Environmental Impact Assessment: does it apply to my photovoltaic project?

Environmental Impact Assessment: does it apply to my photovoltaic project?

10 Feb 2026 | IMPACT STUDY, REGULATIONS

Are you planning to install a solar power plant or a photovoltaic project? Before you get started, one essential question arises: is your project subject to an Environmental Impact Assessment ?
Solar energy is essential for the energy transition. France is accelerating its deployment, notably through the Law for the Acceleration of Renewable Energy Production (APER). However, every solar project has an environmental footprint.
This is why the Environmental Code regulates these projects and, in certain cases, mandates an environmental impact assessment. This is a way to evaluate the potential effects of a project before it is launched. To find out more about impact assessments, you can read our dedicated article.
In this article, we help you clarify whether your photovoltaic project falls under this obligation. Exemption, case-by-case examination, or systematic assessment ? Let’s have a look at what this means in practice.

When do I need to conduct an environmental impact assessment?

The obligation to carry out an impact assessment is defined by Article R. 122-2 of the french Environmental Code and its annexed nomenclature.

It defined the projects concerned according to their nature and size. There are three possibilities for a project:

  1. Exemption: The project is not subject to the procedure.
  2. Case-by-case examination: The project developer must file a simplified folder, and the competent authority (often the Regional Prefect or DREAL – Regional Directoration for Environment, Planning, and Housing-) decides whether a full impact assessment is necessary.
  3. Systematic environmental assessment: Due to its size, the project is deemed to have a significant potential impact, making a complete and detailed study is then mandatory.

Knowing which rules apply to your project is an important step. Submitting an application without an environmental assessment when one is required can lead to the refusal of your building permit or operating license.

What are the regulations applying to photovoltaics projects ?

The regulations for photovoltaic projects are defined in a specific section of the Environmental Code. This is section 30 in the nomenclature of Article R. 122-2. 

This section was modified by Decree No. 2022-970 of July 1, 2022, and simplifies the criteria defining the obligation to perform an environmental impact assessment for a project. The objective is clear: to exclude projects on already built-up surfaces (roofs, parking lots) in order to focus the assessment effort on ground-mounted power plants.

It should also be noted that this procedure is distinct from other requirements, such as the requirement to install solar carports on parking lots larger than 1,500 m² provided for by the APER law for example.

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What are the regulations applying to photovoltaics projects ?

The regulations for photovoltaic projects are defined in a specific section of the Environmental Code. This is section 30 in the nomenclature of Article R. 122-2. 

This section was modified by Decree No. 2022-970 of July 1, 2022, and simplifies the criteria defining the obligation to perform an environmental impact assessment for a project. The objective is clear: to exclude projects on already built-up surfaces (roofs, parking lots) in order to focus the assessment effort on ground-mounted power plants.

It should also be noted that this procedure is distinct from other requirements, such as the requirement to install solar carports on parking lots larger than 1,500 m² provided for by the APER law for example.

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Is my photovoltaïc project subject to an environmental impact assessment?

This depends on two criteria: the typology of the project (location) and its power (kilowatt-peak – kWp).

Case 1: Projects Exempt from Environmental Assessment

Your project is not concerned by an environmental assessment if it is:

  • A rooftop installation.
  • An installation on carports.
  • An installation on hangars/sheds.
  • An installation with a power output of less than 300 kWp.

Case 2: Projects Subject to a “Case-by-Case” Examination

Your project must apply for a “case-by-case examination” if:

  • It is not on a roof nor on a parking shade structure (generally ground-mounted plants and vertical panels).
  • It has a power output between 300 kWp and 1 MWp.

In this scenario, you must compile a specific dossier (Cerfa form n°14734). The environmental authority analyzes this document to decide if a full impact assessment is required.

Case 3: Projects Subject to Systematic Impact Assessment

Your project must mandatorily include a full impact assessment if:

  • It is not on a roof nor on a parking shade structure (generally ground-mounted plants and vertical panels).

It has a power output greater than or equal to 1 MWp.

Impact Assessment: The Case of ICPE Projects

In addition to power thresholds, you must verify if your project falls under the ICPE regime (Classified Installations for the Protection of the Environment). This is a regulatory framework for sites presenting risks or nuisances to the environment and the neighborhood.

A photovoltaic plant is generally not an ICPE, but it can become one if it includes battery storage systems with a capacity ≥ 100 MWh or a charging power > 600 kW. Furthermore, if you install your plant on a site already classified as an ICPE, your project will be considered a modification of that installation.

The consequence here is important: If your project (or its storage component) falls under the ICPE Authorization (A) regime, it will be systematically subject to an impact assessment, regardless of its power or typology.

Why Anticipate ICPE Criteria?

Knowing these criteria during the study phase of your project can help you saves both time and money. It also allows you to secure the project’s execution and obtain the necessary authorizations. Your 3 advantages?

  1. Anticipate costs and delays related to the environmental impact assessment.
  2. Secure your project and its building permits: Following the correct procedure prevents your application from being rejected due to procedural topics.
  3. Adapt the project design: If you know your 900 kWp ground-mounted project will be subject to “case-by-case” review, you might choose a site with lower environmental stakes (degraded land or industrial brownfields) to increase your chances of avoiding a full impact assessment.

By correctly qualifying your project and anticipating its constraints, you limit risks and maximize your chances of success.

Do you have projects that are subject to environmental impact assessment requirements, or would you like to learn more? Our experts are here to help you!

FDES & PEP: How can you promote the environmental performance of your products?

FDES & PEP: How can you promote the environmental performance of your products?

7 Jan 2026 | REGULATIONS

Environmental awareness is now shaping purchasing decisions, and the market increasingly demands tangible proof of environmental performance. In this context of growing transparency, manufacturers and industrial companies must be able to quantify and demonstrate the impacts of their products across their entire life cycle.
Knowing how to showcase this commitment is more than a marketing advantage is a powerful lever for competitiveness and a key to accessing many markets.
An increasing number of public and private tenders now include strict environmental criteria. FDES (Environmental and Health Product Declaration) and PEP (Environmental Product Profile) have therefore become essential tools to meet market expectations.
PINK Strategy offers a clear overview of these two “environmental passports.” You will discover what they are, why they have become indispensable, how to use them strategically, and the concrete benefits they can bring to your business.

What are FDES and PEP?

FDES and PEP are two official environmental transparency frameworks in France. These standardized and verified documents are based on Life Cycle Assessment (LCA) methodology and translate the full environmental and health impacts of a product from cradle to grave. To learn more, feel free to read our dedicated article on LCA.

What is the difference between FDES and PEP?

The difference lies in their scope of application:

  • FDES is specifically dedicated to construction and finishing products, such as concrete, insulation materials, windows and doors, or floor coverings.
  • PEP applies to electrical, electronic, and HVAC equipment, including photovoltaic modules, air-conditioning systems, and lighting products.

These documents are not simple technical datasheets. They transform complex environmental data into clear, comparable, reliable, and publicly available information. For architects, engineering consultancies, and procurement teams, they are essential tools for making informed decisions and designing more sustainable projects.

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How to obtain an FDES or a PEP ?

The process generally involves the following steps:

  1. Conduct a Life Cycle Assessment (LCA) of your product in accordance with applicable standards and the relevant Product Category Rules (PCR).
  2. Draft the declaration, following PCR requirements and the formats defined by verification programs (for example, the INIES association in France).
  3. Have the declaration verified by an independent, accredited third party to ensure objectivity and data reliability.
  4. Publish the FDES or PEP on a recognized database (the INIES database for FDES and the PEP Ecopassport® database for PEP), making it accessible to all professionals.

FDES and PEP are therefore much more than technical documents. They are true environmental passports. Based on the robust methodology of Life Cycle Assessment, they help ensure regulatory compliance, strengthen customer trust, and turn environmental commitments into a tangible competitive advantage.

In a forthcoming article, we will explain how EPDs fit into the international context and present the main organizations and verification programs structuring this global market.

Interested in assessing the environmental impact of your product? Contact our team of recognized experts in environmental certification for tailored support aligned with your strategic objectives.

How can FDES and PEP be used as strategic assets?

These declarations should be seen as powerful differentiation tools that allow you to:

  • Anticipate market demand: act before your clients request them and proactively engage in the process to be ready when environmental requirements become mandatory.
  • Communicate on your environmental performance: once your FDES or PEP is published, it can be promoted through your website, marketing materials, and sales teams, reinforcing your credibility.

Support eco-design strategies: the LCA conducted as part of the certification process is a valuable source of insights. It helps identify environmental hotspots in your product and improve them, reducing both environmental impacts and production costs.

How can FDES and PEP be used as strategic assets?

These declarations should be seen as powerful differentiation tools that allow you to:

  • Anticipate market demand: act before your clients request them and proactively engage in the process to be ready when environmental requirements become mandatory.
  • Communicate on your environmental performance: once your FDES or PEP is published, it can be promoted through your website, marketing materials, and sales teams, reinforcing your credibility.

Support eco-design strategies: the LCA conducted as part of the certification process is a valuable source of insights. It helps identify environmental hotspots in your product and improve them, reducing both environmental impacts and production costs.

ADEME 2022 methodological guide on the carbon footprint of projects: what you need to know !

ADEME 2022 methodological guide on the carbon footprint of projects: what you need to know !

9 Dec 2025 | IMPACT STUDY

The ADEME Methodological Guide emphasises that environmental authorities consider greenhouse gas (GHG) emissions to be insufficiently taken into account in environmental assessments. With increasing climate transparency requirements and carbon neutrality targets, renewable energy and recovery project developers are required to integrate carbon impact from the design phase onwards.
Published in 2022 but still relevant today, the ADEME methodological guide proposes a clear method that is increasingly required by the French Regional Environmental Authority Missions (MRAe).
In this article, discover what this guide covers, the key points to remember and concrete strategies for use in your project.

What are the advantages of the ADEME Guide ?

The ADEME guide « Taking greenhouse gas emissions into account in impact assessments » defines a method for integrating the assessment of GHG emissions and removals into the impact assessment phase of a project.

What does this guide offer you ? It provides a national methodological framework, aligned with the French National Low-Carbon Strategy (SNBC), for analysing the carbon impact of projects. It also complies with Article R122-5 of the French Environment Code, which requires an assessment of « the project’s impact on the climate ».

This guide is therefore a strategic tool for guiding technical choices, strengthening the credibility of the project file and facilitating acceptability.

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How to assess the carbon footprint of your project ?

Assessing a project carbon impact involves seven key steps:

  1. Clearly define the study area and scope: the project’s area of influence, its impact, the construction, operation and end-of-life phases

  2. Establish a description of the initial state of the environment, including existing GHG emissions in the area concerned (regional inventories, PCAET)

  3. Develop two comparative scenarios: ‘without the project’ and ‘with the project’, in order to measure the difference in emissions or reductions

  4. Identify significant emission sources (materials, transport, operation, etc.) and justify the exclusion of insignificant ones

  5. Quantify emissions for each scenario and estimate data uncertainties

  6. Calculate the differential impact of the project: difference between the scenario with and without the project

  7. Present the measures of the ‘Avoid-Reduce-Compensate’ sequence (ARC): avoid environmental damage, reduce damage that could not be avoided, and compensate for significant residual effects

For more details on these seven key steps, see our article on project carbon impact assessments.

And how does this translate into the field of renewable energy ? Our team reveals two concrete examples:

  • For a photovoltaic project, the study must quantify not only the emissions associated with the construction and installation of the panels, but also those avoided thanks to the production of renewable electricity

  • For a methanisation plant, the guide recommends assessing the emissions avoided in relation to organic waste management and the substitution of fossil fuels

What tools and resources are available for assessing the carbon footprint of renewable energy ?

What is the point of conducting an impact assessment ?

The short and medium term benefits are: 

  • Greater clarity regarding the project carbon impact
  • Anticipation of technical choices and reduction of risks related to GHG emissions
  • Improved social acceptability and the possibility of promoting the low-carbon aspect

The long term benefits are:

  • The possibility of quantifying the reduction in tCO2e over the project’s lifetime
  • The integration of results into eco-design, sustainable financing or certification initiatives
  • Contribution to carbon neutrality objectives and the region’s low-carbon strategy
  • Strengthening the project’s resilience in an evolving regulatory environment
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How can carbon obligations be turned into a strategic asset ?

The ADEME 2022 methodological guide is an essential tool for structuring the assessment of greenhouse gas emissions in project impact studies. Beyond regulatory compliance, it is a strategic lever for designing projects in line with climate objectives and meeting stakeholder expectations. By adopting this methodology, the obligation to analyse a project’s carbon footprint becomes an opportunity to stand out from the crowd.

Would you like to assess the carbon footprint of your project ?

Our PINK Strategy experts are here to guide you step by step through the process !

Eco-modulation of photovoltaic panels : Soren’s criteria

Eco-modulation of photovoltaic panels : Soren’s criteria

12 Nov 2025 | SOREN'S CRITERIA

A photovoltaic panel is not just a generator of green electricity: it is also a product with a full life cycle, environmental impacts, and an end-of-life phase that must be anticipated. This is the purpose of eco-modulation, introduced by the French government and implemented by Soren, the approved eco-organization for the collection and recycling of solar panels in France.

What is eco-modulation in the photovoltaics industry?

Eco-modulation is a mechanism introduced by the Anti-Waste for a Circular Economy Act (AGEC), to encourage the eco-design of products throughout their life cycle.

It consists of adjusting the amount of the eco-contribution (the fee paid to finance the collection and treatment of panels at end of life) based on the environmental characteristics of the products.
In short, modules that are easier to recycle or made with more sustainable materials benefit from a reduced eco-contribution. 

This sends a strong message to manufacturers and distributors: the more environmentally responsible your products are, the lower your contribution will be.

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Which eco-modulation criteria has Soren defined ?

Since January 1, 2025, Soren has applied four technical and environmental criteria to determine whether a photovoltaic module is eligible for eco-modulation :

  • Carbon footprint

  • Quantity of silver used in the module

  • Share of recycled content

  • Lead content

A module meeting these criteria is one that both anticipates its end of life and minimizes its environmental footprint.

Who is concerned and why does it matter ?

For manufacturers and distributors, complying with eco-modulation criteria means:

  • Reducing your eco-participation costs

  • Highlighting products that respond to growing sustainability expectations

  • Actively contributing to a circular economy in the solar industry

For installers and integrators, it is a powerful selling point: offering Soren-recognized modules guarantees customers a more sustainable and responsible solution.

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Take the first step towards eco-modulation!

Certisolis is Soren’s official partner for obtaining eco-modulation criteria validation certificates.

Our teams will assist you in reviewing your application to certify your photovoltaic modules with Certisolis by analyzing your panels and your supply chain to verify their compliance with Soren criteria.
From preparing the technical file to official validation, we are the ideal partner to ensure that your products benefit from the most favorable eco-participation possible. 

Contact us right away to check whether your photovoltaic panels meet the eco-modulation criteria and to take the necessary steps. Together, let’s make solar energy an exemplary driver of the circular economy.

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Transition Plan: Turning challenges into Opportunities for Your Business

Transition Plan: Turning challenges into Opportunities for Your Business

16 Oct 2025 | TRANSITION PLAN

Each year, European Union industry is responsible for approximately 20% of greenhouse gas emissions. Faced with this reality, rethinking our models is no longer an option. Between climate change, resource scarcity, and growing regulatory pressure, companies must commit to a transformation process.
The challenges, the inventory, the concrete strategies and the expected benefits: discover how a transition plan can significantly reduce the environmental and energy footprint of organizations.

What is a transition plan?

A transition plan is a strategic roadmap aimed at adapting a business to reduce its environmental impacts and optimize its energy efficiency. It sets clear objectives, describes measurable actions, and includes a monitoring schedule. Beyond regulatory compliance, it is about preparing for the future by strengthening competitiveness, reducing costs and risks, and meeting the expectations of customers, investors, and partners.

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A transition plan: an essential action for the long-term viability of your activities

In a context of tightening regulations, the energy transition is no longer just a matter of corporate responsibility : it has become a vital lever to ensure the resilience and long-term performance of your business.

  • European Union industry accounts for about 24.6% of final energy consumption
  • The surge in gas and electricity prices since 2021—amplified by the war in Ukraine—has increased the energy bill for the French manufacturing industry from €15 billion in 2021 to €45 billion in 2023. 
  • Infrastructures (transport, water, energy) are responsible for a significant share of CO₂e emissions and are already suffering the impact of climate change
  • Regulations (like the European CSRD directive) impose increasingly precise environmental reporting obligations that ripple down the value chain to subcontractors and suppliers

The maturity of European companies depends as much on the sector (energy intensity, regulatory pressure, available innovation) as on their size (investment capacity, internal structure). The leaders are often the major players in energy-intensive or strategic sectors, while smaller structures advance mainly when driven by major clients or demanding markets. 

For example, SNCF Réseau reduced its electricity consumption for lighting by 60% by renovating the lighting in 1,300 km of tunnels, switching from sodium/fluorescent lamps to smart LEDs with presence detection.

What are the prerequisites for launching a transition plan?

  1. Provide meaning and set a clear direction:
      • Identify your challenges (emissions reduction, energy sobriety, competitiveness, regulatory compliance, etc.) within the framework of the company’s overall strategy.
      • Align with the company’s strategy to account for the evolution of the business and its context over the duration of the transition plan
      • Provide a clear vision to all stakeholders and facilitate buy-in
  1. Define the scope of action:
      • Map the risks and opportunities related to your challenges (technical, financial, operational, regulatory) over the lifecycle of your current and future assets
      • Assess the resources needed to carry out the actions
      • Prioritize actions based on their feasibility and return on investment
  1. Track progress:
      • Define objectives and stakes allow you to choose the right indicators and evaluate the real effectiveness of the plan
      • The organization gains productivity by being aligned on decision-making criteria
      • You gain efficiency and transparency with your teams, investors, customers, and authorities

7 steps to make your transition plan a success:

  1. Frame the stakes and scope
  2. Assess and map the risks and opportunities over the duration of your transition plan
  3. Identify potential actions and their contributions
  4. Set SMART goals (Specific, Measurable, Achievable, Relevant, Time-bound)
  5. Plan investments and actions
  6. Track progress
  7. Adjust measures if necessary

Beware of seemingly good ideas: switching from a gas boiler to a heat pump can be beneficial, but it is necessary to verify its relevance in terms of lifecycle and context. Connecting to a nearby district heating network may generate a better return on investment and minimize your environmental impact.

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An early action gives better outcomes : anticipation is the key

Being a leader in a transition process means not only getting ahead of regulations and shaping your market but also locking in sustainable economic advantages. By investing early, as the pioneers of intermittent energies (solar, wind) did, a company benefits from an accelerated learning curve, better access to green financing, and more competitive purchasing or production conditions in the long term.

This head start allows you to:

  • Amortize investments sooner, while followers will have to incur high expenses in a more mature and competitive market
  • Capture the best market shares before saturation, by imposing your standards and innovations.
  • Gain priority access to public incentives (subsidies, preferential tariffs, long-term contracts), which are often limited in time

In the long term, this pioneering position helps optimize operational costs, secure stable revenues through early-signed contracts, and build a leadership image that is difficult for latecomers to catch up to.

Act now to turn your environmental challenges into performance drivers.

A transition plan is a strategic lever that allows you to combine economic performance, regulatory compliance, and environmental responsibility. 

Lead the change, don’t let the change lead you ! Initiate a diagnostic today to start your roadmap. We support our clients in building and succeeding with their transition plan.

Ready to take action? Let’s discuss transition solutions adapted to your business.

Integrate your transition into your business plan

A well-designed transition plan is not limited to reducing the environmental footprint: it becomes a real engine for value creation. Integrating the transition at the core of the business plan means turning environmental challenges into opportunities for sustainable growth.

Resilience and Autonomy

  • Reduction of dependence on resources (water, materials, etc.)
  • Increased capacity to cope with economic fluctuations
  • Sustainable reduction of energy costs and better resilience to energy price volatility
  • Reduction of risks related to climate hazards
  • Sustainable value creation by considering the lifecycle of investments
  • Planning and visibility on the business model

Innovation and Attractiveness

  • Improved image among talents, and creation or maintenance of skilled jobs
  • Increased ability to meet customer expectations
  • Improved reliability and predictability of the business model and increased investor confidence

Act now to turn your environmental challenges into performance drivers

A transition plan is a strategic lever that allows you to combine economic performance, regulatory compliance, and environmental responsibility. 

Lead the change, don’t let the change lead you ! Initiate a diagnostic today to start your roadmap. We support our clients in building and succeeding with their transition plan.

Ready to take action? Let’s discuss transition solutions adapted to your business.

Contact us