Subsection 1: Scope of application

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Article R1333-106

French Public Health CodeIn force

Updated 5 Nov 2023

I.-Subject to the provisions of Article R. 1333-107, the following are exempt from the authorisation, registration or declaration provided for in Article L. 1333-8:

1° The possession, manufacture, use, distribution, import and export of radioactive sources and products or devices containing them if the value of the coefficient Q corresponding to the weighted sum of the radionuclide activities present at any time in the place where the activity is carried out or is the subject of the activity, divided by the exemption limit value set in the second column of table 2 of appendix 13-8 for each of these radionuclides is less than 1 ;

2° The possession, manufacture, use, distribution, import and export of radioactive sources and products or devices containing them if the value of the QM coefficient corresponding to the weighted sum of the radionuclide mass activities of each homogeneous or related assembly present at any time in the place where the activity is carried out or is the subject of the activity, divided by the exemption limit value set in Table 1 or in the third column of Table 2 of Annex 13-8 for each of these radionuclides is less than 1;

3° The nuclear activities mentioned in 2° of the I of Article R. 1333-104 when the components of the electrical apparatus operate at a potential difference less than or equal to 5 kV;

4° The nuclear activities mentioned in a and b of 2° of the I of Article R. 1333-104 and in c of this same 2° when the electrical device is an electron microscope, if the devices do not create, by design and under normal conditions of use, at any point located at a distance of 0.1 m from their accessible surface, a dose equivalent rate greater than 1 microSv. h-1 and meet one of the following two conditions:

a) The equipment is covered by an exemption certificate issued by a decision of the French Nuclear Safety Authority (Autorité de sûreté nucléaire) approved by the Minister responsible for radiation protection, because it provides effective protection for people and the environment against ionising radiation;

b) The electrical equipment used is a cathode ray tube for displaying images, or any other electrical equipment operating at a potential difference of 30 kV or less;

5° All or some of the activities mentioned in 1° of the I of Article R. 1333-104 for consumer goods and construction products that benefit from an exemption granted in application of Article R. 1333-4, when this exemption provides for such an exemption for this or these activities.

II.-For the application of I, the words :

1° By design means without taking into account the specific radiation protection improvements made by the user to a device ;

2° Normal conditions of use means the operating conditions laid down by the manufacturer or supplier of the equipment and incorporating the reasonably foreseeable hazards inherent in these conditions of use;

3° Accessible surface means any area accessible by all or part of a person (finger, hand, whole body, etc.), voluntarily or involuntarily, without dismantling or physically modifying the appliance or its accessories.

III - The provisions of 1° and 2° of I do not apply to the distribution, import and export of radioactive sources used for their radioactive, fissile or fertile properties.

IV - For radionuclides not listed in tables 1 and 2 of appendix 13-8, exemption limit values may be established by order of the minister responsible for radiation protection.

After examining the conditions of practice and the justification for a given category of activity, exemption limit values higher than those set in tables 1 and 2 of appendix 13-8 may be adopted by decision of the Nuclear Safety Authority approved by the Minister responsible for radiation protection provided that :

1° The performance of this activity does not require workers to be classified within the meaning of Article R. 4451-57 of the Labour Code;

2° The criteria mentioned in e of point 3 of Annex VII of Council Directive 2013/59/Euratom of 5 December 2013 are met.

Mariela Petrova

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Working with a corporate lawyer in France — Q&A

Any time a strategic decision changes how the company is owned, governed or contractually bound — incorporation, fundraising, M&A, restructuring, shareholder agreements, or major commercial contracts. Earlier engagement always costs less than later remediation.

A notary (notaire) is a public officer who authenticates specific deeds (mainly real-estate transfers and certain family-law acts). A corporate lawyer (avocat) advises on strategy, negotiates and drafts company documents, and represents you in disputes. The two roles complement rather than overlap.

Yes — most of our clients are foreign suppliers, investors or holding entities. We bridge the gap between French law and your home jurisdiction's expectations and deliver everything bilingually.

The SAS (Société par Actions Simplifiée) is the default choice for most international structures: flexible governance, single shareholder allowed, no minimum capital, and works cleanly with foreign holding entities. We assess SARL, SA, SCI on the merits when the situation calls for it.

Yes — communications with a French avocat are protected by the secret professionnel (Article 66-5 of the Law of 31 December 1971). This protection is broader than the common-law attorney-client privilege and applies to written and oral exchanges.

We work on fixed fees for clearly scoped engagements (incorporation, contract drafting, audits) and on monthly retainers for ongoing advisory. Hourly billing is the exception, not the default. You always know the cost before work starts.

Typical timeline is 2–3 weeks from KYC kick-off to RCS registration, assuming standard documentation. Holding-company structures, foreign-shareholder identification or in-kind contributions can extend this — we flag the gating items at the first meeting.

Absolutely. We routinely coordinate with your in-house counsel, expert-comptable or notaire — pragmatic collaboration is the norm, not the exception. We send them everything they need to do their part without duplicating work.

Mariela Petrova

Mariela Petrova

Avocate au Barreau de Paris

Toque #C2396

15+ Years In Corporate Practice

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