E3G response to new and updated criteria for EU Taxonomy sustainable economic activities

European Commission Flags. Photo by LIBER Europe on Flickr.

This is E3G’s response to the consultation on the new and updated criteria of the EU Taxonomy for sustainable economic activities by the European Commission on 3rd May 2023.

The new criteria cover the four remaining environmental objectives of the EU Taxonomy – Sustainable use and protection of water and marine resources; Transition to a circular economy; Pollution prevention and control; and Protection and restoration of biodiversity and ecosystems. In addition, the Commission published updates of the technical screening criteria of the existing Climate Delegated Acts.


The proposed criteria for the other four environmental objectives are a positive step forward in further developing the EU taxonomy in addition to the climate change mitigation and adaptation criteria.  

The inclusions of sound Disaster Risk reduction criteria are both welcomed, timely and critical given the intensifying weather conditions in Europe. The proposed criteria for Nature-based solutions for flood and drought risk prevention and protection under the sustainable use of water and marine resources, as well as the new climate adaptation criteria for disaster risk management, are particularly good. 


Significant improvements for some sectors and activities are needed where the criteria are not ambitious enough or even weakened from the expert recommendations of the Platform. Specifically, the criteria that correspond to current practices or legal minimum in polluting industries should not be considered as contributing significantly to the climate and environmental objectives. Notably, improvements are needed to the following sectors and activities: 

  • Circular economy: Buildings 
  • Circular economy: Plastic packaging manufacturing 
  • Biodiversity: Conservation and offsets 
  • Mitigation: Shipping and aviation 

Moreover, the criteria need to reflect the adverse climate and environmental impacts of economic activities throughout the whole value chain. A large share of the significant environmental harm could take place outside of the EU but should nonetheless be considered for both the DNSH and the substantial contribution to the EU taxonomy objectives.  


Science-based, ambitious criteria for high-impact sectors that are currently missing should be developed and included in the EU taxonomy. Namely, chemicals, textiles, apparel and footwear, agriculture, and fishing are high-impact and high-risk activities and sectors and should be included with criteria more ambitious than “business as usual”. Similarly, improvements in already existing weak criteria such as the forestry sector, is a missed opportunity to amend and improve the technical screening criteria beyond polluting business as usual practices.  

Read our full consultation response with sector and activity-specific recommendations here. 


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