France: An Environment Overview
Introduction
French environmental law is currently evolving within the dual context of international and national instability.
At the international level, the geopolitical situation is marked by global geopolitical tensions as well as regulatory and economic uncertainties in the United States, which influence global environmental standards and investment flows, all against the backdrop of an accelerating climate crisis and the rapid decline of biodiversity.
At the national level, France is approaching an election cycle, between the municipal elections of 2026 and the presidential election of 2027. Divergences with respect to environmental, energy and land-use issues are crystallising, and the future political and legislative orientation of these sectors will depend on the results of these elections.
Instability in Renewable Energy Policy
The unstable political situation in France, following the dissolution of the National Assembly in 2024, delayed the publication of the third version of the Multiannual Energy Programme (Programmation pluriannuelle de l’énergie – PPE), which sets the major directions of energy policy in metropolitan France.
This steering tool is crucial for the development of renewable energies and, more generally, for aligning the country with decarbonisation goals, setting the development trajectory of each energy sector for the next ten years. This delay, coupled with deep divergences within the political class regarding the energy mix (increasing the share of nuclear energy and decreasing the share of renewable energies in the French energy mix), has created major energy uncertainty, threatening crucial decarbonisation investments and slowing the energy transition.
However, in the third version of the PPE, published in February 2026, the government decided to leave the objective of public support, provided through competitive tenders for onshore renewable energy until 2028, unchanged from the second version while also seeking to revive investments in hydroelectricity.
Another source of uncertainty is the frequent regulatory changes regarding the requirements for solarising roofs and parking lots. The most recent uncertainty arises from the upcoming transposition of the Directive on the Energy Performance of Buildings (EPBD).
Adoption of the Omnibus package and its consequences for the CSRD
The European reporting framework established by the Corporate Sustainability Reporting Directive (CSRD) also experienced a notable shift with the adoption of the Omnibus I package on 16 December 2025, which postponed by two years the implementation of sustainability reporting requirements under the CSRD and increased the threshold of companies in scope (over 1,000 employees and net annual turnover of more than EUR450 million). Large companies in scope will be subject to this reporting obligation in 2028 instead of 2026.
As a reminder, the CSRD requires companies, in their annual reporting, to present their governance model and strategy regarding sustainability issues, explain their objectives for reducing greenhouse gas emissions and describe how their activities contribute to the ecological transition, among other things.
Expansion of EPR schemes
The implementation of extended producer responsibility (EPR) schemes continues in France, as part of a circular economy policy aimed at reducing, reusing and recycling waste. A recent decree (17 November 2025) clarified the framework for producers of professional packaging waste, requiring the use of accredited eco-organisations; this will be implemented in July 2026.
Other EPR schemes are also planned, including schemes for chewing gum and plastic-containing fishing products. Regarding chewing gum, a bill containing various provisions adapting EU law (Ordonnance portant diverses dispositions d’adaptation au droit de l’Union européenne – DDADUE) is currently being adopted by Parliament. Regarding plastic-containing fishing gear, a decree was published in August 2025.
The trend is therefore towards strengthening the environmental obligations of waste generators and expanding EPR schemes.
Recent Developments in Urban Planning Law
In the context of a housing crisis and a declared desire to address it by facilitating real estate projects, a law simplifying urban planning and housing law was adopted on 26 November 2025, aiming to strengthen the legal certainty of authorisations granted to real estate operators.
This legislation primarily aims to reduce refusals of building permits and limit annulments in litigation, in particular by removing the automatic requirement for environmental assessment in case of minor modifications to local urban planning plans (plan local d’urbanisme – PLU) and shortening the time limit for challenging permits through an informal administrative appeal to one month.
The Zero Net Land Take Law (ZAN), which aims to limit and offset land artificialisation by 2050, is also currently under discussion. A bill aiming to limit the scope of ZAN and delay its implementation is under parliamentary review.
PFAS: The Emergence of a New Legal Framework
The risks to public health and the environment caused by perfluoroalkyl and polyfluoroalkyl substances (PFAS) are becoming a major concern for environmental law stakeholders.
On 27 February 2025, a law progressively banning the manufacture, export and marketing of any cosmetic product, wax or clothing textile containing PFAS (“forever chemicals”) was passed.
In addition, a set of decrees (22 and 28 December 2025) provide for health controls in respect of water in industrial facilities, proposing thresholds for the application of the ban on PFAS. This new legislation appears to foreshadow the rise of a new PFAS-focused litigation, illustrated by the recent lawsuit launched by associations and nearly 200 individuals against Arkema and Daikin Chemicals seeking compensation for damages resulting from PFAS contamination of the environment.
Conclusion
In light of political uncertainty and economic difficulties, there is a tendency in France, and across Europe, to temporarily postpone environmental obligations in order to prioritise other economic or social interests. Meanwhile, companies are increasingly exposed to litigation risks, particularly in relation to environmental health issues.