France - New employer obligations in extreme heat waves - Effective 1 July 2025

Regulatory context

The Labour Code does not define minimum or maximum temperature thresholds that would prevent employees from working, but employers are required to maintain a suitable temperature in work premises used for work (R4223-13 of the Labour Code).

From 1 July 2025 (Decree No. 2025-482 of 27 May 2025), new obligations will be imposed on employers to protect the health and safety of employees exposed to heat during ‘periods of intense heat’.

Intense heat waves are determined in relation to the yellow, orange and red alert thresholds defined by Météo-France.

Employers are required to implement four measures.

• 1^st measure: Consider risks for employees exposed to intense heat waves as part occupational risk assessments (DUERP).
• 2^nd measure: Define and implement effective preventative measures for intense heat waves.

The Labour Code now provides a non-exhaustive list of measures to reduce risks, including:

- Implementing workflows that avoid or limit heat exposure;
- Modifying the design and layout of workplaces and workstations;
- Adapting working arrangements, in particular working hours, to limit the duration and intensity of exposure and to provide rest periods;
- Technical measures to reduce solar radiation on exposed surfaces, for example through shading or insulation, and to prevent heat build-up in buildings or at workstations; 
- Providing additional supplies of fresh drinking water for employees as necessary; 
- Choosing appropriate work equipment that allows workers to maintain a stable body temperature, taking into account the work carried out; 
- Providing personal protective equipment to limit or compensate for the effects of high temperatures or to protect against the effects of direct or diffuse solar radiation; 
- Informing and training workers on the appropriate behaviour and use of work equipment and personal protective equipment during heat waves to reduce their exposure to heat to the extent possible.

Implementation depending on company size: Companies with fewer than 50 employees must include these measures in the risk assessment ((DUERP). In larger companies they need to be provided for in the annual programme for the prevention of occupational risks and the improvement of working conditions (PAPRIPACT).

For the first two measures, employers with a works council (CSE) must ensure that it is involved in the process.

• 3^rd measure: Sufficient quantities of fresh drinking water must be provided, kept cool and accessible throughout the working day, in particular for outdoor workstations. Where it is not possible to provide running water, at least 3 litres of drinking water must be provided per employee per day.
• 4^th measure: Emergency procedures must be established, particularly for employees who are isolated or far from the workplace. The employer must establish clear procedures for reporting heat-related illness and for caring for victims of heat, particularly for isolated employees. These procedures must be communicated to employees and to the occupational health service.

Implementation and adaptation

During periods of intense heat, employers must not only apply these measures, but also adapt them as weather conditions intensify.

Penalties 

Non-compliance with these obligations may lead to a formal notice from the Labour Inspector, followed by penalties if employers continue to fail to comply.

Our teams are of course available to assist you with these issues and ensure your company's compliance.