What the draft order provides
On 16 September 2026, the French ministry responsible for energy opened a public consultation on a draft ministerial order that removes 27 standardised operation sheets from the energy savings certificates (CEE) scheme. The consultation runs until 7 October 2026.
A standardised operation sheet is a fixed allowance published by ministerial order: for a typical operation, it sets the eligibility conditions and the volume of certificates issued, expressed in kWh cumac. The sheets are gathered in the annex to the order of 22 December 2014, which the draft amends. According to the DGEC page on standardised operations, the catalogue currently contains 221 sheets.
The text has three articles:
- Article 1 removes the 27 sheets.
- Article 2 organises the exit: the provisions of the withdrawn sheets continue to apply to the operations entered in a list that the certificate applicant submits to the minister within twenty calendar days of publication.
- Article 3 entrusts implementation to the Directorate for Climate, Energy Efficiency and Air.
The order will enter into force on the day after its publication in the Journal officiel. Its date is not known: the draft leaves blank the consultation dates and the opinion of the Higher Energy Council (Conseil supérieur de l'énergie), which are still to come.
Two families of sheets, and seven sheets outside the tables
The consultation page sorts the targeted sheets into two batches, detailed in an annex published as a PDF.
Batch 1 groups the ‘fossil-fuel’ sheets: those that still support energy savings on equipment running on fossil fuels. For each one, the annex gives the volume committed in 2025, in TWh cumac.
| Reference | Title | Volume committed in 2025 |
|---|---|---|
| AGRI-EQ-105 | Stop & Start for motorised agricultural vehicles | 0 TWhc |
| IND-BA-117 | High-performance decentralised heating | 0.14 TWhc |
| IND-UT-104 | Economiser on the flue gases of a steam boiler | 0.37 TWhc |
| IND-UT-105 | Micro-modulating burner on an industrial boiler | 1.3 TWhc |
| IND-UT-118 | Burner with heat recovery device on an industrial furnace | 0.24 TWhc |
| IND-UT-130 | Condenser on the flue gases of a steam boiler | 0.12 TWhc |
| TRA-EQ-104 | Energy-saving lubricant for light vehicles | 2 TWhc |
| TRA-EQ-111 | Vehicles fitted with high energy efficiency autonomous refrigeration units | 0.04 TWhc |
| TRA-EQ-113 | Energy-saving lubricant for passenger or goods transport vehicles | 0.11 TWhc |
| TRA-EQ-115 | Optimised goods transport vehicles | 1 TWhc |
| TRA-EQ-122 | ‘Stop & Start’ for new self-propelled non-road machinery | 0.01 TWhc |
The annex totals 5.3 TWhc for this batch; the consultation page rounds this to 5 TWhc committed in 2025.
Batch 2 groups the inactive sheets, defined in the annex as sheets created several years ago, with no issuance and no commitment in 2024 and 2025. They include silo ventilation control (AGRI-EQ-106), windows with parietodynamic glazing in residential and tertiary buildings (BAR-EN-110 and BAT-EN-111), Services energy performance contracts (BAR-SE-105 and BAT-SE-104), natural light ducts (IND-BA-114), and three transport sheets: driving simulator (TRA-EQ-123), fairing of an inland waterway transport unit (TRA-SE-107) and optimised tyre management (TRA-SE-111). Sheet AGRI-EQ-105 appears in both batches.
Seven sheets in Article 1 appear in neither table. The two batches cover 20 distinct sheets, whereas the draft order removes 27. The sheets missing from the annex are BAR-TH-122 (condensing heat recovery unit), TRA-EQ-119 (optimisation of combustion and cleanliness of Diesel engines), TRA-EQ-125 (‘Stop & Start’ for railway vehicles), TRA-SE-101 and TRA-SE-102 (eco-driving training), TRA-SE-112 (round-trip car-sharing service) and TRA-SE-113 (monitoring of fuel consumption through private fuel cards). They are indeed removed by the draft; only their classification has not been published. This is a point to watch in the final text.
Why the ministry is withdrawing these sheets
The consultation page gives three reasons. First, to streamline a catalogue that has become hard to read. Second, to stop encouraging the installation or retention of equipment running on fossil fuels: according to the ministry, these sheets extend the service life of such equipment and are relatively little used.
The third reason is European. According to the ministry, the energy savings linked to the batch 1 sheets can no longer be counted towards the obligations of Article 8 of the Energy Efficiency Directive. That article sets Member States a target for cumulative end-use energy savings. The consultation page puts it bluntly: the savings from the batch 1 sheets no longer count towards that target. For a scheme designed to meet it, a sheet that no longer contributes loses most of its purpose.
For the inactive sheets, the reasoning is different. The ministry acknowledges that they may be neglected because the allowance is not attractive enough, but considers that the operations concerned do not fall within the public policies it supports as a priority. It therefore rules out a bonus for them and prefers to remove them to make the scheme easier to read.
What it changes for you
Manufacturers: steam boilers, burners, furnaces
This is the group most directly affected among an engineering consultancy's clients. Five industrial sheets in batch 1 disappear: economiser and condenser on a steam boiler (IND-UT-104 and IND-UT-130), micro-modulating burner (IND-UT-105), burner with heat recovery on a furnace (IND-UT-118) and high-performance decentralised heating (IND-BA-117). Sheet IND-UT-105 is the most used of the five, with 1.3 TWhc committed in 2025 according to the annex.
A project under study on one of these sheets needs to be dated precisely. If the operation is committed before the order is published, it can still be valued, provided it is entered in the inventory list. If it is not, the allowance disappears with the sheet.
Transport operators and fleet managers
Transport accounts for more than half of the withdrawn sheets. Sheet TRA-EQ-104 (energy-saving lubricant for light vehicles) is the most used in batch 1, with 2 TWhc committed in 2025, ahead of TRA-EQ-115 (optimised goods transport vehicles, 1 TWhc). Several service sheets also disappear, including eco-driving training.
Social landlords, property managers and tertiary project owners
The practical effect is limited for the batch 2 sheets: by definition, they gave rise to no issuance and no commitment in 2024 and 2025. The case of BAR-TH-122 (condensing heat recovery unit), however, deserves checking, since the annex says nothing about its use. A manager with a project on this sheet should make sure it is committed before publication.
Obligated parties and delegated parties
Article 2 rests on them. The certificate applicant has twenty calendar days after publication to submit to the minister the list of operations concerned, using the ‘Tableau de recensement des engagements’ (commitments inventory table) templates drawn up by the DGEC. Twenty days is short when the documents are spread across several installers and beneficiaries: the list is prepared before publication, not after.
What we recommend
Take stock now. In each portfolio, identify the operations committed, or about to be committed, under the 27 sheets, with their commitment date and the document that proves it. This is the raw material for the inventory list.
Decide on projects that straddle publication. For an industrial operation under study on a batch 1 sheet, there are two routes: commit it before publication and enter it in the list, or reconsider it without this allowance. The decision depends on the works schedule, not only on the value of the certificates.
Respond to the consultation if you are affected. A manufacturer or an obligated party that relies on one of these sheets can submit its observations until 7 October 2026. The observations made during the consultation are referred to in the final order.
Read the final text line by line. A draft put out to consultation can change: list of sheets, inventory deadline, table template. We will update this article when the order is published in the Journal officiel.
Our engineering consultancy assesses the eligibility of each operation against the version of the sheet in force on its commitment date: that is what determines the allowance. See our approach to CEE files, the six markets we analyse or write to us to examine a specific operation.
