Hospital BEGES: a practical guide for your healthcare establishment

The healthcare sector accounts for 49 MtCO₂e per year in France, or 8% of national emissions according to The Shift Project. That is more than French aviation, less than the automotive sector. But here is what surprises every establishment director reading the assessment: a hospital's leading emission category is not building heating. It is not even anaesthetic gases. It is medicines. Followed by medical devices. Energy comes third.

This emissions hierarchy has a simple but radical consequence: a hospital BEGES is not a technical exercise in recording bills. It is an assessment of procurement transformation. And since July 2022, it has been a comprehensive legal obligation. Article L229-25 of the Environmental Code requires healthcare establishments to measure and publish all their scopes, including scope 3, which accounts for 84% of emissions. For ten years, hospitals measured the 16% that were easy to see. Now they must look at the 84% they could not see.

1The healthcare sector's carbon footprint

The Shift Project's figures and the sector's structure

The Shift Project has mapped the French healthcare sector's footprint in detail. The 49 MtCO₂e break down as follows: medicines and pharmaceutical products account for 28% of the total, or 13.7 MtCO₂e. Medical devices (equipment, consumables, implants) account for 21%, or 10.3 MtCO₂e. Energy for buildings and installations, heating, hot water and electricity, accounts for 16%. Travel (establishment vehicles, business travel, commuting) accounts for 11%. Finally, 24% comes from other sources: food, external services, waste and non-medical equipment. What stands out is the scale of procurement scope 3. If you measure only hospital energy and vehicles, you leave out 72% of emissions.

Why medicines weigh more than energy: chemical manufacture at the core

This is the counter-intuitive finding that puts directors on the spot. A hospital consumes megawatts of electricity, heats thousands of square metres 24 hours out of 24, and sterilises continuously. Energy is visible. But a kilogram of active pharmaceutical molecule requires chemical synthesis, often in multiple stages, in a highly selective production unit. Manufacturing one gram of a molecule can require raw materials for a hundred grams. Add the energy-intensive processes: reactors kept at controlled temperatures, distillation and chromatographic separation. Then transport from the synthesis site, often in Asia or Eastern Europe, to the French distribution centre. Finally, packaging: boxes, thermoformed blister packs and secondary packaging each have their own carbon footprint. In March 2025, ADEME updated its pharmaceutical emission factors using the FIGARO MRIO model. The pharmaceutical factor fell by about 60%, from 500 to around 200 kgCO2e/k€ excl. VAT, but this figure reflects a simplification: reality varies enormously by molecule type. A generic injectable medicine does not have the same footprint as a biologically complex anticancer medicine.

2The regulatory framework

The obligation since 2013, scope 3 since 2022, and critical changes

Article L229-25 of the Environmental Code: since 2013, public establishments with more than 250 staff must produce and publish their greenhouse gas emissions inventory every three years, and private companies with more than 500 employees every four years. For healthcare establishments, this means university hospitals, general hospitals, private clinics with more than 500 employees and large nursing homes. The first BEGES in the 2013 wave covered only scopes 1 and 2: the boiler plant, electricity and vehicle fleet, nothing else. A hospital's scopes 1 and 2 represent 16% of its inventory. The remaining 84% (scope 3) were not mandatory.

The July 2022 decree changed the situation. Scope 3 is now included in the mandatory boundaries for public establishments, but not for private clinics that do not publish a sustainability report. In practice, this means healthcare establishments must measure purchases (medicines, medical devices, services, food), travel associated with their activities (staff commuting, patient and visitor travel) and waste. This extension of the boundaries has no deadline. If your BEGES was carried out before July 2022 and you omitted scope 3, it was not non-compliant at that date, but it is now for the next cycle (yours expires in 2025 or 2026 depending on your cycle 2 date). The fine for non-publication is theoretically €50,000 for a first offence, €100,000 for a repeat offence. That is more serious than the old €10,000 figures still circulating. But the fine is only the surface.

The real issues: access to grants and public procurement criteria

The real sanction lies elsewhere. Since June 2024, access to State grants for decarbonisation projects has been conditional on publishing the BEGES. If you seek funding for solar panels or a heat pump, you need a carbon assessment for the site. Regional health agencies, which finance transition projects in healthcare establishments, now request a scope 3 BEGES as an attachment. And from August 2026, the Climate and Resilience Act requires mandatory environmental criteria in public procurement. An establishment buying medicines, diagnostic equipment or services must justify its choices at least through inventory data. Without scope 3, you will not even know which suppliers to change.

The CSRD (Corporate Sustainability Reporting Directive), which will apply from the 2027 financial year, adds another layer for large hospital groups (more than 1,000 employees and more than €450 million in turnover after Omnibus). But even for smaller hospitals, these large groups' pharmaceutical and medical suppliers will receive requests for carbon data. The BEGES is no longer a compliance exercise left in a cupboard: it is the foundation of supply chain transformation.

3A hospital's emissions profiles

Scope 1 + 2: 16%, what is visible within the walls

Scope 1 groups everything the establishment produces directly. The boiler plant: natural gas, the most common fuel, heating oil in old buildings, heat pumps at modernised sites. Specialised medical gases: nitrous oxide (N₂O) in dentistry and recovery rooms, halogenated anaesthetic gases in operating theatres; desflurane has a global warming potential 2,540 times that of CO₂ over 100 years. Replacing desflurane with sevoflurane (GWP 97) cuts emissions from the anaesthesia category by 90%. This is a reduction opportunity that almost no hospital mentions in its initial assessment, so invisible were anaesthetic gas emissions. The internal fleet: ambulances, intra-establishment shuttles, logistics and emergencies. And fugitive emissions: refrigerants from air conditioning (HFCs, HCFCs), nitrogen compounds from fertilisers if the establishment has farmland.

Scope 2: purchased electricity and steam. In France, electricity has a low carbon intensity thanks to the nuclear fleet, with a factor of 50 to 80 gCO₂e/kWh depending on the year and supply source. Compare this with Germany (500+ gCO₂e/kWh) or Poland (700+ gCO₂e/kWh): a French university hospital has no economic or climate interest in seeking green electricity elsewhere. Yet consumption remains high. An operating theatre unit with a recovery room, heavy imaging and enclosed air conditioning running 24 hours out of 24 can consume 500 to 1,000 MWh/year for this area alone. Scopes 1 and 2 together? 16% of the hospital's total footprint. This is the legacy of older BEGES inventories. It matters, but this is not where tonnes are saved.

Scope 3: 84%, the real map of purchases and travel

Purchases dominate. Medicines come first, with 29% to 40% of the total footprint depending on the establishment. Here, measurement is by expenditure, not mass. An average university hospital spends €30 to €50 million per year on pharmacy purchases: antibiotics, anticancer medicines, anticoagulants, painkillers, the full portfolio. The second layer, medical devices, accounts for 15% to 25% of the footprint. The Shift Project quantified it at 10.3 MtCO₂e: syringes, cannulas, intervention kits, scanners, monitoring equipment and ventilators. Then services: laundry, which sterilises, cleaning, with strict medical-sector protocols, maintenance, the equipment's after-sales service, and catering for patients and healthcare staff. Then travel: a mobility survey captures staff commuting, mainly by car, because rural and suburban hospitals do not always have public transport. Patient and visitor travel to the establishment. Finally, waste: incinerated infectious healthcare waste, ordinary waste and laboratory chemical waste.

The technical issue in scope 3 is emission factors. Purchases are measured by budget expenditure (euros excl. VAT), using spend-based emission factors (kgCO₂e / k€). ADEME maintains a table of sector factors for this purpose. Since March 2025, this table has been based on the FIGARO MRIO model, which breaks down by industrial class. For pharmaceuticals, the factor fell to around 200 kgCO2e/k€ excl. VAT (194 to 219 depending on the reference year for euros, compared with 500 previously). For medical devices, the database offers no dedicated factor: the closest sector's is used, around 220 to 270 kgCO2e/k€ (other manufactured products, electronic products). But this average hides variation. An examination glove has nothing in common with an MRI scanner. Real precision comes from a breakdown by supplier category, rather than an overall budget.

4The 5 steps to a successful hospital BEGES

1. Governance: appoint a lead and involve departments across the organisation

Hospital BEGES inventories almost always fail for the same reason: no leadership backing. The subject lands on the desk of a CSR intern or quality, safety and environment officer with no access to accounting data, no contacts in operational departments and no means to make things move. Our Celsius experience on the Institut Pasteur engagement demonstrates this: 70 contributors over three years. Chief executive, finance director, pharmacy, procurement, technical services, operating theatres, quality, waste management and human resources for mobility. This takes time but makes the assessment possible. The committee must meet monthly, at a minimum. There must be a single lead, a CDO or CSR manager with authority to arbitrate between data requests. And this lead must have access to the executive committee, or at least a sponsor at chief executive level.

2. Collection: the 4 data sources and their pitfalls

The first source is energy. Supplier bills, meter readings and consumption estimated from historical records. Scopes 1 and 2 are generally easy to collect: it takes one to two weeks.

The second source is purchases. This is the classic trap. The establishment's management accounts give an overall "pharmacy", "medical devices" or "services" budget but no internal breakdown. Information must be extracted from different systems depending on the establishment. Many university hospitals have pharmacy management software recording each purchase line, but these lines do not always have a usable category for choosing an emission factor. Medical device purchases go through procurement (supplier invoicing), but not always with the categorisation needed for emission factors. Catering sits within technical services or stores management. This is where most collection time is spent: two to four months depending on the establishment's size and IT structure. You need a breakdown of pharmaceutical spending by therapeutic category or at least by supplier, medical device spending by broad category (surgical instruments, care consumables, imaging, medical IT), and services and food budgets.

The third source is waste. Weights by waste stream from the contractor (infectious healthcare waste, waste comparable to household waste, green waste, specialised waste). Generally an Excel file with monthly tonnages. Allow two to three weeks to obtain consolidated data, unless the establishment has never weighed its waste, which happens.

The fourth source is travel. A staff commuting survey, with Google Forms sufficient for a targeted sample. An estimate for visitors, using the average number of visits per patient-day multiplied by estimated distance. This is the least precise but also the smallest in emissions, about 5-8% of scope 3. Allow two to three weeks with questionnaires.

3. Calculation and analysis: select factors and break down by category

Once the raw data have been collected, they must be converted into emissions. Scopes 1 and 2 use standard public factors. Scope 3 procurement data are the most critical. Each purchase category has a spend-based emission factor according to its NACE code or sector. ADEME maintains an up-to-date database. Since March 2025, the EMPREINTE database has used FIGARO to break down sectors. Pharmaceutical molecules have a single factor, about 200 kgCO2e/k€ excl. VAT, but in reality the footprint varies with synthesis. A generic injectable costs less than a biologically oriented anticancer medicine. The imprecision is acceptable overall but becomes visible when comparing two years.

What takes time is validating that the broken-down data match the factors. A BEGES still using pre-March 2025 factors overestimates the pharmaceutical category by a factor of about 2.5. A BEGES without a breakdown of purchases by category gives a flattened picture with no reduction measures.

4. Presentation and action plan: identify the 3 to 5 priority measures

The BEGES report is mandatory on the ADEME platform. But before submitting it, you must present to the executive committee: the total footprint, its breakdown by scope and category, and the three to five main categories explaining 70-80% of the inventory. For medicines, this looks like: "our pharmaceutical spending is €45 million per year, the footprint is about 9,000 tCO2e, and this is 38% of our total. The five most prescribed molecules, by spending volume, represent 30% of this issue." Reduction proposals follow: therapeutic alternatives, generics rather than brands, supplier negotiations on packaging, and ecodesign. For medical devices, rapid decarbonisation comes from comparing single-use and reusable options (a medical device LCA quantifies this). For energy: a building thermal audit, consumption reduction and renewables where compatible. For waste: a sorting audit to reduce misclassified infectious healthcare waste and investment in pretreatment.

5. Publication and monitoring: create a continuous improvement process

Publication on the ADEME website is mandatory. But do not stop there. The real opportunity is setting up monitoring. An annual dashboard covering the plan's three to five actions, with named people responsible, quantified indicators and quarterly milestones. "Replace 20% of pharmaceutical spending with generics by the end of 2026." "Audit infectious healthcare waste sorting and cut falsely classified infectious waste by 20% within 12 months." "Install a renewable source covering 10% of consumption by 2027." The second BEGES, 3 years later for a public establishment, starts with an improved baseline. We have seen it consistently: the first BEGES takes 6-12 months, the second 3-4 months because the collection processes are established.

5What we have learnt in the field

After several hospital engagements (Institut Pasteur, university hospitals, regional general hospitals and private clinics), three patterns emerge without exception. Our climate strategy guide for university hospitals details the specific aspects of management within a hospital establishment. The first: pharmacy is always the leading emission category, even when the director expects energy. Intuition misleads. The buildings are visible, with a gas bill and electricity bills. Medicines are invisible, just an accounting budget line. But when calculated, they always account for 29% or more. The second pattern: collecting scope 3 procurement data takes three to four times longer than scopes 1 and 2 because hospital information systems are fragmented. Pharmacy has its software, procurement another, catering a third. None was designed to feed a BEGES. Data must be checked, cleaned and reconciled. The third pattern is staff involvement. When a BEGES works well, it is because 50 to 70 people are involved, not only managers but department heads, operating theatre leads and pharmacists who understand the issue and propose alternatives. This is the real return on investment: a transformation of procurement practices as well as a report.

One final point: the report is never an end in itself. A BEGES left in a cupboard has served no purpose. A BEGES leading to three to five concrete actions, owned by named people, with budgets and milestones, changes the establishment's carbon trajectory. We measure it every year, improve it and can show the regional health agency, suppliers and patients that progress is being made.

6Key takeaways

A hospital BEGES limited to scopes 1 and 2 misses 84% of the footprint. The real issue is procurement transformation, which concentrates more than half a healthcare establishment's emissions, rather than regulatory compliance. Celsius's regulatory BEGES service specifies boundaries, collection, the transition plan and the elements to prepare for publication.

• Scope 3 = 84% of emissions: medicines alone account for 28-40% of the total inventory. Medical devices add 15-25%. Energy represents only 16%
• Pharmaceutical emission factors have changed: ADEME's March 2025 update, with a fall of about 60% for pharmacy. The reference year of a pre-2025 BEGES must be recalculated to remain comparable
• Replacing desflurane cuts anaesthesia emissions by 90%: GWP of 2,540 versus 97 for sevoflurane, with no documented clinical impact
• 50 to 70 people over 6-12 months: this is the format of a successful hospital BEGES. Pharmacy, procurement, technical services, finance and operating theatres must be represented
• Infectious healthcare waste costs 4-6 times more than ordinary waste: optimising sorting between infectious healthcare waste and waste comparable to household waste cuts both costs and the carbon footprint

7Frequently asked questions and practical answers

Which hospitals are required to carry out a BEGES?

Every public establishment employing more than 250 staff must publish its BEGES every three years (Article L229-25 of the Environmental Code), and every private clinic with more than 500 employees every four years. This means university hospitals, general hospitals, large private clinics, large nursing homes and certain specialised day hospitals if they reach the threshold. Since the July 2022 decree, scope 3 has been mandatory for public establishments.

How much does a complete hospital BEGES cost, and how long does it take?

A complete scope 1-2-3 BEGES for a healthcare establishment: €15,000 to €30,000 excluding VAT depending on size and IT structure. Timeframe: 6 to 12 months, including two to four months of data collection. It costs more and takes longer than for an industrial SME, where collection takes 4-6 weeks, because hospital information systems are fragmented. Diag Décarbon'Action (€10,000 excluding VAT, subsidised at 40% by Bpifrance) measures direct and indirect emissions and leads to an action plan, but is reserved for organisations with fewer than 500 employees, not subject to regulatory BEGES, and with no GHG inventory in 5 years: a general or university hospital cannot access it, while a clinic or private establishment with fewer than 500 employees that has never produced a GHG inventory may qualify.

How can medicine emissions be measured without detailed supplier data?

The standard method uses ADEME's spend-based factors. You have a pharmaceutical budget in euros excluding VAT and apply an emission factor, about 200 kgCO2e/k€ excl. VAT since March 2025. It is not perfect: a simple molecule has a lower footprint than a complex one, but it gives the correct order of magnitude. For greater precision, Ecovamed offers laboratories a tool to calculate specific medicines' footprints, and in February 2025 the State published a public medicines carbon score methodology, led by the Ministries of Economy and Health with Assurance maladie. An October 2025 ministerial note allows hospitals to include this score in procurement from the first quarter of 2026, starting with 18 priority molecules. Meanwhile, breaking down by therapeutic category, cardiology, respiratory medicine, oncology, antibiotics and so on, with appropriate factors gives better precision than the raw average.

Can a healthcare establishment benefit from Diag Décarbon'Action?

Bpifrance's Diag Décarbon'Action is reserved for organisations with fewer than 500 employees that are not subject to regulatory BEGES: a general or university hospital cannot access it. But ADEME has healthcare-specific schemes: grants for building energy audits, medical device LCAs and renewable energy projects. Regions manage dedicated budgets. The best first step is to contact the regional ADEME directorate, which lists accredited BEGES providers and provides information on funding available for healthcare establishments in your region.

Further resources

Frequently asked questions

1Which scope 3 categories are critical in hospitals?

Purchases dominate: medicines account for 28 to 40% of an establishment's total footprint and medical devices for 15 to 25%. Next come services (laundry, cleaning, maintenance, catering), then staff commuting and patient and visitor travel, accounting for about 5 to 8% of scope 3, and finally waste, including incinerated infectious healthcare waste. Purchases are measured in euros using ADEME's spend-based factors, for example about 200 kgCO2e per k€ for pharmacy since March 2025, hence the value of breaking expenditure down by category.

2How are medical devices integrated into the BEGES?

Medical devices account for 15 to 25% of a hospital's footprint and are included in procurement scope 3. The standard method applies ADEME's spend-based emission factors to expenditure, around 220 to 270 kgCO2e per k€ depending on the sector used (other manufactured products, electronic products). This average hides large differences, from an examination glove to an MRI scanner: procurement must therefore provide a breakdown by broad category (surgical instruments, care consumables, imaging, medical IT). For the action plan, comparing single-use and reusable options, quantified through an LCA, often offers rapid decarbonisation.

3How is a hospital's BEGES published?

The BEGES and its transition plan are published on the ADEME platform (bilans-ges.ademe.fr). Before submission, present the total footprint, the breakdown by scope and the 3 to 5 categories explaining 70 to 80% of the inventory to the executive committee, with associated reduction measures. A public healthcare establishment then updates its inventory every 3 years. An annual dashboard with named people responsible, indicators and quarterly milestones enables the plan to be monitored and the next inventory prepared, often completed in 3 to 4 months compared with 6 to 12 for the first.

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