Government submissions

EU Taxonomy Thresholds For Climate Change Mitigation and Adaptation

Consultation Response

seven European flags are lined up outside a building
Photo by Guillaume Périgois on Unsplash.

E3G welcomes the work of the European Commission on the EU Taxonomy Delegated Act with technical screening criteria on climate change mitigation and adaptation. To maintain the credibility of the taxonomy and the coherence across other policy files, E3G has provided a response to the public consultation with sector and activity-specific recommendations.

Overarching recommendations for the Taxonomy Delegated Act:

  • Keep thresholds aligned with up-to-date scientific evidence rather than politically justified decisions, adopting a precautionary threshold where evidence is weak.
  • Follow the recommendations of the Technical Expert Group rooted in robust and evidenced work as the baseline for the criteria and improve further where needed, not going below this level of ambition.
  • Clarify that taxonomy thresholds will be tightened in line with increased ambition under the planned revision of the policy files under the ‘Fit for 55’ package in 2021.
  • Identify the Delegated Act as the single reference for reporting across companies, financial institutions and public authorities.

The taxonomy, pioneered by the Commission in 2018, was presented as a science-based, apolitical tool for scaling up sustainable investments. Although it was intended for the EU single market, the momentum behind it has triggered the creation of taxonomies and green investment classification systems in other countries.

The strength of the EU taxonomy is that it sets out science-based screening criteria as a safeguard against greenwashing. However, the recently published draft Delegated Act (DA) with the criteria on climate change mitigation and adaptation, demonstrates that in some instances these thresholds fail to rely on established policy objectives and scientific evidence. While we recognise that to a large extent the draft DA has taken into account the Technical Expert Group (TEG) recommendations, in some instances the draft has ignored or weakened the TEG scientific advice, or has introduced new activities, which have not been a subject to rigorous a scientific debate. Departing from the recommendations of the TEG raises the possibility that some of the thresholds could be watered down further following the public consultation.

Without its scientific basis the taxonomy risks losing its credibility. If the EU taxonomy is to fulfil the promise of setting the gold standard for the sustainable industries and activities of the future, not only for Europe but globally, then it will be vital that its rules are based on science and not on political convenience.

Our full consultation response with sector and activity-specific recommendations, as well as cross-cutting assessment and recommendations on the EU Taxonomy Delegated Act, can be found here.


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