What is the PEMD diagnostic?

1. Construction waste: a topical subject and issue

Construction is one of the sectors with the greatest impact on the environment, notably through the extraction of raw materials and the production of waste:

Worldwide, 40% of resources are used in the construction sector. This represents 40 billion tonnes of materials extracted every year. As well as depleting resources, this extraction has other consequences: loss of biodiversity, land erosion and degradation of water supplies, for example. The process of transforming raw materials into building products consumes water and emits greenhouse gases. For example, cement manufacturing is responsible for 8% of global CO2 emissions (1 tonne of cement is equivalent to 0.9 tonnes of CO2, and 1 tonne of steel to 1.83 tonnes of CO2).

According to the French Ministry of Energy Transition, the building sector in France represents around 42 million tonnes of waste per year. The tonnages collected come from demolition (49%), rehabilitation (38%) and new construction (13%). They are made up of 75% inert waste, 23% non-hazardous non-inert waste and 2% hazardous waste (notably asbestos). Although the overall material recovery rate for construction waste has been estimated at 67%, this does not reflect the disparities between the different flows. Inert waste, via recycling and quarry backfilling, represents a recovery rate of 76%, while other non-hazardous, non-inert waste remains very little recovered (25% overall), with the exception of wood (77%) and metal (90%). As far as hazardous waste is concerned, it is not uncommon to find asbestos-contaminated waste in illegal dumps.

One of the levers for reducing the sector's impact on the environment is therefore to reduce the extraction of raw materials and cut the quantity of waste. One way of achieving this is by developing the circular economy in the construction sector. As described in the following section, recent regulatory developments are encouraging this trend.

Figure 1: Difference between linear and circular pipes - from Repar2 ©Bellastock

2. Waste and the circular economy: what are the latest regulatory requirements?

On January 30, 2020, the law on the fight against waste and the circular economy was passed. The law aims to transform our linear economy, produce consume, throw away, into a circular economy. For the building sector, its main objectives are to reduce uncontrolled dumping, facilitate reuse and recycling, and achieve EPR. This is reflected in the following measures:  

An eco-contribution, paid by manufacturers of building materials and products, is used to finance the establishment of a network of free collection points for construction waste, provided that it has been collected separately. It also finances the collection and clean-up of illegal construction waste dumps. Through this eco-tax, manufacturers of construction products and materials ensure the end-of-life of these materials, and the "polluter pays" principle is applied.

The AGEC law reforms the waste diagnosis system, which becomes the PEMD (Produit Équipement Matériaux Déchet) diagnosis system. More ambitious than its predecessor, it aims to facilitate the re-use of construction materials and promote waste reduction through the following management approach:

Figure 2: Waste recycling priorities

3. PEMD diagnosis (Product, Equipment, Material, Waste)


The PEMD diagnosis is the result of successive changes to the waste diagnosis (mandatory since 2012). In 2020, as part of the AGEC law, the latter was strengthened and evolved into a Product Materiaux Déchet (PMD) diagnosis, broadening its scope to include products and materials.
On June 25, 2021, with the publication of the implementing decrees for the PEMD diagnosis, the PMD diagnosis was replaced by the PEMD diagnosis, which includes equipment.
It was only recently, on March 26, 2023, and after several successive delays, that the PEMD diagnostic system was fully published, with the publication of a decree clarifying certain definitions. It will finally come into force on July 1, 2023.


The aim of the PEMD diagnostic is to inventory and locate all waste present on site prior to demolition. A distinction must be made between waste, equipment, products and materials, and reusable elements must be identified. For the various elements, the treatment channels must be identified, and in the case of reusable elements, instructions on how to dispose of and store them must be formulated.

Operations concerned

According to the decree of March 26, 2023 on PEMD diagnostics, this concerns demolition and major renovation projects. It covers the following operations:

  • Operations with a total floor area exceeding 1000m².
  • Operations involving at least one building that has hosted an agricultural, industrial or commercial activity and has been the site of the use, storage, manufacture or distribution of one or more substances classified as hazardous.

With regard to demolitions, this concerns operations involving the demolition of at least half the floor area of buildings.

Renovation operations are considered as if they destroy or replace at least two of the finishing elements mentioned below:

  • More than half of the cumulative surface area of the boards does not determine the strength or rigidity of the structure
  • More than half the cumulative surface area of external partitions does not determine the strength or rigidity of the structure
  • More than half of the exterior frames
  • More than half the total surface area of interior partitions
  • More than half of plumbing and sanitary installations
  • More than half of all electrical installations
  • More than half of all heating systems
When to carry out the diagnostic?

Before submitting a request for planning permission or, if the work concerns an establishment open to the public, before submitting a request for permission to work to the mayor of the municipality where the work is to be carried out, and before accepting quotations or awarding contracts for the work, the project owner must have the PEMD diagnosis carried out.

Diagnostic procedure

The PEMD diagnosis is carried out in several stages:

  1. Documentary analysis : the aim is to obtain as much information as possible on the building and the cleaning operation in question, so as to optimize on-site work. It is based on other regulatory diagnostics (asbestos, etc.), the building's DOE and any other document describing the building.
  2. The visit : in addition to estimating the quantities and distribution of materials, the visit allows us to detail the technical characteristics of each material and identify any constraints linked to the removal of materials.
  3. Diagnostic report : it includes the following items:
    • Detailed, quantified and localized inventory of all materials and equipment
    • Description of EMPs identified as potentially reusable
    • A focus on recovery and reuse
    • Recommendations for reuse (selective removal and storage conditions)

This report serves as the basis for completing the recolement form (CERFA n°16287*01), which must be sent to the CSTB before estimates are accepted or work contracts awarded.

The following figures show extracts from the inventory tables.

Thanks to its experience in construction and its expertise in civil engineering, Intégrale Ingénierie can help you carry out your PEMD diagnosis.


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