Warehouses excluded from 15 CEE tertiary sheets

What the draft order provides

On 5 October 2026 the French ministry responsible for energy opened a public consultation on a draft ministerial order that amends 15 standardised operation sheets. These sheets belong to the energy savings certificates (CEE) scheme. The consultation is open until 27 October 2026. Our guide to energy savings certificates explains how the scheme works as a whole.

A standardised operation sheet is the regulatory text that sets, for a type of works, the sector concerned, the technical requirements and the flat-rate volume of CEE issued. Draft order NOR ECOR2624789A adds the same sentence to the scope of each of the 15 sheets: « Les entrepôts logistiques, les réserves, les entrepôts (frigorifiques ou non) et les locaux de stockage sont exclus. » In other words, logistics warehouses, stockrooms, warehouses (refrigerated or not) and storage premises are excluded. The same statement appears in the sworn statement (Part A) of each sheet.

The text amends the order of 22 December 2014 defining standardised operations. The sheets annexed to the draft replace those bearing the same references in Annex 3 of that order. The draft also amends the order of 28 September 2021 on inspections.

Which sheets are affected?

The 15 sheets cover most heating, ventilation and control works in existing tertiary buildings. The table lists their titles and the commitment deadline written into the draft.

According to the consultation page, the date of 31 December 2028 is new for nine sheets. Until now, these nine sheets had no repeal date. The dates for BAT-TH-109, BAT-TH-162, BAT-TH-163 and BAT-TH-164 appear in the draft without being presented as additions.

Why the ministry is excluding warehouses

The consultation page gives two reasons. The first is technical: the flat-rate amounts in these sheets were not sized for storage premises. They are therefore unsuited to them.

The second reason concerns practice. The CEE volume of these sheets depends on heated floor area. According to the ministry, this dependence has recently led to misuse of certain sheets, reported by several stakeholders.

A warehouse has a large floor area with heating needs unrelated to those of an office or a healthcare facility. A flat rate calculated per square metre mechanically produces a volume of certificates far removed from the actual savings.

The Government is not closing the door. It says it is open to revising some of these sheets for warehouse heating technologies. It invites the sector and the scheme's stakeholders to submit proposals.

On-site inspections change too

Article 2 of the draft amends Annex III of the order of 28 September 2021, which sets the frameworks for on-site inspections. Three parts of this framework are supplemented: Part AK, Part BC for BAT-TH-162 and Part BD for BAT-TH-163 and BAT-TH-164.

Under these frameworks, an operation that concerns a logistics warehouse, a stockroom, a warehouse or a storage premises « au moins en partie » (at least in part) becomes a ground for non-compliance. The inspection body will also have to check that these premises are excluded.

This wording is the most far-reaching point of the text. Take a collective heat pump serving both offices and a storage area on the same network. After entry into force, it could no longer be claimed under BAT-TH-163 or BAT-TH-164. It would not matter that storage accounts for only a fraction of the building.

Entry into force and operations already committed

Under Article 3 of the draft, the order comes into force on the day after its publication in the Journal officiel. It applies to operations committed from that date. The publication date is not known: the consultation closes on 27 October 2026 and the opinion of the Conseil supérieur de l'énergie is still to be obtained.

Operations committed before that date keep the previous versions of the sheets on one condition. They must appear on a list that the certificate applicant sends to the minister responsible for energy within ten calendar days of publication. This list follows the templates entitled « Tableau de recensement des engagements » (commitments inventory table). These templates are drawn up by the Directorate-General for Energy and Climate (DGEC) and published on the ministry's website.

Ten calendar days is a short window. The draft order withdrawing 27 sheets, put out to consultation in September 2026, allowed twenty days for the same exercise. We covered it in our article on the withdrawal of CEE sheets.

What the text does not yet settle

The draft defines neither storage premises nor stockrooms. Both terms appear only in the exclusion sentence and in the non-compliance grounds. Yet a shop, a healthcare facility or a school often includes stockrooms. The exact reach of the exclusion will therefore depend on the final wording and on how inspection bodies read it.

Nor does the draft provide a rule for splitting floor areas in mixed-use buildings. For the heat pump and geothermal sheets, the criterion used by the inspection frameworks concerns the operation as a whole. The consultation is the right moment to ask for clarification on these two points.

Finally, the announced revision of the sheets applicable to warehouse heating has no timetable. Promoters of logistics projects must therefore plan, at this stage, without a standardised replacement.

What it means for you

For an owner or operator of a logistics platform

If the text is adopted as drafted, a heat pump, geothermal, BMS or ventilation project in a warehouse will no longer be able to rely on these 15 sheets. A project already committed should be reported now to the certificate applicant, so that it appears in the ten-day inventory.

For a landlord or tertiary project owner

Mixed-use buildings are the most exposed. Examples include an office building with stockrooms, a shop with storage space, or a business site whose heating network also serves a warehousing area. The way floor areas and networks are divided becomes an eligibility factor in its own right.

For an installer

Tertiary heating projects currently being priced must take into account the exact nature of each space served. An operation committed after publication on a building that includes storage risks an unsatisfactory rating at the on-site inspection.

For an obligated party or a delegated party

The inventory to be sent within ten days requires knowing, before publication, which operations are under way on affected premises. The new non-compliance ground added to the frameworks for BAT-TH-162, BAT-TH-163 and BAT-TH-164 makes this sorting necessary from the commitment stage.

Our recommendations

The text is still a draft and may change after the consultation. Stakeholders can submit their comments until 27 October 2026 on the public consultation website.

In the meantime, three matters deserve immediate attention. The first is an inventory of operations committed, or about to be, in buildings that include storage. The second is preparing the inventory with the certificate applicant. The third is qualifying future projects on mixed-use buildings.

IHD, an independent engineering consultancy, supports project owners, installers and delegated parties in qualifying operations. We also work on sizing collective heat pumps and on securing files all the way to their valuation. To review a tertiary project affected by the draft, see our energy audit offer or contact us.