
%20Plan%20Ressources%20pour%20la%20France%202018.pd
f.  

(6)  Ministry of Ecological Transition and Solidaire, Plan national de 
gestion 
2019, 
déchets, 
https://www.ecologie.gouv.fr/sites/default/files/documents/P
lan%20national%20des%20dechets_octobre%202019.pdf. 

Paris, 

des 

France  6 

of projects are under way to refine and enrich the plan, 
particularly on the subjects of the circular economy and 
adaptation. 

After  the  2015  regional  reorganisation,  the  new 
economic 
and 
internationalisation  regional  strategies  often  include 
support for the circular economy among their priorities. 

development, 

innovation 

Green public procurement 

Public procurement  accounts for a  large proportion of 
European  consumption,  with  public  authorities’ 
purchasing power representing around 14 % of EU GDP. 
Public procurement using green or circular criteria (life-
cycle analysis, platform as a service, second hand) can 
help  drive  the  demand  for  sustainable  products  that 
meet reparability and recyclability standards. 

More than EUR 160 billion are spent each year on public 
procurement by the French state, local authorities and 
municipalities,  promoted  by  the  waste  management 
plan  mentioned  above.  Since  2021,  specific  public 
procurement  provisions  have  obliged  contracting 
authorities  to  acquire  certain  products  derived  from 
reuse  or  re-employment  or  products  that  include 
recycled  materials. 
line  with  the  new  decree 
published  in  2024,  the  mandatory  percentages  will 
gradually 
free 
acquisitions through donations are now included in this 
scheme. A National Sustainable Purchasing Plan (PNAD) 
2022-2025 
the 
implementation of these obligations by providing tools, 
training  and  advisors  to  integrate  sustainable  aspects 
into purchasing processes. 

increase  until  2030. 

In  addition, 

supports 

buyers 

public 

In 

in 

In  its  report  dated  6 December  2024 (10),  the  French 
Court of Auditors highlighted the success of integration 
of environmental criteria in public procurements, which 
rose to 55 % in 2023 from 20 % in 2022. The Climate and 
Resilience  Law  foresees  a  target  of  100 %  by  August 
2026. 

(7) 

(8) 

(9)  

(10) 

the 

RRP 

2023 

updated 

See 
(https://www.tresor.economie.gouv.fr/Articles/53f6c4b5-
4d49-42ba-b778-140c53b6b3f5/files/23723bb4-2c21-4fdf-
9943-c6d53e95eb35). 
Loi  No 2021-1104  du  22  août  2021  portant  lutte  contre  le 
dérèglement climatique et renforcement de la résilience face à 
effets 
ses 
(https://www.legifrance.gouv.fr/jorf/id/JORFTEXT0000439569
24). 
https://www.quechoisir.org/action-ufc-que-choisir-label-hve-
il-trompe-le-consommateur-la-justice-doit-le-condamner-
n105322/.  
https://www.ccomptes.fr/fr/publications/la-prise-en-compte-
des-enjeux-du-developpement-durable-dans-les-achats-de-
letat. 

2025 Environmental Implementation Review – France 

 
 
 
France  7 

chains,  and  stimulating  demand  for  recycled 
content in all products; 
limiting  energy 
materials; and 

to  non-recyclable 

recovery 

(v) 

(vi)  phasing out landfilling of recyclable or recoverable 

waste. 

One  of  the  main  objectives  of  EU  waste  law  is  to 
decouple  economic  growth  from  its  environmental 
impacts.  

The  EU’s  approach  to  waste  management  is  based  on 
the  waste  treatment  hierarchy:  prevention,  preparing 
for reuse, recycling, recovery and, as the least preferred 
option,  disposal 
landfilling  and 
incineration without energy recovery).  

includes 

(which 

in 

the 

legislative  proposals 

field  of  waste 
All 
management  put  forward  by  the  Commission  since 
2021  are  intended  to  encourage  Member  States  to 
promote better product design, to require producers to 
cover  the  costs  of  managing  the  waste  resulting  from 
their products and to ensure that waste is managed at 
the higher levels of the waste hierarchy.   

In  2022,  345 million tons  of  waste  was  generated  in 
France, nearly the same as in 2018. In 2020, the COVID-
19 pandemic led to a decrease in waste in all economic 
sectors,  mainly 
industry  and  construction,  while 
household waste increased because of lockdowns and 
remote working. The increase after 2020 can be mainly 
attributed to  the largest  waste categories, namely soil 
and  mineral  waste  from  construction  and  demolition. 
Excluding  major  mineral  waste 
the 
stabilisation  of  the  overall  waste  generation.  France’s 
GDP  has  shown  a  steady  growth,  but  dropped 
significantly  in  2020,  most  likely  due  to  the  COVID-19 
outbreak, and total waste generation followed suit. 

results 

in 

Overall,  there  appears  to  be  only  a  slight  decoupling 
between economic growth and waste generation, and 
since around 2016, total waste generation has followed 
the GDP trend.  

Figure 3:  Generation  of  waste  (total  and  excluding 
major  mineral  wastes),  population  and  GDP,  2010–
2022 

The EU Ecolabel and the eco-management and audit 
scheme 

The  number  of  EU  Ecolabel  product  groups  and  the 
number of eco-management and audit scheme (EMAS)-
licensed  organisations  in  each  country  provide  some 
indication of the extent to which the private sector and 
national  stakeholders 
in  that  country  are  actively 
engaged in the transition to a circular economy. The EU 
Ecolabel  is  awarded  to  products  with  best-in-class 
environmental  performance.  EMAS 
is  a  voluntary 
environment  management  scheme  aimed  at  reducing 
the environmental impacts of organisations.  

As of September 2024, France had 12 539 products out 
of 98 977, and 490 licences out of 2 983 registered in the 
EU Ecolabel scheme (11). This places France among the 
top countries for the uptake of the EU Ecolabel. 

As  of  November  2022,  France  had  14  organisations 
registered  for  EMAS,  which  is  very  low  for  a  large 
Member State. France has no accredited EMAS verifier. 

The priority actions included in the 2022 environmental 
implementation report (EIR) only focused on waste and 
not on the circular economy more broadly. While France 
is strengthening its circular economy policy framework, 
a  coherent  approach  to  the  implementation  of  the 
measures in place is key. 

2025 Priority action 
• 

Speed  up  the  transition  to  a  circular  economy  by 
implementing an updated national strategy and the 
EU framework and recommendations, in particular 
to  complement 
it  with  upstream  circularity 
measures. 

Waste management 

Turning waste into a resource is supported by: 

(i)  addressing  the  full  life  cycle  of  products,  from 
conception to end of life, by setting requirements 
on the design of products to ensure that they are 
more sustainable; 

(ii)  fully  implementing  EU  waste  legislation,  which 
includes  the  waste  hierarchy,  the  obligation  to 
landfill 
ensure  separate  collection  of  waste, 
diversion targets, etc.; 

(iii)  reducing  waste  generation  per  capita  and 

in 

absolute terms; 

(iv)  increasing  the  recycling  rates  of  waste  containing 
critical  raw  materials  (CRMs),  with  a  view  to 
reducing dependencies and building resilient value 

(11) 

European Commission, ‘EU Ecolabel facts and figures’, 
European Commission website, 
https://environment.ec.europa.eu/topics/circular-

economy/eu-ecolabel/businesses/ecolabel-facts-and-
figures_en. 

2025 Environmental Implementation Review – France 

 
 
 
 
accessed 

15 October 

income)’,  nama_10_gdp, 

Sources:  Eurostat,  ‘GDP  and main components (output,  expenditure 
and 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/nama_10_gdp__c
ustom_9301905/default/table;  Eurostat,  ‘Generation  of  waste  by 
waste  category,  hazardousness  and  NACE  Rev. 2  activity’, 
env_wasgen, last updated 30 September 2024, accessed 22 October 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/env_wasgen/defa
ult/table?lang=en;  Eurostat, 
‘Population  change –  Demographic 
balance  and  crude  rates  at  national  level’,  demo_grind,  accessed 
15 October 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/demo_gind/defaul
t/table?lang=en&category=demo.demo_ind. 

Critical raw materials  

The recovery of CRMs is covered by the French roadmap 
for circular economy and is also the focus of a dedicated 
strategy on recyclability, recycling and incorporation of 
precious  metals (12).  Dedicated  funding  has  been 
allocated to this issue through various instruments (13), 
and  notably has been adopted  under the  France 2030 
investment  plan.  Many  measures  to  favour  reuse  or 
increased recycling of CRMs are implemented through 
EPR schemes. 

Construction and demolition waste 

Construction and demolition waste accounts for almost 
40 % of all waste generated in the EU. A recent study (14) 
by the Joint Research Centre shows that preparing for 
reuse  and  recycling  operations  are  preferred  over 
incineration  and  landfilling  from  an  environmental 
perspective  for  most  of  the  different  streams  of 
construction  and  demolition  waste.  However,  the 
economics  are  often  unfavourable  for  preparing  for 
reuse  and  recycling  compared  with  incineration  and 
landfilling. If available technology were to be applied, it 
is estimated that the increase in preparing for reuse and 
recycling  would 
lead  to  an  additional  33 Mt  of 
greenhouse gas (GHG) emission savings annually (more 

(12)

(13) 
(14) 

(15) 

https://www.info.gouv.fr/upload/media/organization/00

01/01/sites_default_files_contenu_piece-
jointe_2021_09_20210913_dp_stratgie_recyclage_pia4.pdf. 
https://www.cnrs.fr/fr/pepr/recyclage. 
European Commission: Joint Research Centre, Cristóbal García, 
J., Caro, D. et al., Techno-economic and environmental 
assessment of construction and demolition waste 
management in the European Union, Publications Office of the 
European Union, Luxembourg, 2024, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC13
5470. 
European Commission: Directorate-General for Internal 
Market, Industry, Entrepreneurship and SMEs, EU Construction 
& Demolition Waste Management Protocol including 
guidelines for pre-demolition and pre-renovation audits of 
construction works – Updated edition 2024, Publications Office 
of the European Union, Luxembourg, 2024, 

France  8 

than, for example, the combined annual GHG emissions 
of Estonia, Latvia and Luxembourg). 

The  preparing  for  reuse  and  recycling  rate  of  mineral 
construction  and  demolition  waste  in  France  in  2022 
was  65 %,  compared  with  the  EU  average  of  79.8 %. 
Measures  to  further  increase  the  preparing  for  reuse 
and recycling rate of construction and demolition waste 
include  separate  collection  at  source,  for  instance 
through digitalised pre-demolition audits (15) (‘resource 
assessments’),  EPR  and  other  economic  instruments, 
and upstream measures such as increasing the recycled 
content  in  construction  products  and  the  circular 
design (16) of construction works. 

Boosting implementation – the 2023 Waste Early 
Warning Report 

This  section  focuses  on  the  management  of  municipal 
waste (17),  for  which  EU  law  sets  mandatory  recycling 
targets.  In  June  2023,  the  Commission  published  the 
Waste Early Warning Report (18) identifying the general 
trends in waste management and the Member States at 
risk of missing 2025 waste targets (see Figure 4). France 
is  in  the  category  of  countries  at  risk  of  missing  the 
municipal  waste  target  but  not  the  packaging  waste 
target. 

(16) 

https://op.europa.eu/en/publication-detail/-
/publication/d63d5a8f-64e8-11ef-a8ba-
01aa75ed71a1/language-en. 
European Commission, Circular Economy – Principles for 
buildings design, Brussels, 2020, 
https://ec.europa.eu/docsroom/documents/39984. 
(17)  Municipal waste consists of (i) mixed waste and separately 
collected waste from households, including paper and 
cardboard, glass, metals, plastics, biowaste, wood, textiles, 
packaging, waste electrical and electronic equipment, waste 
batteries and accumulators, and bulky waste, including 
mattresses and furniture; and (ii) mixed waste and separately 
collected waste from other sources, where such waste is 
similar in nature and composition to waste from households 
(Directive 2008/98/EC, Article 3.2b). 
https://environment.ec.europa.eu/publications/waste-early-
warning-report_en.  

(18) 

2025 Environmental Implementation Review – France 

 
 
 
 
Figure 4:  Member  States’  prospects  of  meeting  the 
preparing for reuse and recycling targets for municipal 
waste and packaging waste  

Member  States  not  at  risk  of  missing  the  55 % 
preparing  for  reuse  and  recycling  target  for 
municipal waste and the 65 % recycling target for 
packaging waste 

Member  States  at  risk  of  missing  the  preparing 
for reuse and recycling target for municipal waste 
but not at risk of missing the recycling target for 
packaging waste 

Member states at risk of missing both targets 

Outside coverage 

Source:  European  Environment  Agency  (EEA),  ‘Many  EU  Member 
States not on track to meet recycling targets for municipal waste and 
packaging waste’, briefing No 28/2022, Copenhagen, 2023. Reference 
data © ESRI.  

Under  certain  conditions,  the  EU  waste  legislation 
enables Member States to postpone the deadlines for 
reaching certain waste management targets, notably in 
the  fields  of  municipal  waste,  packaging  waste  and 
landfilling.  Member  States  are  entitled 
the 
postponement if they notify the Commission within the 
deadline set out in EU waste law, and if they submit an 
implementation plan setting out the steps to reach the 
postponed targets within a new time frame. Regarding 
the  2025  targets,  11  Member  States,  not  including 
France, have used this prerogative. 

to 

In  the  Waste  Early  Warning  Report,  the  Commission 
recommended  that  Member  States  accelerate  their 

19  

20  

Directive 2008/98/EC of the European Parliament and of the 
Council of 19 November 2008 on waste and repealing certain 
Directives, Directive - 2008/98 - EN - Waste framework 
directive - EUR-Lex. 
European Parliament and Council Directive 94/62/EC of 20 
December 1994 on packaging and packaging waste (OJ L 365, 
31/12/1994, p. 10–23), Directive - 94/62 - EN - EUR-Lex. 

France  9 

efforts  to  improve  their  recycling  performance.  The 
Commission is, on one hand, working together with the 
national  authorities  and  stakeholders  to  speed  up  the 
implementation  of  measures  necessary  to  meet  the 
targets,  including  through  dedicated  financing.  On  the 
other  hand,  the  Commission  is  pursuing  enforcement 
actions against those Member States, including France, 
that,  based  on  data  submitted  to  the  Commission,  do 
not  achieve  the  targets  of  the  Waste  Framework 
Directive19, 
the  Packaging  and  Packaging  Waste 
Directive20  and  the  Directive  on  Waste  Electrical  and 
Electronic Equipment21 .  

Municipal waste 

Municipal waste generation in France slightly decreased 
between 2010 and 2016 (Figure 5). After an increase in 
2016, which was due to the broadening of the reporting 
scope and changes in the collection of treatment data, 
the generation of waste per capita remained relatively 
stable. In 2022, the country generated 535 kg per capita 
of municipal waste, which is very close to the estimated 
EU-27 average of 513 kg per capita.  

Figure 5: Municipal  waste management  and recycling 
(including preparation for reuse), 2010–2022 

‘Municipal  waste  by  waste  management 
Source:  Eurostat, 
operations’, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/de
fault/table. 

22 October 

accessed 

The  recycling  rate  of  municipal  waste  has  slightly 
increased from 36 % in 2010 to 41 % in 2022 (Figure 6), 
which  is below the  (estimated) EU-27 average of 49 % 
for  the same year. The incineration rate in France  has 
remained  stable,  sitting  at  31 %  in  2022.  In  the  same 

21  

Directive 2012/19/EU of the European Parliament and of the 
Council of 4 July 2012 on waste electrical and electronic 
equipment (WEEE) (OJ L 197, 24.7.2012, p. 38), Directive - 
2012/19 - EN - EUR-Lex 

2025 Environmental Implementation Review – France 

 
 
 
 
 
 
 
 
period, the landfilling rate decreased from 29 % in 2010 
to 23 % in 2022. 

Figure 6:  Recycling  (including  preparation  for  reuse) 
and landfill rates (%), 2010–2022 

the  same  year (25).  This  is  mainly  driven  by  paper  and 
cardboard and glass packaging waste, which represent 
the highest shares of packaging waste. 

Figure 7: Packaging waste generation, 2010–2022 

France  10 

Source: Eurostat, ‘Municipal waste by waste management operations’, 
accessed 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/de
fault/table. 

22 October 

Starting  in  2016,  treated  amounts  have  been  directly 
derived from a survey of treatment facilities instead of 
collectors.  From  reference  year  2020,  new  reporting 
rules  apply  for  calculating  recycled  municipal  waste, 
pursuant to the targets laid down in Article 11.2(c–e) of 
Directive  2008/98/EC.  However,  it  is  unclear  from  the 
information  available  whether  these  new  reporting 
rules have been implemented in France yet. 

In this respect, the Commission started an infringement 
procedure in July 2024 against France for its failure to 
comply  with  waste  targets  in  the  Waste  Framework 
Directive  and  the  Directive  on  Waste  Electrical  and 
Electronic Equipment (22). 

Good transposition of EU waste law is also paramount 
to ensure its successful implementation. In this respect, 
the  Commission  launched  infringement  procedures 
against France for its failure to correctly transpose the 
amended  Waste  Framework  Directive 
(Directive 
2018/851) (23)  and  the  Single-use  Plastics  Directive 
(Directive (EU) 2019/904) (24). 

Source:  Eurostat, 
operations’, 
updated 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__c
ustom_842634/default/table?lang=en. 

‘Packaging  waste  by  waste  management 
2024, 

23 October 

last 

Figure 8: Packaging waste recycling rates (%), 2010–
2022 

Source:  Eurostat, 
updated 
operations’, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__c
ustom_842634/default/table?lang=en. 

‘Packaging  waste  by  waste  management 
2024, 

23 October 

last 

Packaging waste 

France’s  packaging  waste  generation  has  remained 
relatively  stable  since  2010  (Figure 7).  The  country 
generated 188 kg per capita in 2022, which is very close 
to the (estimated) EU-27 average of 186 kg per capita in 

Plastic packaging waste has the lowest recycling rate out 
of  all  packaging  materials  (Figure 8).  The  volume  of 
plastic packaging collected is  limited because separate 
collection is restricted in most municipalities to plastic 
bottles.  Consequently,  the  European  Commission’s 
Waste  Early  Warning  Report  highlights  that  separate 

(22) 

(23) 

INFR(2024)2141;  see  the  July  2024  infringements  package 
(https://ec.europa.eu/commission/presscorner/detail/en/inf_
24_3228). 
INFR(2024)2017;  see  the  April  2024  infringements  package 
(https://ec.europa.eu/commission/presscorner/detail/en/inf_
24_1941). 

(24) 

(25) 

INFR(2024)2096; see the October 2024 infringements package 
(https://ec.europa.eu/commission/presscorner/detail/en/inf_
24_4561). 
The EU average might have been influenced by not all Member 
States fully applying the reporting rules for packaging waste set 
out in Commission Implementing Decision (EU) 2019/665. 

2025 Environmental Implementation Review – France 

 
 
 
 
 
 
 
 
 
 
 
 
 
collection  systems  should  be  extended  and  improved, 
especially  for  plastic  waste.  Legislative  changes  were 
implemented 
the  separate 
in  2022,  mandating 
collection of all plastic packaging and an extension and 
simplification of the sorting instructions and process for 
citizens.  The  effect  of  these  measures  remains  to  be 
seen. 

Policies to encourage waste prevention 

are 

instrumental 

Waste  management  plans  and  waste  prevention 
programmes 
full 
implementation  of  EU  waste  legislation.  They  set  out 
key  provisions  and  investments  to  ensure  compliance 
with existing and new legal requirements (e.g. on waste 
prevention,  on  separate  collection  for  certain  waste 
streams, on recycling and on landfill targets). 

the 

to 

indicators 

France’s  2019  national  waste  prevention  programme 
for  2021–2027  (26)  consists  of  five  key  areas,  with 
specified  sub-targets  and 
to  monitor 
progress. Priority waste streams are household waste, 
food waste, waste from consumer products and waste 
from economic activities, mainly the building and public 
sectors. The programme was updated in January 2020; 
includes  several  measures  to  promote  reuse, 
it 
supported by funds financed through EPR schemes. 

stands  out 

Compared  with  other  Member  States,  France’s 
programme 
comprehensive 
description  of  planned  waste  prevention  actions. 
Nevertheless, 
the 
for 
specific 
implementation of the programme is indicated. 

budget 

for 

no 

its 

France  then  adopted  an Anti-Waste Law  for a  Circular 
Economy  in  2020 (27).  Regional  waste  management 
plans  and  waste  prevention  plans  complement  the 
national plan.  

Policies to encourage separate collection and 
recycling 

More  specifically,  the  Anti-Waste  Law  for  a  Circular 
Economy  aims  at  reusing  and  recycling  60 %  of 
household waste by 2030 and at banning the marketing 
of all single-use plastic packaging by 2040. Furthermore, 
the  national  waste  management  plan  sets  a  target  of 
100 %  separate  collection 
for  household  plastics 
packaging by 2025.  

In France, residual waste and most  types of recyclable 
waste  are  collected  door  to  door.  However,  plastics 

26 

(27) 

https://www.prevention-dechets.gouv.fr/plan-national-

prevention-dechets-ses-objectifs-ses-mesures.html.  
Loi No 2020-105 du 10 février 2020 relative à la lutte contre le 
circulaire 
gaspillage 

l'économie 

et 

à 

France  11 

collection  is  limited  to  plastic  packaging.  From  2025, 
separate collection of biowaste will become mandatory. 

Until now, only 9 % of the French population has been 
covered  by  a  pay-as-you-throw  system  for  waste 
collection. 

France is a pioneer in implementing EPR schemes, which 
are  approved  by  public  authorities  to  reach  the 
collection,  reuse  and  recycling  targets  set  in  decrees. 
The  schemes  are  financed  by  their  members.  In  2021, 
9.4 Mt of waste was collected through the EPR schemes. 
By 2025, there are meant to be 23 EPR schemes covering 
close to all consumer goods. 

Producer responsibility organisations may benefit from 
the introduction of additional support tools to increase 
packaging 
enforcement 
In 
mechanisms will apply if targets are not met. 

recycling. 

return, 

In 2020, the recyclability, recycling and reincorporation 
of materials strategy was launched as part of the France 
improve  the 
Relance  recovery  plan. 
performance  of  secondary  raw  materials  markets  by 
identifying  obstacles  and  points  for  action  at  the 
different stages of the recycling value chain in plastics, 
composite  materials,  textiles,  paper/cardboard  and 
strategic metals. 

It  aims  to 

Policies to discourage landfilling or incineration 

France has a ban on the landfilling of waste collected for 
recycling and waste originating from municipalities and 
economic  actors  without  source  separation  schemes. 
France  also  levies  a  landfill  tax  with  rates  between 
EUR 30/ton and EUR 175/ton depending on the type of 
landfill and waste. The lower end of this range is close 
to  the  EU  average,  and  the higher  end  is  considerably 
higher than the EU average. The landfill tax will further 
increase by 2025. An incineration tax has been in place 
since  2009  and  has  increased  throughout  the  years. A 
substantial  increase  in  the  general  tax  on  polluting 
activities for thermal treatment facilities is planned with 
the  aim  of  making  reuse  and  material  recovery  more 
competitive. In 2025, the rates will increase to between 
EUR 7.5/ton and EUR 25/ton, depending on the energy 
efficiency of the incineration plant. 

There has been some progress in the implementation of 
the 2022 priority actions. New initiatives were launched, 
but  progress  on  the  separate  collection  of  waste 
remains  limited,  and  the  recycling  rate  of  plastic 
packaging remains very low.  

(https://www.legifrance.gouv.fr/jorf/id/JORFTEXT0000415537
59/#:~:text=LOI%20n°%202020%2D105,économie%20circulair
e%20(1)%20%2D%20Légifrance). 

2025 Environmental Implementation Review – France 

 
 
 
 
France  12 

2025 priority actions 

• 

• 

• 

Improve  separate  collection  at  the  source  (e.g. 
through  using  economic  instruments,  investing  in 
infrastructure  for  separate  collection,  sorting  and 
recycling, and increasing public awareness). 
Improve municipal waste preparation for reuse and 
recycling. 
Increase the collection and recycling rate of waste 
electrical and electronic equipment (WEEE). 

• 

• 

• 

Invest in waste prevention measures to reduce the 
total amount of waste generated. 
Implement  and  expand  the  pay-as-you-throw 
system for businesses and households. 
Ensure the achievement of the 2025 waste targets, 
following  the  recommendations  made  by  the 
Commission  in  the  early  warning  reports  where 
applicable. 

2025 Environmental Implementation Review – France 

 
 
 
2. Biodiversity and natural capital

Global and EU biodiversity frameworks 

France  13 

Biological diversity and healthy ecosystems are critical for 
our societies, underpin our economies and well-being and 
are  essential 
for  climate  change  adaptation  and 
mitigation.  The  Kunming–Montreal  global  biodiversity 
in  December  2022,  sets 
framework  (GBF),  adopted 
comprehensive  and  measurable 
tackle 
biodiversity  loss  by  2030.  To  implement  this  global 
framework and integrate biodiversity considerations into 
national decision-making, the EU – as well as all Member 
States – had to submit national biodiversity strategies and 
action plans (NBSAPs), or to communicate national targets 
aligned with the global targets, by the end of 2024. 

targets 

to 

The EU biodiversity strategy for 2030 (BDS) aims to put EU 
biodiversity  on  a  path  to  recovery  by  2030.  It  sets 
quantified targets intended to protect and restore nature 
and manage ecosystems in a sustainable manner, as well 
as measures to enable implementation and commitments 
to  support  global  biodiversity.  A  BDS  actions  tracker (28) 
and a dashboard of indicators (29) provide information on 
implementation progress. 

recently 

adopted 

EU  Nature 

The 
Restoration 
Regulation (30) is the first EU-wide, comprehensive law of 
its kind and a key instrument for the EU to deliver on the 
global  biodiversity  targets  for  2030.  It  lays  down  an 
overarching  objective  at  the  EU  level  to  put  in  place 
effective restoration measures on 20 % of EU land and sea 
by 2030 and for all ecosystems in need of restoration by 
2050. To achieve this, it sets binding targets for Member 
States to restore and maintain ecosystems, as well as an 
effective  implementation  framework  based  on  national 
restoration plans. 

The BDS is the main instrument used by the EU to deliver 
on  its  obligation  under  the  GBF.  The  Commission  has 
submitted  to  the  Convention  on  Biological  Diversity  its 
report on GBF-aligned EU targets that stem from the BDS 
and  from  other  policy  instruments  under  the  European 
Green Deal. 

Member  States’  NBSAPs  need  to  provide  coherent 
frameworks  for  national  delivery  on  the  global  and  EU 
2030  biodiversity  targets. 
line  with  the  global 
obligations,  NBSAPs  should  also  include  a  biodiversity 
financing  plan  and  a  capacity-building  plan,  based  on 
needs assessments, as well as an overview of the national 
indicators used to measure progress. 

In 

in  November  2023, 

France’s  national  biodiversity  strategy  for  2030 (31)  was 
adopted 
following  extensive 
consultations  with  sub-national  authorities  and  citizens, 
and  a  co-creation  process  with  scientists,  sector 
stakeholders and professional organisations. The strategy 
responds  to  the  EU  and  global  biodiversity  targets  for 
2030, and makes links with national strategies, plans and 
legislation in other relevant areas. It sets 40 measures in 
four  key  areas:  (i)  reducing  pressures,  (ii)  restoring 
degraded biodiversity, (iii) mobilising stakeholders and (iv) 
securing the means to deliver results, as well as indicators 
to track progress. In July 2024, France also uploaded these 
measures  to  the  Convention  on  Biological  Diversity’s 
online reporting tool (32). 

The EU aims to allocate to biodiversity objectives at least 
7.5 %  of  annual  spending  under  the  EU  budget  in  2024, 
rising to 10 % in 2026 and 2027. For details on biodiversity 
financing and investments for France, see Chapter 5. 

Nature protection and restoration – Natura 
2000  

Natura  2000 (33),  the  largest  coordinated  network  of 
protected areas in the world, is key to the achievement of 
the objectives set out in the Birds and Habitats Directives. 
These objectives are to ensure the long-term protection, 
conservation and survival of Europe’s most valuable and 
threatened species and habitats and the ecosystems they 
underpin. Key milestones towards meeting the objectives 
of the Birds and Habitats Directives are (i) the setting up 
of a complete and coherent Natura 2000 network; (ii) the 
designation  of  sites  of  community  importance  (SCIs)  as 

(28) 

(29) 

(30) 

Actions 

Tracker 

Strategy 

Strategy 

Dashboard 

Biodiversity 

Biodiversity 

EU 
(https://dopa.jrc.ec.europa.eu/kcbd/actions-tracker/). 
EU 
(https://dopa.jrc.ec.europa.eu/kcbd/EUBDS2030-
dashboard/?version=1). 
Regulation (EU) 2024/1991 of the European Parliament and of the 
Council  of  24 June  2024  on  nature  restoration  and  amending 
(OJ  L,  2024/1991,  29.7.2024), 
Regulation 
the 
http://data.europa.eu/eli/reg/2024/1991/oj; 
Commission 
law 
the 
on 
(https://environment.ec.europa.eu/topics/nature-and-
biodiversity/nature-restoration-law_en). 

(EU)  2022/869 

page 

web 

also 

see 

strategy 

(31)  Government of France, Living in Harmony with Nature – National 
biodiversity 
2023, 
https://www.ecologie.gouv.fr/sites/default/files/documents/Nati
onal-Biodiversity-Strategy-2030.pdf. 
https://ort.cbd.int/national-targets?countries=fr. 

(32) 
(33)  Natura 2000 comprises sites of community importance (SCIs), 

2030, 

Paris, 

designated pursuant to the Habitats Directive, as well as special 
protection areas (SPAs), classified pursuant to the Birds Directive. 
Numbers of protected areas in Figure 9 do not add up to the total 
of SCIs plus SPAs, because some SCIs and SPAs overlap. A special 
area of conservation (SAC) is an SCI designated by a Member 
State. 

2025 Environmental Implementation Review – France 

 
 
special areas of conservation (SACs) (34); and (iii) effective 
management of all Natura 2000 sites through the setting 
of site-specific conservation objectives and measures. 

Figure 9: Natura 2000 terrestrial protected area 
coverage per Member State (%), 2023 

France  14 

Setting up a complete and coherent network of Natura 
2000 sites 

The  setting  up  of  a  complete  and  coherent  network  of 
is  a  cornerstone  of  the  EU’s 
Natura  2000  sites 
international  commitments,  under  the  BDS  and  GBF,  to 
legally protect a minimum of 30 % of its land area and 30 % 
of its sea area by 2030. 

the 

these 

requires 

commitments 

full 
Meeting 
implementation of Article 3 of the Habitats Directive. The 
Natura  2000  network  should  represent  a  complete  and 
coherent  ecological  network  composed  of  sites  hosting 
natural habitat types and species of community interest. 
The  Natura  2000  network  enables  the  natural  habitat 
types  and  the  species’  habitats  concerned  to  be 
maintained  or,  where  appropriate,  restored  to  a 
favourable conservation status in their natural range.  

France  hosts  130  habitat  types  and  291  species (35) 
covered  under  the  Habitats  Directive.  The  country  also 
hosts  populations  of  145  bird  taxa  listed  in  the  Birds 
Directive Annex I (36). 

In  2023,  13 %  of  the  national  land  area  of  France  was 
covered  by  Natura  2000  sites  (EU-27  average:  18.6 %) 
(Figure 9). Special protection areas (SPAs) classified under 
the  Birds  Directive  covered  8 %  of  the  territory  (EU-27 
average:  12.8 %),  with  insufficiencies  for  migratory  birds 
and  in  marine  coastal  areas.  SCIs  under  the  Habitats 
(EU  average:  14.3 %);  an 
Directive  covered  8.9 % 
assessment of their gaps is ongoing. Therefore, France has 
still to complete its Natura 2000 network, in particular the 
marine network. An EU pilot dialogue on assessing gaps is 
ongoing with France. 

On  a  positive  note,  France  legally  protects  28.1 %  of  its 
terrestrial  areas  and  45.3 %  of  its  marine  areas,  beyond 
the EU-27 averages of 26.1 % and 12.3 %, respectively (37). 
This  includes  Natura  2000  sites  and  other  nationally 
designated protected areas. 

France reported 4.2 % of highly protected area in 2023 in 
biodiversity pledges – protected areas. 

Source: European Environment Agency (EEA), ‘Natura 2000 Barometer’, 
2023 data, accessed March 2025, https://www.eea.europa.eu/data-and-
maps/dashboards/natura-2000-barometer. 

Designating special areas of conservation and setting 
site-specific conservation objectives and measures  

To  ensure  that  SCIs  contribute  to  the  objectives  of  the 
Habitats  Directive,  Member  States  must  designate  them 
as SACs, setting site-specific conservation objectives based 
on  the  ecological  needs  of  the  species  and  habitats 
present  on  the  sites.  Such  site-specific  conservation 
objectives  should  define  attributes  and  targets  that 
describe the habitats’ or species’ condition as favourable 
or  unfavourable,  addressing  key  pressures  and  threats. 
Under Article 6 of the Habitats Directive, Member States 
must establish and implement measures to achieve these 
objectives.  

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; and (vii) the stability and expertise of the 
different bodies working on biodiversity, which are based 
around  the  sites  themselves.  France  received  a  Natura 
2000 award in 2024 for the preservation of grazing areas 
in the Pyrenees (38). 

However,  the  Natura  2000  network  still  faces  the 
following gaps in France: (i) the lack of diversification of 

(34) 

(35) 

(36) 

SCIs are  designated pursuant  to  the  Habitats Directive,  whereas 
SPAs  are  designated  pursuant  to  the  Birds  Directive.  Figures  of 
coverage do not add up because some SCIs and SPAs overlap. 
European  Environment  Agency  (EEA),  ‘Number  of  habitats  and 
species  per  Member  State’,  Article 17  dashboard,  Annex I  total, 
19 December 
2019, 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species. 
EEA,  ‘Number  of  bird  species/populations  per  Member  State’, 
Article 12  dashboard,  Annex I  total,  last  updated  11 May  2023, 

(37) 

(38) 

https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-12-national-summary-
dashboards/general-information-on-bird-species-populations. 
 Eurostat dataset env_bio4, protected area percentage for 2022, 
accessed 
2025, 
https://ec.europa.eu/eurostat/databrowser/view/env_bio4/defa
ult/table?lang=en. 
European 
https://environment.ec.europa.eu/news/grazing-preserve-
natura-2000-habitats-and-species-pyrenees-example-france-and-
spain-2024-03-14_en. 

Commission: 

March 

2025 Environmental Implementation Review – France 

 
 
funding  sources;  (ii)  the  underuse  of  the  financial 
instrument  for  the  environment  (LIFE)  programme;  and 
(iii)  insufficient  ecological  connection  between  the  sites. 
The implementation of the Natura 2000 network after the 
transfer in early 2024 of the management competences of 
terrestrial sites to the regions needs to be assessed. 

and 

France  also  does  not  do  enough  to  prevent  damage 
caused  by  agricultural,  forestry  and  fishing  practices 
(Article 6(2) of the Habitats Directive). The quality of the 
objectives and measures assigned to the sites is not always 
sufficient  and  tailored  to  the  ecological  needs  of  the 
designated  habitats 
creates 
uncertainties  when  evaluating  plans  and  projects  under 
Article 6(3). Despite the setting up of a national working 
group  on  the  cumulative  effects  of  marine  renewable 
energy  projects,  other  projects  of  small  dimension  but 
that have a cumulated impact on Natura 2000 sites are at 
risk  of  infringing  Article 6(3).  Finally,  some  evidence 
suggests  that  compensation  under  Article 6(4)  in  France 
may not always be effective (39). 

species. 

This 

Considering the above explanation, there is still progress 
to  be  made  despite  efforts.  In  particular,  the  work 
underway  on  the  Natura  2000  network  at  sea  to 
strengthen the management of sites and develop fisheries 
risk analyses is too slow to complete the work by 2027. 

2025 priority actions 

• 
• 

the 

Complete the Natura 2000 site designation process. 
Finalise 
site-specific 
establishment 
conservation objectives and measures for all Natura 
2000 sites (including by adopting their management 
plans) and ensure their effective implementation. 

of 

Recovery of species 

One objective set by the BDS is that, by 2030, there should 
be no further deterioration in conservation trends or the 
status of any protected species. The BDS also states that 
Member States should ensure that at least 30 % of species 
not  currently  in  favourable  conservation  status  achieve 
that  status  or  show  progress  towards  doing  so  (e.g.  by 
exhibiting  positive  population  dynamics  or  stable  or 
increasing range and habitat size), by 2030. According to 
the  European  Environment  Agency  (EEA),  based  on 
reporting  required  under  Article 17  of  the  Habitats 

(39) 

See the annual  reports of  the Environmental Authority  for 2022 
and 2023 (https://www.igedd.developpement-durable.gouv.fr/le-
rapport-annuel-2023-de-l-autorite-a3369.html); Weissgerber, M., 
Roturier, S., Julliard, R. et al., ‘Biodiversity offsetting: Certainty of 
loss  but  uncertainty  of  the  net  gain’,  Biological 
the  net 
Conservation, 
pp. 200–208, 
https://doi.org/10.1016/j.biocon.2019.06.036;  and  Padilla,  B., 
Gelot, S., Guette, A. et al., ‘La compensation écologique permet-
elle  vraiment  de  tendre  vers  l’absence  de  perte  nette  de 
biodiversité?’,  Cybergeo:  European  Journal  of  Geography,  2024, 
online article, https://doi.org/10.4000/cybergeo.40826.  

Vol. 237, 

2019, 

France  15 

Directive,  a  quarter  of  species  in  the  EU  were  of  good 
conservation status as of 2018 (40).  

One of the primary objectives of the Habitats Directive is 
favourable 
the  maintenance  of  or  restoration  to 
conservation status of all species of community interest. 
Moreover, the Birds Directive also aims to ensure that all 
wild  birds  in  the  EU  enjoy  a  secure  status.  In  order  to 
achieve  these  objectives,  it  will  be  necessary  to  address 
key  pressures  and  threats.  The  Birds  Directive  and  the 
Habitats  Directive  lay  down  a  framework  of  species 
protection rules and rules on the conservation of habitats 
and species in order to combat these threats. 

Under Article 17 of the Habitats Directive, Member States 
are  required  to  report  on  the  conservation  status  of 
habitats and species every six years. The current reporting 
cycle,  covering  the  years  2019  to  2024,  is  due  for 
submission in July 2025. 

In this respect, France has established a species protection 
regime since 1976. It is characterized by a high number of 
protected species (more than 7,000 species are protected 
on all or part of the national territory), going far beyond 
the list of species protected by the “Birds” and “Habitats” 
directives.  However,  some  species  such  as  huntable 
species under the Bird Directive are not protected under 
the French national law. 

In  addition  to  this  regulatory  regime,  France  also 
establishes and implements more than 70 National Action 
Plans  for  the  benefit  of  some  species,  for  which 
conservation France has a particular responsibility.  

However, France is one of the few Member States that still 
allow  hunting  birds  with  nets  and,  in  this  context,  the 
Commission launched an infringement procedure in 2019 
against  France for its infringement  of the Birds Directive 
(41)  concerning  several  means  of  hunting.  However, 
several means of hunting at issue in this infringement case 
are now prohibited in France, following judgments of the 
Court  of  Justice  of  the  EU  and  the  French  supreme 
administrative court (Conseil d'Etat). 

An  infringement  case  was  also  launched  in  2020  for 
France’s  failure  to  correctly  transpose  and  apply  the 
Habitats  Directive (42).  France  fails  to  protect  marine 
species from becoming bycatch, that is, protected species 
such  as  dolphins,  seals,  birds  or  sea  turtles  being 

(40) 

(41) 

(42) 

EEA,  ‘Conservation  status  and  trends  of  habitats  and  species’, 
Article 17 dashboard, last updated 22 August 2023 (19 December 
https://www.eea.europa.eu/en/analysis/maps-and-
2019), 
charts/conservation-status-and-trends-article-17-national-
summary-dashboards-archived. 
INFR(2019)2151;  see  the  January  2023  infringements  package 
(https://ec.europa.eu/commission/presscorner/detail/en/inf_23
_142). 
INFR(2020)4036. 

2025 Environmental Implementation Review – France 

 
 
France  16 

incidentally  captured  in  fishing  gear.  The  case  concerns 
the lack of bycatch monitoring and conservation measures 
but  also  the  lack  of  provisions  on  Natura  2000  sites 
protection  and  on  the  surveillance  of  the  conservation 
status  of  certain  species.  Finally,  the  procedure  covers 
France’s failure to correctly transpose some provisions of 
the Habitats Directive. 

https://www.eea.europa.eu/en/analysis/maps-and-
charts/conservation-status-and-trends-article-17-national-summary-
dashboards-archived. 

A  priority  action  was  mentioned  in  the  2022  EIR  report 
relating to the protection of species, especially cetaceans, 
huntable birds and farmland birds, and large carnivores. 
Some implementation progress has been noticed. 

Figure 10: Assessments of conservation status of 
habitats for the 2007–2012 and 2013–2018 reporting 
periods 

2025 priority actions  

• 

• 

Strengthen the integration of biodiversity actions into 
other  policies,  e.g.  energy,  agriculture,  fisheries, 
forestry,  urban  and 
infrastructure  planning  and 
sustainable  tourism,  and  promote  communication 
between stakeholders. 
Enhance  efforts  to  collect  reliable  data  on  the 
conservation status of habitats and species as well as 
their occurrence at site level. In view of this, consider 
the  creation  of  a  body  in  charge  of  monitoring  and 
reporting, to ensure that data are not provided only 
ad hoc on a contract basis. 

•  Reinforce  action  for  habitats  and  species  with 
for 
increased 
and 

unfavourable  conservation  status 
example, 
connectivity,  better  policy 
integration and increased funding. 

restoration  measures, 

coordination 

through, 

NB: The values shown for 2007–2012 and 2013–2018 are not necessarily 
directly  comparable  because  changes  in  area  conservation  status  in  a 
Member State may result from changes to methods or use of better data, 
rather than reflecting genuine changes. 

Source:  EEA,  ‘Conservation  status  and  trends  of  habitats  and  species’, 
Article 17 
2019,  
dashboard, 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/conservation-status-and-trends-article-17-national-summary-
dashboards-archived. 

19 December 

Figure 11: Assessments of conservation status of species 
for the 2007–2012 and 2013–2018 reporting periods 

Recovery of ecosystems  

Agricultural ecosystems 

The BDS works alongside the common agricultural policy 
(CAP) to support the transition to sustainable agriculture. 

The  strategy  has  set  five  common  agriculture-related 
targets for 2030, namely to: 

— 

— 

— 

— 

— 

reduce by 50 % the overall use of – and risk  from – 
chemical pesticides;  
reduce  by  50 %  the  use  of  more  hazardous 
pesticides;  
reduce  by  50 %  losses  of  nutrients  from  fertilisers 
(which  will  result  in  a  20 %  reduction  in  the  use  of 
fertilisers)  while  ensuring 
is  no 
deterioration of soil fertility; 
restore at least 10 % of agricultural area to have high-
diversity landscape features; and  
increase the area  under organic farming to at least 
25 %.  

there 

that 

NB: The values shown for 2007–2012 and 2013–2018 are not necessarily 
directly  comparable  because  changes  in  area  conservation  status  in  a 
Member State may result from changes to methods or use of better data, 
rather than reflecting genuine changes. 

Source:  EEA,  ‘Conservation  status  and  trends  of  habitats  and  species’, 
2019, 
Article 17 

19 December 

dashboard, 

The CAP and national CAP strategic plans that establish the 
framework for the transition to a sustainable agriculture 
are key instruments to facilitate and strengthen the efforts 
of  European  farmers  to  protect  biodiversity  and  the 
environment at large. The Commission approved Member 
States’ CAP  strategic plans in 2022 for the programming 
period 2023-2027. The CAP is the largest source of funding 

2025 Environmental Implementation Review – France 

 
 
 
 
 
for  the  implementation  of  EU  environment  policy  and 
strategic  plans  should  lead  to  better  protection  of  soil, 
water,  air  quality  and  biodiversity.  The  “Vision  for 
agriculture  and 
food”,  adopted  by  the  European 
Commission in February 2025, sets a roadmap to an agri-
food  system  that  is  attractive,  competitive,  sustainable 
and  fair  for  current  and  future  generations.  To  ensure  a 
sustainable future for EU agriculture, it is crucial that these 
four priority areas are pursued together, and that public 
and private support are adequately targeted toward this 
objective(43). 

sustainable 

While certain CAP result indicators focus on interventions 
favouring 
that 
regenerate the ecosystems, the impact of these measures 
is  difficult  to  assess.  The  uptake  of  the  eco-schemes  is 
voluntary for farmers. 

agriculture 

practices 

The  utilised  agricultural  area  in  France  increased  from 
29 000 000 ha  in  2012  to  29 101 000 ha  in  2017  and 
decreased to 28 577 000 ha in 2023 (44). 

Landscape features are small fragments of non-productive 
and  typically  –  but  not  exclusively  –  semi-natural 
vegetation present in or adjacent to agricultural land. They 
provide ecosystem services and support  for biodiversity. 
The  indicator  ‘share  of  agricultural  land  covered  with 
landscape features’ is the ratio between the area covered 
by landscape features and the area covered by agricultural 
land.  Based  on  the  Land  Use/Cover  Area  Frame  Survey 
landscape  features  estimates,  the  share  of  agricultural 
land  covered  by  non-productive  landscape  features  in 
France is 6.4 %, above the EU average of 5.6 %. 

In  2024,  the  CAP  basic  regulations  were  amended (45) 
regarding,  inter  alia,  the  standards  for  good  agricultural 
and  environmental  condition  of  land.  These  changes 
removed the obligation for  farmers  benefiting  from  CAP 
area-related support to have a minimum share of 3–4 % of 
non-productive area or landscape features in their farms. 
That said, the amended  regulation  does not  remove the 
obligation  under  the  GAEC  8  to  maintain  the  existing 
landscape features and sets out an obligation for Member 
States to establish and provide support for eco-schemes 
covering practices for the maintenance of non-productive 
areas, such as land lying fallow, and for the establishment 
of new landscape features, on arable land. 

(43) 

(44) 

(45) 

https://agriculture.ec.europa.eu/overview-vision-agriculture-

food/vision-agriculture-and-food_en  
Eurostat,  ‘Area  under  organic  farming’,  sdg_02_40,  accessed 
5 December 2024, Statistics | Eurostat 
Regulation (EU) 2024/1468 of the European Parliament and of the 
Council  of  14 May  2024  amending  Regulations  (EU)  2021/2115 
and 
regards  good  agricultural  and 
for  climate, 
environmental  condition  standards,  schemes 
environment and animal welfare, amendment of the CAP strategic 
plans,  review  of  the  CAP  strategic  plans  and  exemptions  from 

(EU)  2021/2116  as 

France  17 

The  recently  adopted  Nature  Restoration  Regulation (46) 
focuses on the restoration of agricultural ecosystems and 
requires Member States to put in place measures that aim 
to achieve an increasing trend at  the national level of at 
indicators  for  agricultural 
least  two  out  of  three 
ecosystems (47).  One  of  these  indicators  is  the  ‘share  of 
agricultural land with high-diversity landscape features. 

Organic  farming  practices  are  highly  beneficial  to 
biodiversity.  As  reported  in  Eurostats  estimated  data  in 
figure 12, it is estimated that 9.87% of France’s land area 
is under organic farming. The figure for 2023 reported by 
France is 10.4%(48), close to the EU average of 10.50%(49). 
France  is  not  contributing  enough  to  the  target  to  have 
25% of the EU’s agricultural land under organic farming by 
2030. 

Figure 12: Share of total utilised agricultural area 
occupied by organic farming per Member State (%), 
2022 

Source:  Eurostat,  ‘Area  under  organic  farming’,  sdg_02_40,  accessed 
5 December 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/t
able?lang=en. 

2025 priority actions 
• 

Implement  eco-schemes  and  agri-environmental 
measures and practices to address the environmental 
needs of France. 
Implement and scale up the uptake of organic farming 
practices. 

(OJ 

L,  2024/1468,  24.5.2024), 

controls  and  penalties 
http://data.europa.eu/eli/reg/2024/1468/oj. 
Regulation (EU) 2024/1991 of the European Parliament and of the 
Council  of  24 June  2024  on  nature  restoration  and  amending 
Regulation 
(OJ  L,  2024/1991,  29.7.2024), 
http://data.europa.eu/eli/reg/2024/1991/oj. 
The  three  indicators  are  ‘grassland  butterfly  index’,  ‘stock  of 
organic carbon in cropland mineral soils’ and ‘share of agricultural 
land with high-diversity landscape features’. 

(EU)  2022/869 

(48)   Observatoire de la production bio - Agence Bio 
(49)    Agriculture biologique au sein de l’union européenne (europa.eu) 

• 

(46) 

(47) 

2025 Environmental Implementation Review – France 

 
 
Soil ecosystems 

Soil is an essential, finite and extremely fragile resource. 
Its  increasing  degradation  poses  a  threat  to  EU  food 
resilience,  adaptation  and 
security  and 
mitigation.  

climate 

The EU soil strategy, adopted in November 2021, aims to 
support soil protection, sustainable soil management and 
the  restoration  of  degraded  soils  to  achieve  the  Green 
Deal objectives as well as land degradation neutrality by 
2030. 

This entails: 
—  preventing further soil degradation;  
—  making sustainable soil management the new 

normal;  

—  taking action for ecosystem restoration.  

The  proposed  directive  on 
soil  monitoring  and 
resilience (50)  aims  to  introduce  the  first  comprehensive 
legislation on the protection of all soils in the EU. Should 
the  Directive  be  adopted,  Member  States  will  have  to 
transpose  it  into  national  legislation  and  implement  it, 
starting with putting in place the governance systems and 
a  sound  monitoring  framework  building  on  existing 
national soil monitoring frameworks. The objective of the 
proposed  directive 
is  to  provide  better  and  more 
comparable  soil  health  data  with  the  view  of  attaining 
healthy soils by 2050. 

Degradation  of  soil  ecosystems  encompasses  several 
aspects. The proposed directive requires Member States 
to  assess  soil  health  according  to  a  set  of  common 
indicators  and  to  define  the  necessary  regeneration 
measures. The area of soil that is sealed is an important 
factor  in  monitoring  land-use  change  and  represents  an 
important pressure on nature and biodiversity. Other soil 
issues  related  to  land  degradation  are  soil  erosion,  soil 
soil 
compaction, 
contamination, soil salinisation and the presence in soil of 
nitrogen  and  phosphorus 
impact 
assessment accompanying the proposal, which builds on 
the  data  available  in  the  EU  Soil  Observatory,  points  to 
some soil degradation issues in France (51). 

in  excess.  The 

soil  organic 

loss  of 

carbon, 

The greatest contributor to France’s unhealthy soils is loss 
of  soil  organic  carbon  in  mineral  soils (52),  which  affects 
18 % of the land. 16 % of the national territory experience 
unsustainable  soil  erosion  by  water,  wind,  tillage  and 

(50) 

(51) 

of 

final 

5 July 

Proposal  for  a  directive  of  the  European  Parliament  and  of  the 
Council  on  soil  monitoring  and  resilience  (Soil  Monitoring  Law), 
COM(2023) 416 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex:52023PC0416. 
Commission staff working document – Impact assessment report: 
Annexes –  Accompanying  the  proposal  for  a  directive  of  the 
European  Parliament  and  of  the  Council  on  soil  monitoring  and 
resilience  (Soil  Monitoring  Law),  SWD(2023) 417  final  of  5 July 
https://environment.ec.europa.eu/system/files/2023-
2023, 

2023, 

France  18 

harvest,  representing  53 %  of  cropland  area.  A  high 
concentration  of  nutrients  in  soils  is  also  an  important 
in  the  northern  and  north-
contributor,  particularly 
western 
soils  containing 
concentrations of nitrogen exceeding 50 kg/ha, and 10 % 
of  soils  containing  concentrations  of  phosphorus 
exceeding 50 mg/kg. 

regions,  with  16 %  of 

Grasslands 

Grasslands are among the most diverse ecosystems in the 
EU; they can contain as many as 80 different plant species 
per  square  metre  and  are  home  to  a  large  variety  of 
animals, ranging from small insects, birds and rodents to 
large herbivores.  Grasslands are essential for agriculture 
and  livestock  herding.  Natural  grasslands  also  play  an 
important  role  in  storing  carbon.  However,  changes  in 
agricultural  practices  and 
land  uses  have  caused 
grasslands to disappear at an alarming rate, making them 
one of Europe’s most threatened ecosystems. 

According  to  France’s  Article 17  reporting,  20.45 %  of 
grassland  habitats  listed 
in  Annex I  of  the  Habitats 
Directive have a favourable conservation status. 59.60 % 
of habitats are reported to be affected by pressures from 
agriculture. 

Wetlands/peatlands 

Wetlands act as water sources and purifiers; they are the 
planet’s  greatest  natural  carbon  stores  and  they  are 
crucial to agriculture and fisheries. Peatlands are a special 
type of wetlands dominated by peat-forming plants such 
as Sphagnum mosses. Nearly all peatlands in the EU are 
habitat  types  listed  in  Annex I  of  the  Habitats  Directive. 
Drained  peatlands  under 
intensive  agricultural  use 
constitute only 3 % of the EU’s utilised agricultural area. At 
the same time, they are responsible for 25 % of the GHG 
emissions  from  the  EU’s  agricultural  sector.  Restoring 
peatlands brings multiple benefits, as peatlands improve 
water  retention  and  quality,  store  carbon,  reduce  GHG 
emissions and increase biodiversity. 

According to France’s Article 17 reporting, only 3.57 % of 
the peatland habitat types listed in Annex I of the Habitats 
Directive  have  a  favourable  conservation  status.  France 
has set a target of restoring 50,000 hectares of wetlands 
by 2026, promoting protection of wetlands and creating 
two Ramsar sites a year53. 

07/IMPACT 
REPORT_ANNEXES_SWD_2023_417_part4.pdf. 

ASSESSMENT 

(52)  De  Rosa,  D.,  Ballabio,  C.,  Lugato,  E.  et  al.,  ‘Soil  organic  carbon 
stocks in European croplands and grasslands: How much have we 
lost  in  the  past  decade?’,  Global  Change  Biology,  Vol. 30,  No 1, 
2023, e16992, https://doi.org/10.1111/gcb.16992. 

(53) 

https://www.ecologie.gouv.fr/sites/default/files/documents

/plan_national_milieux_humides.pdf.  

2025 Environmental Implementation Review – France 

 
 
 
Forest ecosystems 

Forests are important carbon sinks, and conserving them 
is vital if the EU is to achieve climate neutrality by 2050. 
The EU forest strategy for 2030, adopted in July 2021, is a 
plan of actions to promote the many services that forests 
provide. Its key objective is to ensure healthy, diverse and 
resilient  EU  forests  that  contribute  significantly  to  the 
achievement  of  the  EU’s  biodiversity  and  climate 
ambitions.  About  27 %  of  the  forest  area  in  the  EU  is 
covered by habitat types listed in Annex I to the Habitats 
Directive.  Moreover, 
forests  host  several  species 
protected  under  the  Birds  and  Habitats  Directives, 
including  those  for  which  there  is  a  requirement  to 
designate Natura 2000 sites and to protect breeding sites 
and resting places.  

Several  Commission  guidelines  on  forestry  management 
were  published  in  2023.  They  cover  biodiversity-friendly 
afforestation,  reforestation  and  tree  planting;  closer-to-
nature  forest  management;  and  defining,  mapping, 
monitoring and strictly protecting primary and old-growth 
forests.  Further  guidance  on  payment  schemes  for 
ecosystems services has also been published. 

In  2023,  the  Commission  proposed  a  new  forest 
monitoring law (54) that aims to create a comprehensive 
forest  knowledge  base,  address  information  gaps  and 
enable a better response to growing pressures on forests. 

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

In 2020, forests covered 31.5 % of France’s territory (55). 
According to France’s Article 17 reporting, only 17.74 % of 
the  forest  habitat  types  listed  in  Annex I  of  the  Habitats 
Directive  have a  favourable conservation status. 37 % of 
habitats  assessed  are  being  affected  by  pressures  from 
forestry. 

In December 2020, France launched a reforestation plan 
with  the  aim  of  planting  45 000 ha  of  trees,  to  increase 
carbon  storage  capacity  and  repopulate  existing  forests 
suffering  from  climate  change  impacts  and  biological 
degradation (56).  The  plan  was  supported  by  the  EU 
Recovery  and  Resilience  Facility  (RRF).  The  French 
authorities  eventually  adapted  the  financial  eligibility 
conditions  of  this  plan  to  better  integrate  biodiversity 

(54)   Proposal for a Regulation of the European Parliament and of the 
Council on a monitoring framework for resilient European forests, 
COM(2023)728, 
2023, 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2023)728&lang=en 

November 

22 

France  19 

provisions  and  limit  the  use  of  clear-cutting  that  were 
made in the initial stages of the plan. Furthermore, France 
adopted provisions to better articulate Habitats directive 
and forest fire protection system. Since 2021, France aims 
to plant 1 billion trees and renew 10% of its national forest 
area by 2032. 

Figure 13: Conservation status of forests protected under 
the  Habitats  Directive  per  Member  State  (%  of 
assessments), 2013–2018 

Source: Commission staff working document – New EU forest strategy for 
2030, 
eur-
of 
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021SC0652. 

SWD(2021) 652 

16 July 

2021, 

p. 24, 

final 

. 

Among  forest  disturbances  contributing  to  loss  of  forest 
integrity and related biodiversity loss, wildfires constitute 
a  particular  reason  for  concern.  In  2022,  the  EU  saw  a 
record  number  (2 700)  of  wildfires  affecting  more  than 
30 ha, which led to the destruction of 785 605 ha of forest, 
the second highest annual figure recorded. Recent years 
have  also  witnessed  the  occurrence  of  widespread 
uncontrollable  fires  (so-called  megafires),  which  are 
associated with loss of life and an enormous cost in terms 
of  damage  to  the  environment,  businesses  and  society 
(over  EUR 2 billion  annually)  and  carbon  dioxide  (CO2) 
emissions.  Megafires  are  practically  beyond  suppression 
capacity and can be prevented only by an integrated risk 
management  approach.  Wildfires  prevention 
is  also 
essential to preserve resources for the bioeconomy. 

The EU Timber Regulation (EUTR) (57)  prohibits the placing 
on the EU market of illegally harvested timber. 

(55) 
EEA, forest information system for Europe, ‘Countries – FISE 
country  factsheets’,  forest  information  system  for  Europe  website, 
https://forest.eea.europa.eu/countries. 
(56) 

https://agriculture.gouv.fr/francerelance-le-renouvellement-des-
forets-francaises. 

(57)

https://environment.ec.europa.eu/topics/forests/deforestat

ion/regulation-deforestation-free-products_en. 

2025 Environmental Implementation Review – France 

 
 
 
 
 
 
On  29 June  2023,  the  Regulation  on  Deforestation-free 
Products  (EUDR)  entered  into  force  (58).  The  regulation 
seeks  to  guarantee  that  products  in  the  EU  that  are 
produced using any of a list of seven commodities have no 
links to deforestation. The EUDR repeals the EUTR.  

Marine ecosystems 

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  other  Member  States  sharing  the 
same marine region or subregion. These marine strategies 
comprise  different 
to  be  developed  and 
implemented over six-year cycles.  

steps 

in 

Since  the  2022  EIR  report,  no  additional  data  regarding 
Member  States’  set  of  GES  characteristics  for  each 
descriptor 
the  MSFD  have  become  available. 
Nevertheless,  Member  States  had  to  report  updates  by 
October 2024. These will be assessed by the Commission. 
In  this  context,  in  accordance  with  the  MSFD  and  the 
Commission  GES  decision (59),  Member  States  must 
include  as  part  of  their  set  of  GES  characteristics  any 
threshold values for the descriptors in the MSFD that may 
have been established in cooperation with other Member 
States at the EU or regional level (60). 

The  Commission  assessed  the  updated  monitoring 
programme reported by Member States in 2020. At that 
time  their  updates  on  the  elements,  features  and 
parameters  identified  monitoring  gaps.  The  Commission 
recommended that Member States should prioritise work 
to address those gaps at all levels of implementation of the 
MSFD. 

Member States also reported their updated programmes 
of  measures,  which  are  required  under  Article 13  of  the 
MSFD  and  which  must  be  updated  every  six  years.  The 
Commission has assessed Member States’ programmes of 
measures. 

(59) 

(58)   The law will apply to large and medium-sized companies starting 
on December 30, 2025, and to micro and small enterprises starting 
on June 30, 2026. 
Commission Decision (EU) 2017/848 of 17 May 2017 laying down 
criteria  and  methodological  standards  on  good  environmental 
status  of  marine  waters  and  specifications  and  standardised 
methods for monitoring and assessment, and repealing Decision 
2010/477/EU 
(OJ  L  125,  18.5.2017,  p.  43),  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32017D0848.  
Communication  from  the  Commission  of  11 March  2024 – 
Commission notice on the threshold values set under the Marine 
Strategy  Framework  Directive 
(Directive  2008/56/EC)  and 
Commission  Decision  (EU)  2017/848  (OJ  C,  C/2024/2078, 
11.3.2024), 
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=OJ:C_202402078.  
In accordance with Article 17 of Directive 2008/56/EC. 

(61) 

(60) 

France  20 

The  adequacy  of  France’s  updated  programme  of 
measures  is  considered  moderate  or  good  for  most 
descriptors, with D1 standing out as ‘very good’ in contrast 
to D5, which is rated ‘poor’. 

Additional  measures  for  biodiversity  (D1)  are  more 
targeted  towards  specific habitats and species, while for 
sea-floor integrity (D6), direct measures are proposed to 
tackle relevant pressures, including managing activities in 
specific habitats, regulating ship mooring and aiming for 
‘net zero artificialisation’. 

Gaps  remain,  however,  in  particular  for  eutrophication 
(D5), for which no quantitative gap analysis is proposed, 
and underwater noise (D11), for which targeted measures 
addressing specific sources such as shipping and light are 
missing. 

2025 priority action 

•  Report  updates  on  the  assessment  of  the  state  of 
France’s  marine  waters, 
its 
determinations  of  GES (61),  which  are  expected  to 
include any threshold values for the descriptors in the 
MSFD that may have been established in cooperation 
with other Member States at the EU or regional level. 

targets  and 

its 

Prevention and management of invasive alien 
species 

Invasive  alien  species  (IAS)  are  a  major  cause  of 
biodiversity  loss  in  the  EU.  Besides  inflicting  direct  and 
indirect  damage  on  nature  and  the  economy,  some  IAS 
also carry and spread infectious diseases, posing a threat 
to  humans  and  wildlife.  Regulation  (EU)  No 1143/2014 
(the  IAS  Regulation)  aims  to  prevent,  minimise  and 
mitigate  the  adverse  impacts  of  IAS  on  biodiversity.  It 
focuses action on a list of IAS of EU concern (the  ‘Union 
list’), which is regularly updated (62). 

The third update of the Union list (63) entered into force 
on 2 August 2022. The fourth update is in preparation. 

(62) 

(63) 

Implementing  Regulations 

Commission Implementing Regulation (EU) 2016/1141 of 13 July 
2016  adopting  a  list  of  invasive  alien  species  of  Union  concern 
pursuant  to  Regulation  (EU)  No 1143/2014  of  the  European 
Parliament  and  of  the  Council  (OJ  L 189,  14.7.2016,  p. 4),  as 
amended  by  Commission 
(EU) 
2017/1263,  (EU)  2019/1262  and  (EU)  2022/1203,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:02016R1141-
20220802&from=EN. 
Commission Implementing Regulation (EU) 2022/1203 of 12 July 
2022  amending  Implementing  Regulation  (EU)  2016/1141  to 
update the list of invasive alien species of Union concern (OJ L 186, 
13.7.2022, 
https://eur-lex.europa.eu/legal-
p. 10), 
content/EN/TXT/?uri=CELEX%3A32022R1203. 

2025 Environmental Implementation Review – France 

 
 
The IAS Regulation (64) currently lists 88 species subject to 
restrictions  on  keeping, 
importing,  selling,  breeding, 
growing  and  releasing  into  the  environment.  Member 
States  are  required  to  take  measures  to  (i)  prevent  the 
introduction  of  IAS,  (ii)  ensure  early  detection  and  rapid 
eradication of IAS and (iii) manage species that are already 
widespread on their territory. This aligns with target 6 of 
the GBF to reduce the introduction of IAS by at least 50 % 
by 2030 and minimise their impact. 

Preventing  the  introduction  and  spread  of  IAS,  and 
managing  them, 
including  through  eradication  and 
control,  can  result  in  a  substantial  cost  saving.  Studies 
estimate that the total cost of IAS in Europe (damages and 
management)  amounted  to  EUR 116.61 billion  between 
1960 and 2020 (65). More recent studies have put this cost 
at  USD 28 billion  per  year  in  the  EU,  increasing  to 
USD 148.2 billion  by  2040 (66),  and  at  USD 423 billion 
annually at the global level (67).  

The total number of IAS of EU concern in France is 60. This 
includes  44  species  recorded  in  the  previous  EIR  (2021) 
and  16  new  additions.  Of  these  new  additions,  5  were 
already on the EU concern list in 2021, and 11 were added 
later  under  Commission  Implementing  Regulation  (EU) 
2022/1203. 

(64) 

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 (OJ L 317, 4.11.2014, p. 35). 

(65)  Haubrock,  P. J.,  Turbelin,  A. J.,  Cuthbert,  R. N.  et  al.,  ‘Economic 
costs of invasive alien species across Europe’,  NeoBiota, Vol. 63, 
2021, pp. 153–190. 

(66)  Henry, M., Leung, B., Cuthbert, R. N. et al., ‘Unveiling the hidden 
economic  toll  of  biological  invasions  in  the  European  Union’, 
Environmental Sciences Europe, Vol. 35, No 1, 2023, p. 43. 
IPBES (Intergovernmental Science-Policy Platform on Biodiversity 
and  Ecosystem  Services),  Summary  for  Policymakers  –  Invasive 
2023, 
alien 

assessment, 

species 

(67) 

France  21 

Figure 14: Number of IAS of EU concern, based on 
available georeferenced information for France, 2024  

Regarding the 2022 priority actions on IAS, France took the 
necessary  steps  to  fully  comply  with  the  requirements 
specified in Article 13 of the IAS Regulation. 

2025 priority action 

• 

Step  up 
implementation  of  the  IAS  Regulation, 
including  with  regard  to  enforcement  and  the 
capacity of inspection authorities. 

Ecosystem assessment and accounting 

The  BDS  calls  on  Member  States  to  better  integrate 
biodiversity  considerations 
into  public  and  business 
decision-making at all levels and to develop natural capital 
accounting. 

Similarly, target 14 of the GBF (68) aims to ensure the full 
integration  of  biodiversity  and  its  multiple  values  into 
policy  and  planning  and,  as  appropriate,  national 
requires  effective  and  coherent 
accounting.  This 
biodiversity  observation  and  reporting  on  ecosystem 
condition in the EU (69).  

https://www.ipbes.net/document-library-catalogue/summary-
policymakers-invasive-alien-species-assessment. 

(69) 

(68)  Decision 15/4  adopted  by  the  Conference  of  the  Parties  to  the 
Convention  on  Biological  Diversity:  Kunming–Montreal  global 
biodiversity  framework (https://www.cbd.int/doc/decisions/cop-
15/cop-15-dec-04-en.pdf). 
European  Commission:  Joint  Research  Centre  and  EEA,  EU 
Ecosystem Assessment – Summary for policymakers, Publications 
Office 
2021, 
https://op.europa.eu/en/publication-detail/-
/publication/81ff1498-b91d-11eb-8aca-01aa75ed71a1/language-
en. 

European  Union, 

Luxembourg, 

the 

of 

2025 Environmental Implementation Review – France 

 
 
France  22 

The  amended regulation (EU) No 691/2011 on European 
environmental  economic  accounts (70)  introduces  new 
requirements  for  Member  States  to  report  on  the 
condition  of  ecosystems  including  urban  ecosystems, 
croplands,  grasslands,  forest  and  woodlands,  coastal 
beaches,  dunes  and  wetlands.  Data  reported  by  the 
Member  States  will  feed  into  the  second  European 
ecosystem assessment, due in 2027, and can also be used 
to support policy decisions.  

An 
increasing  number  of  platforms,  networks  and 
communities of practice involve businesses in protecting 
biodiversity,  including  the  EU  Business  &  Biodiversity 
Platform (71).  These  platforms  and  communities  are  key 
tools  for  promoting  and  facilitating  natural  capital 
assessments  among  businesses  and  financial  services 
providers. 

Natural  capital  assessments  help  private  businesses  to 
better understand both the negative and positive impacts 
that they have on nature, and to appreciate how nature 
contributes 
their  success.  Such  understanding 
contributes to the implementation of the EU’s BDS. 

to 

Three French business networks are members of the EU 
Business & Biodiversity Platform. A specific business and 
biodiversity network was founded in October 2024 in the 
context of the Conference of the Parties of the Convention 
on Biological Diversity. 

Due  to  the  lack  of  data,  the  assessment  of  the  2022 
priority actions related to the mapping and assessment of 
ecosystems  and  the  development  of  business  and 
biodiversity platforms is not possible. 

(70) 

Proposal for a regulation of the European Parliament and of the 
Council  amending  Regulation  (EU)  No 691/2011  as  regards 
introducing  new  environmental  economic  accounts  modules, 
COM(2022) 329 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=COM:2022:329:FIN. 

11 July 

2022, 

final 

of 

(71) 

The  EU  Business  &  Biodiversity  Platform 
(https://green-
to 
business.ec.europa.eu/business-and-biodiversity_en)  aims 
promote  the  business  case  for  biodiversity  to  businesses  and 
financial institutions through workshops, seminars, reports and a 
cross-media communication strategy. 

2025 Environmental Implementation Review – France 

 
 
 
 
 
France  23 

3. Zero pollution 

Clean air 

EU  clean  air  policies  and  legislation  have  successfully 
reduced  emissions  of  key  air  pollutants  and  significantly 
improved  air  quality,  which  is  now  moving  towards  the 
levels  recommended  by  the  World  Health  Organization 
(WHO).  This  has  resulted  in  clear  health  benefits  and 
reduced adverse impacts on ecosystems and biodiversity. 
However, to achieve the WHO-recommended levels, more 
efforts  are  needed,  including  full  compliance  with  EU 
legislation.  To  guide  these  efforts,  the  EU  zero  pollution 
action plan sets targets for 2030 relative to 2005. These 
are to reduce the health impacts of air pollution by 55 % 
and  to  reduce  the  EU  ecosystems  threatened  by  air 
pollution by 25 %.  

The EU has developed a comprehensive suite of air quality 
policies (72).  These  set  health-based  EU  air  quality 
standards (73)  and  stipulate  Member  States’  national 
emission 
several  air 
pollutants (74).  

reduction  commitments 

for 

The air quality in some parts of France continues to cause 
concern, as underlined by Santé Publique France75. 

The  latest  available  annual  estimates  (for  2022)  by  the 
EEA (76) for France attribute 20 700 deaths each year (or 
214 200 years of life lost (YLL)) to fine particulate matter 
(PM2.5) (77);  5 000  deaths  each  year  (or  51 300 YLL)  to 
nitrogen dioxide (NO2) (78); and 9 000 deaths each year (or 
94 100 YLL) to ozone (79). 

The  emissions  of  several  air  pollutants  have  decreased 
significantly in France since 2005, while GDP growth has 
continued  (see  Figure 15).  According  to  the  inventories 
submitted  under  Article 10(2)  of  the  National  Emission 
Reduction  Commitments  Directive  (NECD) (80)  in  2024, 
France  has  met  its  emission  reduction  commitments  for 

2020–2029 for air pollutants  nitrogen oxides (NOx), non-
methane  volatile  organic  compounds  (NMVOC),  sulphur 
dioxide (SO2), ammonia (NH3) and PM2.5. According to the 
latest  projections  submitted  under  Article 10(2)  of  the 
NECD, France is projected to meet its emission reduction 
commitments  for  2030  onwards  NOx,  NMVOC,  SO2,  NH3 
and PM2.5. 

Figure 15: Emission trends of main pollutants / GDP in 
France (%), 2005–2022 

150%

100%

50%

0%

NH₃

PM2.5

NMVOC

SO₂

NOₓ

GDP

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
25 June 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

(72) 

(73) 

(74) 

75  

(76) 

(77) 

European  Commission,  ‘Air’,  European  Commission  website, 
https://environment.ec.europa.eu/topics/air_en. 
European  Commission,  ‘EU  air  quality  standards’,  European 
Commission 
website, 
https://environment.ec.europa.eu/topics/air/air-quality/eu-air-
quality-standards_en. 
European  Commission,  ‘Reducing  emissions  of  air  pollutants’, 
European 
website, 
Commission 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants_en. 
https://www.statistiques.developpement-durable.gouv.fr/la-
pollution-de-lair-exterieur-en-france-synthese-des-
connaissances-en-2024.  
EEA, Harm to human health from air pollution in Europe: Burden 
of  disease  2024,  briefing  No 21/2024,  Copenhagen,  2024, 
https://www.eea.europa.eu/en/analysis/publications/harm-to-
human-health-from-air-pollution-2024. 
Particulate matter (PM) is a mixture of aerosol particles (solid and 
liquid) covering a wide range of sizes and chemical compositions. 

PM10  refers  to  particles  with  a  diameter  of  10 µm  or  less.  PM2.5 
refers to particles with a diameter of 2.5 µm or less. PM is emitted 
from many human sources, including combustion 

(79) 

(78)  Nitrogen  dioxide  (NO2)  here  pertains  to  a  group  of  gases  called 
NOx, which also comprises nitrogen monoxide (NO). NOx is emitted 
during fuel combustion – for example, from industrial facilities and 
the road transport sector. 
Low-level  ozone 
is  produced  by  photochemical  action  on 
pollution.  This  year,  for  the  first  time,  the  impact  of  long-term 
exposure to ozone has also been taken into account. In previous 
analysis by the EEA, only the impact of short-term exposure was 
estimated. 

(80)  Directive (EU) 2016/2284 of the European Parliament and of the 
Council  of  14 December  2016  on  the  reduction  of  national 
emissions of  certain atmospheric pollutants, amending Directive 
2003/35/EC  and  repealing  Directive  2001/81/EC  (OJ  L 344, 
17.12.2016, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2016.344.01.0001.01.ENG. 

p. 1), 

2025 Environmental Implementation Review – France 

 
 
 
 
Figure 16:  PM2.5  and  NOx  emissions  by  sector  in  France 
(%), 2022 

100%

80%

60%

40%

20%

0%

Waste

Transport

Residential,
commercial &
institutional

Manufacturing
and extractive
industry

Energy supply

Agriculture

PM2.5

7,85%

12,21%

NOₓ

0,38%

54,10%

58,38%

10,13%

15,81%

11,23%

1,15%

4,60%

4,40%

19,76%

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
25 June 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

In  2023,  exceedances  above  the  limit  values  set  by  the 
Ambient Air Quality Directive (AAQD) (81) were registered 
for NO2 in three air quality zones (82) and for PM10 in two 
air  quality  zones (83)  in  France.  Furthermore,  the  target 
values  for  ozone  concentrations  have  not  been  met  for 
several  air  quality  zones,  and  neither  have  the  target 
values for nickel concentrations in one air quality zone (84). 

Persistent  breaches  of  air  quality  requirements,  which 
have  severe  negative  effects  on  health  and  the 
environment,  are  being  followed  up  by  the  European 
Commission through infringement procedures covering all 
Member States concerned, including France. The CJEU has 
delivered two judgments confirming non-compliance with 

(81)  Directive  2008/50/EU  of  the  European  Parliament  and  of  the 
Council of 21 May 2008 on ambient air quality and cleaner air for 
https://eur-
Europe 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32008L0050. 
Paris, Montpellier, Lyon. 

11.6.2008, 

L 152, 

p. 1), 

(OJ 

(82) 
(83)  Mayotte and Marseille-Aix. 
(84) 

European  Environment  Agency,  Eionet  Central  Data  Repository 
(https://cdr.eionet.europa.eu/). 

France  24 

Directive  2008/50/EC,  in  2019  for  exceedances  of  NO2 
limit  values  and  in  2022  for  exceedances  of  PM10  limit 
values (85). Appropriate measures  should be  put  in place 
to  bring  all  air  quality  zones  into  compliance  as  soon  as 
possible. 

the 

that 

emission 

2020–2029 

In the 2022 EIR, France received three priority actions in 
this  area.  The  first  priority  action  was  to  further  reduce 
emissions in the context of  national air pollution control 
programme (NAPCP), which  was updated and submitted 
to  the  Commission 
in May  2023.  France  has  made 
substantial  progress  on  this,  as  the  latest  reported  data 
show 
reduction 
commitments  have  been  met  and  that  the  emission 
reduction commitments  for 2030 onwards  are projected 
to be reached. The second priority action was to ensure 
full compliance with EU air quality standards and maintain 
downward  emission  trends.  Based  on  the  latest  data, 
France  has  made  some  progress  in  this  regard.  S²ince 
2019, downward emission trends have been reported for 
all  main  pollutants.  However,  exceedances  above  limit 
values and target values remain for NO2, PM10, ozone and 
nickel. The third priority action received by France was to 
ratify  the  amended  Gothenburg  Protocol,  which  was 
fulfilled in December 2021. 

2025 priority actions 

•  As part of the NAPCP, take action to reduce emissions 

• 

of air pollutants. 
Ensure  full  compliance  with  the  current  AAQD 
standards, also in light of future stricter requirements 
under the revised AAQD. 

Industrial emissions 

The  main objectives of EU policy on industrial emissions 
are to: 

(i)  protect  air,  water  and  soil  and  to  prevent  harmful 
effects on human health and the environment; 

(ii)  prevent and manage waste; 
(iii)  improve  energy  and  resource  efficiency,  including 

water; 

(iv)  contribute to decarbonisation. 

The  cornerstone  of  the  policy  is  the  Industrial  Emissions 
Directive (IED), which was revised in 2024 (86). The revision 

(85) 

Judgment  of  24 October  2019,  European  Commission  v  French 
Republic,  C-636/18,  EU:C:2019:900;  Judgment  of  28 April  2022, 
European Commission v French Republic, C-286/21, C:2022:319. 

(86)  Directive  2010/75/EU  of  the  European  Parliament  and  of  the 
Council of 24 November 2010 on industrial and livestock rearing 
emissions (integrated pollution prevention and control) (OJ L 334, 
17.12.2010, p. 17), as amended by Directive (EU) 2024/1785 of the 
European  Parliament  and  of  the  Council  of  24 April  2024, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02010L0075-
20240804&qid=1725983863299. 

2025 Environmental Implementation Review – France 

 
 
 
improves the directive’s contribution to the zero pollution 
objective. It has a strong focus on innovation, and builds 
solid  links  between  depollution,  decarbonisation  and 
circularity, making it a key regulatory tool to accompany 
the green transformation of EU industry by 2050. 

average in the EU, they appear to be decoupled from the 
industrial  activity,  which  has  increased  over  the  same 
period (expressed in GVA), as shown in Figure 18. 

Figure 18: Industrial releases of pollutants to water and 
industrial activity in the EU-27 

France  25 

The overview of industrial activities regulated by the IED 
below  is  based  on  data  reported  to  the  EU  Registry  in 
2022 (87). 

In France, there were about 7 000 installations covered by 
the  IED  in  2022,  almost  half  of  them  (48 %)  being 
installations  for  intensive  rearing  of  poultry  or  pigs.  The 
other  main  sectors  are  the  waste  management  sector 
(16 %),  the  food  and  drink  industry  (12 %),  the  metals 
sector (9 %) and the chemicals sector (6 %). 

Figure 17  shows  the  damage  to  health  and  the 
environment due to the main industrial air pollutants. As 
this  depends  on,  among  other  factors,  the  size  of  the 
industrial  sector  in  each  Member  State,  the  figure  also 
shows  the  ratio  between  the  damage  and  the  industrial 
activity  (expressed  in  gross  value  added  (GVA)),  which 
gives an indication of the emissions  ‘intensity’. Although 
France has the third highest damage in the EU, it comes 
16th  for  emissions  intensity,  below  the  EU  average  of 
EUR 27.5/EUR 1 000  GVA. 
industrial 
contributors to emissions to air (88) are the energy sector 
and the mineral sector for nitric oxide (NOX) emissions, the 
waste  management  and  chemical  industries  for  dust 
emissions,  and  the  energy  sector,  the  metals  sector  and 
the  mineral  sector  for  sulphur  dioxide  (SO2)  and  heavy 
metals. 

The  main 

Figure 17: Industrial air pollution damage and intensity 
per Member State, 2021 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
air  pollution  damage  costs  intensity’,  European  Industrial  Emissions 
Portal, 
https://industry.eea.europa.eu/analyse/industrial-
emissions-indicator. 

2024, 

Overall, the industrial emissions to water in the EU have 
decreased  over  time  for  all  the  main  pollutants.  On 

(87) 

European 

Portal, 
Industrial 
EEA, 
https://industry.eea.europa.eu/, 2022 being the baseline year for 
all reports. 

Emissions 

NB: Cd, cadmium; Hg, mercury; Ni, nickel; Pb, lead; total N, total nitrogen; 
total P, total phosphorous. 

Source:  EEA,  ‘Industrial  pollutant  releases to  water  in Europe’,  30 May 
2024, 
https://www.eea.europa.eu/en/analysis/indicators/industrial-
pollutant-releases-to-water. 

Concerning  France  in  particular,  Figure 19  shows  the 
industrial emissions of heavy metals to water, taking into 
account the human toxicity of each metal, as well as  the 
emissions intensity, based on its ratio with the industrial 
activity  (expressed  in  GVA).  France  has  the  sixth  highest 
amount of emissions of heavy metals to water, and is in 
14th  position  for  emissions  intensity  (below  the  EU 
average 
intensity  of  0.864 kg/EUR 1 billion  GVA).  As 
shown  in  Figure  20,  the  main  industrial  contributors  to 
emissions to water in France are the chemicals sector for 
heavy metals, nitrogen and total organic carbon, the pulp 
and  paper 
industry  for  phosphorus,  and  the  metal 
production and processing sector for polycyclic aromatic 
hydrocarbons. 

(88) 

European  Environment  Agency,  LRTAP,  Air  pollutant  emissions 
data viewer (Gothenburg Protocol, LRTAP Convention) 1990-2022, 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/air-pollutant-emissions-data-viewer-1990-2022. 

2025 Environmental Implementation Review – France 

 
 
 
 
 
 
France  26 

mandatory  requirements  on  environmental  inspections, 
requiring  a  site  visit  to  take  place  at  least  every  one  to 
three  years,  using  risk-based  criteria.  In  addition,  IED 
enforcement  provisions  require  Member  States  to 
determine  effective,  proportionate,  and  dissuasive 
penalties  applicable  to 
IED-based 
national provisions. In the revised directive, the provisions 
set that worst infringements can be sanctioned by fines of 
at least 3% of the annual EU turnover of the legal person. 
The  revised  IED  also  introduces  a  right  to  compensation 
for  people  whose  health  has  been  harmed  by  such 
infringements. 

infringements  of 

The development of best available techniques (BATs), BAT 
reference  documents  and  BAT  conclusions  ensures 
effective collaboration between stakeholders and enables 
better implementation of the IED. 

Since  the  2022  EIR,  the  Commission  has  adopted  BAT 
conclusions on (i) ferrous metal processing, (ii) the textiles 
industry,  (iii)  common  waste  gas  management  and 
in  the  chemical  sector  and  (iv) 
treatment  systems 
smitheries and foundries. 

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  2022,  France  received  priority  actions  to  address 
pollution from metal production and processing. Data are 
not yet available to assess progress on this priority action. 
Two installations in this sector in France were among the 
in  2021 (90).  The 
top  30  emitters  of  air  pollutants 
Commission  adopted  new  BAT  conclusions  for  ferrous 
metal processing in 2022 and will start the revision of the 
BAT conclusions for iron and steel production in 2026. 

2025 priority actions 

•  Reduce industrial air pollution damage and intensity. 
•  Reduce 
industrial  releases  to  water  and  their 

• 

• 

intensity. 
Engage  with  industry  and  environmental  NGOs  to 
ensure proper contribution to and implementation of 
BAT conclusions and ensure timely updates to permits 
following the publication of BAT conclusions. 
Ensure  effective  public  participation  and  access  to 
justice in relation to the IED. 

Figure 19: Industrial releases and intensity of heavy 
metals to water per Member State, 2022 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
water  pollution  intensity’,  European  Industrial  Emissions  Portal,  2024, 
https://industry.eea.europa.eu/analyse/industrial-emissions-indicator. 

Figure 20: Relative releases to water from industry in 
France (%), 2022 

100%

75%

50%

25%

0%

Heavy Metals
Ecotoxicity

Heavy Metals
Human
Toxicity

Polycyclic
aromatic
hydrocarbons
(PAHs)

Total nitrogen Total organic
carbon (TOC)

Total
phosphorus

Chemicals
Extractive industry
Food and drink
Landfill
Non-ferrous metal
Other manufacturing
Pulp, paper and wood

Electricity and heat production
Ferrous metal
Incineration with energy recovery
Livestock
Non-metallic minerals
Other waste management
Refineries

Source: EEA, ‘Industrial reporting under the Industrial Emissions Directive 
2010/75/EU  and  European  Pollutant  Release  and  Transfer  Register 
Regulation (EC) No 166/2006 – ver. 12.0 Sep. 2024 (tabular data)’, EEA 
2024, 
Catalogue, 
Geospatial 
https://doi.org/10.2909/cf5e54c1-be99-4426-bcad-baa26c4f27a0. 

13 September 

Data 

France launched in 2023 a campaign measuring per- and 
polyfluoroalkyl  substances  (PFAS)  in  emissions  to  water 
from industrial installations, as part of a wider PFAS action 
plan (89). 

IED  provisions  on  public  information  and  participation 
require Member States to adopt transposition legislation 
enabling members of the public to have access to relevant 
information  and  participate  in  the  approval  process  for 
potentially  polluting  installations.  Thus,  the  public  and 
(NGOs),  alongside 
non-governmental  organisations 
competent authorities, play a role in ensuring compliance 
of  these  permits  with  EU  legislation.  The  IED  contains 

(89) 

(90) 

https://presse.economie.gouv.fr/plan-dactions-interministeriel-
sur-les-pfas/. 
EEA, The costs to health and the environment from industrial air 
in  Europe –  2024  update,  briefing  No 24/2024, 
pollution 

Copenhagen, 
https://www.eea.europa.eu/publications/the-cost-to-health-
and-the. 

2024, 

2025 Environmental Implementation Review – France 

 
 
 
 
 
Major industrial accidents prevention – Seveso 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to:  

(i)  control  major-accident  hazards  involving  dangerous 

substances, especially chemicals;  

(ii)  limit the consequences of such accidents for human 

health and the environment;  

(iii)  continuously 

improve 

the 

prevention 

of, 

preparedness for and response to major accidents.  

The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso III Directive (91).  

The overview below of industrial plants regulated by the 
Seveso III Directive (‘Seveso establishments’) is based on 
data  reported  on  eSPIRS  (e-Seveso  Plants  Information 
Retrieval  System)  for  2022–2024 (92)  and  the  report  by 
France on the implementation of the Seveso III Directive 
for 2019–2022.  

In  France,  in  September  2024,  of  the  1 300  Seveso 
establishments,  620  were  lower-tier  establishments  and 
680  were  upper-tier  establishments  (UTEs),  with  more 
stringent  requirements  proportionate  to  the  risks  they 
represent (e.g. the obligation to produce a safety report 
and emergency plans, and more frequent inspections). 

Figure 21: Number of Seveso establishments in France, 
2018, 2022 and 2024 

NB: LTE, lower-tier establishment. 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
https://op.europa.eu/en/publication-detail/-
Luxembourg, 
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 

2022, 

France  27 

reports  on 
2024;  Analysis  and  summary  of  Member  States' 
implementation of Directive 2012/18/EU on the control of major accident 
hazards  involving  dangerous  substances  according  to  the  format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en 

Member  States  are  required  to  draw  up  external 
emergency plans (EEPs) for UTEs. These EEPs are essential 
to allow proper preparation and effective implementation 
of the actions necessary to protect the environment and 
the  population should  a  major  industrial  accident  occur. 
According  to  France  own  figures,  in  2022,  an  EEP  was 
required for 630 UTEs, out of 686 in total. 

Figure 22: Situation regarding EEPs in France, 2022 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
2014/896/EU 
Implementing  Decision 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States' 
reports  on 
implementation of Directive 2012/18/EU on the control of major accident 
hazards  involving  dangerous  substances  according  to  the  format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en 

The  following  types  of  information  are  permanently 
available for all the Seveso UTEs in France: (i) information 
for  the  public  referred  to  in  Annex V  to  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) the date of the last site visit. 

The  shares  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  was  actively  made 
available to the public in 2022 in the EU-27 are presented 
in Figure 23. This provision on knowledge is an important 
provision of the Seveso III Directive, as awareness by the 

(91)  Directive  2012/18/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  the  control  of  major-accident  hazards 
involving  dangerous  substances,  amending  and  subsequently 

(92) 

repealing  Council  Directive  96/82/EC  (OJ  L 197,  24.7.2012,  p. 1), 
https://eur-lex.europa.eu/eli/dir/2012/18/oj. 
https://espirs.jrc.ec.europa.eu/en/espirs/content; data extracted 
in September 2024. 

2025 Environmental Implementation Review – France 

 
 
 
 
 
public  of 
consequences of a major industrial accident. 

information  may  ameliorate 

this 

France  28 

the 

• 

Ensure full and correct transposition of the Seveso III 
Directive. 

Figure 23: Share of UTEs for which information on safety 
measures and requisite behaviours was actively made 
available to the public per Member State (%), 2022 

NB: No data available for Greece. 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
involving 
2012/18/EU  on  the  control  of  major  accident  hazards 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States' 
reports  on 
implementation of Directive 2012/18/EU on the control of major accident 
hazards  involving  dangerous  substances  according  to  the  format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

The conformity of how the Seveso III Directive was turned 
into national legislation in France has been assessed, and 
there  is  currently  an  ongoing  infringement  case  on 
citizens’ rights to access information and to participate in 
decision-making. 

In  2022,  France  received  a  priority  action  to  strengthen 
monitoring  and  enforcement  to  ensure  compliance  with 
Seveso III  Directive  rules,  especially  on  EEPs  and 
information  to  the  public.  Data  reported  on  the 
implementation  of  the  directive  for  2019–2022  show  an 
improvement in the number of EEPs established for UTEs 
in France. 

2025 priority actions 
• 

Ensure  access  to  transparent  and  clear  information 
for citizens on risks and behaviour in the event of an 
accident. 

(93) 

https://www.gendarmerie.interieur.gouv.fr/gendinfo/sur-le-
terrain/immersion/2024/lutte-contre-l-orpaillage-illegal-en-
guyane-quel-bilan. 

Mercury Regulation 

The  Mercury  Regulation  establishes  measures  and 
conditions concerning the use and storage of and trade in 
mercury,  mercury  compounds  and  mixtures  of  mercury, 
the manufacture and use of and trade in mercury-added 
products and the management of mercury waste, in order 
to ensure a high level of protection of human health and 
the  environment  from  anthropogenic  emissions  and 
releases of mercury and mercury compounds. The revision 
of the Mercury Regulation adopted in 2024 sets out rules 
to address the last intentional uses of mercury in the EU 
by  phasing  out  the  use  of  dental  amalgam  by  1 January 
2025 except when deemed strictly necessary by the dental 
practitioner  based  on  the  specific  medical  needs  of  the 
patient,  and  prohibiting  the  manufacture  and  export  of 
additional mercury-containing lamps from 1 January 2026 
or 1 January 2027 (depending on the lamp category).  

In France, French Guiana is the only territory where gold 
mining  is  a  concern.  An  order  prohibiting  the  use  of 
mercury was issued on 8 June 2004, considering the risks 
of  contamination  of  ecosystems  by  mercury  and  its 
consequences on the health of populations and workers. 
Consequently,  the  use  of  mercury  for  gold  mining  in 
French Guiana has been prohibited since 1 January 2006. 
However,  illegal  gold  panning  persists  in  French  Guiana 
and mercury is frequently used in this process. The region 
set  up  a  specific  administrative  and 
judicial  police 
operation, called Harpie, dedicated to the fight against this 
activity in 2008. The main field of action of this operation 
consists of destroying the production tools of illegal gold 
miners.  However,  despite  its  effective  implementation 
through  interministerial  cooperation  and  cooperation 
with  the  armed  forces,  Harpie  makes  it  possible  only  to 
reduce the development of new sites, not to eradicate the 
activity  as  such.  According  to  2024  information,  there 
were 600 illegal gold mining sites in 2010, and 300 in 2024, 
with the number staying relatively stable for the last three 
years (93). 

To implement the Mercury Regulation, France has had to 
regulate all industries using large amounts of mercury. In 
mainland  France,  the  main  sector  to  address  was  the 
chloralkali industry, which used mercury catalysts but has 
now switched to a new process. Chloralkali facilities are all 
classified as Seveso establishments in French regulations 
and are regularly visited by environmental inspectors. Of 
the last three facilities using mercury, two changed their 
process and one closed in 2017. The three plants sent the 

2025 Environmental Implementation Review – France 

 
 
 
France  29 

remaining mercury to Batrec, Switzerland, in 2017, 2018 
and  2019.  The  quantities  in  2018  and  2019  totalled  less 
than 50 t. 

In 2019, 25 % of the dental treatments in France were still 
using  dental  amalgam.  It  is  important  to  quicky  put  in 
place  the  necessary  measures,  such  as  an  adequate 
reimbursement  of  the  alternatives  to  dental  amalgam 
through the health insurance scheme and the training of 
dental practitioners, to ensure a socially and economically 
sound  phase-out.  France  also  needs  to  ensure  that  the 
manufacture and export of mercury-containing lamps are 
prohibited  by  the  deadlines  set  out  in  the  Mercury 
Regulation. 

2025 priority action 
• 

Take  effective  action  against  illegal  gold  mining  in 
French Guiana. 

Noise 

The Environmental Noise Directive (94) requires a common 
approach to avoid, prevent and reduce the harmful effects 
of  noise.  The  designated  authorities  are  responsible  for 
making  and  approving  noise  maps  and  action  plans  for 
agglomerations,  major  roads,  major  railways  and  major 
airports.  Member  States  decide  on  noise  limits  that  are 
not  set  at  the  EU  level.  Nevertheless,  the  zero  pollution 
action  plan  sets  as  a  2030  target  a  30 %  reduction 
compared  with  2017  in  the  share  of  people  chronically 
disturbed by transport noise. 

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 stress (95). 

In  France,  environmental  noise  is  estimated  to  cause  at 
least  around  6 500  cases  of  ischaemic  heart  disease 
annually (96)  and  some  854  000  people  to  suffer  from 
disturbed sleep(97). 

Based  on  the  latest  set  of  information  analysed,  France 
has  completed  its  noise  mapping  of  roads,  railways  and 

airports, but its noise mapping of agglomerations remains 
incomplete. 

Action  plans  for  noise  management  for  agglomerations, 
roads,  railways  and  airports  must  be  updated  and 
submitted  to  the  Commission  every  five  years.  The 
deadline for reporting noise action plans under the most 
recent  reporting  cycle  was  18 January  2025;  these  plans 
have not been assessed yet. 

In July 2024, the Commission decided  to refer  France to 
the  CJEU  for  failure  to  comply  with  the  requirements  of 
the  Noise  Directive,  in  particular  with  regard  to  missing 
action plans for agglomerations and major roads (98). 

France  received  a  priority  action  in  the  2022  EIR  to 
complete  and/or 
implement  action  plans  on  noise 
management. Given that reporting under the most recent 
reporting  cycle  for  noise  action  plans  was  due  in  early 
2025, these plans have not yet been assessed. Therefore, 
this priority action has been repeated for the 2025 EIR and 
another one on noise mapping has been added. 

2025 priority actions 

•  Complete noise mapping. 
•  Complete  and  implement  action  plans  on  noise 

management. 

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures on transitional waters, coastal waters and fresh 
water  (including  surface  waters  and  groundwater)  be 
significantly reduced. Achieving, maintaining or enhancing 
a  good  status  of  waterbodies  as  defined  by  the  Water 
Framework Directive will ensure that EU citizens and the 
environment 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. 

(94)  Directive  2002/49/EC  of  the  European  Parliament  and  of  the 
Council  of  25 June  2002  relating  to  the  assessment  and 
management  of  environmental  noise –  Declaration  by  the 
Commission  in  the  Conciliation  Committee  on  the  directive 
relating  to  the  assessment  and  management  of  environmental 
noise (OJ L 189, 18.7.2002, p. 12), https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32002L0049. 

(95)  WHO,  Environmental  Noise  Guidelines  for  the  European  Region, 
Copenhagen, 
2018, 
https://www.who.int/europe/publications/i/item/978928905356
3. 
These figures are an estimation by the EEA based on (i) the data 
reported  by  Member  States  on  noise  exposure  covered  by 
Directive 2002/49/EC for the round of noise mapping of 2022; (ii) 
European  Topic  Centre  on  Air  Pollution,  Transport,  Noise  and 
Indicators  under  the 
Industrial  Pollution  (ETC/ATNI),  Noise 

(96) 

Environmental Noise Directive 2021: Methodology for estimating 
missing  data,  Eionet  report  ETC/ATNI  No 2021/06,  Kjeller,  2021; 
and  (iii)  the  methodology  for  health  impact  calculations  in 
European  Topic  Centre  on  Air  Pollution  and  Climate  Change 
Mitigation  (ETC/ACM),  Implications  of  environmental  noise  on 
in  Europe,  Eionet  report  ETC/ACM 
health  and  wellbeing 
No 2018/10, 
2018, 
https://www.eionet.europa.eu/etcs/etc-atni/products/etc-atni-
reports/eionet_rep_etcacm_2018_10_healthimplicationsnoise.  

Bilthoven, 

(97)  More information on the adverse health effects of noise pollution 

(98) 

is available at: 
https://www.eea.europa.eu/themes/human/noise/noise-2 
INFR(2013)2006;  see  also  the  press  release  about  the  decision 
(https://ec.europa.eu/commission/presscorner/detail/en/ip_24_
3741). 

2025 Environmental Implementation Review – France 

 
 
  
Water Framework Directive 

Directive 

The Water Framework Directive (99) is the cornerstone of 
EU  water  policy  in  the  21st  century (100).  The  Water 
other  water-related 
and 
Framework 
directives (101) form the basis of sustainable and integrated 
water management in the EU. They aim to achieve a high 
level  of  protection  of  water  resources,  prevention  of 
further  deterioration  and  restoration  to  good  status. 
These  objectives  are  very 
important  for  the  EU’s 
competitiveness,  strategic  autonomy  and  security,  yet 
have become even more challenging in the face of climate 
change affecting our precious water resources. 

The Water Framework Directive establishes a procedural 
framework for reaching good surface water ecological and 
chemical  status  and  good  groundwater  quantitative  and 
chemical status. This implies monitoring and classification 
of all waterbodies, assessment  of pressures and impacts 
and identification of the most cost-effective measures to 
achieve the objectives of the directive. The directive dates 
from 2000 and set an initial deadline of 2015 for achieving 
its objectives, with the option to extend the deadline to 
the  end  of  2027.  Every  six  years,  Member  States  must 
report their river basin management plans (RBMPs) to the 
Commission. They should cover river basin districts in their 
countries,  some  of  which  may  be  shared  with  other 
countries. The Commission has assessed the third cycle of 
RBMPs, which were to be submitted by March 2022, and 
reported  its  findings  to  the  European  Parliament  and  to 
the Council on 4th February 2025102. 

France’s  14  river  basin  districts  count  11 406  surface 
waterbodies  plus  689  groundwater  bodies.  7 %  of  all 
surface  waterbodies  are  heavily  modified,  and  for  lakes 
this  percentage  is  68 %.  2 %  of  surface  waterbodies  are 
artificial,  with  lakes  again  having  the  biggest  proportion 
(15 %). 

Figures  24  to  27  show  the  change 
in  ecological 
status/potential  and  chemical  status  of  surface  waters, 
and the quantitative and chemical status of groundwater 
in  2010,  2015  and  2021.  Heavily  modified  and  artificial 
waterbodies must reach good ecological potential rather 
than  good  ecological  status,  which  means  that  all 
measures must be taken to mitigate the adverse impact of 

(99) 

https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32000L0060. 

(100)  https://environment.ec.europa.eu/topics/water_en. 
(101)  These 

include 

the  Groundwater  Directive 

(https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32006L0118), 
the  Environmental  Quality  Standards  Directive  (https://eur-
lex.europa.eu/eli/dir/2008/105/oj), 
Directive 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32007L0060), the Bathing Water 
(https://eur-lex.europa.eu/legal-
Directive 
content/EN/TXT/?uri=celex%3A32006L0007), 
Urban 
Wastewater 
(https://eur-
Directive 
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31991L0271), 

Treatment 

Floods 

the 

the 

France  30 

the sustainable human development activities causing the 
waterbody  to  be  heavily  modified /  artificial,  while  not 
significantly affecting these activities. 

It follows from the assessment of the third RBMPs that the 
ecological  status/potential  of  surface  waterbodies  in 
France has slightly deteriorated since the second RBMPs, 
with  43.6 %  in  good  or  high  ecological  status/potential. 
This small decrease from 44.2 % in the  second RBMPs  is 
due  to  improved  monitoring  in  French  Guiana,  which  is 
home to 8 % of all surface waterbodies. 68 % of all surface 
waterbodies  have  good  chemical  status,  when  uPBT  are 
included. 

Figure 24: Ecological status/potential of surface 
waterbodies (SWB) in each RBMP cycle (%) 

Hydromorphological  pressures  affect  65 %  of  French 
waterbodies and are therefore the most significant type of 
pressure.  Pressures 
flood  protection, 
hydropower, transport, urban development or other uses. 
Diffuse  pollution  affects  56%  of  surface  water  bodies, 
among which 41% relate to pesticides and nutrient diffuse 
pollution from agriculture. 

result 

from 

the 

Directive 

(https://eur-

Drinking  Water 

the 
new 
lex.europa.eu/legal-
Nitrates 
content/EN/TXT/?uri=CELEX%3A32020L2184), 
Directive 
(https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=celex%3A31991L0676), the Marine Strategy 
(https://eur-lex.europa.eu/legal-
Framework 
Directive 
content/en/TXT/?uri=CELEX%3A32008L0056) 
IED 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010L0075). 
https://webgate.ec.europa.eu/circabc-ewpp/ui/group/c04f478b-
d4dc-44f9-a211-087c01165b2c/library/faada4be-9fc3-4a48-
b972-f71e356019d5?p=1&n=10&sort=modified_DESC.  

and 

the 

102 

2025 Environmental Implementation Review – France 

 
 
 
 
 
Figure 25: Chemical status of surface waterbodies in 
each RBMP cycle (%)  

Figure 27: Chemical status of groundwater bodies in 
each RBMP cycle (%) 

France  31 

(PAHs), 

Failure to achieve good chemical status (in 32 % of surface 
waterbodies)103 is mainly attributed to polycyclic aromatic 
and 
hydrocarbons 
perfluorooctanesulfonic acid. PAHs are caused by various 
kinds of combustion processes and affect more than 70 % 
of  the  waterbodies.  Two  pesticides,  namely  isoproturon 
and  cypermethrin,  also  cause  failure  to  achieve  good 
chemical status. 

mercury 

Figure 26: Quantitative status of groundwater bodies 
(GWB) in each RBMP cycle (%) 

consideration 

least  10.6 %,  this 

11.9 %  of  groundwater  bodies  have  poor  quantitative 
is  for  reasons  of 
status.  For  at 
abstractions  exceeding 
the  available  groundwater 
resource. The situation has slightly deteriorated since the 
second  RBMPs,  partly  because  of  improved  monitoring 
groundwater-dependent 
and 
ecosystems.  A  recent  increase  (mainly  for  irrigation 
purposes)  in  the  construction  of  off-stream  reservoirs, 
which  are  filled  with  groundwater  in  the  winter,  may 
impact the quantitative status of groundwater, especially 
as the replenishment is structurally decreasing as a result 
of climate change. 

of 

The  top  five  pollutants  causing  failure  to  achieve  good 
chemical  status  are  pesticides  and  their  relevant 
total 
metabolites,  nitrates, 
trichloroethylene 
and 
phosphate. Nitrates, pesticides and electrical conductivity 
show  sustained  upward  trends.  This  shows  that  the 
pressures from agriculture are sustained. 

chloride,  ammonium, 
tetrachloroethylene, 

and 

Until the end of 2027, Member States can still apply time-
related  exemptions,  subject  to  providing  evidence  of 
compliance  with  the  strict  criteria  set  out  in  the  Water 
Framework  Directive.  After  2027,  the  possibilities  for 
applying exemptions will be much more limited. 

The 2022 EIR had identified the following priority actions. 

•  Assess new physical modifications to waterbodies in 
line  with  Article 4(7)  of  the  Water  Framework 
Directive. 
Improve the quality of water, in particular water that 
has  been  polluted  by  nitrates  in  groundwater  from 
agriculture. 

• 

large  number  of 

France  has  made  some  progress,  and  a  positive  note  is 
that  the  third  RBMPs  provide  both  basic  measures  and 
supplementary measures. There are measures addressing 
a 
individual  substances  to  reduce 
pressures  from  industrial  and  wastewater  discharges. 
10 % of agricultural land is  used for  organic farming and 
France intends to double this to 18 % by 2027 with  CAP 
support. After the extreme long drought of 2022, France 
adopted  the  water  plan  (the  “Plan  Eau”),  with  53 
measures to reduce water use in all sectors. In particular, 
measures to increase water efficiency were taken by the 
50  biggest  industrial  sites.  Intelligence  is  also  being 
actively considered by the French authorities and debated 
with stakeholders on options to reduce water demand104 
over the 2050 horizon. 

103  

Surface waters chemical status | WISE Freshwater, corrected with 
Guiana 

104  

France  Stratégie  explore  les  futurs  possibles  de  la  demande  en 
eau : La demande en eau - Prospective territorialisée à l’horizon 
2050 | France stratégie 

2025 Environmental Implementation Review – France 

0%20%40% 0% 0%100%1st2nd3rdS B chemical status for FRGoodFailing to achieve goodUnknown 
 
 
 
 
 
France  32 

2025 priority actions 

2025 priority actions 

Without prejudice to the list of recommended actions in 
the Commission report to the European Parliament and to 
the  Council  on  the  assessment  of  the  third  RBMPs,  the 
following priority actions can be highlighted: 

• 

• 

• 

• 

• 

• 

Improve  river  continuity  and  ecological  flows, 
boosting efforts on nature-based solutions to reduce 
hydromorphological pressures 
Ensure  periodic  reviews  of  permits  for  discharges, 
abstractions  and  other  water  uses, 
including 
hydropower pressures 
Reduce pollution from nutrients, chemicals,  metals 
and saline discharges 
Better  justify  exemptions  to  the  achievement  of 
good status  
Improve  the  classification  of  water  bodies  and 
strengthen monitoring systems 
Develop  more  robust  programmes  of  measures, 
tackle obstacles identified in the implementation of 
for 
measures  and  ensure  adequate 
implementation, including through better use of the 
cost recovery and polluter pays principle 

financing 

Floods Directive 

Every six years, following the same reporting cycle as the 
RBMPs,  all  Member  States  also  report  their  flood  risk 
management  plans  (FRMPs),  based  on  the  flood  hazard 
and risk maps and the preliminary flood risk assessments 
drawn up during the second cycle (2016–2021). 

The  Commission  assessed  the  FRMPs  and  reported  its 
findings to the European Parliament and to the Council on 
4th  February  2025,  together  with  the  assessment  of  the 
RBMPs. 

The second FRMPs have improved insofar as they clearly 
assess the impacts of flood risk management measures on 
the environment, including natural/protected areas. They 
also outline measures to address the expected effects of 
climate  change  on  the  likelihood  and  potential  adverse 
consequences of flooding. 

• 

• 

• 

FRMPs  should  provide  details  on  how  the  FHRMs 
were  used  in  the  choice  of  measures  and  how  to 
consider pluvial flooding 
Better  explain  the  choice  and  implementation  of 
flood  prevention 
and  protection  measures 
(prioritisation, monitoring, costs of measures) 
Improve  public  consultation  and 
involvement. 

stakeholder 

Drinking Water Directive 

The  objectives  of  the  directive  are  to  protect  human 
health  by  ensuring  the  quality  intended  for  human 
consumption, and to improve access to drinking water. 

The recast Drinking Water Directive is now applicable, and 
Member States were required to transpose its provisions 
into  their  national  legal  systems  by  12 January  2023. 
France  has  communicated  its  transposition  measures  to 
the Commission within the deadlines set by the directive. 
Since  the  entry  into  force  of  the  recast  directive,  the 
several  delegated  and 
Commission  has  adopted 
implementing  acts  establishing  (i)  a  watch 
list  of 
substances  and  compounds  of  concern  for  drinking 
water (105), (ii) a methodology for measuring microplastics 
in drinking water (106) and (iii) an EU system for testing and 
approving materials that will be allowed to be in contact 
with drinking water (107). Member States will have to take 
these  various  Commission  acts 
into  account  when 
implementing  the  recast  directive.  The  recast  Drinking 
Water Directive also introduces a risk-based approach to 
water safety, which covers the entire supply chain, from 
the  river  basin  to  extraction,  treatment,  storage  and 
distribution. Assessments based on this approach must be 
reviewed  periodically,  in  particular  to  address  threats 
posed by extreme weather phenomena linked to climate 
change,  known  variations  in  human  activities  in  the 
extraction area, or accidents affecting the source. 

Finally,  the  Commission  has  now  received  data  from 
Member States on the quality of drinking water supplied 
by  large  water  suppliers  in  2017–2019.  In  summary,  the 
compliance for all parameter groups in France was at least 
99.63 % in 2017, 99.64 % in 2018 and 99.67 % in 2019. 

(105)  https://environment.ec.europa.eu/publications/implementing-

decision-drinking-water-directive-watch-list_en. 

(106)  Commission Delegated Decision (EU) 2024/1441 of 11 March 

2024 supplementing Directive (EU) 2020/2184 of the European 
Parliament and of the Council by laying down a methodology to 
measure microplastics in water intended for human consumption 
(notified under document C(2024) 1459) (OJ L, 2024/1441, 
21.5.2024), http://data.europa.eu/eli/dec_del/2024/1441/oj. 

(107)  OJ L, 2024/365, 23.4.2024, 

http://data.europa.eu/eli/dec_impl/2024/365/oj; OJ L, 
2024/367, 23.4.2024, 

http://data.europa.eu/eli/dec_impl/2024/367/oj; OJ L, 
2024/369, 23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/369/oj; OJ L, 2024/368, 
23.4.2024, http://data.europa.eu/eli/dec_impl/2024/368/oj; OJ 
L, 2024/370, 23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/370/oj; OJ L, 2024/371, 
23.4.2024, http://data.europa.eu/eli/reg_del/2024/371/oj; see 
the Commission web page on all six delegated acts for more 
information 
(https://environment.ec.europa.eu/publications/delegated-acts-
drinking-water-directive_en). 

2025 Environmental Implementation Review – France 

 
 
 
 
 
In July 2024, the Commission decided to refer  France to 
the  CJEU  for  failure  to  comply  with  the  requirements  of 
the Drinking Water Directive, in particular with regard to 
exceedances of nitrates in drinking water (108).  

From  January  2026,  the  European  quality  standards  for 
per- and polyfluoroalkyl substances in drinking water will 
apply, ensuring harmonised Member States’ reporting of 
per- and polyfluoroalkyl substances monitoring data in the 
future. On 12th February 2025, France adopted a national 
law  aiming  at  protecting  the  population  against  these 
substances109. 

2025 priority action 

•  Take action to ensure full compliance with the Drinking 

Water Directive. 

Bathing Water Directive 

The  Bathing  Water  Directive  requires  Member  States  to 
monitor and assess bathing water. It requires that, during 
the  bathing  season,  Member  States  disseminate  to  the 
public information on bathing water quality actively and 
promptly. In particular, notices banning or advising against 
bathing should be rapidly and easily identifiable. 

In  2023,  out  of  the  3 361  French  bathing  waters,  2 517 
(74.9 %)  were  of  excellent  quality,  521  (15.5 %)  were  of 
good  quality  and  137  (4.1 %)  were  of  sufficient  quality, 
while 99 (2.9 %) were of poor quality and 87 (2.6 %) were 
not classified. 

Detailed information on bathing waters is available from a 
national portal (110) and through an interactive map of the 
EEA (111). 

Figure 28: Bathing water quality per Member State, 
Albania and Switzerland (%), 2023 

France  33 

Source: EEA and European Topic Centre on Inland, Coastal and Marine 
Waters,  ‘European  bathing  water  quality  in  2020’,  20 April  2023, 
https://discomap.eea.europa.eu/bathingwaterstory/. 

Nitrates Directive 

The  Nitrates  Directive (112)  aims  to  protect  water  quality 
across  Europe  by  preventing  nitrates  from  agricultural 
sources that can pollute groundwater and surface waters 
and by promoting the use of good farming practices. The 
latest  Commission  report  on  the  implementation  of  the 
Nitrates  Directive (113),  dating  back  to  2021,  warns  that 
nitrates are still causing harmful pollution to water in the 
EU. Excessive nitrates in water are harmful to both human 
health  and  ecosystems,  causing  oxygen  depletion  and 
eutrophication. Cleaning of waters by national authorities 
or  farmers,  where  it  has  been  undertaken,  has  had  a 
positive  impact  on  the  drinking  water  supply  and  on 
biodiversity.  It  has  also  benefited  the  sectors –  such  as 
fisheries and tourism – that depend on biodiversity and on 
a good supply of drinking water. Nevertheless, excessive 
fertilisation remains a  problem in  many parts of the EU, 
including France. 

The  analysis  of  France’s  RBMPs  has  identified  nutrients 
from  agriculture  as  an 
important  pressure  on 
groundwater /  surface  waters  that  is  affecting  these 
waters’ good status and as one of the main factors in not 
meeting the Water Framework Directive objectives. 

Since  the  report  on  the  implementation  of  the  Nitrates 
Directive covering 2020–2023 will be available in 2025, the 
2022  priority  action  cannot  be  assessed  and  has  to  be 
repeated. 

2025 priority action 

•  Tackle  nutrient  pollution,  especially  nitrates  from 
implementation  of  the 

agriculture,  through  the 
Nitrates Directive. 

Urban Wastewater Treatment Directive 

The  Urban  Wastewater  Treatment  Directive  (UWWTD) 
aims to protect human health and the environment from 
the effects of untreated urban waste water. It therefore 
requires Member States to collect and treat (secondary or 
biological  treatment)  waste  water  in  all  urban  areas  of 
more  than  2 000  people,  and  to  apply  a  more  stringent 
treatment 
than  secondary,  with  nitrogen  and/or 
phosphorus  removal,  to  the  waste  water  generated  in 
urban areas, also known as agglomerations, of more than 

(108) 

INFR(2020)2273;  see  also  the  press  release  about  the  decision 
(https://ec.europa.eu/commission/presscorner/detail/en/ip_24_
3742). 

109   Texte de la commission, n° 929-A0 - 17e législature - Assemblée 

nationale 

(110)  https://baignades.sante.gouv.fr/baignades/homeMap.do. 

(111)  EEA, ‘State of bathing water’, EEA website, 2024, 

https://www.eea.europa.eu/en/topics/in-depth/bathing-
water/state-of-bathing-water. 
(112)  https://eur-lex.europa.eu/legal-

content/EN/TXT/?qid=1561542776070&uri=CELEX:01991L0676-
20081211. 

(113)  https://environment.ec.europa.eu/topics/water/nitrates_en. 

2025 Environmental Implementation Review – France 

 
 
 
France  34 

10 000 people, before they are discharged into waters and 
their  catchments,  when  they  are  sensitive  to  nitrogen 
and/or phosphorus (i.e. eutrophic or tending to become 
eutrophic). 

Overall, in France, the compliance rate was 91 % in 2020; 
498  agglomerations,  generating  6 337,540 population 
equivalent of urban waste water, did not comply with the 
requirements of the directive. 

Figure 29: Proportion of urban waste water that fully 
complies with the UWWTD (%), 2020 

establishing an EPR system to ensure sustainable financing 
of  micropollutant  treatment  by  the  most  polluting 
industries and ensuring access to sanitation, especially for 
vulnerable  and  marginalised  groups.  France  has  until 
31 July  2027  to  transpose  the  new  directive  into  its 
national legal system. 

Despite  some  progress  made,  France  has  not  fully 
implemented the UWWTD, and the 2022 priority action is 
repeated. 

2025 priority action 

• 

the  necessary  measures 

full 
Take 
implementation  of  the  current  UWWTD,  taking  into 
account the new requirements of the recast directive. 

to  ensure 

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 (115), 
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. 

The  EU’s  chemicals  legislation (116)  provides  a  baseline 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating in the internal market. 

Since 2007, the Commission has gathered information on 
the  Registration,  Evaluation, 
the  enforcement  of 
Authorisation  and  Restriction  of  Chemicals  (REACH) 
Regulation and the Classification, Labelling and Packaging 
(CLP)  Regulation.  In  December  2020,  the  Commission 
assessed  the  Member  States’  reports (117)  on  the 

p. 1), 

chemicals  (REACH),  establishing  a  European  Chemicals  Agency, 
amending Directive 1999/45/EC and repealing Council Regulation 
(EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as 
well as Council Directive 76/769/EEC and Commission Directives 
91/155/EEC,  93/67/EEC,  93/105/EC  and  2000/21/EC  (OJ  L 396, 
30/12/2006, 
https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32006R1907; and Regulation (EC) 
No 1272/2008 of the European Parliament and of the Council of 
16 December  2008  on  classification,  labelling  and  packaging  of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
No 1907/2006 
L 353,  31.12.2008,  p. 1),  https://eur-
(OJ 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02008R1272-20221217. 
(117)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
2020, 
European 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

Source:  European  Commission:  12th  technical  assessment  of  UWWTD 
implementation - Publications Office of the EU 

In October 2024, the CJEU criticised France for failure to 
correctly implement in 78 agglomerations the treatment 
and monitoring obligations of the UWWTD. It is essential 
that France take the necessary measures to fully comply 
with the requirements of the directive. 

This  is  all  the  more  important  as  the  directive  has  been 
revised (114).  The  revised  directive  builds  on  the  current 
acquis,  strengthens  existing  treatment  standards  and 
establishes a new additional treatment of micropollutants 
in  urban  wastewater.  Other  new  requirements  relate  to 
moving  towards  the  energy  neutrality  of  the  sector, 

(114)  Directive (EU) 2024/3019 of the European Parliament and 
of  the  Council  of  27 November  2024  concerning  urban 
wastewater  treatment 
(OJ  L,  2024/3019,  12.12.2024), 
http://data.europa.eu/eli/dir/2024/3019/oj. 

(115)  Communication 

to 

from 

the  Commission 

the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Chemicals 
strategy  for  sustainability:  Towards  a  toxic-free  environment, 
COM(2020) 667 
final  of  14 October  2020,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A667%3AFIN;  Regulation 
(EC) No 1272/2008 of the European Parliament and of the Council 
of 16 December 2008 on classification, labelling and packaging of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
No 1907/2006 
p. 1), 
L 353, 
https://publications.europa.eu/resource/cellar/c6b6a31d-8359-
11ee-99ba-01aa75ed71a1.0004.02/DOC_2. 

31.12.2008, 

(OJ 

(116)  Namely,  Regulation 

(EC)  No 1907/2006  of  the  European 
Parliament  and  of  the  Council  of  18 December  2006  concerning 
the  registration,  evaluation,  authorisation  and  restriction  of 

2025 Environmental Implementation Review – France 

 
 
 
of 

and 

enforcement 

these 
implementation 
regulations (118).  It  is  apparent  from  the  Commission’s 
report  that  there  are  still  many  disparities 
in  the 
implementation  of  the  REACH  and  CLP  Regulations, 
law  enforcement.  Recorded 
notably  in  the  area  of 
compliance  levels  in  Member  States,  generally  quite 
stable over time, appear to be getting slightly worse. This 
may be because: (i) enforcement authorities are becoming 
non-compliant 
effective 
more 
detecting 
products/companies;  and 
(ii)  more  non-compliant 
products are being placed on the EU market. 

in 

In August 2021, the Commission published a measurable 
assessment  of the enforcement (119) of the two main EU 
regulations  on  chemicals  using  a  set  of  indicators  on 
different  aspects  of  enforcement.  Since  2021,  the  list  of 
chemicals  subject  to  restrictions  has  been  expanded  as 
new entries have been added to Annex XVII to the REACH 
Regulation (120). 

In  2023,  new  hazard  classes  were  added  to  the  CLP 
Regulation, and the revision of the regulation was tabled 
(published  on  20 November  2024)  (121).  The  new  hazard 
classes  cover  endocrine  disruptors  and  persistence-
related  hazards  while  the  revision  of  the  regulation 
encompasses  new  rules  on  online  sales  to  better  tackle 
non-compliances  observed  over  the  years.  Also  in  2023, 
the  Conference  of  the  Parties  of  the  Stockholm 
Convention (COP) decided to include, in its Annex A (which 
lists  banned  substances),  three  new  chemicals (122).  The 
Commission  is  working  on  the  delegated  acts  to  include 
these  substances  in  Annex I  to  the  Persistent  Organic 
Pollutants Regulation by 2025 at the latest. 

Authorities responsible for checking compliance with the 
REACH and CLP Regulations have not changed since 2022. 

France  has  devised  and  fully  implemented  enforcement 
strategies  for  both  the  REACH  and  CLP  Regulations (123), 

France  35 

with  the  following  features,  which  have  been  overall 
stable since 2022: 

• 

Each  national  enforcement  authority  develops  its 
own strategy, but in a coordinated manner leading to 
the  adoption  of  a  shared  yearly  strategy  for  the 
enforcement of chemicals. 

•  Water  Exploitation  Index  Plus  strategies  can  be  on 

REACH-EN-FORCE or pilot projects. 

•  Annual planning is utilised, and strategies are revised 

• 

based on an annual evaluation. 
Since 2016, 5 % of inspections of classified industrial 
sites have included a chemical products check, and an 
objective  of  200  specialised  inspections  has  been 
consistently  applied.  These  inspections  cover  all 
(registration, 
aspects  of 
supply 
authorisation, 
information 
restrictions 
dissemination). The regional coordinators responsible 
for  chemicals  legislation  meet  three  times  a  year  to 
share good practices at the national level. 

chain 
and 

the 

in 
The  Member  States’  reporting  exercise  set  out 
Article 117 of the REACH Regulation and Article 46 of the 
CLP Regulation is conducted every five years. The results 
of  the  coming  one  are  expected  in  2025,  hence  the 
absence  of  new  country-specific  data  on  enforcement 
since 2022. 

In  France,  among  the  1 568  inspectors (124)  from  the 
Ministry  of  Ecological  Transition  in  charge  of  overseeing 
classified  industrial  sites,  20  specialised  inspectors  are 
allocated  specifically  to  the  enforcement  of  the  REACH 
and  CLP  Regulations (125).  Most  REACH  checks  are 
proactive  ones  (i.e.  conducted  in  the  framework  of 
planned  inspections)  rather  than  reactive/non-routine 
ones  (i.e.  investigations  following  complaints,  accidents 
and referrals). 

(118) 

line  with  Article 117(1)  of  the  REACH  Regulation  and 

In 
Article 46(2) of the CLP Regulation. 

UV-328,  the  COP  decision 
exemptions. 

lists  some  time-limited  specific 

the 

European 

(119)  European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  REACH  and  CLP 
Enforcement: EU-level enforcement indicators, Publications Office 
2021, 
Union, 
of 
https://op.europa.eu/en/publication-detail/-
/publication/e5c3e461-0f85-11ec-9151-01aa75ed71a1/. 
(120)  These are substances in tattoo inks and permanent make-up, N,N-
dimethylformamide, formaldehyde (and formaldehyde releasers), 
lead in PVC (polyvinyl chloride), siloxanes (D4, D5, D6) and, finally, 
microplastics. 

Luxembourg, 

(121)  Regulation (EU) 2024/2865 of the European Parliament and of the 
Council  of  23  October  2024  amending  Regulation  (EC)  No 
1272/2008 on classification, labelling and packaging of substances 
and mixtures, OJ L, 2024/2865, 20.11.2024, p.1 (Regulation - EU - 
2024/2865 - EN - EUR-Lex) 

(122)  These are methoxychlor, dechlorane plus and UV-328. In the case 
of the pesticide methoxychlor, there are no exemptions from the 
ban. However, for the two plastic additives, dechlorane plus and 

(123)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
p. 76, 
European 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

(124)

https://www.ecologie.gouv.fr/sites/default/files/documents

/Bilan_ICPE_2023_perspectives_2024.pdf.  

(125)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
p. 74, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

2025 Environmental Implementation Review – France 

 
 
 
Figure 30: Compliance of imported products – results of 
the REF-8 project (%) 

France  36 

particular when related to imported products. 

In  2022,  France  received  a  priority  action  related  to 
upgrading  administrative  capacities  in  implementation 
and  enforcement  to  move  towards  a  policy  of  zero 
tolerance of non-compliance. In the absence of reporting 
since 2022, no progress has been shown and this priority 
action  remains  valid  in  2025,  partly  because  of  the 
experience with the REF-8 project. 

2025 priority actions 

•  Upgrade 

the 

capacities 

in 
administrative 
implementation and enforcement to move towards a 
policy of zero tolerance of non-compliance. 
Increase involvement in the activities of the Forum for 
Exchange  of  Information  on  Enforcement  of  the 
the 
European  Chemicals  Agency, 
coordinated  enforcement  projects,  called  REF 
projects. 
Increase  customs  controls  and  controls  of  products 
sold online with regard to compliance with chemicals 
legislation. 

including 

in 

• 

• 

A  risk  approach  was  used  for  the  targeting  of  control 
measures in order to maximise the chances of identifying 
non-compliance.  Therefore,  the  non-compliance  rates 
presented above cannot be considered the average non-
compliance  rates  of  products  in  the  EU.  However,  the 
proportion  of  non-compliance  cases  found  in  the  REF-8 
project are of concern. 

Figure 31: Number of REF-8 checks performed per 
100 000 inhabitants (EU average = 1.24) 

France  participated  to  a  small  extent  in  the  REF-8 
coordinated enforcement project. Online sales have been 
proved  to  correspond  consistently  to  higher  non-
compliance  rates  in  checks  performed  across  the  EU,  in 

2025 Environmental Implementation Review – France 

 
 
 
France  37 

4. Climate action

The key strategic document at country level is the National 
Energy and Climate Plan (NECP) (128). France submitted its 
updated  plan  in July  2024  after  the  deadline  set  by  the 
regulation.  The  European  Commission  assessed  the  final 
plan  and  the  extent  to  which  France  has  followed  the 
recommendations for the draft version. The findings from 
the assessment are: 

• 

• 

• 

• 

Emissions  under  the  Effort  Sharing  Regulation  will 
decrease  by  46%  in  2030  compared  to  2005,  and 
France will have to use flexibilities to meet its target 
of 48%. 
The  latest  projections  show  a  gap  to  the  LULUCF 
target, meaning that current levels of removals have 
been insufficient.  
France has a gap towards the target for the share of 
renewable energy. 
France is in line with its energy efficiency targets. 

To minimise the impacts of climate policies on vulnerable 
people  and  sectors,  France  is  using  the  Just  Transition 
Fund  and  will  use  Social  Climate  Fund  from  2026.  (for 
more information, see Chapter 5 Finance). 

Figure 32: Total GHG emissions (excluding international 
aviation) (%), 1990–2022 

The impacts of climate change have continued to increase 
in recent years, inflicting damage and suffering in the EU 
and around the world. Globally, 2023 was the hottest year 
on  record,  while  Europe  has  been  warming  twice  as 
quickly  as  the  global  average,  and  is  now  the  fastest-
warming  continent.  The  frequency  and  severity  of 
extreme  climate  events  are  also  increasing.  Against  this 
backdrop, the EU has demonstrated its determination to 
implement  the  European  Green  Deal  and  to  become 
climate neutral and resilient by 2050, ensuring sustainable 
competitiveness  and  supporting  EU  industry  in  the  net-
zero  transition.  The  European  Climate  Law  is  the  EU’s 
response  to  the  need  for  action.  It  sets  the  objective  of 
achieving climate neutrality by 2050 and a midterm target 
of a reduction in GHG emissions of at least 55 % by 2030, 
and outlines the adaptation efforts necessary to adjust to 
climate  change’s  present  and  future  impacts.  Almost  all 
the  ‘Fit  for  55’  proposals  set  out  in  the  European  Green 
law,  and  the  European 
in 
Deal  have  been  agreed 
Commission  recommended  a  new  intermediate  climate 
target of a 90 % reduction in emissions by 2040. In 2024, 
the  Member  States  submitted  updated  national  energy 
and climate plans for 2021–2030, reflecting the increased 
ambition  of  the  revised  EU  legislation.  In  2024,  the 
European Commission also released, jointly with the EEA, 
the first-ever European climate risk assessment. 
Over  the  last  three  decades,  since  1990,  the  EU  has 
achieved  steady  decreases  in  its  emissions,  reaching  a 
running  total  in  2022  of  – 32.5 % (126).  However,  the  EU 
and 
their 
implementation  efforts  and  accelerate  emissions 
reduction to stay on track to reach their targets of a 55 % 
reduction  in  net  GHG  emissions  by  2030  and  climate 
neutrality  by  2050.  Between  1990  and  2022,  net  GHG 
emissions of France  by 28%, making it one of the countries 
with below-average decrease. 

its  Member  States  need 

to  step  up 

The  ‘Fit  for  55’  legislative  package  reflects  the  need  to 
speed up the green transition. It includes (i) strengthening 
and expanding the EU emissions trading system (ETS), with 
the  creation  of  a  new,  second,  ETS  for  transport  and 
buildings together with a dedicated Social Climate Fund to 
help  citizens  during  the  transition;  (ii)  increasing  targets 
under  the  effort  sharing  regulation;  and  (iii)  a  revised 
regulation 
for  Land  Use,  Land  Use  Change  and 
Forestry (127). The package has been fully adopted, and the 
Member States have been implementing the legislation. 

The EU emissions trading system 

The  EU  ETS  is  the  key  tool  for  reducing  GHG  emissions 
cost-effectively across all Member States. It is the world’s 
biggest carbon market, covering around  40% of the EU’s 
total GHG emissions from electricity and heat generation, 
the  manufacturing  industry,  aviation  within  Europe (129) 
and, from 2024, maritime transport also. 

(126)  EU net domestic emissions, including the land use, land-use 

(128)  More information about NECP is on the dedicated website 

change and forestry (LULUCF) sector and excluding international 
aviation. 

https://energy.ec.europa.eu/topics/energy-strategy/national-
energy-and-climate-plans-necps_en 

(127)  A full overview of the Fit for 55 package is available at 

https://commission.europa.eu/strategy-and-policy/priorities-
2019-2024/european-green-deal/delivering-european-green-
deal/fit-55-delivering-proposals_en. 

(129)  Flights between the EU Member States including departing flights 
to Norway, Iceland, Switzerland and the United Kingdom. 

2025 Environmental Implementation Review – France 

 
 
 
The system sets a limit or cap on the total amount of GHGs 
that  can  be  emitted  at  the  EU  level.  Within  this  limit, 
companies buy emissions allowances (one allowance gives 
the  right  to  emit  1 tonne  of  CO2  eq  (carbon  dioxide 
equivalent)),  in  auctions  or  through  trading  allowances 
with  others.  The  cap  is  reduced  annually  to  ensure  that 
overall  emissions  in  the  sectors  covered  decrease  over 
time. 

The emissions under the ETS decreased by 52% from 2005 
to 2023. 

In  2023,  power  generation  in  France  caused  24 %  of  all 
ETS-covered  emissions,  less  than  half  the  EU  average 
share (57 %). Of the total greenhouse gas emissions from 
all industry sectors, 26 % came from the metals industry, 
20 %  from  cement  and  lime  production,  19 %  from  the 
chemical  industry,  and  15 %  from  refineries.  A  diverse 
group of other industries accounted for 20 % of France’s 
industry  greenhouse  gas  emissions.  Between  2019  and 
2023, France reduced greenhouse gas emissions of its ETS 
is  composed  by  a  25 % 
installations  by  27 %.  This 
greenhouse gas emissions reduction in the power sector 
and  an  32 %  reduction  in  the  industry  sectors.  In  the 
decade  up  until  2022,  France’s  emissions  reduction  rate 
reached  an  early  peak,  with  a  12 %  reduction  between 
2013 and 2014. 

From 2027, a new emissions trading system, called ETS2, 
for  buildings,  road  transport  and  additional  sectors, 
(mainly  industry  not  covered  by  the  current  ETS)  will 
become  fully  operational (130).  Member  States  should 
have  notified  full  transposition  the  provisions  of  the 
revised  EU  ETS  directive  related  to  the  new  ETS2  into 
national law by 30 June 2024. France did not communicate 
full  transposition  into  national  law  by  this  deadline.  The 
Commission 
infringement 
procedure  against  France  on  25 July  2024,  by  sending  a 
letter  of  formal  notice  for  failing  to  fully  transpose  the 
provisions into national law. 

launched  an 

therefore 

launched 

The  Commission 
infringement  procedures 
against  France  on  25 January  2024,  for  failing  to  fully 
transpose  previous  revisions  of  ETS  directive (131)  into 
national 
full 
transpositions  of  the  abovementioned  directives  to  the 
Commission. 

law (132).  France  has  since  notified 

Effort sharing 

The  Effort  Sharing  Regulation (ESR) (133)  covers  GHG 
(excluding  CO₂ 
emissions 
emissions  from  aviation),  buildings,  agriculture,  small 

from  domestic  transport 

France  38 

industry and waste. Emissions from these sectors account 
for  around  60 %  of  the  EU’s  domestic  emissions.  The 
regulation  sets  the  EU-wide  target  to  reduce  emissions 
from the effort sharing sectors by 40 % by 2030 compared 
to 2005 levels. This overall target for the EU translates to 
binding  national  emission  reduction  targets  for  each 
Member State. France‘s target is – 47.5%. 

In  addition  to  the  2030  targets,  Member  States  have 
annual GHG emissions limits (annual emission allocations), 
reducing every year until 2030. 

There  is  some  flexibility  to  take  account  of  annual 
in  emissions,  by  trading  emissions  and 
fluctuations 
transfers from the ETS and LULUCF. 

Based  on  historical  emissions  and  the  most  updated 
projections  France  is  on  track  to  achieve  its  2030  ESR 
target.  Nevertheless,  excess  of  emissions  in  the  LULUCF 
sector automatically tightens ESR annual emission limits in 
2021–2025 (134).  Based  on  available  data,  France  may 
struggle to stay within these limits each year in this period. 

The  projected  gap  is  1.1  percentage  point  to  its  2030 
target. 

The largest  contributor is the domestic transport  sector, 
which accounted for 40 % of all effort sharing emissions in 
2022. The shift to sustainable transport is starting to gain 
ground  in  France.  Cars  are  used  for  85 %  of  distances 
travelled, close to the EU average of 87.5 %. At  9 %, the 
share of rail passenger transport is the highest in the EU. 
For  freight,  however,  road  is  the  dominant  form  of 
transport at 85 %, with only 10 % of freight transported by 
rail (against the EU average share of 75 % to 16 %). 59 % 
of the rail network is electrified which is slightly above EU 
average  (56 %).  The  share  of  battery  electric  cars  in  the 
passenger car fleet has been increasing rapidly, reaching 
1.7 % in 2022 (EU average: 1.2 %). In 2023, France had 118 
000 publicly accessible charging points, or one for every 10 
electric vehicles, in line with the EU average. 

The buildings sector is a significant concern for France. In 
2022, buildings accounted for 21 % of total effort sharing 
emissions  and  France  needs  to  step  up  its  efforts  in  the 
residential sector to achieve a meaningful contribution to 
its  2030  reduction  target  for  energy  consumption  by 
buildings. While total emissions of buildings decreased by 
26 % between 2015 and 2022, final energy consumption 
in  the  residential  sector  increased  by  2.8 %  in  the  same 
period.  The  national 
long  term  renovation  strategy 
envisages  a  22 % 
reduction  of  buildings’  energy 
consumption by 2030 compared to 2015. 

(130)  Directive (EU) 2023/959 (https://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=uriserv:OJ.L_.2023.130.01.0134.01.ENG) 

(133)  Regulation (EU) 2018/842 (https://eur-
lex.europa.eu/eli/reg/2018/842). 

(131)  Directive - 2023/959 - EN - EUR-Lex and Directive - 2023/958 - EN 

(134)  See article 9(2) of Effort Sharing Regulation Regulation - 2018/842 

- EUR-Lex 

(132)  Case INFR(2024)0061. 

- EN - EUR-Lex 

2025 Environmental Implementation Review – France 

 
 
France  39 

France  has  all  three  regions  identified  as  a  hotspots  of 
climate risks most affected by climate change – Southern 
Europe, 
regions  and  outermost 
regions (135). 

low-lying  coastal 

Water  management 
is  a  key  challenge  regarding 
adaptation to climate change in France, also given the risk 
of  electricity  disruption  to  hydro-  and  nuclear  energy 
provision as floods, heat and drought have an impact on 
energy  production.  France’s  climate  protection  gap 
remains low thanks to a high share of insurance coverage 
across risk categories, though half of France’s forests are 
estimated  to  be  at  risk  of  wildfires.  By  2050,  France  is 
estimated  to  face  a  water  shortage  of  two  billion  m3. 
Water supply and sanitation are also particular concerns 
in  France’s  outermost  regions,  due  to  the  effects  of 
climate change on rainfall. 

France  adopted  its  national  adaptation  strategy  in  2006 
and replaced it  by the  national adaptation plan in 2011. 
The plan was updated in 2018 and a second draft update 
was  presented  on  25  October  2024  and  was  subject  to 
public  consultation  until  the  end  of  2024.  The  aim  is  to 
prepare France to cope with a temperature increase of 4°C 
by  2100.  There  are  no  regional  or  sectoral  adaptation 
plans.  There  is  a  significant  progress  in  sustainability  of 
transport, but freight transport is still dominated by road, 
the share of rails remains below the EU average. 

The  new  law  on  renewable  energy  acceleration  makes 
progress  on  granting permits  and  offshore  planning,  but 
more is needed to deliver the necessary acceleration. In 
fact,  there  is  still  a  need  for  clear  and  accelerated 
deadlines  for  projects  outside  the  acceleration  zones 
introduced  in  the  new  law.  In  addition,  France  is  still 
lagging behind on the introduction of a one-stop shop for 
renewable energy permitting. 

Agriculture  is  on  a  good  track  to  achieve  2030  national 
targets. 

Priority action 2025 

• 

the  next  period  France  should 

In 
focus  on 
implementing  all  polices  and  measures  that  are 
needed  to  achieve  targets  defined  by  Effort  Sharing 
Regulation  and  LULUCF  regulation.  More  detailed 
priority actions are set out in the assessment of the 
final national energy and climate plan (NECP)(136).

Emissions in agriculture decreased by 14 % from 2005 and 
the  pace  sped  up  in  recent  years.  Now,  France  has  to 
ensure that all measures are implemented and there are 
no policies that could compromise reaching the objectives 
set for 2030 (for example, long-standing tax refund for fuel 
used in agriculture). 

Figure 33: Effort-sharing emissions by sector (%), 2022 

Land use, land-use change and forestry 

The LULUCF sector plays a significant role in achieving the 
EU’s climate neutrality goal. In the EU, this sector absorbs 
more GHGs than it emits, removing significant volumes of 
carbon  from  the  atmosphere.  Thus,  it  is  the  only  sector 
with negative emissions. 

France  increased  its  LULUCF  net  carbon  sink  between 
1990 and 2008, after which it plateaued and then in 2013 
it went into sharp decline in a worrying trend. 

France‘s  target  for  2030  is  to  enhance  land  removals  by 
additional  – 6.7  Mt  of  CO2  equivalent  compared  to  the 
yearly  average  of  the  period  2016–2018.  The  latest 
available projections show a gap to target  of  13.4 Mt  of 
CO2 equivalent in 2030. Therefore, France needs to apply 
additional measures to reach its 2030 target. 

Adaptation to climate change 

Halting  all  greenhouse  gas  emissions  would  still  not 
prevent  climate  impacts  that  are  already  occurring. 
Therefore,  adaptation  to  climate  change  is  also  a  key 
component of climate policy. 

(135)  European  Climate  Risk  Assessment  (EUCRA).  2024.  Available  at 

(136)  National energy and climate plans 

European Climate Risk Assessment (europa.eu) 

2025 Environmental Implementation Review – France 

 
 
 
France  40 

Part II: Enabling framework – implementation tools 

5. Financing

The EU budget supports climate investment in France with 
significant  amounts 
in  the  2021–2027  period,  with 
revenues  from  the  ETS  also  feeding  into  the  national 
budget.  During  2020–2022,  France’s  revenues  from 
auctioning  reached  EUR 4 billion  in  total,  with  all  of  it 
spent on climate and energy. 

2021–2027 (with around 60 % of this via the ERDF), with a 
further  EUR 274 million  from  the  European  Maritime, 
Fisheries and Aquaculture Fund (138). 

The  RFF  contributes  to  climate  finance  in  France  with 
EUR 19.9 billion  up  to  2026,  representing  49.5 %  of  the 
RRP (139). 

In  addition,  the  annual  investment  needed  to  meet  its 
environmental  objectives 
in  the  areas  of  pollution 
prevention and control, the circular economy and waste, 
water protection and management, and biodiversity and 
ecosystems is estimated to be EUR 63.8 billion per year in 
France. 

(EIB)  provided 
Investment  Bank 
The  European 
EUR 109.9 billion  financing  across  the  EU-27  between 
2021  and  mid  2024  to  support  energy,  transport  and 
industry  projects  that  are  aligned  with  the  EU’s  climate 
objectives. Of this amount, EUR 19.4 billion was assigned 
to France in the reference period (140). 

These  four  environmental  areas  currently  receive  total 
funding of around EUR 42.7 billion per year; thus, there is 
a gap of EUR 21.1 billion per year. 

National financing, including EU emissions trading 
system revenues 

the 

annual 

Of 
gap, 
environmental 
EUR 8 billion  concerns  pollution  prevention  and  control, 
EUR 4.5–4.6 billion  biodiversity  and  ecosystems  and 
circular  economy  (each)  and  EUR 3.9 billion  the  water 
objective. 

investment 

Climate finance landmarks 

EU funding for climate action 

The EU budget supports climate action in the EU-27 with 
EUR 657.8 billion  in  the  2021–2027  budgetary  period 
across  the  various  programmes  and  funds,  representing 
an  overall  34.3 %  contribution  level.  Of  this,  cohesion 
policy provides EUR 120 billion (over half of it through the 
European  Regional  Development  Fund  (ERDF)),  the 
Recovery  and  Resilience  Facility  (RRF)  EUR 275.7 billion 
and the CAP EUR 145.9 billion (137). 

In  France,  the  EU  cohesion  policy  (considering  EU 
contribution)  provides  EUR 4 billion  for  climate  action  in 

(137)  European  Commission,  Statement  of  Estimates  of  the  European 
Commission –  For  the  financial  year  2025,  Publications  Office  of 
the 
pp. 94–96, 
https://commission.europa.eu/document/download/7a0420e1-
599e-4246-9131-ccb7d505d6d9_en?filename=DB2025-
Statement-of-Estimates_1.pdf. 

European  Union, 

Luxembourg, 

2024, 

(138)  See 

the 

Cohesion 

Open 

Data 

Platform 

(https://cohesiondata.ec.europa.eu/). 

(139)  EU  Commission  datasets  and  the  Recovery  and  Resilience 
(https://ec.europa.eu/economy_finance/recovery-

Scoreboard 
and-resilience-scoreboard/index.html). 

(140)  A 

list  of 

financed  projects 

is  provided  by 

the  EIB 

(https://www.eib.org/en/projects/loans/index.htm). 

to  EUR 728 million 

Revenues  from  the  auctioning  of  emission  allowances 
under  the  EU  ETS,  which  feed  directly  into  national 
in  2020, 
budgets,  amounted 
EUR 1 469 million in 2021 and EUR 1 868 million in 2022 in 
France,  totalling  EUR 4 066 million 
in  the  three-year 
period. In France, the auctioning revenues co-fund energy 
efficiency improvements for low-income housing, up to a 
maximum  of  EUR 420 million  per  year.  The  remainder  is 
not  earmarked  but  goes  to  the  general  budget,  which 
covers,  among  other 
things,  climate  and  energy 
investments (141). 

From the remaining part of the EU ETS revenues that feed 
into  the  Innovation  Fund  and  the  Modernisation  Fund, 
further  support  is  available  to  climate  action  at  the  EU 
level (142). 

the  environment 

It should be noted that investment in climate action also 
supports 
the 
environmental  investments  described  in  the  following 
sections  cannot  be  regarded  as  entirely  additional  to 
climate investment (143). 

therefore, 

and, 

(141)  European  Commission:  Directorate-General  for  Climate  Action, 
Progress Report 2023 – Climate action, Publications Office of the 
European 
2023, 
https://climate.ec.europa.eu/news-your-voice/news/climate-
action-progress-report-2023-2023-10-24_en. 

Luxembourg, 

Union, 

(142)  European  Commission:  Directorate-General  for  Climate  Action, 
Progress Report 2023 – Climate action, Publications Office of the 
European 
2023, 
https://climate.ec.europa.eu/news-your-voice/news/climate-
action-progress-report-2023-2023-10-24_en. 

Luxembourg, 

Union, 

(143)  NB:  Indirect  investments  (from  climate  and  other  policies)  in 

support of the environment are accounted for via the tracking. 

2025 Environmental Implementation Review – France 

 
 
France  41 

European  Agricultural  Fund 
for Rural Development 

European 
Maritime, 
Fisheries  and  Aquaculture 
Fund 

Other MFF sources 

RRF (d) (2021–2026) 

115.9 

3 170.7 (c) 

 10 390 

(a) 

(b) 

European  Commission,  2021-2027  cohesion  policy  (planned) 
allocations  in  EU  amount  excluding  national  co-financing,  based 
on the tracking in the Common Provisions Regulation (CPR, 2021) 
Annex I. Please note potential data changes that may have arisen 
between the EIR preparation cut-off date (31 October 2024) and 
its  publication  date.  Note  that  France  is  not  eligible  for  the 
information: 
and 
Cohesion 
https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data. 

further 

Source 

Fund. 

Regulation (EU) 2021/2115 of the European Parliament and of the 
Council  of  2 December  2021  establishing  rules  on  support  for 
strategic  plans  to  be  drawn  up  by  Member  States  under  the 
common agricultural policy (CAP strategic plans) and financed by 
the  European  Agricultural  Guarantee  Fund  (EAGF)  and  by  the 
European  Agricultural  Fund  for  Rural  Development  (EAFRD)  and 
repealing Regulations (EU) No 1305/2013 and (EU) No 1307/2013 
(OJ 
https://eur-
p. 1), 
lex.europa.eu/eli/reg/2021/2115. Note that 2021-2027 combines 
factual data for 2021 and 2022 and expenditure under the relevant 
specific  objectives  (SOs)  of  the  CAP  strategic  plans  from  2023, 
using 
tracking  methodology  
(https://commission.europa.eu/system/files/2023-
06/Biodiversity%20tracking%20methodology%20for%20each%20
programme%202023.pdf). Source: European Commission.  

biodiversity 

6.12.2021, 

Annex XI, 

L 435 

the 

EU 

instrument  for  the 

Space  Fund,  Horizon  Europe,  financial 
environment and the Connecting Europe Facility. 
Outside  the  MFF.  Note  that  the  RRF  applies  a  similar 
environmental tracking scheme (set in the RRF Regulation, Annex 
VI)  as  the  EU’s  cohesion  policy.  RRF  dataset  version  used:  July 
2024, prior to 2025 revisions. Data source: European Commission.   

France,  in  addition  to  receiving  EU  funds  earmarked 
specifically  for  it  in  2021–2027,  can  also  benefit  from 
funding programmes that can be accessed at the EU level 
and which are open to all Member States. These include 
instrument  for  the  environment  (LIFE) 
the  financial 
(EUR 5.4 billion) (145),  Horizon 
programme 
Europe 
(EUR 95.5 billion) (146),  the  Connecting  Europe  Facility 

Environmental financing and investments 

This section describes France’s investment needs, current 
financing  and  gaps  as 
four 
environmental  objectives  beyond  climate  objectives, 
namely  tackling  pollution,  the  circular  economy  and 
waste,  water  protection  and  management,  and 
biodiversity and ecosystems (144). 

relate 

they 

the 

to 

The environment overall 

Investment needs 

investment  needs  to  be 
The  overall  environmental 
sufficient  to  enable  France  to  meet  its  objectives  in  the 
areas  of  pollution  prevention  and  control,  the  circular 
economy and waste, water protection and management, 
and biodiversity and ecosystems. The required investment 
is  estimated  to  be  EUR 63.8 billion  per  year  (in  2022 
prices). 

A  significant  part  of  the  estimated  requirement,  around 
EUR 26.4 billion per year, can be attributed to the need to 
support  the  circular  economy.  For  pollution  prevention 
and control, the annual investment needs are estimated 
to be EUR 13.2 billion; for water, they are EUR 15.3 billion 
and  for  biodiversity  and  ecosystems  EUR 8.9 billion  (in 
2022 prices). 

Current investments 

To implement the environmental investments needed, the 
available  financing  is  estimated  to  currently  reach  an 
annual  EUR 42.7 billion  in  France  from  EU  and  national 
sources combined (in 2022 prices). 

(c) 

(d) 

Total  environmental  funding  from  the  multiannual 
financial  framework  (MFF)  is  estimated  to  reach  around 
EUR 16.3 billion for France in total, during 2021–2027 (or 
EUR 2.3 billion per year). 

Table 1: Key environmental allocations from EU funds to 
France (million EUR), 2021–2027 

Instrument 

Cohesion policy 
ERDF 
Cohesion Fund 
Just Transition Fund 

CAP 
European 
Guarantee Fund 

Agricultural 

Allocations  

2 685.5 (a) 
2 438.9 
not applicable 
246.6  

10 306.3 (b) 
7 243.7 
3 062.6 

(144)  Research,  development  and  innovation  is  accounted  for  under 
each environmental objective. The financing needs, baselines and 
gap  estimates  are  based  on  the  Directorate-General  for 
Environment’s 
internal  analysis  (of  2024).  Throughout  this 
chapter,  specific  references are  provided to  the  most  important 
data sources used. 

(145)  https://cinea.ec.europa.eu/programmes/life_en. 
(146)  European  Commission,  Horizon  Europe    (https://research-and-
innovation.ec.europa.eu/funding/funding-opportunities/funding-
programmes-and-open-calls/horizon-europe_en). 

2025 Environmental Implementation Review – France 

 
 
 
 
 
(EUR 33.7 billion) (147)  and  funds  that  can  be  mobilised 
through the InvestEU programme (148). 

France’s RRP supports climate objectives through funding 
of  EUR 19.9 billion  (49.5 %  of  total),  with  an  additional 
EUR 0.71 billion (1.8 % of total) for the environment. 

The EIB provided around  EUR 8.3 billion in environment-
related financial contributions to France in from 2021 to 
mid 2024, most of which, EUR 7.3 billion (89 %), was in the 
area  of  sustainable  energy,  transport  and  industrial 
projects,  which  provides  significant  co-benefits  to 
reducing  air  pollution,  environmental  noise  and  other 
pollution. 

The  EU’s  total  national  expenditure  on  environmental 
protection  (operating  plus  capital  expenditure)  was 
EUR 298 billion  in  2020  and  EUR 321 billion  in  2021, 
representing  around  2.2 %  of  EU-27  GDP.  In  France,  the 
total national environmental protection expenditure was 
EUR 46.5 billion  in  2020  and  EUR 50.4 billion  in  2021, 
representing 2 % of GDP in both years. 

Of  the  total  environmental  expenditure,  the  national 
capital  expenditure 
(investment)  on  environmental 
protection  amounted  to  EUR 54.5 billion  in  2020  and 
EUR 59.9 billion in 2021 in the EU-27, representing around 
In  France,  the  national 
0.4 %  of  the  EU’s  GDP. 
environmental 
reached 
protection 
EUR 9.4 billion in 2020, rising to EUR 10.6 billion in 2021, 
representing around 0.4 % of GDP. 

investment 

protection 

investment 

Splitting by institutional sector, 65 % of France’s national 
environmental 
(capital 
expenditure) comes from the general government budget, 
with 14 % coming from specialist private-sector producers 
(of environmental protection services, such as waste and 
water  companies)  and  22 %  from  the  general  business 
sector,  whose  environmental  activities  are  usually 
ancillary  to  its  main  activities.  At  the  EU  level,  38 %  of 
environmental  protection 
from 
governments,  40 % 
specialist  private-sector 
producers and 22 % from the general business sector (149). 

investment  comes 

from 

France’s  total  financing  for  environmental  investment 
reaches an estimated  EUR   42.7 billion per year (in  2022 
prices),  including  EU  funding  and  national  public  and 
national private expenditure. Of the total, the share of EU 
fund (including EIB funds) reaches 11 %, with around 89 % 
national  financing.  The  total  public  financing  (EU  plus 
national public) represents 68 % of the total. 

(147)  The  Connecting  Europe  Facility 

includes 
EUR 11.3 billion  transferred  from  the  Cohesion  Fund,  of  which 
30 % 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. 

(Transport)  also 

France  42 

The gap 

To meet its four environmental objectives beyond climate 
change, the additional investment need over the current 
levels (i.e. the gap) reaches an estimated EUR 21.1 billion 
per year in France, representing around 0.8 % of national 
GDP, close to the EU average (0.77 %). 

Figure 34: Environmental financing, needs and gaps  per 
Member State (% of GDP) 

Source: Analysis of Directorate-General for Environment. 

The following table provides the distributions of France’s 
environmental  investment  gap  (expressed  in  various 
forms) by environmental objective. 

Table 2: Summary of environmental investment gaps in 
France per year, 2021–2027 

Environmental 
objective 

Pollution prevention 
and control 

Circular economy and 
waste 

Water management 
and water industries 

Investment gap per year  

 % of 
total 

% of GDP 

Million 
EUR 
(2022 
prices) 

8 034 

38.1 

0.30 

4 598 

21.8 

0.17 

 3 925 

18.6 

0.15 

(148)  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  EIB  group 
and others. 

(149)  Eurostat, 

‘Environmental  protection  expenditure  accounts’, 

env_ac_epea. 

2025 Environmental Implementation Review – France 

 
 
 
 
France  43 

Biodiversity and 
ecosystems 

4 540 

21.5 

Total 

 21 097 

100.0 

Source: Directorate-General for Environment analysis. 

0.17 

0.80 

Pollution prevention and control 

Investment needs 

In pollution prevention and control,  France’s investment 
needs  are  estimated  to  reach  EUR 13.2 billion  per  year 
(including  baseline  investments)  in  2021–2027.  Most  of 
this,  EUR 9.8 billion,  relates  to  air  pollution  control,  to 
comply with the clean air requirements for the five main 
air  pollutants  under  the  NECD  by  2030.  The  estimated 
needs to reduce environmental noise reach  EUR 4 billion 
per  year,  most  of  which  is  delivered  by  the  (same) 
sustainable  energy  and  transport  investments  that  also 
benefit clean air (150). Industrial site remediation requires 
an  estimated  EUR 0.5 billion  per  year.  Microplastics 
pollution  and  the  chemicals  strategy  require  around 
EUR 300–400 million per year (each) (151). 

Current investments 

investment 

levels  supporting  pollution 
The  current 
prevention and control reach an estimated EUR 5.2 billion 
per  year  in  France  in  2021–2027.  Most  of  the  financing 
concerns clean air (EUR 3 billion per year). Protection from 
environmental  noise  receives  around  EUR 1 billion  per 
year, with a further EUR 528 million for site remediation. 

In  France, the EU MFF provides an estimated  6 % of the 
clean  air  financing  (mostly  via  cohesion  policy),  with  a 
further 23.5 % from the RRF, adding up to  29.5 % of the 
total.  EIB  financing  contributes  19.3 %  and  national 
sources reach 51 % (152). 

The gap 

To meet its environmental objectives concerning pollution 
prevention  and  control  (towards  zero  pollution),  France 

implementation  of 

needs  to  provide  an  additional  EUR 8 billion  per  year 
(0.3 % of GDP), mostly related to clean air and noise. The 
adequate 
the 
investments included for sustainable energy and transport 
would largely deliver this, while in many Member States 
additional measures and investments may be required to 
comply with the ammonia reduction requirements. 

the  NECP  with 

According to the latest (2023) NAPCP review report (153), 
France complied with ammonia reduction requirements in 
2020 and 2021, while it is at high risk of non-compliance 
with  ammonia  concerning  the  NECD’s  2030  emission 
reduction  commitments  (and  at  low  risk  concerning  the 
other four pollutants), based on the policies and measures 
in  its  NAPCP  that  take  into  account  climate,  energy  and 
CAP plans and financing baselines. 

Circular economy and waste 

Investment needs 

France’s  investment  needs  in  the  circular  economy  and 
waste reach EUR 26.4 billion per year (including baseline 
investments).  Most  of  this,  around  EUR 23.6 billion  per 
year, relates to circular economy measures in the mobility, 
food  and  built  environment  systems,  with  a  further 
EUR 2.9 billion  necessary 
for  waste  management 
(municipal  and  packaging  waste),  covering  waste 
collection,  biowaste  treatment,  recycling  reprocessors, 
waste-sorting  facilities,  and  digitalisation  of  the  waste 
registry. The amount for waste excludes the investments 
needed for the uptake of circularity and waste prevention 
across the economy (154). 

Current investments 

Circular economy investments across the economy reach 
around EUR 19.6 billion per year in France in 2021-2027, 
with  a 
for  waste 
further  EUR 2.2 billion  provided 
management that does not constitute circular economy. 

(150)  2021 

assessment 

Phenomena 

project 
(https://op.europa.eu/en/publication-detail/-
/publication/f4cd7465-a95d-11eb-9585-01aa75ed71a1)  and  the 
Directive 
Commission’s 
report 
implementation 
(https://environment.ec.europa.eu/system/files/2023-
03/COM_2023_139_1_EN_ACT_part1_v3.pdf). 

Environmental 

Noise 

2023 

(151)  European  Commission,  Third  Clean  Air  Outlook,  Brussels,  2022, 

https://environment.ec.europa.eu/topics/air/clean-air-
outlook_en. See also the impact assessment for the revision of the 
AAQD, available from the Commission web page on the proposed 
revision 
(https://environment.ec.europa.eu/publications/revision-eu-
ambient-air-quality-legislation_en). 

(152)  Through  the  tracking  of  EU  funds,  EIB  projects  and  national 
expenditure  (environmental  protection  expenditure  accounts, 
Eurostat). Note that the bulk of clean air financing is provided as a 
contribution from climate (energy and transport) measures, as per 
the tracking schemes in the Common Provisions Regulation Annex 

I and the RRF Regulation Annex VI. Further information on clean 
air 
tracking: 
https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf 
(153)  European Commission, ‘National air pollution control programmes 
website, 
European 

Commission 

projections’, 

and 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants/national-air-pollution-control-
programmes-and-projections_en. 

(154)  See Systemiq and Ellen MacArthur Foundation, Achieving ‘Growth 
Within’, 2017; and European Commission: Directorate-General for 
Environment, Study on investment needs in the waste sector and 
on  the  financing  of  municipal  waste  management  in  Member 
States,  Publications  Office  of  the  European  Union,  Luxembourg, 
https://op.europa.eu/en/publication-detail/-
2019, 
/publication/4d5f8355-bcad-11e9-9d01-01aa75ed71a1. 

2025 Environmental Implementation Review – France 

 
 
Around 0.4 % of this combined financing for circularity and 
waste comes from the EU MFF, with a further 0.3 % from 
the  RRF,  adding  up  to  0.7 %  of  the  total.  EIB  loans 
identified  in  support  of  circularity  and  waste  represent 
0.3 %  of  the  total.  The  share  of  national  sources  is 
absolutely  overwhelming,  reaching  99 %  of  the  total 
financing (155). 

The gap 

To  meet  its  environmental  objectives  concerning  the 
circular  economy  and  waste,  France  needs  to  increase 
investments  by  an  estimated 
circular  economy 
additional 
EUR 3.9 billion 
EUR 661 million  concerning  waste  management  action, 
not  belonging  to  circular  economy.  Combined,  this 
amounts to EUR 4.6 billion per year, representing 0.17 % 
of France’s GDP. 

year,  with 

per 

an 

Of  the  circular  economy  gap,  EUR 1 billion  relates  to 
recent  initiatives,  such  as  eco-design  for  sustainable 
products,  packaging  and  packaging  waste,  labelling  and 
digital  tools,  CRM  recycling,  and  measures  proposed 
under the amendment of the Waste Framework Directive, 
and EUR 2.9 billion constitutes further investment need to 
unlock France’s circular economy potential. 

Water protection and management 

Investment needs 

The  annual  water  investment  needs  reach  an  estimated 
EUR 15.3 billion (in 2022 prices) in France. This comprises 
investment needs both for the water industry and for the 
protection and management of water. Of the total annual 
need, EUR 6.9 billion relates to the management of waste 
water (also including additional costs associated with the 
revised  UWWTD),  another  EUR 6.9 billion  to  drinking-
water-related  investments  and  around  EUR 1.5 billion  to 
the protection and management of water (156). 

(155)  Waste management and circular economy expenditure tracking in 
the  EU  funds,  EIB  projects  and  in  the  national  expenditure 
(Eurostat).  Datasets:  environmental  protection  expenditure 
accounts  (env_epi)  and  circular  economy  private  investments 
(cei_cie012). 

(156)  See  European  Commission,  ‘Estimating  investment  needs  and 
financing capacities for water-related investment in EU Member 
States’, 
2020, 
2  May 
https://commission.europa.eu/news/estimating-investment-
needs-and-financing-capacities-water-related-investment-eu-
member-states-2020-05-28_en;  and  OECD,  Financing  Water 
Supply, Sanitation and flood Protection: Challenges in EU Member 
States  and  policy  options,  OECD  Publishing,  Paris,  2020, 
https://www.oecd-ilibrary.org/environment/financing-water-
supply-sanitation-and-flood-protection_6893cdac-en. 

(157)  Water investment levels are estimated through tracking EU funds, 
EIB projects and national expenditure (environmental protection 
expenditure accounts, Eurostat). 

France  44 

Current investments 

Water investments in France are estimated to be around 
EUR 11.4 billion per year (in 2022 prices) in 2021–2027. Of 
this,  EUR 4.3 billion  supports  wastewater  management, 
EUR 5.9 billion drinking water and around  EUR 1.2 billion 
the  other  aspects  of  the  Water  Framework  Directive 
(water management and protection). 

Of  the  total  financing,  0.8 %  is  provided  by  the  EU  MFF 
(mostly  through  cohesion  policy),  with  further  0.1% 
contribution from the RRF. EIB financing is around 0.5 % of 
the  total,  and  almost  the  entire  financing  comes  from 
national sources (98.7 %) (157). 

The gap 

To  meet  the  various  environmental  targets  under  the 
Water  Framework  Directive  and  the  Floods  Directive, 
France’s water investment gap reaches EUR 3.9 billion per 
year (0.15 % of GDP), with over half related to waste water 
(EUR 2.6 billion  per  year).  Drinking  water  measures 
require  an  additional  EUR 1.1 billion  per  year  and  the 
other  aspects  of  the  Water  Framework  Directive 
EUR 292 million  per  year  over  the  existing  levels  of 
financing. 

Biodiversity and ecosystems 

Investment needs 

The investment needs for biodiversity and ecosystems are 
estimated to be EUR 8.9 billion per year (in 2022 prices) in 
France in 2021–2027. This includes the following financing 
needs: 

• 

• 

• 

action 

prioritised 

framework (158), 
France’s 
concerning  the  Natura  2000  areas:  EUR 651 million 
per year, mostly running costs; 
additional BDS costs (159): EUR 5.9 billion per year on 
top of the framework; 
sustainable  soil  management  costs (160):  EUR 2.3 
million per year. 

(158)  European Commission, ‘Financing Natura 2000 – Prioritised action 
website, 

Commission 

frameworks’, 
https://environment.ec.europa.eu/topics/nature-and-
biodiversity/natura-2000/financing-natura-2000_en. 

European 

(159)  See European Commission: Directorate-General for Environment, 
Biodiversity  Financing  and  Tracking –  Final  report,  Publications 
Office 
2022, 
https://op.europa.eu/en/publication-detail/-
/publication/793eb6ec-dbd6-11ec-a534-
01aa75ed71a1/language-en. 

European  Union, 

Luxembourg, 

the 

of 

(160)  See Proposal for a directive of the European Parliament and of the 
Council  on  soil  monitoring  and  resilience  (Soil  Monitoring  Law) 
COM(2023) 416 
2023, 
https://environment.ec.europa.eu/publications/proposal-
directive-soil-monitoring-and-resilience_en.  

5 July 

final 

of 

2025 Environmental Implementation Review – France 

 
 
Current investments 

The current level of biodiversity financing is estimated to 
be EUR 4.3 billion per year (in 2022 prices) in 2021–2027. 
88.3 % of this is considered direct financing to biodiversity 
and ecosystems, with a 100 % coefficient  in the tracking 
schemes. 

1.7 % of the total financing is estimated to come from EU 
cohesion  policy,  32 %  from  CAP,  3.6 %  from  Horizon 
Europe  and  around  1.4 %  from  LIFE.  The  EU  MFF 
altogether  accounts  for  39.4 %  of  the  financing  and  the 
RRF  for  2.7 %,  adding  up  to a  total  of  42 %  from  the  EU 
budget. The rest, 58 %, comes from national sources (161). 

At 2.2 %, France has a relatively high share of RRF funding 
dedicated  to  supporting  measures 
for  biodiversity 
compared  with  other  Member  States.  France  has  also 
programmed 16.9 % of its CAP budget for 2021–2027 for 
biodiversity, which is below the EU average. Lastly, 5.9 % 
of  France’s  cohesion  policy  EU  contribution  amount 
(disregarding  ESF+) 
is  estimated  to  contribute  to 
biodiversity, which corresponds to the EU average. 

Figure 35: 2021–2027 contributions to biodiversity from 
the main EU instruments per Member State (% of policy 
total) 

NB: ESF+ :European Social Fund Plus, excluded. 

The gap 

To  meet  the  environmental  objectives  concerning  the 
protection and restoration of biodiversity and ecosystems 
and  other  relevant  cross-cutting  measures,  France’s 

France  45 

investment gap is estimated to be around EUR 4.5 billion 
per year, corresponding to 0.17 % of its GDP. 

Public financial management 

Green budgeting practices 

Green  budgeting  refers  to  the  use  of  budgetary  tools to 
achieve climate and environmental goals. Some Member 
States,  including  France,  already  use  green  budgeting 
tools  for  identifying  and  tracking  green  expenditures 
and/or revenues (162). Green budgeting practices provide 
increased transparency on the environmental implications 
of budgetary policies. 

France  is  a  frontrunner  on  green  budgeting,  identifying 
both  environmentally 
favourable  and  unfavourable 
expenditures  in  its  national  budget  at  a  highly  granular 
level 
tagging 
and 
methodology (163). 

continuously 

refining 

its 

The  Commission  has  developed  a  non-mandatory  green 
budgeting  reference  framework  that  brings  together 
methodologies  for  assessing  the  impacts  of  budgets  on 
climate and environmental goals (164). 

To help Member States develop national green budgeting 
and  thereby  improve  policy  coherence  and  support  the 
green  transition,  the  Commission  facilitated  a  technical 
support instrument (TSI) project on green budgeting from 
2021  to  2024 (165).  France  informally  participated  in  the 
training, providing expertise to other Member States. 

France has been selected as a beneficiary of the 2025 TSI 
on green budgeting, requesting support on the roll-out of 
green  budgeting  practices  to  the  subnational  level.  The 
legal basis has been introduced with the 2024 finance law, 
mandating ‘green budgets’ for local authorities with more 
than 3 500 inhabitants (166). 

from  support  at  the 

France  has  also  benefitted 
subnational level in previous TSI cycles: 
• 

regions 

Two  French 
(Brittany  and  Occitania) 
participated in a workshop on best practices of green 
budgeting at the regional level (167). 

•  Beyond  green  budgeting,  under  a  2024  TSI  project, 
the  City  of  Bordeaux,  jointly  with  other  European 

(161)  Based  on  biodiversity 

tracking 

in 

the  EU  budget 

(164)  European  Commission, 

(https://circabc.europa.eu/ui/group/3f466d71-92a7-49eb-9c63-
6cb0fadf29dc/library/8e44293a-d97f-496d-8769-50365780acde), 
and national expenditure into biodiversity from the Classification 
of the Functions of Government accounts. 

(162)  European  Commission,  Green  Budgeting  in  the  EU.  Key  Insights 
from the 2023 European Commission Survey of Green Budgeting 
Practices, 
https://economy-
finance.ec.europa.eu/economic-and-fiscal-governance/national-
fiscal-frameworks-eu-member-states/green-budgeting-
eu_en#:~:text=European%20Commission%20Green%20Budgetin
g%20Survey%C2%A0.  

2023, 

(163) The 4th edition of the French Green Budget – 2024  

‘European  Union  green  budgeting 
https://economy-

2022, 

framework’, 

reference 
finance.ec.europa.eu/economic-and-fiscal-governance/green-
budgeting-eu_en. 

(165)  https://reform-support.ec.europa.eu/what-we-do/revenue-

administration-and-public-financial-management/supporting-
implementation-green-budgeting-practices-eu_en. 
(166)  https://www.collectivites-locales.gouv.fr/finances-

locales/budget-vert-des-collectivites. 

(167)

https://webgate.ec.europa.eu/TMSWebRestrict/resources/j

s/app/#/library/detail/85541. 

2025 Environmental Implementation Review – France 

 
 
 
 
 
 
France  46 

revenues  from  taxes  and  social  security  contributions 
(under the EU average of 5.0 %) (171). 

Figure 36: Environmental taxes per Member State, 2022 

cities,  has  begun  developing  methodologies  to  align 
local 
sustainable 
budgeting 
development goals (168). 

processes  with 

The  regional  dimension  of  the  EU  Green  Deal  has  been 
emphasised  by  the  Committee  of  the  Regions  with  the 
Green Deal going local initiative (169). 
Beyond green budgeting, to improve policy outcomes, the 
Commission  has  also  drawn  up  climate-proofing  and 
sustainability-proofing  guidance (170)  as  tools  to  assess 
project  eligibility  and  compliance  with  environmental 
legislation and criteria. 

Green taxation and tax reform 

Total environmental taxes amounted to EUR 54.9 billion in 
France in 2022, representing 2.1 % of its GDP (EU average: 
2.0 %).  Energy  taxes  formed  the  largest  component  of 
environmental taxes, accounting for 1.7 % of GDP, which 
is slightly higher than the EU average of 1.6 %. Transport 
taxes,  at  0.23 %  of  GDP,  were  under  the  EU  average 
(0.4 %), while taxes on pollution and resources, at 0.13 %, 
were  above 
In  2022, 
environmental taxes in France accounted for 4.5 % of total 

the  EU  average 

(0.08 %). 

The EU Green Deal emphasises the role of well-designed 
tax  reforms  (e.g.  shifts  from  taxing  labour  to  taxing 
pollution) to boost economic growth and resilience, and to 
foster  a  fairer  society  and  a  just  transition  through  the 
right price signals. The Green Deal promotes the ‘polluter-
pays  principle’,  which  makes  polluters  bear  the  costs  to 
prevent, control and remedy pollution. 

According  to  a  2024  study (172),  France  applies  various 
charges  on  pollutant  emissions  to  air,  water  and  soil; 
volumetric charges on water abstraction and disposal; and 
a charge on waste producers based on quantity. 

Green bonds and sustainable bonds 

In 2023, the total value of green bonds issued by Member 
States  was  USD 245 billion  (EUR 227 billion),  up  from 
USD 234 billion (EUR 198 billion) in 2021. 

During 2021–2023 combined, France issued green bonds 
worth  USD 96.5 billion  (EUR 81.6 billion).  Of  this,  the 

(168)  Technical support has been received under TSI project 24FR16. 
(169)  Green Deal Going Local | European Committee of the Regions. 
(170)  Commission notice – Technical guidance on the climate proofing 
of infrastructure in the period 2021–2027 (OJ C 373, 16.09.2021, 
p. 1), 
https://op.europa.eu/en/publication-detail/-
/publication/23a24b21-16d0-11ec-b4fe-
01aa75ed71a1/language-en. 

(171)  Eurostat, ‘Environmental taxes accounts’, env_eta. 
(172)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
Annex 1, 
https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
en.  

2025 Environmental Implementation Review – France 

 
 
 
 
France  47 

2023 
issuance 
(EUR 27.7 billion) (173). 

in 

amounted 

to  USD 30 billion 

During  2014–2023,  83 %  of  the  green  bonds  issued  by 
European  countries  (excluding  supranational  entities) 
served objectives in energy, buildings or transport, while 
5 % supported objectives in water, 5.1 % related to land 
use  (with  links  to  nature  and  ecosystems)  and  3.8 % 
applied  to  waste  management.  By  2023,  the  combined 
share of energy, buildings and transport had decreased to 
73 %, the share of waste management and land use had 
increased (to 5.9 % and 8.4 %, respectively) and the share 
of water had remained around 5 %. 

In  2021–2023,  31.7 %  of  the  European  green  bonds 
(excluding  those  issued  by  supranational  entities)  was 
issued  by  financial  corporates,  29.1 %  by  sovereign 
governments  and  23.1 %  by  non-financial  corporates. 
8.3 % of the issuances was linked to government-backed 
entities, 6.4 % to developments banks and 1.4 % to local 
governments. 

Figure 37: Value of green bonds issued per Member State 
(billion EUR), 2021, 2022 and 2023  

further  step  towards  achieving  the  eighth  environment 
action  programme  objectives  and 
the  enabling 
conditions (174). FFS are costly for public budgets and make 
it difficult to achieve European Green Deal objectives. 

The overall downward trend of FFS mentioned in past EIRs 
was disrupted from 2022 due to the European response to 
the 2021 energy crisis and subsequent increase in energy 
prices. 

As  a  direct  consequence,  annual  FFS  in  the  EU  have 
increased to EUR 109 billion in 2023 from EUR 57 billion in 
2020. From 2021 to 2023, there was a marked increase in 
annual FFS of 72 % in the EU (175). These amounts of Fossil 
Fuel Subsidies are based on the work of the Commission 
(DG  Energy)  and  have  been  used  in  past  EIR  reports  as 
giving  a  view  of  foregone  revenue  to  the  state’s  budget 
across Member States176. 

For the majority of the Member States (16), the year 2022 
saw  a  peak  in  the  amount  of  overall  FFS.  A  decline  was 
then observed in 2023 (177). In particular, FFS for coal and 
lignite, natural gas and oil increased in 2022 and a strong 
increase was observed for natural gas subsidies. 

In  France,  the  energy  subsidies  showed  some  increases 
in  2019–2021.  Overall,  they 
from  2015,  plateauing 
increased significantly in 2022 and started to decrease in 
2023. 
and 
EUR 13.4 billion  in  2015–2021,  and  after  a  spike  of 
EUR 30.5 billion  in  2022,  they  returned  to  more  normal 
values in 2023 (EUR 15.2 billion). 

ranged  between 

EUR 9.4 billion 

FFS 

Data source: Climatebonds.net, with some additional data from national 
sources (e.g. Croatia, Slovenia). 

Environmentally harmful subsidies 

Addressing  and  phasing  out  environmentally  harmful 
subsidies,  in  particular  fossil  fuel  subsidies  (FFS),  is  a 

(173)  Climate  bonds  initiative  (https://www.climatebonds.net/).  NB. 
Additionally (and not included in this), national sources indicated 
EUR 544.8 million issuance for Croatia, in 2022-2023, and a slightly 
higher  amount  for  Slovenia  (+0.27  billion)  during  2021-2023  in 
total. 

(174)  Article 3(h) and 3(v) of the eighth environment action programme. 
(175)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 
European Union, COM(2025), Register of Commission Documents 
- COM(2025)17 

176  France  mentioned  to  the  Commission  some  complementary 
methodologies such as effective carbon rate indicators, developed 
by  the  OCDE  (https://www.oecd.org/en/publications/effective-
carbon-rates-2023_b84d5b36-en.html 

(177)  16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, AT, 

PT, RO and SE. 

2025 Environmental Implementation Review – France 

 
 
 
 
As a share of GDP, FFS in 2022 ranged from 1.8 % in Croatia 
to less than 0.1 % in Denmark and Sweden. France’s value 
reached 1.1 %, above the EU average (0.8 %) (178). 

Figure 38:  Energy  subsidies  by  energy  carrier  (billion 
EUR), 2015–2023 

NB: RES, renewable energy source. 

Source: analysis of Directorate-General Energy 

The  2022  priority  actions  for  France  in  the  field  of 

France  48 

environmental finance included the following. 

•  Remove  (direct  or  indirect)  energy  subsidies  and 
other  forms  of  support  when  they  adversely  affect 
reaching  climate  neutrality  and  the  broader  Green 
Deal objectives. 
Shift the tax burden to green taxes, provide incentives 
to  change  long-term  behaviour  in  all  sectors  of  the 
the  green  budgeting 
economy,  and  complete 
initiative,  expanding  the  scope  of  budgetary  fields 
covered in the budget bill. 

• 

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

France’s  efforts  to  reduce  harmful  subsidies  has  been 
hampered by the energy crisis, so in this respect, limited 
progress has been made. The same goes for fiscal reform. 
On  the  other  hand,  the  government  and  some  local 
authorities have developed expertise in green budgeting. 

2025 priority action 

In  light  of  the  assessment  of  previous  actions  and  the 
observed gaps, the following recommendation is made. 

• 

Use more national funding (for instance by increasing 
taxes  in  favour  of  the  environment  and  reducing 
environmentally harmful subsidies), EU funding and 
private funding to help close the investment gap.  

(178)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 
COM(2025), 

European 

Union, 

https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en  

2025 Environmental Implementation Review – France 

 
 
 
 
 
France  49 

6. Environmental governance 

Information, public participation and access to 
justice 

Table 3: France dashboard on the implementation of the 
Inspire Directive, 2016–2023 

to 

(iii) 

and 

access 

justice 

Citizens  can  more  effectively  protect  the  environment  if 
they rely on the three ‘pillars’ of the Aarhus Convention: 
(i)  access  to  information,  (ii)  public  participation  in 
decision-making 
in 
environmental  matters.  It  is  of  crucial  importance  to 
public  authorities,  the  public  and  businesses  that 
environmental 
is  shared  efficiently  and 
effectively (179).  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 
environment, safeguard the rights of citizens and ensure 
accountability  of  authorities (180).  It  includes  the  right  to 
bring legal challenges (‘legal standing’) (181). 

information 

Environmental information 

This  section  focuses  on  the  implementation  of  the 
Infrastructure  for  Spatial  Information  in  the  European 
Community (Inspire) Directive. The Inspire Directive aims 
to  set  up  a  European  spatial-data  infrastructure  for 
sharing environmental spatial information between public 
authorities across Europe. It is expected that this will help 
policymaking  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. 

(179)  The  Aarhus 

Convention 

(https://unece.org/environment-
policy/public-participation/aarhus-convention/text),  the  Access 
to  Environmental  Information  Directive  (Directive  2003/4/EC) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32003L0004) 
Inspire 
Directive  (Directive  2007/2/EC)  (https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32007L0002) together create a legal 
foundation for the sharing of environmental information between 
public authorities and with the public. 

and 

the 

2016 

2023 

Legend 

Effective coordination and data sharing 

Ensure 
coordination  

effective 

Data 
without obstacles  

sharing 

■ 

■ 

INSPIRE performance indicators 

i.  Conformity  of 
metadata  

ii.  Conformity  of 
spatial data sets 

■ 

■ 

■ 

■ 

■ 

■ 

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

■  ■  

iv.  Conformity  of 
network services 

■  ■  

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

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

■ 
Implementation 
of  this  provision  is 
falling  significantly 
behind, with limited 
or  no  progress. 
Serious  efforts  are 
necessary  to  close 
the implementation 
gap. 
Percentage: 
<31%  

Source:  European  Commission,  ‘France’,  Inspire  Knowledge  Base, 
https://knowledge-base.inspire.ec.europa.eu/france_en. 

in 

implementing  the 

INSPIRE 
France’s  performance 
Directive  has  been  reviewed  based  on  the  reported 
monitoring  data  for  2023  (182).  In  2022,  the  European 
Commission  identified  a  priority  action  on  the  need  to 
make  spatial  data  more  widely  accessible  and  prioritise 
the environmental datasets (183). Despite steady progress 
on  making  spatial  data  accessible,  more  efforts  are 
needed. Therefore, the priority action is repeated in 2025. 

(https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:52017XC0818(02))  and  a  related 
2018 citizen’s guide (https://op.europa.eu/en/publication-detail/-
/publication/2b362f0a-bfe4-11e8-99ee-01aa75ed71a1/language-
en/format-PDF). 

(181)  This  EIR  focuses  on  the  means  used  by  Member  States  to 
guarantee  rights  of  access  to  justice  and  legal  standing  and  to 
overcome other major barriers to bringing cases on environmental 
protection. 

(180)  These  guarantees  are  explained  in  the  European  Commission’s 
2017  notice  on  access  to  justice  in  environmental  matters 

(182) European Commission, INSPIRE knowledge base France. 
(183) European Commission, List of high value spatial data sets. 

2025 Environmental Implementation Review – France 

 
 
 
 
  
More  efforts  are  needed  to  make  the  data  more  widely 
accessible,  and  environmental  datasets  must  be 
prioritised  in implementation, especially those  identified 
as  high-value 
implementing 
environmental legislation (184). Therefore, a priority action 
is specified in relation to this for 2025. 

spatial  datasets 

for 

Public participation 

Public involvement  at both the planning and the project 
phase  maximises  transparency  and  social  acceptance  of 
programmes  and  projects.  Consultation  with  the  public 
(including  NGOs)  and  environmental,  local  and  regional 
authorities  is  a  key  feature  of  an  effective  impact 
assessment procedure. Such consultation also provides an 
opportunity for public authorities and project promoters 
to  engage  with  the  public  actively  and  meaningfully  by 
making information on the likely significant effects widely 
available. If carried out with due diligence and taking into 
consideration  useful  public  input,  this  process  leads  to 
better-informed decision-making and can promote public 
acceptance.  Making 
increases 
stakeholder  involvement,  thus  lessening  resistance  and 
preventing (or minimising) litigation. On the other hand, it 
is paramount that the procedure is effective. 

information  available 

It  is  worth  noting  that  the  Green  Industry  Law (185) 
introduced some interesting provisions to increase public 
consultation,  even  if  some  reserve  has  been  expressed 
with regard to the consultation timing and the replies by 
the investigating commissioner to the observations made 
by the public (186). 

This  section  examines  how  public 
involvement  and 
transparency are ensured under two instruments, namely 
the Environmental Impact Assessment (EIA) Directive (187) 
and  the  Strategic  Environmental  Assessment  (SEA) 
Directive (188). 

EU law provides for a flexible framework concerning EIAs. 
The aim of this framework is to ensure the application of 

France  50 

the  necessary  environmental  safeguards,  while  enabling 
speedy  approval  of  projects.  The  Commission  has 
contributed to simplifying and accelerating permitting for 
renewable energy projects and continues to support the 
Member  States  in  this  regard  (189).  France  has  already 
taken 
to  accelerate  permit-issuing 
procedures  taking  advantage  of  the  broad  flexibilities 
offered  by  the  EU 
legal  framework,  such  as  the 
establishment  of  one-stop  shops  and  accelerated  short 
deadlines  for 
issuing  permits  for  renewable  energy 
projects. 

steps  aiming 

(screening, 

scoping,  EIA 

The average speed in the EU for issuing permits involving 
is  20.6 months,  with  a  minimum 
an  EIA  procedure 
duration  of  11.4 months  and  a  maximum  duration  of 
75.7 months (190).  The  duration  of  each  step  in  an  EIA 
process 
report,  public 
consultation, reasoned conclusion, development consent) 
varies considerably between Member States and projects. 
There are no data reported for France. A priority action is 
included for 2025 to provide more detailed information on 
the average duration of the EIA process. Effective use of 
EU  procedures  can  positively 
influence  the  timely 
approval of activities underpinning the decarbonisation of 
the economy on the way to net zero by 2050. 

A new report  is not  yet  available on the application and 
effectiveness of the SEA Directive in the EU. Nevertheless, 
a support study has been published with information by 
Member State (191). 

While public participation is essential to the EIA process, it 
is  also  essential  that  the  national,  regional  and  local 
competent authorities tasked with the implementation of 
the  EIA  Directive  do  not  find  themselves  in  a  situation 
giving rise to a conflict of interest, in particular when the 
competent authority is also the developer. In this context, 
the Commission has found that such a conflict may arise 
in  certain  situations  and  has  therefore  launched  an 
infringement procedure to ensure that France puts an end 
to this practice. 

(184)  https://github.com/INSPIRE-MIF/need-driven-data-

(189) 

Commission  Staff  Working  Document    (SWD/2022/0149 
final), 18 May 2022, EUR-Lex - 52022SC0149 - EN - EUR-Lex. 

(185) 

prioritisation/blob/main/documents/eReporting_PriorityDataList
_V2.1_final_20201008.xlsx.  
Loi No 2023-973 du 23 octobre 2023 relative à l'industrie verte (1) 
(https://www.legifrance.gouv.fr/loda/id/LEGIARTI000048243190
/2023-10-25/).  

(186)  https://www.actu-environnement.com/ae/news/loi-industrie-
verte-decret-application-democratie-environnementale-
commissaire-enqueteur-44940.php4. 

(187)  Directive  2011/92/EU  of  the  European  Parliament  and  of  the 
Council of 13 December 2011 on the assessment of the effects of 
certain public and private projects on the environment (OJ L 26, 
28.1.2012, 
https://eur-lex.europa.eu/legal-
p. 1), 
content/EN/TXT/?uri=CELEX%3A32011L0092. 

(188)  Directive  2001/42/EC  of  the  European  Parliament  and  of  the 
Council of 27 June 2001 on the assessment of the effects of certain 
plans and programmes on the environment (OJ L 197, 21.7.2001, 
p. 30), 
https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32001L0042. 

Impact  Assessment 

(190)  European  Commission:  Directorate-General  for  Environment, 
Collection of information and data on the implementation of the 
revised  Environmental 
(EIA)  Directive 
(2011/92/EU) as amended by 2014/52/EU), Publications Office of 
the  European  Union,  Luxembourg,  2024,  Tables 5  and  6, 
https://op.europa.eu/en/publication-detail/-
/publication/8349a857-2936-11ef-9290-01aa75ed71a1/. 
(191)  European  Commission:  Directorate-General  for  Environment, 
Lundberg, P., McNeill, A., McGuinn, J., Cantarelli, A. et al., Study 
supporting  the  preparation  of  the  report  on  the  application  and 
effectiveness  of  the  SEA  Directive  (Directive  2001/42/EC)  –  Final 
study,  Publications  Office  of  the  European  Union,  2025, 
https://data.europa.eu/doi/10.2779/1615072 

2025 Environmental Implementation Review – France 

 
 
 
Access to justice 

UNECE ESPOO EIA convention and the SEA protocol   have 
since been ratified on 16 January 2024. 

France  51 

Access to justice, guaranteed by Article 19(1) of the Treaty 
on  European  Union  and  Article 47  of  the  EU  Charter  of 
Fundamental Rights, is a fundamental right and part of the 
democratic process. It is vital to ensure the full application 
of EU law in all Member States and the legal protection of 
the  rights  of  individuals,  including  in  environmental 
matters.  Access  to  justice  is  essential  to  enable  judicial 
review of the decisions of public authorities and to allow 
the  correction  of  any  wrongdoing  committed  by  these 
authorities. 

This  section  provides  a  snapshot  of  the  state  of  play  of 
access to courts by the public, particularly when it comes 
to challenging plans, or the non-adoption of plans, under 
EU law, in the areas of water, waste, air quality and noise, 
irrespective of the form of the legal act (i.e. regulatory act 
or administrative decision). 

As stated in the 2022 EIR, France provides the possibility 
to access justice in environmental matters in the areas of 
water,  waste,  air  quality  and  noise.  Appeals  by 
organisations  in  defence  of  their  statutory  purpose  are 
admitted in a flexible manner by administrative judges. An 
appeal  by  an  organisation  is  only  admissible  if  the 
contested decision adversely affects the collective interest 
that the organisation defends. 

The  SEA  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).  The  Conseil  d'Etat 
ruled 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. 

In  the  2022  EIR,  France  received  priority  actions  on 
publishing data on public participation, improving access 
to  environmental  information  and  access  to  justice,  and 
missing ratification of international EIA protocols and SEA 
treaties. 

Progress  has  been  made  to  facilitate  public  access  to 
environmental 
information  related  to  projects  and 
programmes.  On  the  contrary,  no  evidence  has  been 
found  related  to  access  to  justice  rights;  this  should  be 
assessed by the authorities. The first amendment on the 

(192)  The concept is explained in detail in the European Commission’s 
2018  communication  on  EU  actions  to  improve  environmental 
compliance  and  governance  (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52018DC0010)  and  the  related 
(https://eur-
Commission 

document 

working 

staff 

2025 priority actions 

environmental 

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

datasets 

in 

•  Provide  information  on  the  average  duration  of  all 

steps in the EIA process. 

•  Ensure  correct  transposition  of  the  revised  EIA 

Directive. 

Compliance assurance 

Environmental  compliance  assurance  covers  all  work 
undertaken by public authorities to ensure that industries, 
farmers and others fulfil their obligations to protect water, 
air and nature, to manage waste (192) and to remedy any 
environmental  damage.  It  includes  measures  such  as  (i) 
compliance  promotion,  (ii)  compliance  monitoring  (i.e. 
inspections  and  other  checks),  (iii)  enforcement,  that  is, 
steps taken to stop breaches and impose sanctions, and 
(iv) ensuring damage prevention and remediation in line 
with the polluter-pays principle. 

Compliance promotion, monitoring and enforcement 

Non-compliance  with  environmental  obligations  may 
occur for different reasons, including poor understanding 
or  lack  of  acceptance  of  the  rules,  opportunism  or  even 
criminality.  Compliance  promotion  activities  help  duty-
holders to comply by providing information, guidance and 
other  support.  This  is  particularly  important  in  areas 
where new and complex legislation is put in place. 

When  inspections  and  other  control  activities  identify 
problems,  a  range  of  responses  may  be  appropriate, 
including 
the  use  of  administrative  and  criminal 
enforcement tools.  

police 

department 

Since  the  2022  EIR,  France  has  made  further  efforts  to 
in  2023  a  new 
support  specialisation  and  created 
combating 
on 
specialised 
environmental 
pour 
l’environnement et la santé (193)). This body has functions 
related  to  training,  coordination  and  development  of 
practical  tools  for  the  investigation  of  environmental 
technologies.  The 
crime  based  on  use  of  new 

(Commandement 

crime 

lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52018SC0010). 

(193)  https://www.gendarmerie.interieur.gouv.fr/notre-

institution/notre-organisation/le-commandement-pour-l-
environnement-et-la-sante-cesan. 

2025 Environmental Implementation Review – France 

 
 
 
establishment of such specialised departments facilitates 
effective enforcement and coordination and can be seen 
as good practice. 

The  2022  EIR  recommended  that  France  (i)  ensure  that 
websites  of  national  and  regional  authorities  with 
environmental  responsibilities  include  clear  information 
on how the public can report breaches or file complaints; 
(ii)  improve  cooperation  systems  between  professionals 
improve 
combating  environmental  crimes;  and  (iii) 
information  for  the public on the availability of financial 
securities  to  meet  the  costs  of  environmental  damage. 
Concerning  compliance  promotion,  monitoring  and 
criminal  and  administrative  enforcement,  the  2022 
priority  actions  are  not  assessed  here  due  to  lack  of 
systematic information. 

The new EU Environmental Crime Directive 

The EU has recently strengthened its legal framework on 
tackling  the  most  serious  breaches  of  environmental 
obligations,  notably  by  the  adoption  of  the  new 
Environmental  Crime  Directive  (ECD)  (Directive  (EU) 
2024/1203)194 and new sectoral legislation with stronger 
provisions  on  compliance  monitoring,  enforcement  and 
penalties. Issues important for the transposition and the 
implementation  of  the  relevant  new  instruments  are 
highlighted below. A detailed assessment of these topics 
will  be  included  in  the  next  EIR  once  the  relevant 
implementation  measures  are  put  in  place  and  more 
systematic information is available. 

The  new  ECD  replaced  the  2008  ECD  and  introduced 
several  new  offence  categories,  such  as  unlawful  ship 
recycling,  unlawful  water  abstraction,  and  serious 
breaches  of  EU 
legislation  on  chemicals,  mercury, 
fluorinated GHG and IAS of EU concern. It also covered the 
establishment  of  qualified  offences,  subject  to  more 
severe penalties where one of the offences defined in the 
directive  leads  to  serious  widespread  and  substantial 
damage  or  destruction  of  the  environment.  Concrete 
provisions on the types and levels of penalties that can be 
imposed  for  natural  and  legal  persons  who  commit  an 
offence were also introduced. Other provisions will help 
considerably  to  improve  the  effectiveness  in  combating 
environmental crime of all actors along the enforcement 
chain.  These  include  obligations  to  ensure  adequate 

law 

criminal 

194  Directive  2024/1203/EU  on  the  protection  of  the  environment 
through 
(https://eur-
lex.europa.eu/eli/dir/2024/1203/oj/eng), 
(195)  https://www.impel.eu/en. 
(196) 

LIFE+SATEC 
(https://webgate.ec.europa.eu/life/publicWebsite/project/LIFE2
0-PRE-ES-000001/fight-against-environmental-crime-at-a-
strategic-level-through-the-strengthening-of-envicrimenet-
network-of-experts-in-environmental-criminal-investigations). 

project 

France  52 

resources  and  investigative  tools,  specialised  regular 
training  and 
cooperation 
the  establishment  of 
mechanisms within and between Member States as well 
as national strategies on combating environmental crime. 

including  by 

Member  States  are  required  to  transpose  the  new  ECD 
into national law by 21 May 2026 and to take additional 
measures  to  more  effectively  combat  environmental 
crime, 
in  particular  through  training,  coordination, 
cooperation  and  strategic  approaches.  The  Commission 
will  provide  support, 
facilitating  the 
identification  and  sharing  of  good  practices.  Member 
States are expected to ensure the necessary resources and 
specialised skills and they are invited  to encourage their 
authorities to support and cooperate with the recognised 
EU-level  networks  of  environmental  enforcement 
practitioners, 
the 
Implementation  and  Enforcement  of  Environmental 
Law (195),  EnviCrimeNet (196),  the  European  Network  of 
Prosecutors for the Environment (197) and the EU Forum of 
Judges  for  the  Environment (198).  The  European  Union 
Agency for Law Enforcement  Cooperation and European 
Union  Agency 
Justice  Cooperation 
mechanisms for cooperation on cross-border cases should 
be used more systematically for environmental offences. 

EU  Network 

for  Criminal 

such 

the 

for 

Environmental Liability Directive 

The  Environmental  Liability  Directive  (ELD)199  aims  to 
ensure that environmental damage is remediated in kind 
at the expense of those who have caused it, in line with 
the polluter-pays principle. It helps to halt the net loss in 
biodiversity,  as  well  as  reducing  the  number  of 
contaminated  sites  and  protecting  the  environmental 
quality of groundwater and surface waters. The ELD is a 
cross-cutting 
for  better 
tool  and  a  key  enabler 
implementation of EU environmental law. 

The  ELD  addresses  cases  of  significant  environmental 
damage  to  protected  species  and  natural  habitats,  and, 
when caused by operators carrying out certain potentially 
hazardous  activities,  also  damages  to  water  and  to  soil. 
The  Commission  has  the  legal  obligation  to  periodically 
evaluate  the  ELD.  The  ELD  has  undergone  the  second 
evaluation (200), which will be finalised in 2025, and which 
was  supported  by  an  external  study (201),  containing, 
among  other  things,  evidence,  views,  reports  and  other 

199  199  Directive  2004/35/EC  on environmental  liability  with  regard  to 
the  prevention  and  remedying  of  environmental  damage  (https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02004L0035-
20190626). 
(200)  Commission  staff  working  document  -  Evaluation  of  the 

Environmental Liability Directive, forthcoming 2025.  

(201) 

 European Commission: Directorate-General for Environment and 
in  support  of  the  evaluation  of  the 
Fogleman,  V.,  Study 

(197)  https://www.environmentalprosecutors.eu. 
(198)  https://www.eufje.org/index.php?lang=en. 

2025 Environmental Implementation Review – France 

 
 
 
 
relevant information gathered from different stakeholder 
groups, including Member States. 

indicators 

One  of  the  most  relevant 
in  assessing 
implementation  and  enforcement  of  the  ELD  is  the 
number  of  environmental  damage  cases  handled  under 
the  ELD,  especially  when  this  number  is  compared  with 
the  previous  reporting  period.  Fewer  ELD  cases  were 
reported in the second reporting period (2013–2022) than 
in  with  the  first  one  (2007–2013).  However,  the 
downward  tendency  in  the  number  of  ELD  occurrences 
and their overall low number do not necessarily mean that 
the  ELD  has  achieved  its  objectives,  as  it  needs  to  be 
compared  with  the  overall  number  of  environmental 
damage  cases,  some  of  which  may  have  been  handled 
under the other liability instruments. 

The ELD has not always been effective in ensuring that the 
polluter  pays,  because  the  liable  operators  often  lack 
financial  capacity  to  carry  out  remediation  measures. 
While the ELD does not provide for a mandatory financial 
security  system,  it  explicitly  calls  for  Member  States  to 
encourage 
financial  security 
instruments  and  markets,  with  the  aim  of  enabling 
operators  to  use  financial  guarantees  to  cover  their 
responsibilities under this directive. 

the  development  of 

From 1 May 2013 to 31 December 2021, France reported 
only one occurrence of environmental damage under the 
ELD  (water  and  biodiversity  damage).  No  environmental 
damage  under  the  ELD  was  reported  in  the  previous 
reporting period. 

insurance  policies 

France has not imposed mandatory financial security for 
ELD  liabilities,  but  there  is  strong  demand  for  such 
that 
instruments.  Environmental 
provide  cover  for  all  liabilities  under  the  ELD,  including 
complementary  and  compensatory  remediation  for  on-
site  and  off-site  damage,  are  widely  available. 
Environmental extensions to general liability policies are 
commonly  included  in  the  body  of  the  policies  and 
typically provide coverage only for the remediation of off-
site pollution from a sudden and accidental incident on an 
insured  site.  Some  insurers  offer  extensions  for  ELD 
liabilities  as  well  as 
liabilities  related  to  ecological 
prejudice under the French Civil Code. 

The  2022  EIR  suggested  that  France  improve  public 
information  on  the  availability  of  financial  securities  to 
meet  the  costs  of  environmental  damage.  There  is  no 

Environmental  Liability  Directive  and  its  implementation –  Final 
report,  Publications  Office  of  the  European  Union,  Luxembourg, 
2024, 
https://op.europa.eu/en/publication-detail/-
/publication/006d90e5-980a-11ef-a130-
01aa75ed71a1/language-en. 

(202)  See 

the  European  Commission  web  page  on  Compact 
(https://reform-support.ec.europa.eu/public-administration-and-
governance-coordination/enhancing-european-administrative-
space-compact_en). 

France  53 

information available about  the progress on this priority 
action. Therefore, efforts to implement it should continue 
along with the 2025 priority action. 

2025 priority action 

• 

Encourage the use of training programmes provided 
by  the  Commission  (or  developed  at  the  national 
level) and covering the ELD and its interactions with 
the  other  national  liability-related  instruments,  to 
ensure  more  efficient  ELD  implementation,  improve 
the expertise of the competent authorities and raise 
awareness among all stakeholder groups. 

EU-supported environmental capacity building 

initiative 

The  Commission’s  2023  Compact (202) 
to 
enhance  the  administrative space  identifies  the  capacity 
to  lead  the  green  transition  as  one  of  three  key  pillars, 
along with the public administration skills agenda and the 
capacity  for  Europe’s  Digital  Decade.  Compact  also 
recognises the role of the EIR reporting tool in improving 
environmental  governance.  The  two  main  capacity-
building  opportunities  for  the  environment  provided  by 
the European Commission are the TSI (203) and the TAIEX-
EIR  PEER  2  PEER  tool (204).  The  technical  assistance 
available through the cohesion policy is subject to shared 
management and is not dealt with in this subsection. 

The Commission’s technical support instrument  

The  TSI  provides  Member  States  with  tailor-made 
technical expertise on the design and implementation of 
reforms.  The  support  is  demand  driven  and  does  not 
require national co-financing. The TSI had annual calls in 
2021, 2022, 2023, 2024 and 2025. 

In  2023,  the  French  Authority  for  Prudential  Control 
(Autorité de Contrôle Prudentiel et de Résolution - ACPR) 
received support on ESG risk management framework for 
the financial sector. 

In 2024, France benefited from the TSI to support for the 
preparation of the French national restoration plan, with 
the beneficiary authority being the Ministry of Ecological 
Transition.  

Furthermore,  the  City  of  Bordeaux  (together  with 
Amsterdam,  Hamburg,  Barcelona)  benefited  from  TSI 
support  for  integrating  the  Sustainable  Development 

(203)  See 

the  European  Commission  web  page  on 

the  TSI 

(https://commission.europa.eu/funding-tenders/find-
funding/eu-funding-programmes/technical-support-
instrument/technical-support-instrument-tsi_en). 

(204)  See the European Commission web page on the TAIEX-EIR PEER 2 
(https://environment.ec.europa.eu/law-and-

PEER 
governance/environmental-implementation-review/peer-2-
peer_en). TAIEX: Technical Assistance and Information Exchange. 

tool 

2025 Environmental Implementation Review – France 

 
 
Goals (SDGs) into local frameworks and aligning them with 
local  budgets  (Sustainability  in  Local  Public  Finances 
project (2024). 

The Commission’s TAIEX-EIR PEER 2 PEER tool 

The Commission launched the TAIEX-EIR PEER 2 PEER tool 
in 2017. It aims to facilitate peer-to-peer learning among 
Member  States’  environmental  authorities  through 
workshops  (single  or  multi-country),  expert  missions 
(where a  delegation of  experts travels to the requesting 
institution) and study visits (where a delegation from the 
requesting  institution  travels  to  a  host  country).  Multi-
country  workshops  events  are  those  requested  by  the 
Commission to present new and upcoming environmental 
legislation and policy in all Member States (205). 

Workshops involving France are as follows: 

•  Climate adaptation and blue infrastructure (31 May–

• 

1 June 2022); 
Legal-regulatory 
management 
16 June 2022); 

frameworks 

coastal 
in  Mediterranean  countries 

for 

•  Circular economy (in the Irish Midlands) (4–6 October 

2022); 

France  54 

• 

Future  challenges  for  air  protection  (24 November 
2022) with the EU Czech Presidency; 

•  Make  space  for  biodiversity:  Regional  action  to 
mainstream  biodiversity  and  empower  stakeholders 
(21–23 March 2023); 

•  Biowaste management in Italy (6–8 June 2023); 
•  Green budgeting at regional level (9 April 2024); 
•  Biodiversity, nature conservation and large predators: 

Examples across European regions (4–6 June 2024); 

•  Reducing air pollution from transport and residential 

energy (11–13 June 2024); 

•  Online  platforms:  EU  batteries,  packaging  and 
packaging waste regulation (28–29 September 2024); 
•  New aspects in the cross-border cooperation against 
environmental crime (19–20 November 2024) (206). 

France  (Occitanie)  hosted  a  study  visit  from  the  Västra 
region  in  Sweden  on  Integrating  biodiversity  in  regional 
land-use planning: data, decision making and local action 
in Montpellier, 29 - 31 January 2025. 

land 
(15–

2025 priority action 

• 

overall 

national 

improve 
environmental 
governance, in particular administrative capacity 
to support the green transition and coordination 
at the regional and local levels. 

(205)  Flagship  multi-country  workshops  in  the  reporting  period  are 
Recast  Drinking    Water  Directive  (3  April  2025);  Environmental 
compliance  and  governance  (18  March  2025);  Planning  of 
Renewable  Energy  Projects  (20  February  2025);  Air  Quality: 
Implementation  of  the  revised  Air  Quality  Directive  (16  January 
2025); Industrial safety: awareness raising of emerging risks linked 
with climate change and decarbonation (12 December 2024); Air 
pollution: 
implementation  of  the  NEC  Directive  to  further 
mainstream  air  and  broader  pollution  reduction  in  agricultural 
policy  (25 September  2024);  Industrial  emissions  transposition 
and implementation of the revised directive (12 September 2024); 
Noise:  progress  towards  meeting  Member  States’  noiselimit 
values and EU reduction targets (5 June 2024); Best practice use 
of  environmental  footprint  methods  on  the  EU  market  (30 May 
2024);  Sustainable  finance  (9 November  2023);  Textile  waste 

separate collection, treatment and markets (3 October 2023); EU 
environmental  funding  and  support  (13 June  2023);  Advisory 
service for businesses to go circular (24 April 2023); Digital product 
passport implementation (6 December 2022); Public involvement 
in  planning  and  approval  of  renewable  energy  projects 
(17 November 2022); Environmental compliance and governance 
(14 November  2022);  Biowaste  management  (19–20 September 
2022);  and  Renewable  energy  projects:  permit  granting 
procedures    (13 June  2022).  NB:  The  first  flagship  workshop  on 
zero  pollution  for  air,  water  and  soil  took  place  on  9 February 
2022.  

https://webgate.ec.europa.eu/TMSWebRestrict/resources/j

s/app/#/library/detail/90076?hasBackBtn=false. 

(206)

2025 Environmental Implementation Review – France 

 
 
 
 
 
France  55 

Annex 

2025 priority actions 
Circular economy and waste management 
Transitioning to a circular economy 

Speed  up  the  transition  to  a  circular  economy  by  implementing  an  updated  national 
strategy and the EU framework and recommendations, in particular to complement it with 
upstream circularity measures.  

Waste management 

• 

• 

• 
• 

Improve separate collection at the source (e.g. through using economic instruments, 
investing in infrastructure for separate collection, sorting and recycling, and increasing 
public awareness).  
Improve municipal waste preparation for reuse and recycling.  
Increase the collection and recycling rate of waste electrical and electronic equipment 
(WEEE).  
Invest in waste prevention measures to reduce the total amount of waste generated.  
Implement and expand the pay-as-you-throw system for businesses and households.  

• 
• 
•  Ensure the achievement of the 2025 waste targets, following the recommendations 

made by the Commission in the early warning reports where applicable.  

Biodiversity and natural capital 
Nature protection and restoration – Natura 2000 

•  Complete the Natura 2000 site designation process.  
• 

Finalise  the  establishment  of  site-specific  conservation  objectives  and  measures  for  all 
Natura  2000  sites  (including  by  adopting  their  management  plans)  and  ensure  their 
effective implementation.  

• 

Recovery of species  
Strengthen the integration of biodiversity actions into other policies, e.g. energy, 
agriculture, fisheries, forestry, urban and infrastructure planning and sustainable tourism, 
and promote communication between stakeholders.  

•  Enhance efforts to collect reliable data on the conservation status of habitats and species 
as well as their occurrence at site level. In view of this, consider the creation of a body in 
charge of monitoring and reporting, to ensure that data are not provided only ad hoc on 
a contract basis.  

•  Reinforce action for habitats and species with unfavourable conservation status through, 
for example, restoration measures, increased connectivity, better policy coordination and 
integration and increased funding.  

Recovery of ecosystems 

• 

Implement l eco-schemes and agri-environmental measures and practices to address the 
environmental needs of France.  
Implement and scale up the uptake of organic farming practices.  

• 
•  Report updates on the assessment of the state of France’s marine waters, its targets and 
its determinations of GES (62), which are expected to include any threshold values for the 
descriptors in the MSFD that may have been established in cooperation with other 
Member States at the EU or regional level. 

Prevention and management of invasive alien species  

2025 Environmental Implementation Review – France 

 
 
 
 
  
 
France  56 

• 

Step up implementation of the IAS Regulation, including with regard to enforcement and 
the capacity of inspection authorities.  

Zero pollution 
Clean air 

•  As part of the NAPCP, take action to reduce emissions of air pollutants.  
•  Ensure full compliance with the current AAQD standards, also in light of future stricter 

requirements under the revised AAQD.  

Industrial emissions 

•  Reduce industrial air pollution damage and intensity.  
•  Reduce industrial releases to water and their intensity.  
•  Engage with industry and environmental NGOs to ensure proper contribution to and 

implementation of BAT conclusions and ensure timely updates to permits following the 
publication of BAT conclusions.  

•  Ensure effective public participation and access to justice in relation to the IED.  

Major industrial accidents prevention – Seveso 
•  Ensure access to transparent and clear information for citizens on risks and behaviour in 

the event of an accident.  

•  Ensure full and correct transposition of the Seveso III Directive.  

Mercury Regulation 

•  Take effective action against illegal gold mining in French Guiana.  

•  Complete noise mapping.  
•  Complete and implement action plans on noise management.  

Water quality and management 

Noise 

• 

Improve river continuity and ecological flows, boosting efforts on nature-based solutions 
to reduce hydromorphological pressures  

•  Ensure periodic reviews of permits for discharges, abstractions and other water uses, 

including hydropower pressures  

•  Reduce pollution from nutrients, chemicals, metals and saline discharges  
•  Better justify exemptions to the achievement of good status   
Improve the classification of water bodies and strengthen monitoring systems  
• 
•  Develop more robust programmes of measures, tackle obstacles identified in the 
implementation of measures and ensure adequate financing for implementation, 
including through better use of the cost recovery and polluter pays principle  
FRMPs should provide details on how the FHRMs were used in the choice of measures 
and how to consider pluvial flooding  

• 

•  Better explain the choice and implementation of flood prevention and protection 

measures (prioritisation, monitoring, costs of measures)  
Improve public consultation and stakeholder involvement.  

• 
•  Take action to ensure full compliance with the Drinking Water Directive 
•  Tackle nutrient pollution, especially nitrates from agriculture, through the 

implementation of the Nitrates Directive.  

•  Take the necessary measures to ensure full implementation of the current UWWTD, 

taking into account the new requirements of the recast directive.  

Chemicals 

2025 Environmental Implementation Review – France 

 
 
 
 
 
 
France  57 

•  Upgrade the administrative capacities in implementation and enforcement to move 

• 

• 

• 

towards a policy of zero tolerance of non-compliance.  
Increase involvement in the activities of the Forum for Exchange of Information on 
Enforcement of the European Chemicals Agency, including in the coordinated 
enforcement projects, called REF projects.  
Increase customs controls and controls of products sold online with regard to compliance 
with chemicals legislation. 

Climate action 

In the next period France should focus on implementing all polices and measures that are 
needed to achieve targets defined by Effort Sharing Regulation and LULUCF regulation. 
More detailed priority actions are identified in the assessment of the final national 
energy and climate plan (NECP). 

Financing 
•  Use more national funding (for instance by increasing taxes in favour of the environment 
and reducing environmentally harmful subsidies), EU funding and private funding to help 
close the investment gap. 

Environmental governance 
•  Make spatial data more widely accessible and prioritise environmental datasets in the 

implementation of the Inspire Directive, especially those identified as high-value spatial 
datasets for implementing environmental legislation.  

•  Provide information on the average duration of all steps in the EIA process.  
•  Ensure correct transposition of the revised EIA Directive.  
•  Encourage the use of training programmes provided by the Commission (or developed at 
the national level) and covering the ELD and its interactions with the other national 
liability-related instruments, to ensure more efficient ELD implementation, improve the 
expertise of the competent authorities and raise awareness among all stakeholder 
groups. 
Improve overall national environmental governance, in particular administrative capacity 
to support the green transition and coordination at the regional and local levels.  

• 

2025 Environmental Implementation Review – France