Energy transition: decarbonisation is not enough

On 13 February 2026, France published its third Multi-Year Energy Plan (Programmation Pluriannuelle de l'Énergie, PPE 3). Its central objective: reducing the share of fossil fuels in national energy consumption from 60% to 29% by 2035. A commitment three years in the making, and one whose delay already signals something about the difficulty of the task.

But cutting greenhouse gas (GHG) emissions is not the same as reducing all environmental impacts. A multi-criteria analysis, drawing on several environmental indicators, makes this plain: the trajectory mapped out by PPE 3 will shift environmental pressures as much as it eliminates them, on mineral resources, on biodiversity, on supply chains.

For industrial players tasked with translating these orientations into concrete decisions, the real question becomes: how do you decarbonise without simply moving the problem elsewhere?

Energy in LCA: a cross-cutting impact driver

In a life cycle assessment (LCA), energy is everywhere. It is not tied to any one sector or stage: it is modelled at raw material extraction, manufacturing, transport, use, and end of life. Across virtually all products studied, energy ranks among the leading impact categories, and therefore among the primary levers for eco-design.

Figure 1: share of energy in LCA results (electricity grid, left; global ecological footprint breakdown, right)

This link between energy and environmental impacts is well established for climate. According to the Global Footprint Network, GHG emissions from fossil fuel combustion account for 56% of the global ecological footprint. The large-scale use of fossil fuels and certain forms of intensive agriculture are among the primary drivers of planetary boundary overshoot. The energy transition addresses one of these pressures. The others remain intact.

What PPE 3 says and what it leaves out

PPE 3 defines French energy policy for the period 2026–2035. It follows on from the third National Low-Carbon Strategy (Stratégie Nationale Bas Carbone, SNBC 3, published in December 2025), and arrives nearly three years behind the schedule originally set by the 2019 Energy and Climate Act (loi Énergie-Climat), which had mandated publication by 2023. A significant delay for a document of this structural importance.

Its targets are ambitious: cutting the share of fossil fuels in total energy consumption from roughly 60% to 29%, raising electricity's share to 38%, and non-electric renewables to 32%.

Figure 2: PPE 3 priorities

Figure 3: projected energy production mix to 2035

Energy sufficiency [sobriété énergétique] is embedded as a condition of the transition, not treated as a residual variable. Most current prospective scenarios share the same starting point: the cleanest energy is the energy you do not consume.

Renewable energy targets were, however, revised downward before the final text was published.

From an environmental standpoint, PPE 3 reasons almost exclusively in terms of GHG reduction. Necessary, and consistent with the SNBC — but blind to a structurally important dimension: no multi-criteria framework is integrated. Yet the transition it maps out will shift and transform certain environmental pressures well beyond the single issue of climate change.

Impact shifting: what LCA reveals

Impact shifting [transfert d'impacts] occurs when an improvement on one environmental indicator is accompanied by a deterioration on another, or when pressures move from one life cycle stage to another, sometimes to the other side of the world. It is one of the central concepts in LCA methodology, and one of the most useful for evaluating decisions that appear sound when assessed against a single criterion.

Applied to the energy transition, the picture is straightforward: France will emit fewer GHGs by 2035 as fossil fuels recede. But the expansion of renewable electricity and nuclear will intensify pressure on other resources. Per kWh produced, renewable electricity technologies are more mineral-intensive than thermal power plants.

Pressure on mineral resources will increase globally, driven by the combined effect of Europe's energy transition and worldwide decarbonisation dynamics. Greater demand for minerals means greater impacts on ecosystems and biodiversity, often far removed from the sites where energy is actually produced. According to Systext, a French NGO specialising in mining issues, the extractive industry generates more environmental and social conflicts worldwide than any other sector: land grabbing, water contamination, destruction of local ecosystems.

In short: the energy transition as designed by PPE 3 should ease pressure on the planetary boundary for climate change. It risks intensifying pressure on the physical boundaries related to resource use and on the planetary boundary for biosphere integrity.

From fossil fuel dependency to critical material dependency

Impact shifting is not the only risk to anticipate. The energy transition also creates new strategic dependencies. As the EU Critical Raw Materials Act makes clear, Europe risks substituting one form of structural dependency for another, different in nature, but potentially just as constraining, with respect to the metals and minerals required by low-carbon technologies: lithium, cobalt, rare earth elements, copper.

Figure 4: materials, technologies and sectors most affected by the EU Critical Raw Materials Act (closely tied to the energy transition)

The distinction matters. Impact shifting falls within the scope of environmental assessment in the LCA sense. Critical material dependencies belong to the domain of value chain resilience and supply risk. The two dimensions overlap without being equivalent: the responses they call for, and the actors responsible for them, are not the same.

What this means for industrial players

Regulatory pressure is not simply migrating from carbon to other indicators: it is accumulating. GHG requirements are not going away; they are being joined by growing obligations on biodiversity, resources and supply chains. An industrial player that optimises solely for its GHG footprint today risks being out of step with the regulatory framework within a foreseeable horizon of five to ten years.

Critical material dependencies represent a growing strategic risk. The geographic concentration of extraction and refining for certain metals exposes supply chains to real procurement vulnerabilities. Established methods make it possible to incorporate a criticality indicator directly into an LCA to assess a product's exposure, or to evaluate risks at company level through complementary approaches such as criticality matrices.

Stakeholders are raising these questions with increasing frequency. Investors, prime contractors and public procurement bodies are beginning to require environmental assessments that go beyond carbon.
One example: an industrial player in the energy sector has engaged its suppliers in joint R&D programmes to develop components with a lower carbon footprint while also limiting impact shifting, using LCA as the analytical framework throughout.

Multi-criteria LCA as a decision-support tool

Multi-criteria LCA is not a tool for slowing decisions down. It is a tool for framing them, one that makes it possible to distinguish a decision that appears sound from one that genuinely is. It enables impact shifting to be identified before it occurs, new dependencies to be anticipated, and trade-offs to be made between options that each carry advantages and limitations depending on the indicator in question.

In its current form, PPE 3 does not yet provide an explicit framework for a fully multi-criteria reading of the transition. Combining multi-criteria LCA with a critical raw materials analysis is what allows us to move from a decision that looks robust to one that actually is.

Mike Nunes, LCA and Eco-design Project Manager, Electrical Systems Specialist | EVEA