EU taxonomy - review of the climate delegated act

The Programme for the Endorsement of Forest Certification (PEFC) welcomes the opportunity to contribute to the European Commissions review of the EU Taxonomy Climate Delegated Act, aimed at updating and simplifying the technical screening criteria. The current draft texts introduce welcome improvements, particularly in enhancing usability and streamlining assessment requirements.

Avfall Sverige (Swedish Waste Management) wishes to further clarify the need to adjust the EU taxonomy framework to ensure that carbon capture and storage (CCS) and carbon capture and utilisation (CCU) at waste-to-energy (WtE) facilities can be recognised as sustainable activities, and thereby qualify for green finance, in line with the previous response submitted by Sysav in the context of earlier Call for…

Public Housing Sweden is hereby leaving comments on the consultation: review the EU taxonomy climate delegated act. Our purpose with this answer is to give input to the strengthening of the climate delegated act from a perspective of mitigating climate change and decarbonising the building stock both from a perspective of embodied carbon and operational carbon. We leave comments on 7.1, 7.2 and 7.7.

Iceberg Data Lab (IDL), as an environmental data provider supporting financial institutions and investors in sustainability analysis and regulatory reporting, welcomes the Commissions review of the EU Taxonomy Climate Delegated Act. We recognise this initiative as an important step to improve the usability, coherence, and operationalisation of the Taxonomy framework.

This initiative will review the EU Taxonomy Climate Delegated Act to update the technical screening criteria and simplify them by stopping gas use within 3 years, the time to activate a renewable energy system stabilised by H2.

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Finnish Energy represents companies that produce, acquire, transmit and sell electricity, gas, district heat and district cooling and offer related services. Finnish Energy welcomes the opportunity to comment on the European Commissions review of the EU Taxonomy Climate Delegated Act.

Assonave welcomes the European Commissions review of the Technical Screening Criteria and the extension of the EU Taxonomy to a wider range of maritime activities, and highlights the need for a proportionate, technology neutral and pragmatic implementation approach.

Legnica, 14 April 2026 ZPPM/20S/IV/2026 European Commission Secretariat-General Rue de la Loi 200/Wetstraat 200 B – 1049 Brussels Bruxelles/Brussel/Brussels Belgium/Belgium Directorate-General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA) European Commission Spa2 Pavillon, Rue de Spa 2/Spastraat 2000 Bruxelles/Brussel, PO Box 1049 Belgium Position of the Employers’ Union Polska…

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EY appreciates the opportunity to comment on the proposed amendments to the Climate Delegated Act (CDA) and the Environmental Delegated Act (EDA). We welcome the efforts of the European Commission to simplify the EU Taxonomy Regulation (EUTR) requirements while retaining its policy objectives.

Please find attached in PDF format FEDIL The Voice of Luxembourgs Industrys feedback on the European Commission draft act on the review of the EU Taxonomy Climate Delegated Act. FEDIL welcomes the Commissions initiative to review the technical screening criteria (TSC) in light of implementation experience.

Taxonomy Climate Change Delegated Act - activity 8.1 Data processing, hosting and related activities DIGITALEUROPE welcomes the European Commission's efforts to update the technical screening criteria for Activity 8.1 under the EU Taxonomy Climate Change Mitigation (Annex I) and Climate Change Adaptation (Annex II) Delegated Acts.

SEVAIA, a French energy, environmental and sustainable finance consultancy company, welcomes the opportunity to provide input through this feedback consultation on the revision of the Taxonomy climate and environmental delegated acts. We strongly support Taxonomy's role as a key instrument in the EU's sustainable finance framework and see its effects in directing investments toward a sustainable real estate sectors.

ASD welcomes formal inclusion of the aviation sector within the EU Taxonomy framework and the opportunity to provide feedback on the proposed amendments to the EU Taxonomy Climate Delegated Act. We appreciate the European Commissions continued efforts and the visible changes introduced since the previous stakeholder consultation.

Bioenergia ry the Bioenergy Association of Finland - welcomes the continued recognition of bioenergy in the Draft Climate Delegated Act of the Taxonomy Regulation. The line taken previously and now supported in the draft has been confirmed by two European Court of Justice case rulings.

UIP welcomes the opportunity to provide its feedback to to the publication of the EU taxonomy climate delegated act Draft delegated regulation and Annexes - Ares(2026)28796. UIP, the association representing the interests of private wagon keepers and entities in charge of maintenance in Europe, would like to make several recommendations regarding the technical screening criteria for the economic activity 6.2.

Comments on the Draft Amendment to the EU Taxonomy Climate Delegated Act: Towards Tech-nology-Neutral, Life-Cycle-Based Criteria for Transport MRF is a trade association for Swedens motor industry that represents the majority of authorized dealers, most body repair workshops, and companies that sell and repair trucks in Sweden, while promoting high standards and fair business practices.

The Directorate welcomes the opportunity to provide input to this review and wishes to maintain consistency with previous submissions and consultations held with the European Commission. We underline the importance of ensuring that both new and existing owners of historic buildings and cultural environments are granted appropriate and equitable conditions within financial services, now - and as the Taxonomy…

The European Construction Industry Federation (FIEC) welcomes the call for feedback on the EU Taxonomy Climate and Environmental Delegated Acts. The EU Taxonomy is a key instrument to channel investments towards sustainable economic activities and to support the transition to a climate-neutral economy. The construction sector plays a central role in this transition.

This draft amendment to Delegated Act (EU) 2021/2139 supports the Commission’s objective of improving the usability and consistency of the EU Taxonomy criteria. For this reason, the revision of the DNSH criteria is in principle welcomed. Businesses urgently need tangible and practical simplifications.

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The intended harmonising of the Sustainability Taxonomy with the Carbon Removals Certification Framework (CRCF) gives a clear imperative for the inclusion of agroforestry in both the Climate and Environment Deleglated Acts.

Bulgarian Industrial Association Union of the Bulgarian Business (Българска стопанска камара съюз на българския бизнес, БСК) welcomes the initiative and suggests that the European Commissions review of the EU Taxonomy Climate Delegated Act must prioritize a realistic, performance-based transition over blanket sectoral exclusions to safeguard industrial competitiveness and energy security.

Thank you for the opportunity to respond to proposed changes to the Climate and Environment Delegated Act to the EU Taxonomy. Ørsted considers the Taxonomy a powerful tool for the EU, Member States and private investors to align their financing with core sustainability objectives.

CLEPA, the European Association of Automotive Suppliers, welcomes the initiative to improve the clarity, usability, legal certainty, and cost-effectiveness of the EU Taxonomy via targeted amendments while maintaining its robustness and credibility, and would like to submit the attached comments to the proposed Commission Delegated Regulation (EU) amending Delegated Regulation (EU) 2021/2139 as regards enhancing the…

INTERTANKO welcomes the European Commissions efforts to refine the Taxonomy. While we see considerable progress in aligning the Delegated Act with maritime realities, several technical ambiguities remain that could hinder its usability. Please find our detailed feedback attached

UNESID, the Spanish Steel Association, welcomes the opportunity to provide feedback on the draft Commission Delegated Regulation amending Delegated Regulation (EU) 2023/2486. Our comments on specific provisions of the draft acts are set out in the attached document.

GE Vernova welcomes the opportunity to contribute to the European Commission's call for evidence on the revised Climate Delegated Act of the EU Taxonomy and commends the Commission's efforts to simplify criteria, improve usability, and align the framework with updated EU legislation.

We welcome the opportunity to provide comments in the context of the Call for Evidence on the review of the EU Taxonomy Climate Delegated Act (Ares(2025)9618554). In the present submission, we respectfully highlight certain selected elements of the proposed framework which, from a legal and practical perspective, may give rise to a degree of uncertainty in their interpretation and application, thus causing…

The European Association for Investors in Non-Listed Real Estate Vehicles (INREV) supports the development of professional standards, transparency and best practice through research, industry guidance and policy engagement, bringing together institutional investors, investment managers and advisors across the world.

BNP Paribas Asset Management welcomes the European Commissions call for evidence on the revision of the technical screening criteria under the EU Taxonomy Climate and Environmental Delegated Acts. BNP Paribas Asset Management (BNPP AM) is the asset manager of BNP Paribas, a leading banking group in Europe with international reach.

EuroCommerce, representing European retailers and wholesalers, welcomes the opportunity to provide feedback regarding the consultation on the review of the EU taxonomy climate delegated act. Our sector broadly welcomes the proposed amendments, as many of the changes are expected to result in simplification and a reduction of unnecessary documentation and administrative requirements.

Submer supports the EU Taxonomy as a critical strategic instrument to steer capital towards economic activities that deliver genuine and measurable contributions to climate mitigation and adaptation. As digital infrastructure becomes an increasingly material driver of Europes energy system and emissions footprint, the effectiveness of the Taxonomy will depend on how well it distinguishes between mere compliance and…

Dassault Systèmes, as a global software company providing virtual twin experiences, fully supports the objectives of the Taxonomy and the opportunity this framework provides for companies to demonstrate their alignment with the EUs sustainability objectives.

Complex new wording with many references to other texts and footnotes. - Significant changes in generic criteria (including Appendix C Pollution and Appendix D Biodiversity) and impacting several taxonomic activities in cascade. - Mitigation/Energy performance criterion: confirm that the NZEB-10% criterion remains the one referred to in Directive 2024/1275 to which reference is now made in the draft act.

The WorldGBC network welcomes the European Commissions initiative to enhance the usability of the EU Taxonomy technical screening criteria, improve clarity, reduce administrative burdens, and ensure a proportionate and evidence based update of those criteria. WorldGBC specifically welcomes the alignment with the 2024 recast of the Energy Performance of Buildings Directive (EPBD) (Directive (EU) 2024/1275).

Dydon AG is a software development company that, in collaboration with VÖB-Service GmbH, a subsidiary of the Federal Association of Public Banks in Germany, develops and provides an AI-powered software solution (TAXOTOOL) for reporting under the EU Taxonomy.

EDF welcomes this initiative as the proposed amendments move towards greater alignment with the requirements of existing legislation. Indeed, as a general principle, the Taxonomy should rely on and refer to existing legislation and avoid adding more stringent requirements.

We welcome the Commission's initiative to update the Technical Screening Criteria (TSC) and, in particular, the extension of Taxonomy-compliant economic activities to include workboats. This enlargement represents a positive step towards a more comprehensive coverage of the maritime sector within the EU Taxonomy framework.

The undersigned NGOs welcome the possibility to give our comments to the EU Taxonomy CDA with focus on the criteria for nuclear activities. In the first phase of this consultation process we submitted a comment with arguments for excluding nuclear energy from the taxonomy altogether. This comment is still valid and is attached here.

FEDENE brings together six professional associations that work to improve energy efficiency and building services, decarbonize heat and cold production using renewable and waste heat, in cities, housing, the tertiary sector, and industry. Its 1,500 local companies, covering the entire value chain and spreading across the country, employ 50,000 people in France.

The Cruise Lines International Association (CLIA) welcomes the initiative of the European Commission to proceed with substantial simplifications in EU Taxonomy and the opportunity to provide comments on the consultation on the draft EU taxonomy climate delegated act. Please find attached our detailed response and we are at your disposal should you have questions or wish to discuss.

EUBP welcomes the opportunity to provide input on the review of the EU Sustainable Taxonomy, in particular the Commission Delegated Regulation amending Delegated Regulation (EU) 2021/2139 as regards enhancing the usability of the technical screening criteria. This review matters not only for the enforceability of taxonomy as such, but also for investment and financing decisions.

Regarding transport sector, the EU Taxonomy should shift from a tailpipe-based approach to a technology-neutral life-cycle (Well-to-Wheel) assessment to reflect real climate outcomes rather than predefined technologies.

ONCE Social Group welcomes the opportunity to contribute to the European Commissions consultation on the revision of the EU Taxonomy Regulation, particularly the Climate and Environmental Delegated Acts. As a leading organisation promoting the inclusion of persons with disabilities in employment and society, and at the same time an annual reporter under the EU Green Taxonomy, the ONCE Social Group supports the EUs…

Schneider Electric welcomes the opportunity to contribute to the public consultation on the revision of the EU Taxonomy Climate Delegated Act. Our company supports the Commissions objective of making this strategic framework more usable and simpler. While we acknowledge some positive improvements, we strongly reiterate our call for the inclusion of energyefficient equipment for data centres in the EU Taxonomy.

We welcome the European Commissions initiative to consult on the drafts to amend the Climate and Environmental Delegated Acts under the EU Taxonomy. As representatives of the refining and chemical sector, we recognize Taxonomys critical role in guiding sustainable finance and supporting the EUs climate objectives.

European Entrepreneurs CEA-PME considers that the proposed revision of the Climate Delegated Act does not adequately address the key challenges SMEs face in applying the EU Taxonomy. Despite acknowledging the significant administrative burden, the proposal largely maintains existing levels of ambition and technical requirements, leaving core obstacles unresolved.

While this call for feedback focuses on the revision of the Technical Screening Criteria (TSC), EDFI considers that the impact of any TSC improvements for EMDE investments also depends on two related enabling factors: (i) the current design of Taxonomy-related main KPI (the Green Asset Ratio - GAR) and (ii) persistent data gaps for nonEU counterparties.

COGEN Europe welcomes the European Commissions initiative to review the EU taxonomy climate delegated act to update and simplify the technical screening criteria. Despite efforts to improve provisions across different activities, COGEN Europe remains concerned with inconsistencies linked to the assessment of high efficiency cogeneration.

Eurogypsum, the European association representing gypsum product manufacturers, thanks the European Commission for the opportunity to provide feedback on the proposed act reviewing the EU taxonomy climate delegated act, presented on 17 March 2026.

The Japan Business Council in Europe (JBCE) welcomes the opportunity to submit its opinion in support of the review of the EU Taxonomy Environmental Delegated Act and Climate Delegated Act. Having previously submitted our opinions on the Do No Significant Harm (DNSH) criteria during the EU Taxonomy Stakeholder consultation in 2023 and 2025 , we are eager to continue supporting the European Commissions efforts for…

Michelin is pleased to contribute to the consultation on the revision of Taxonomy criteria for existing activities, as it offers a possibility to enhance the EU framework by making it more operable, comparable and valuable for all stakeholders (including preparers, customers, investors, NGOs). The following improvements should be considered for the current framework : 1.

Norsk Hydro (Hydro), the largest aluminium producer in Europe with operations in 18 countries and over 13,000 employees, fully supports the objectives of the EU Taxonomy, which is essential for channeling investments toward sustainable economic activities and aiding industry in its transition. Therefore, we welcome the opportunity to provide feedback to the public consultation.

Thank you for providing the opportunity to submit feedback on the recent drafts of the Taxonomy Delegated Acts. Please, find attached our position on the Technical Screening Criteria of the activity CCM 3.17. Manufacture of plastics in primary form and plastic compounding activities.

Umicore does not support the separation of battery manufacturing and battery recycling into distinct EU Taxonomy activities. A closed-loop, value chain approach is essential. The EU Battery Regulation is based on a life cycle logic, with binding obligations applying to batteries placed on the EU market as a whole, including recycling and recovery targets.

IECA (Spanish Institute of Cement and its Applications) welcomes the opportunity to contribute to the consultation opened by the European Commission to review the EU taxonomy climate delegated act (draft delegated regulation and annexes). Please find attached the document where we propose our technical contributions and comments, which we believe will be useful for consideration in the final document.

Cefic welcomes the review of the Climate and Environmental Delegated Acts of the EU Taxonomy, as it gives the opportunity to address existing concerns, and provides the following recommendations: Climate Delegated Act Address inconsistencies with the EU ETS Support the retention of current GHG emission thresholds Maintain use of ISO standards to calculate life-cycle GHG emissions until PEF-related shortcomings are…

Ferrovie dello Stato S.p.A. welcomes the European Commissions draft delegated act aimed at amending the Climate Delegated Act, endorsing its general approach and supporting, in particular, the objective of ensuring that the technical assessment criteria remain clear, consistent and practically applicable by industry operators.

Euroheat & Power welcomes the Commissions efforts to simplify the framework and better align it with the latest developments in EU energy and climate legislation. This review is timely and necessary. As a tool intended to guide capital towards sustainable activities, the Taxonomy should be practical, coherent and capable of supporting investment in sectors essential to the transition.

The Dutch Fund and Asset Management Association (DUFAS) welcomes the opportunity to comment on the draft proposal to amend the Climate Delegated Act and annexes. Our response focuses on several areas where we see clear improvements, as well as a number of concerns regarding the level of ambition and the robustness of the do no significant harm (DNSH) criteria.

Liquid Gas Europe (LGE) welcomes the opportunity to contribute to the European Commissions Call for Evidence on the review of the EU Taxonomy Climate Delegated Act. This review provides an important opportunity to improve the coherence and effectiveness of the Taxonomy framework, ensuring that it better reflects real-world decarbonisation pathways and aligns with existing EU climate and energy legislation.

BioChem Europe welcomes the European Commissions continued efforts to refine the EU Taxonomy framework and acknowledges the positive recognition of biomass-based pathways in the draft revisions of the Climate and Environmental Delegated Acts (DA). Particularly, the explicit reference to sustainability criteria under the Renewable Energy Directive (RED III) is an important step toward policy coherence.

On behalf of the heat pump, air conditioning and refrigeration equipment sector, represented by the European Heat Pump Association (EHPA) and the European Partnership for Energy and the Environment (EPEE), we welcome the opportunity to provide feedback on the revision of the EU Taxonomy Climate Delegated Acts to simplify and update their technical screening criteria.

The EU Taxonomy Climate Delegated Acts are currently under review to simplify and update their technical screening criteria. In November 2025, the European Commission organised a reality check workshop on practical implementation challenges.

INTERFERRY welcomes the opportunity to provide comments on the consultation on the draft EU Taxonomy Climate Delegated Act and on the European Commissions efforts to improve the usability of the Technical Screening Criteria (TSC) under the EU Taxonomy. In summary, our salient points are: 1) The use of EEDI/EEXI as a measure for energy efficiency for ro-ro cargo and ro-ro passenger ships is misguided.

Dear Madam or Sir, We thank you for the opportunity to comment on the European Commissions Draft Delegated Regulations amending Commission Delegated Regulations (EU) 2021/2139 and (EU) 2023/2486. The Institut der Wirtschaftsprüfer in Deutschland e.V.

Energy Efficiency for Europe (formerly EFIEES) is the voice of private energy service companies (ESCOs) and their national associations across Europe. Our members represent over 100.000 professionals committed to the design and implementation of energy efficiency measures in public and private buildings, industrial facilities, as well as to the efficient operation of district heating & cooling networks.

EDP supports the objectives underpinning the EU Taxonomy as a cornerstone of the EU sustainable finance framework and welcomes the proposed simplification of the reporting templates, which contributes to reducing administrative burden while safeguarding policy coherence and ambition.

Esterifrance is the professional organisation representing French manufacturers of fatty acid methyl desters-type biodiesel. She called for essential and urgent consistency between the Renewable Energy Directive (RED), which recognised biofuels from agricultural crops for human or animal consumption as contributing to the decarbonisation of transport, and the European Taxonomy, which paradoxically excluded them from…

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The EACB welcomes the opportunity to provide comments on the proposed amendments and clarifications to the EU Taxonomy framework and appreciates the Commission's efforts to improve the clarity, usability and proportionality of the technical screening criteria and related reporting requirements.

Gas Infrastructure Europe (GIE), an association representing the interests of European gas infrastructure operators, welcomes the opportunity to contribute to the ongoing public consultations on the revision of the Delegated Regulations amending the EU Taxonomy Climate Delegated Act and acknowledges the EU Commissions efforts to enhance the frameworks usability and effectiveness.

The Swedish Construction Federation supports revising the EU Taxonomy and highlights concrete issues such as recycling targets, rules on emissions testing and material scope, rigid water requirements, and uncertainty around reporting climate impacts. The Federation also stresses that land use criteria are problematic.

The attached document contains the contribution of the Polish Electricity Association (PKEE), outlining key considerations for ensuring that the revised Climate Delegated Act remains coherent, technologyneutral and operational for market participants across the Union.

The European Banking Federation strongly supports the goal of simplifying and harmonizing the technical screening criteria across the EU regulatory framework. While we support all efforts for simplification, proportionality, practical applicability and consistency with EU law, we believe the proposed simplification is insufficient to significantly improve the usability of the whole Taxonomy framework.

We appreciate the opportunity to comment on the European Commissions (EC) consultation on revising the technical screening criteria (TSC) of the EU Taxonomy (EUT). We have consulted with our member firms to ensure this letter represents the views of the KPMG network.

Ance welcomes the efforts undertaken in the revision of the EU Taxonomy Climate and Environmental Delegated Acts, aimed at updating and simplifying the related technical screening criteria, which have so far often proved difficult to apply, overly complex, and at times inconsistent or legally uncertain.

Dear Commissioner, Please find attached the response of the Compagnie Nationale des Commissaires aux Comptes (CNCC) to the European Commissions Call for public feedback on draft revisions to the EU Taxonomys technical screening criteria. Kind regards, [name removed]

The Accounting Standards Committee of Germany (DRSC) is the national standard setter in the area of group financial reporting in Germany. The organisation was established on 17 March 1998 as an independent and registered not-for-profit association by German Industry and is domiciled in Berlin. The DRSC had been formally acknowledged by the Ministry of Justice as the private standardisation organisation pursuant sec.

We welcome the proposed amendments to the EU Taxonomy Delegated Acts. The adaptations provide more clarity and strengthen the practicality of the requirements. We would like to suggest two DNSH criteria. Water and marine resources We welcome the clarifications provided by the European Commission.

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Please find the European Cargo Alliance's (ECA) feedback attached. The European Cargo Alliance (ECA) represents leading European air cargo carriers, including ASL Aviation Holdings, Cargolux Airlines International S.A., DHL Express, and Maersk Air Cargo A/S. Our members hold key market positions in scheduled and charter air cargo operations, parcel and express courier flights, and aircraft leasing.

Polskie Elektrownie Jądrowe sp. z o.o. (PEJ) welcomes an opportunity to provide feedback on the draft delegated regulation amending Delegated Regulation (EU) 2021/2139 as regards enhancing the usability of the technical screening criteria. PEJ's position is attached.

Airbus particularly appreciates the formal inclusion of the aviation sector within the EU Taxonomy framework and the opportunity to provide feedback on the proposed amendments to the EU Taxonomy. This serves as a vital acknowledgment of the industry's decarbonisation plan, underpinned by continuous technical progress.

We welcome the proposed amendments, which aim to strengthen the robustness, coherence and operational applicability of the EU Taxonomy. We provide below targeted comments on specific sections and encourage further clarifications to ensure that the criteria remain both environmentally robust and practically implementable.

As a global innovation leader in biotechnology with a strong industrial footprint in Europe, IFF welcomes the European Commission's recognition in the draft Delegated Acts of plastics produced in primary form from sustainable bio-based feedstock, including sustainable agricultural feedstock, as an economic activity contributing to climate change mitigation.

The Austrian Association of Public Economy and Public Economy (Verband der öffentlichen Wirtschaft und Gemeinwirtschaft Österreichs, VÖWG) welcomes the draft revision of Delegated Regulation 2021/2139 and supports the Commission’s objective of making the EU taxonomy more practical, legally certain and consistent.

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Eurogas welcomes the possibility to comment on this critical piece of legislation. Please find attached a combined document listings our recommendations on this file: - our views on the proposal - our recent position on CCDA aspects - our previous submission on the call for evidence Thank you for this opportunity.

ESWET the European Suppliers of Waste-to-Energy Technology welcomes the opportunity to contribute to the European Commissions consultation on the revision of the Climate and Environmental Delegated Acts under the EU Taxonomy framework. However, ESWET regrets that Waste-to-Energy (WtE) activities have once again been excluded from the scope of the Taxonomy.

Insurance Europe's detailed comments can be found in the document attached. Insurance Europe welcomes the European Commissions initiative to review and update the Technical Screening Criteria (TSC) under the EU Taxonomy Climate and Environmental Delegated Acts and supports the overarching objective of directing capital towards sustainable activities in line with the EUs climate and environmental ambitions.

Dear Sir or Madam, Business & Science Poland is pleased to submit its members recommendations in the context of the review of the EU Taxonomy Climate and Environmental Delegated Acts. We thank the European Commission, in particular DG FISMA, for the opportunity to contribute to this process and remain at your disposal should further information or clarification be required.

Eurelectric appreciates and supports the Commissions effort to streamline the Taxonomy. The priority should be on improving the clarity, usability and consistent interpretation of the existing criteria to ensure effective implementation and steer investments towards the clean transition. In the support attachment, we provide recommendations for further improvements.

Nucleareurope welcomes this initiative as the proposed amendments move towards greater alignment with the requirements of existing legislation. Indeed, as a general principle, the Taxonomy should rely on and refer to existing legislation and avoid adding more stringent requirements.

The Bank welcomes the Commissions proposal to revise the TSC of the Climate and Environmental Acts and supports the broader objective of making the Taxonomy framework more workable and easier to apply in practice.

The French Banking Federation (FBF) supports the European Taxonomy and has welcomed the European Commission's desire for simplification. However, the members of the FBF were very surprised by the proposal to revise the delegated acts of the Taxonomy published in February 2026, for the following two reasons.

Please find attached the detailed feedback from the Wiener Stadtwerke Group on individual economic activities. This draft amendment to Delegated Act (EU) 2021/2139 supports the Commission’s objective of improving the usability and consistency of the EU Taxonomy criteria. For this reason, the revision of the DNSH criteria is in principle welcomed.

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Tata Consultancy Services (TCS) welcomes the European Commission's initiative to review the technical screening criteria under the EU Taxonomy Delegated Acts. As a global leader in IT services and consulting with a significant presence across the EU, TCS serves clients in financial services, manufacturing, energy, and other sectors subject to Taxonomy reporting obligations, giving us direct insight into the…

The VDMA welcomes the Commissions intention to revise the Climate Delegated Act and acknowledges certain positive developments, such as the recognition of energy efficiency services and the replacement of the benchmarking concept best available alternative with current state of the art.

New construction: The application of the SCC to buildings larger than 1000m² would result in a significantly larger number of residential buildings falling within scope. Additionally, all properties should immediately align with the ZEB standard and be subject to a GWP analysis, massively restricting applicability.

MEDEF consulted its members on the proposed amendments to the delegated acts concerning the green taxonomy. We note that trade associations are finding it very difficult to assess the proposed changes within such a short consultation period.

The proposed amendments to the EU Taxonomy aim to simplify the framework and align the technical screening criteria with updated EU legislation. We welcome this direction. Clearer guidance through the Level(s) methodology will make reporting more consistent across Europe. We also support streamlining to the Energy Performance of Buildings Directive as well as the introduced 1 000 m² thresholds.

Thank you for the opportunity to participate in the public consultation process on the EU Taxonomy. As an important gas Transmission System Operator (TSO) in Austria, we are committed to sustainability, transparency, and the use of standardized frameworks, we value the role that the EU Taxonomy plays in supporting credible and comparable environmental disclosures.

BDEW welcomes the revision of the EU Taxonomy Climate and Environment Delegated Acts. The EU Taxonomy is an important tool to channel investments into the transition towards climate neutrality. However, in order to be able to perform this function effectively, the technical screening criteria need to be legally certain, proportionate and applicable in practice.

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Statkraft welcomes the Commissions objective to simplify the EU Taxonomy and align the technical screening criteria for hydropower with the Water Framework Directive (WFD). Statkraft particularly supports the proposed recital 24 that says: Given that Directive 2000/60/EC of the European Parliament and of the Council provides robust safeguards for hydropower activities, the Do No Significant Harm criteria for…

We welcome the opportunity to provide feedback on the Commissions draft amendments to the EU Taxonomy Climate Delegated Act and Environmental Delegated Act. We appreciate the Com missions effort to simplify, clarify and improve the usability of the technical screening criteria. We continue to acknowledge that the EU Taxonomy can play a valuable role as a common refer ence framework for sustainable investments.

The NGO Shipbreaking Platform welcomes the opportunity to provide input on the draft revision of the Climate and Environmental Delegated Acts under Regulation (EU) 2020/852 (EU Taxonomy Regulation). While we support the new elements brought to strengthen the screening criteria for DNSH - Transition to a circular economy under sections 6.10, 6.11 and 6.12 of the Climate Delegated Act related to the maritime sector…

Valmet is a global technology leader serving process industries. We work closely with our customers throughout the lifecycle, delivering cutting-edge technologies and services, as well as mission-critical automation and flow control solutions to support the transformation towards a regenerative tomorrow.

Finance Denmark thanks for the opportunity to comment on the Commission’s proposal regarding the delegated acts under the EU Taxonomy. We support the ambition to simplify the framework and reduce unnecessary complexities in application. At the same time, we fundamentally support the intention of the taxonomy as a key tool to support the transition to a more sustainable economy.

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The Confederation of European Forest Owners (CEPF) acknowledges the opportunity to comment on the revised technical screening criteria of the EU taxonomy climate delegated act. In our feedback we will focus on the forest-related activities, particularly forest management. While the revision addresses some concerns, fundamental barriers remain.

PostEurop welcomes the European Commission initiative to review the EU taxonomy climate delegated act to update and simplify the technical screening criteria. Its feedback to the draft delegated act focuses on the Climate one. This position is based on the practical experience of PostEurop members in the implementation of the technical screening criteria.

The European Automotive Manufacturers' Association (ACEA) welcomes the opportunity to provide feedback on the draft Climate Delegated Act of the EU Taxonomy legislation. Whereas the draft presents some acceptable changes, several key issues remain outstanding. Please see the ACEA detailed feedback in attachment.

PwC International Limited (PwC), on behalf of the PwC network, appreciates the opportunity to provide feedback to the European Commissions proposed amendments to the Taxonomy Delegated Acts supporting the Taxonomy Regulation. Please see our detailed suggestions and comments in the attached letter.

Utilitalia welcomes the European Commissions review of the Technical Screening Criteria under the EU Taxonomy Climate and Environmental Delegated Acts. The attached document sets out our technical observations and proposals concerning activities in the water, waste and energy sectors, with the aim of supporting a coherent, workable and science-based framework.

Albioma is the leading independent renewable electricity producer in the French outermost regions (ORs), where biomass forms the backbone of the decarbonisation of isolated electricity systems. Albioma welcomes the European Commission's initiative to revise the technical screening criteria of the Climate Delegated Act of the EU Taxonomy (Delegated Regulation EU 2021/2139), and takes this opportunity to call for…

TRAFFIC welcomes the 2026 revisions to the EU Taxonomy Climate Delegated Act. Significant gaps remain that risk undermining the credibility and effectiveness of the framework, particularly in relation to supply chains involved in the use of wild species and ingredients (fisheries, wild plants, timber) and the prevention of environmental crime across key economic sectors.

The draft will not lead to broader application and greater market acceptance of the EU taxonomy with regard to property financing, environmental objective climate change mitigation and the activities 7.1, 7.2 and 7.7.

Europacable, the voice of Europes leading cable system manufacturers, welcomes the opportunity given by the European Commission to provide feedback to the review proposals of the EU taxonomy climate and environment delegated acts.

Directing investments towards a climate-resilient and net-zero economy by focusing on six environmental objectives, the EU Taxonomy is a cornerstone of the EUs sustainability strategy. Recycling Europe strongly supports this simplification initiative, while emphasizing it must not undermine the environmental ambition of EU legislation.

The European Data Centre Association (EUDCA) welcomes the European Commissions efforts to revise the EU Taxonomy Climate Delegated Act with the aim of improving clarity, usability and regulatory coherence, and supports the overarching ambition to promote more sustainable data centre operations.

WE Data Europe welcomes the amendment of the description of Activity 7.5 (Installation, maintenance, and repair of instruments and devices for measuring, regulating, and controlling energy performance of buildings), notably the extension of its scope to the acquisition, rental, or leasing of smart meters for gas, heat, cooling, and electricity.

The Norwegian Green Building Council welcomes the Commission´s efforts to improve the usability of the EU Taxonomy technical screening criteria. We strongly support the Commissions aim with the taxonomy: to prevent greenwashing, and reduce financial risk.

Air France KLM strongly supports the objectives of the EU Taxonomy as a cornerstone framework to channel capital towards sustainable economic activities and to enhance transparency in the transition to a climateneutral economy. As a leading European airline group, AFKL is fully committed to aviation decarbonization and to contributing credibly to the EUs environmental objectives.

We submit feedback on behalf of the Norwegian Green Building Council, EBA (The Norwegian Contractors Association), RIF (The Norwegian Engineering Consultancy Association) and The Norwegian Property Federation. We appreciate the opportunity to provide feedback on the proposed amendments to the EU Taxonomy Delegated Act.

The draft amendment to Regulation 2021/2139 on taxonomy raises serious doubts from the point of view of the development of the biomethane industry. So far, the European Union has obliged member states to develop biomethane industry, which is the only renewable gas with the quality of natural gas.

The structural and methodological reorganisation of the proposal to amend the Delgado Regulation (EU) 2021/2139 to the CS and NSH criteria for adaptation is positive as it clarifies its application logic and aligns the criteria with an explicit climate risk management approach. However, some challenges remain in the implementation of these criteria.

Filed in Portuguese · English published by the European Commission

Île-de-France Mobilités (IdFM), a local public administration, welcomes the European Commissions initiative to reassess the Climate and Environmental Delegated Acts under the EU Taxonomy Regulation. We reaffirm our support for the Taxonomy as a foundational instrument of the EU sustainable finance architecture, crucial for channelling investment toward sustainable economic activities.

AGFW e. V. is the independent, impartial German association promoting energy efficiency, (district) heating, cooling and CHP (Combined Heat and Power) at national and international levels. AGFW comprises more than 700 regional und municipal energy suppliers, consultants, experts manufacturing companies including component and system manufacturers, assembling companies and testing institutes within Germany and…

Credit Agricole Group firmly supports the objective of simplifying and harmonising the sustainable finance regulatory framework. As underscored in the Draghi and Letta reports one year ago, this is a key condition for preserving and strengthening Europes competitiveness. In this context, we are therefore surprised by the Commissions proposal which falls significantly short of expectations.

T&E welcomes the opportunity to provide feedback on the revised draft delegated act and supports the ongoing efforts to simplify and streamline the EU Taxonomy criteria. However, we are deeply concerned that the current direction of revision risks lowering the overall level of ambition rather than improving the usability of the framework.

Aena welcomes the European Commissions 2026 review of UE Taxonomy Delegated Regulations amending Delegated Regulation (EU) 2021/2139 and Delegated Regulation (EU) 2023/2486. The initiative addresses issues widely highlighted by stakeholders, including excessive complexity, insufficient clarity in the technical screening criteria, and challenges in practical implementation.

Thank you for the opportunity to provide feedback on the Commissions review of the EU Taxonomy Climate Delegated Act, aimed at updating and simplifying the technical screening criteria. Finance Norway supports the objective of channelling capital towards sustainable activities.

AKL Position on the EU Taxonomy Climate Delegated Act Amendment The Finnish Central Organisation for Motor Trades and Repairs (AKL) calls on the European Com-mission to make the EU Taxonomy's transport screening criteria technology-neutral by introducing a life-cycle (Well-to-Wheel) assessment pathway alongside the existing tailpipe criterion.

This submission prepared by Climate Bonds Initiative sets out recommendations to strengthen the technical screening criteria across key industrial sectors, with the overarching objective of ensuring environmental integrity, coherence across value chains, and alignment with net-zero goals.

Our input mainly concerns hydropower, and thus the proposed amendments of Section 4.5, subsection Technical screening criteria, point 3. Key messages: We strongly support the Commission in that Taxonomy compliance requires Good Ecological Status or Good Ecological Potential.

The full set of recommendations can be found in the attached paper. Below, the most urgent comments: 1. Scope: Recognise the role of energy efficiency solutions (esp. manufacturing) for industrial processes to foster EUs decarbonization, resilience and competitiveness objectives and include relevant activities in the Taxonomy scope. 2.

Cerame-Unie, the European Ceramic Industry Association, welcomes the Commission's initiative to review the EU taxonomy climate delegated act to update and simplify the technical screening criteria. Please find in the document attached our comments related to construction activities.

Leaseurope, the European Federation representing the leasing and automotive rental industries, welcomes the opportunity to provide feedback on the proposals amending the EU Taxonomy Delegated Regulations. Leaseurope welcomes the proposals amending the DNSH criteria for the environmental objective (5) pollution prevention control in relation to activities CCM 6.5 and CCM 6.3.

The National Alliance of Forest Owners (NAFO) appreciates the opportunity to provide comments on the European Commissions proposed amendments to the EU Taxonomy Climate Delegated Act, particularly regarding forest management (Activity 1.3) and the introduction of cascading principles for biomass energy use (Activities 4.8, 4.20, and 4.24). The full NAFO position is set out in the attached document.

As the Italian National Promotional Institution and one of the largest Italian financial institutions disclosing information according to the EU Taxonomy, CDP shares the following recommendations. Simplification: many companies and local public entities may need to significantly review internal processes, data collection systems and governance arrangements to comply with the revised requirements.

The EU Taxonomy Regulation, adopted in 2020, aims to steer investment towards activities that support the EUs decarbonisation objective. In this context, delegated acts were also created, which are now to be revised.

GDV appreciates the opportunity to provide feedback on the EU Commissions proposals to amend the Technical Screening Criteria (TSC) under the Taxonomy Regulation (i.e., Delegated Regulations 2021/2139 and 2023/2486). We suggest further amendments to the TSC to improve the application for users and comparability for investors.

We broadly support the EU Taxonomy framework for the energy sector and consider the existing technical screening criteria largely appropriate. We particularly welcome the simplifications introduced in July 2025 and the recent amendments in the Climate Delegated Act, notably with regard to life-cycle emissions for geothermal energy.

General Remarks This is the third revision of Appendix C in four years. Each revision creates additional administrative burden, forces practitioners to re-examine and re-report, and generates confusion across the market. This is the opposite of simplification and good governance, and it erodes trust in the Taxonomy as a stable and reliable framework. The direction of travel is also wrong.

Eviny AS is a public owned renewable energy company based in Bergen on the west coast of Norway. We own and operate 44 Hydro Power Plants (HPP) with an installed capacity of 1981 MW and yearly production of 7300 GWh. We align with the submission provided by our industry association Renewables Norway, where we emphasize the need to clarify DNSH criteria 3 for hydropower.

Consistency with EU regulation, proportionality and usability: Alignment with existing EU legislation has improved but is not applied consistently. Compliance with existing regulation, including EIA outcomes and permits, should generally be sufficient. Additional requirements create misalignment and unnecessary complexity.

The Association for Emissions Control and Climate (AECC) welcomes the opportunity to comment on the draft amendment to Delegated Regulation (EU) 2021/2139 as regards enhancing the usability of the EU Taxonomy technical screening criteria. AECC understands the overarching objectives of the EU Taxonomy as a tool to accelerate the transition to climate neutrality.

Please find here a summary of the feedback from the Ministry for the Ecological Transition and the Demographic Challenge of Spain on the proposed amendments to the Climate Delegated Act (CDA). Further details on these comments are provided in the attached document.

The draft revised delegated act marks a step forward by proposing an increase to the current threshold. However, a single pan-European maximum U-value of 1.2 (W/m² K) for windows remains a significant limitation. While the manufacturing capacity is not an issue, a maximum U-value of 1.2 (W/m² K) is not fully appropriate for all European climates.

Fortum appreciates the work done by the Commission to streamline the taxonomy criteria. We strongly support the goal of the revision to make the framework simpler and easier to use. Fortum agrees with the conclusion that the EU Taxonomy Regulation is a cornerstone of the EUs sustainable finance framework, steering investments towards sustainable projects.

We welcome the Commissions efforts to improve the clarity, usability, legal certainty and cost-effectiveness of the EU Taxonomy criteria while maintaining environmental integrity. In this context, we consider that a targeted clarification would be useful in relation to construction and real estate activities.

With reference to a public consultation held by the European Comission on the Sustainable investment review of the EU taxonomy climate delegated act, attached please find position paper of Polish Association of Heat Energy (Polskie Towarzystwo Energetyki Cieplnej).

Confederation of Industry of the Czech Republic supports the direction of simplification, however we are of the opinion that even greater pragmatism, legal certainty and consideration of the practical realities of industrial production at key points are necessary, so that the taxonomy can serve as functional means of supporting sustainable investments.

Stockholm Exergi Feedback with regard to the inclusion of Cascading of biomass in relation to the promotion of the Circular Economy. There is a range of harvested forest biomass that is not suitable for long-lived wood products but can be used for many other applications.

GdW Bundesverband deutscher Wohnungs- und Immobilienunternehmen e.V. (Federal Association of German Housing and Real Estate Companies), as the largest German indus-try umbrella organisation, represents around 3,000 municipal, cooperative, church-run, private-sector, state-owned and federally-owned housing companies nationwide and at European level.

The review of the EU Taxonomy Climate and Environmental Delegated Acts represents a critical opportunity to align the EUs sustainable finance framework with its broader strategic imperatives. Copper and other non-ferrous metals as the EUs most strategically significant critical raw materials for the green and digital transitions must be at the centre of this revision.

CEZ Group welcomes many of the proposed changes, as they remove uncertainties and express the requirements, or relevant exemptions, more clearly in taxonomy. However, we also strongly believe that in many cases the changes were not improving the situation and in some Sections we are missing a corrective action by the EC altogether and CEZ Group would very much welcome, if EC would reconsider and make some…

RWE welcomes the opportunity to provide feedback on the draft amendments to the Climate Technical Screening Criteria (TSC). We support most of the proposals that aim to improve the usability of the Taxonomy. However, we believe that the draft delegated act could be improved further. Please see our detailed feedback attached, focusing on Annex I on Climate Change Mitigation.

The purpose of the current consultation is to make the EU Taxonomy simpler, clearer and easier to apply, while improving transparency and facilitating access to sustainable finance. ITAD welcomes this review as an important opportunity to address current gaps in the framework and to better recognise Waste-to-Energy (WtE) as an essential and unavoidable component of the circular economy and the waste hierarchy.

DI Danish Energy Industries welcomes the review of the EU Taxononmys Climate and Environmental Delegated Acts. We fully support the EU Taxonomy and its purpose of directing investments towards sustainable projects and activities.

The Unified Water Label Association (UWLA), as a trade association promoting water and energy efficiency for kitchen and bathroom sanitaryware products, welcomes the opportunity to contribute to the review of the EU Taxonomy Climate and Environmental Delegated Acts.

On behalf of Renewables Norway we submit our feedback on the draft changes in the EU taxonomy delegated act. We organise the hydropower producers in Norway. Hydropower constitutes the backbone of Norways electricity system, and the EU taxonomy plays a vital role in enabling sustainable financing and guiding investments toward environmentally sound activities.

The draft amendment to Regulation 2021/2139 on taxonomy raises serious doubts from the point of view of biomethane industry. So far, the EU has obliged MS to develop biomethane industry. The REPowerEU plan (2022) set an ambitious goal to achieve the production of 35 billion m3 of biomethane by 2030. The Gas Package (2024) supports this industry.

Attached document is the contribution of Republiková únia zamestnávateľov (tripartite social partner representing wide spectrum of business associations and companies of Slovakia) to the consultation on amendments to the EU taxonomy Climate Delegated Act (EU) 2021/2139.

As Potash and Salt Association (Verband der Kali- und Salzindustrie, VKS), we represent the interests of the German potash and salt producers. With 13,500 employees, the industry ranks among the worlds leading suppliers of potash and salt products. We welcome the European Commissions goal and effort to reduce administrative burdens and streamline processes.

Issue: We very much welcome the progress made by considering curtain walls as windows. However, the technical screening criteria for the energy efficiency of transparent building components remain incorrectly defined, as neither climate differentiation nor solar energy gains are considered.

ZVEI welcomes the European Commissions efforts to simplify the EU Taxonomy framework and improve its usability. While the overarching objective of fostering sustainable investment is fully supported, the current proposalsparticularly regarding Appendix C and the Technical Screening Criteria (TSC)remain overly complex, legally unclear, and insufficiently aligned with existing EU legislation.

The Agence Française de Développement (AFD) Group, a French Public Development Bank (PDB), funds, supports and accelerates the transitions towards a fairer and more sustainable world. The Group contributes to the commitment of France and French people to support the Sustainable Development Goals (SDGs).

Forvis Mazars is a leading international audit and assurance, tax and advisory firm of 40,000 professionals, in more than 100 countries. We pride ourselves on being a different kind of firm one that contributes to a fair and prosperous world by caring for the success of our people and clients, the health of financial markets, and the integrity of our profession.

As a major player in the waste and water management sector, SUEZ intends to take an active part in the second consultation launched by the European Commission on the EU taxonomy environmental and climate delegated acts to update and simplify both the technical screening criteria (TSC) and do not significantly harm criteria (DNSH).

1. The Luxembourg Stock Exchange (LuxSE) welcomes the European Commissions efforts to simplify the EU Taxonomy framework, notably through the consolidation of closely related activities into a single activity for Construction, extension, operation and renewal of water collection, treatment and supply systems. This represents a constructive step towards greater clarity and usability. 2.

Slovenské elektrárne, a.s. welcomes the initiative to review the EU Taxonomy Climate Delegated Act with the aim of updating and simplifying the technical screening criteria. However, based on the published Draft Delegated Regulation amending the EU Taxonomy Climate Delegated Act, several shortcomings have been identified.

Copa and Cogeca represent th European farmers and Agri-Food Cooperatives. We would like to reiterate our comments on the revision of the Climate Delegated Act (CDA), which have not been sufficiently reflected in the current draft Delegated Regulation.

ZIA welcomes the revision of the EU Taxonomy Delegated Act and Technical Screening Criteria (TSC). The taxonomy has potential to mobilize capital for building sector decarbonization, but practical challenges have prevented full realization of this potential. Main Recommendations 1.

Copa and Cogeca represent th European farmers and Agri-Food Cooperatives. We would like to reiterate our comments on the revision of the Climate Delegated Act (CDA), which have not been sufficiently reflected in the current draft Delegated Regulation.

We would like to thank the European Commission for the opportunity to provide feedback. We appreciate the constructive dialogue and acknowledge the steps taken to simplify the EU-Taxonomy legislation. At the same time, we would like to raise several comments. In particular, we note that certain elements remain highly complex from an implementation perspective.

The Green Building Council of Australia (GBCA) strongly welcomes the European Commissions proposed amendments to the EU Taxonomy Climate and Environmental Delegated Acts. The GBCA supports both the objective and the approach: sharpening the substantial contribution bar for new construction advancing to zero-emission building (ZEB) compliance under the EPBD 2024/1275 while reducing complexity through clearer DNSH…

The OFI is an Austrian research institute that has been coordinating a research project for the past three years examining how the requirements of the EU Taxonomy Regulation can be implemented in the renovation of buildings. Within this project, specific reference buildings from different construction periods are being analysed.

For specific feedback, we would like to refer to our position paper from the last Consultation in December. We welcome some adjustments that have been made in the delegated acts on climate (EU) 2021/2139 and environment (EU) 2023/2485, e.g. the focus on post-consumer waste in plastic manufacturing (3.17 Annex I Climate DA) but also note that some important changes have unfortunately not been considered.

Deutsches Aktieninstitut welcomes the opportunity to comment on the European Commissions draft Delegated Acts amending the Climate and Environmental Technical Screening Criteria under the EU Taxonomy Regulation. We would like to highlight several aspects where the proposed TSC risk impeding rather than accelerating the transition to a decarbonised European economy.

BETTER FINANCE welcomes the review of the EU Taxonomy Climate Delegated Act and supports targeted efforts to improve the usability of the technical screening criteria for climate change mitigation and climate change adaptation.

Pohjolan Voima (PVO), one of Finlands largest energy producers, thanks the European Com-mission for the opportunity to provide feedback on the Draft Delegated Regulation amending the Climate Delegated Act (EU) 2021/2139. PVO welcomes the Commissions objective of en-hancing the usability and practical applicability of the Climate Delegated Act.

A2A welcomes the European Commission's initiative to review the Climate Delegated Act and supports the effort to improve the usability and coherence of the EU Taxonomy as a key tool for directing capital towards sustainable investments.

The European Geothermal Energy Council (EGEC) welcomes the European Commissions initiative to review the Climate Delegated Act of the EU Taxonomy legislation, especially its proposal to remove the LCA and emission thresholds for geothermal energy in Activity 4.6 (electricity generation from geothermal energy), Activity 4.18 (Cogeneration of heat/cool and power from geothermal energy) and Activity 4.22 (production of…

EBAA welcomes the Commissions review of the EU Taxonomy Climate Delegated Act and reiterates its call for this revision to correct the continued exclusion of general and business aviation aircraft from its scope.

ESPP welcomes the clarification of Taxonomy criteria for nutrient recycling in composting and anaerobic digestion of biowaste, but regrets that other proposed clarifications and facilitations for nutrient recycling are not taken into account.

The European Biogas Association (EBA) welcomes the Commission's efforts to improve the usability of the Taxonomy and recognises several positive changes in the draft Delegated Act published on 17 March 2026. These notably include the more practical treatment of digestate in activities 4.13, 4.20, 4.8, 5.6 and 5.7 of the Climate Delegated Act (CDA), the overall improvements to activities 2.1 and 2.5 of the…

Please find our feedback in the attached document. EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, represents the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide.

The proposed amendments to the EU Taxonomy Delegated Acts to Regulation (EU) 2021/2139 (Climate Delegated Act) and Delegated Regulation (EU) 2023/2486 (Environmental Delegated Act) represent a pragmatic and necessary step to improve the usability, clarity and practical applicability of the framework and are supported by the steel industry in Germany.

Czech Energy Association (CEA) considers the current design of the EU Taxonomy disadvantageous for nuclear energy, which plays and will continue to play a crucial role in the Czech energy mix. The Delegated Act includes nuclear energy only for a limited period and under very restrictive conditions.

The European lighting industry strongly supports the proposed changes to Section 3.5 of the Climate Delegated Act, where the subsection Technical screening criteria now explicitly includes controllable luminaires with LED-based light source for indoor lighting or architectural lighting under letter (g).

Please find below PGE Polska Grupa Energetyczna's key messages on the review of the EU Taxonomy climate delegated act. For specific comments please see the attached document. Key recommendations: The transition of gas-fired installations, including in the district heating sector, to full use of renewable or low-emission gaseous fuels by the end of 2035 requires broad access to decarbonized fuels.

Restoration of Wetlands Neova welcomes the Commissions draft proposal included in the revision of the Sustainable Finance Taxonomy Climate Delegated act, to extend the scope of the Restoration of wetlands economic activity to cover restoration of partially excavated peatlands and recognising rewetting and restoration of degraded wetlands, including activities that improve wetland functions without necessarily…

L'Afep welcomes this opportunity to comment on the Taxonomy Delegated Acts. Despite the changes proposed some technical screening criteria still lacks clarity and risks of interpretation increase the reporting burden for undertakings (e.g.: for activity 3.6, the reference to the EU labelling regulation should be explicitly mentioned as an alternative to demonstrate life-cycle GHG emissions savings).

Bureau Veritas (BV) Polska welcomes the opportunity to contribute and to provide feedback on the review of the EU Taxonomy Climate Delegated Act. With respect to Activity 3.10 and the Substantial Contribution to Climate Change Mitigation criteria, the legislation currently in force allows lifecycle greenhouse gas (GHG) emission savings to be demonstrated either in accordance with Directive (EU) 2018/2001 (RED) or by…

Dear European Commission: The Japanese Bankers Association (JBA) appreciates the opportunity to provide its comments on the draft amendments to EU Taxonomy Climate and Environmental Delegated Acts, released on 17 March 2026.

Bureau Veritas welcomes the Commission's initiative to review the EU Taxonomy Climate Delegated Act, and shares the ambition to strengthen the framework's environmental integrity while improving its practical workability for economic operators and third-party verifiers alike.

The ICCT appreciates the opportunity to provide input through this public consultation. We strongly support the Taxonomy's role as a cornerstone of the EU's sustainable finance framework and recognize its importance in directing capital toward environmentally sustainable economic activities.

Veolia welcomes the Commissions initiative to review the EU taxonomy climate delegated act, and our company shares the ambition to reduce the burden and the administrative costs associated with reporting obligations derived from EU rules, while not changing course with the direction of travel as set out in the Green Deal. You will find our contribution attached.

Italgas welcomes the EC proposal to review the EU Taxonomy climate delegated act to update and simplify the technical screening criteria for determining whether an economic activity can qualify as environmentally sustainable.

Jernkontoret, the Swedish iron and steel producers association, provides feedback on the draft Climate Delegated Act. AA. Regarding Annex I (Climate change mitigation) Section 3.9 on the manufacture of iron and steel, we welcome the addition of a criterion 1(c) bringing life-cycle perspective to the activities, and the ambition of point 3 to address practical difficulties in reporting economic data at the level of…

EEM NL Hub has been analysing Section 7 of the Taxonomy since its start. We have been advocating a simplification of the TSC to create a more workable version of the EUT, one that is aligned with reality and criteria that can be applied in financial products that reward homeowners for energy efficiency renovations.

As the German Demolition Association (Deutscher Abbruchverband (DA) e.V.), Germany’s leading business association for the demolition and recycling sector and Europe’s largest national association for this sector, we welcome in principle the revision of the Taxonomy criteria.

Filed in German · English published by the European Commission

WWF European Policy Office welcomes the opportunity to respond to this consultation on the review of the EU Taxonomy technical screening criteria. We support the EU Taxonomy as a cornerstone of the EU sustainable finance framework and recognise the Commission's efforts to update the criteria across all three taxonomy delegated acts.

The European Public Real Estate Association (EPRA) represents the listed real estate sector in Europe, among which more than 270 (companies, investors, and their suppliers) and over 930 billion EUR of real estate assets (European companies only) and 95% of the market capitalisation of the FTSE EPRA Nareit Europe Index including Real Estate Investment Trusts (REITs) which are companies that own, develop and trade…

Centrica is supportive of the efforts to simplify the technical screening criteria (TSC) for determining whether economic activities meet the Do No Significant Harm (DNSH) requirements for both climate change mitigation and adaptation, and we are broadly supportive of the proposed amendments.

Please find attached the contribution of Dassault Aviation on the draft Delegated Regulation amending Delegated Regulation (EU) 2021/2139 as regards improving the usability of the technical screening criteria. I have the honour to be, Sir/Madam, yours faithfully,

Filed in French · English published by the European Commission

TAP, the European section of the Southern Gas Corridor, welcomes the opportunity to contribute within the ongoing call for evidence on the revision of the Delegated Regulation amending the EU Taxonomy Climate Delegated Act and acknowledges the European Commissions efforts to enhance the frameworks usability and effectiveness.

The EU Taxonomy is a central instrument to guide sustainable investment and to define environmentally sustainable economic activities. The ongoing review of the Climate and Environmental Delegated Acts is therefore an important opportunity to further enhance the frameworks clarity, coherence and usability.

IOGP Europe welcomes the European Commissions draft Delegated Act (DA) amending the Climate Delegated Act and supports its objective of ensuring that the Technical Screening Criteria (TSC) remain clear, coherent and workable in practice while preserving their environmental integrity.

ePURE the European Renewable Ethanol Association supports the objective of the EU Taxonomy Regulation to guide financial flows towards sustainable growth and accelerate the transition to a climate-neutral economy.

European Aluminium, on behalf of the European Aluminium value chain, welcomes the opportunity to provide feedback on the draft delegated acts. The attached paper presents our views and recommendations, which we kindly invite you to take into consideration. We are happy to further discuss and remain available to provide additional information.

European Metals, the European non-ferrous metals industry association, supports the objectives of EU Taxonomy Regulation EU/2020/852 to channel investments into sustainable economic activities, as well as the proposed amendments to the Climate and Environmental delegation acts which aim to improve the usability and implementation of the existing criteria.

The revision of the EU Taxonomy Climate Delegated Acts with the aim of cutting red tape and reducing the complexity of the assessment criteria is in principle to be welcomed. However, in the construction sector (Section 7), some reinforcements are foreseen, such as on GWP identification obligations (GWP: Global Warming Potential), air tightness testing and waste recovery.

Filed in German · English published by the European Commission

La Poste welcomed the work on revising the Taxonomy delegated acts and the fact that some of the requests for revision and simplification had been taken into account. On the basis of the proposed revisions, it would like to provide additional feedback based on its experience of several years in the field of taxonomy reporting.

Filed in French · English published by the European Commission

The requirements regarding cement are OK. The requirements regarding steel Annex I Section 3.9, Technical screening criteria, point 1 (a) (vi) should be added the following: Electric Arc Furnace (EAF) carbon steel (including DRI technology) = 0,209.

The European Biodiesel Board (EBB) reiterates the points raised during the consultation on the call for evidence on the revision of the Climate Delegated Act (CDA), as the sectors concerns have not been addressed (or very marginally) in the draft Delegated Regulation (DR).

Dear Sir or Madam, Please find attached a contribution from Assarmatori, the Italian Shipowners Association, to the consultation on the review of the EU Taxonomy Climate Delegated Act, with particular regard to the technical screening criteria relevant to the maritime sector. We welcome the opportunity to submit this contribution and look forward to continuing our engagement with the Commission on this matter.

ASECAP welcomes the European Commissions initiative to revise the EU Taxonomy framework, viewing it as a key opportunity to address practical challenges identified since its implementation. These include the complexity of technical screening criteria, inconsistencies between legal provisions and guidance, and resulting difficulties in usability, legal certainty, and market uptake.

When introduced the EU taxonomy was meant to help guide investments towards environmentally sustainable economic activities, creating a competitive edge for companies able to meet the set criteria as a key incentive. The aim was also to create an actual taxonomy of economic activities, making it possible to compare how companies perform from a sustainability perspective with a great level of objectivity.

In the attached document, the Belgian Green Building Council (BGBC) provides its detailed, point-by-point feedback in response to the European Commissions public consultation on the draft EU Taxonomy Delegated Act (April 2026).

ASECAP welcomes the European Commissions initiative to revise the EU Taxonomy framework, viewing it as a key opportunity to address practical challenges identified since its implementation. These include the complexity of technical screening criteria, inconsistencies between legal provisions and guidance, and resulting difficulties in usability, legal certainty, and market uptake.

Executive Summary CEIR welcomes the revision of the EU Taxonomy, the key framework for sustainable investment. This paper provides input to the European Commissions public consultations on the review of the Climate and Environmental Delegated Acts. The taps and valves industry provides enabling technologies that support water efficiency, energy performance, climate resilience and circularity in buildings.

The Lithuanian Green Finance Institute, a competence centre operating within the National Development Bank ILTE, welcomes the long-awaited proposals to update the technical screening criteria. Please find enclosed our comments and suggestions regarding the draft Climate Delegated Act.

Uniper SE greatly appreciates the opportunity to comment on the European Commissions (EC) Proposal for amending Delegated Regulation (EU) 2021/2139 as regards enhancing the usability of the Technical Screening Criteria (TSC). Please find our full reply attached. Best regards, [name removed], on behalf of Uniper SE

EurEau, the European Association of Water Services, welcomes the opportunity to share its views, concerns and suggestions on proposed amendments to the Climate Delegated Regulation to the Taxonomy Regulation, particularly to those addressing water related activities.

Bioenergy Europe welcomes the continued recognition of bioenergy in the Draft Climate Delegated Act of the Taxonomy Regulation and supports the European Commissions efforts to improve clarity and coherence with existing EU legislation.

The purpose of the current consultation is to make the EU Taxonomy simpler, clearer and easier to apply, while improving transparency and facilitating access to green finance. EEW welcomes this re-view as an important opportunity to address current gaps in the framework and to better recognise Waste-to-Energy as an essential and, in the foreseeable future, unavoidable component of the circu-lar economy and the waste…

New construction: The application of the SCC to buildings larger than 1000m² would result in a significantly larger number of residential buildings falling within scope. Additionally, all properties should immediately align with the ZEB standard and be subject to a GWP analysis, massively restricting applicability.

The Nordic Family Forestry Alliance (NSF) welcomes the opportunity to provide feedback on the proposed revision of the technical screening criteria under the EU Taxonomy. In our feedback, we will focus on forest management. Nordic forest owners do not use the Taxonomy criteria due to its complexity and lack of knowledge on the added value it would bring.

We, the Global Nature Fund and the Tropical Forest Foundation OroVerde, appreciate the opportunity to provide our comments on the current draft of the EU Taxonomy and thank you for taking time to consider these. In the attached document, we list aspects where we observe a weakening of the requirements, which in our view leads to a reduced level of protection for the forests, the biodiversity and valuable ecosystems.

VR Group welcomes the opportunity to provide feedback on the review of the EU Taxonomy Climate and Environmental Delegated Acts. The attached comments are based on VR Groups practical experience with EU Taxonomy reporting for passenger transport and rail logistics since 2022.

This document sets out the comments of Magnon Green Energy on the European Commissions Draft Delegated Regulation amending Delegated Regulation (EU) 2021/2139, which establishes the Technical Screening Criteria (TSC) and related sustainability requirements under the EU Taxonomy framework.

Support for proposals under Activity 3.2 and 3.10 As an investor specialized in low-carbon hydrogen, managing only Article 9 SFDR funds and using the EU Taxonomy to demonstrate the attainment of our sustainable investment objective (climate change mitigation) we sincerely appreciate the draft proposals to amend the technical screening criteria for Activities 3.2 (Manufacture of equipment for the production and use…

This document sets out the comments of Ence Energía y Celulosa on the European Commissions Draft Delegated Regulation amending Delegated Regulation (EU) 2021/2139, which establishes the Technical Screening Criteria (TSC) and related sustainability requirements under the EU Taxonomy framework.

VCI, the German Chemical Industry Association, supports the European Commission's efforts to reduce burdens and simplify processes and welcomes the European Commissions draft of the EU Taxonomy Climate and Environmental Delegated Acts technical screening criteria (TSC).

We welcome the Commissions objective to enhance the usability of the EU Taxonomy technical screening criteria and to align them with updated legislation and technological developments. However, the current drafting of proposed Annex I section 3.18 appears to recognise repair and maintenance for M/N vehicles as a substantial contribution to climate change mitigation only when those vehicles have zero specific CO…

Onesto is a Belgian social mortgage lender providing home purchase and renovation loans exclusively to modest-income households in the Flemish Region. Our clients typically purchase older, poorly-performing properties and renovate them progressively.

LASPIM supports the simplification of the European Commission and in particular the inclusion in Activity 7.7 of a criterion enabling building managers to valorise energy renovation measures. However, this proposal gives rise to misunderstandings and requires some clarification.

Filed in French · English published by the European Commission

SEOPAN, the Spanish Association of Infrastructure Builders and Concessionaires, welcomes the consultation launched by the European Commission on the review of the draft amendments to the Climate Taxonomy and Environmental Taxonomy Delegated Acts in order to contribute to a clearer and more consistent application of the Taxonomy and submits the comments set out below.

Filed in Spanish · English published by the European Commission

Nuclear energy is neither green, nor renewable or sustainable. It is not compatible with the Do No Significant Harm principle. Nuclear power can never be the basis for renewable energies; on the contrary, it is their competitor! The reasons for this are known. Nuclear power is dangerous and uneconomic.

Filed in German · English published by the European Commission

To the European Commission, Directorate-General for Financial Stability, Financial Services and Capital Markets Union, Natus Capital SLU is a Spanish advisory and investment firm specialising in sustainable finance, climate risk management, and transition finance strategy.

To the European Commission, Directorate-General for Financial Stability, Financial Services and Capital Markets Union, Natus Capital SLU is a Spanish advisory and investment firm specialising in sustainable finance, climate risk management, and transition finance strategy.

European Aluminium welcomes the possibility to provide input to the review of the EU Taxonomy criteria. Detailed comments and suggestions related to windows and curtain walling are provded here below. Windows and curtain walling in climate delegated act Mitigation, amendment to Section 3.5 Issue: While a step forward has been made by considering transparent curtain walls as widows, still climate differentiation and…

NaTran is the leading gas transmission system operator in France and the second largest in Europe. Together, we enable an energy future that is safe, affordable and climate neutral is the corporate purpose adopted by NaTran in October 2020. In line with French and European objectives to achieve carbon neutrality by 2050, NaTran is committed to the development of renewable and low-carbon gases.

Rolls-Royce develops and delivers complex power and propulsion solutions for safety-critical applications in the air, at sea and on land. Our products and service packages enable our customers to connect and protect people, societies, cultures, and economies together, and they meet the growing need for power generation across multiple industries.

The International Union of Property Owners (UIPI), as the largest European association representing individual homeowners, co-owners and private landlords, welcomes the European Commission's call for feedback on the Delegated Regulation amending Delegated Regulation (EU) 2021/2139 as regards enhancing the usability of the technical screening criteria (review of the EU taxonomy climate delegated act).

The ENGAGE Consortium deems positive the acknowledgement in recital 33 of the draft Act the fact that the technical screening criteria for construction and real estate activities should be revised to align those criteria with the evolution in Union law, and in particular, the EPBD. 1.

Mobivia, the European leader in automotive maintenance and repair (Norauto, Midas, ATU, etc.), provided feedback on the EU Taxonomy Climate Delegated Act, advocating for the circular economy's recognition in the green transition. The group, which pursues carbon neutrality by 2050 through measures like tyre retreading, battery reconditioning, and 25+ recycling channels, proposed five key recommendations: 1.

At present, French banks do not have any renovation loans that comply with the taxonomy. The overwhelming majority of their Green Asset Ratio (which is very modest, ranging from 0.8% to 5.9%) is generated by investment in new-build residential properties.

The Union of Agricultural Producers and Forest Owners (MTK) want to thank for the opportunity to comment the revision regarding the technical screening criteria on the EU taxonomy climate delegated act. MTK has previously emphasized in the preparation of taxonomy criteria the importance of criteria being encouraging, practically applicable, and accessible.

SANOFI Réponse à la consultation publique de la Commission européenne Révision des critères techniques de la Taxonomie européenne (Actes délégués Climat et Environnement) Sanofi accueille favorablement la décision de la Commission européenne de supprimer les activités pharmaceutiques 1.1 Fabrication de substances actives et 1.2 Fabrication de médicaments du périmètre de l'objectif Pollution.

The European Commissions ongoing review of the taxonomy legislation marks a pivotal moment for the future assessment of sustainable energy generation in Europe. Now is the time when key decisions are being made decisions that will determine whether climate-friendly technologies actually receive the regulatory support they need to expand. The draft proposals present both significant progress and remaining hurdles.

FEDIOL reiterates the need for policy coherence between the Renewable Energy Directive (RED), which recognises food and feed crops complying with the RED sustainability criteria as contributing to the EUs transport decarbonisation goals, and the EU Taxonomy Climate Delegated Act, which explicitly excludes food-and feed crops for the manufacture of biofuels for use in transport from counting as a sustainable…

Summary of our key comments (also see attached file) We have no objections to the proposed amendments where no specific comments are provided below. For activity 7.1, we highlight the lack of robust reference data for life-cycle GWP calculations and request clarification of the purpose and scope of on demand disclosure.

1. Recognition of biomethane as biomass derived fuel Where applicable in the descriptions of several activities we propose to change the following wording: bioliquids, solid biomass fuels or biogas to: bioliquids, solid biomass fuels or biogas, including biomethane.

BVI supports the EU Commissions initiative to update and simplify the technical screening criteria under the EU Taxonomy. With regard to real estate activities, we welcome the improved alignment between the EU Taxonomy criteria and the Energy Performance of Buildings Directive (EPBD).

ASFINAG welcomes the European Commissions initiative to review the EU Taxonomy framework under the EU Taxonomy Regulation and takes the opportunity to submit comments regarding the revision of the technical screening criteria for CCM.

Section 4.14 Transmission and distribution networks for renewable and low-carbon gases The proposed amendments to Section 4.14 raise significant concerns for investments in energy infrastructure. The revised wording would restrict eligibility solely to the transport of hydrogen.

At this stage, the European taxonomy treats biomass in an aggregated and indirect manner, by stoning only through the forms of denergy from which it is possible to produce, namely electricity, heat or cooling. This approach, which focuses on end uses, does not explicitly recognise certain forms of biomass stripping such as solid biofuel, in particular wood pellets.

Filed in French · English published by the European Commission

UPSI-BVS is the leading professional association representing real estate developers and investors in Belgium. The Real Estate sector reaffirms its ambition to increase EU Taxonomy alignment and highlights the need for clarity and consistency between financial and real estate stakeholders. To support an effective transition, UPSI-BVS emphasizes: 1.

We welcome the direction of the proposed changesespecially the effort to align evidence requirements more closely with existing guidelines, regulations, and permits in the DNSH and TSC criteria. Here are some comments for further consideration. For activity 3.10 (Manufacture of hydrogen): The current Substantial Contribution (SC) criteria do not cover hydrogen uses other than as a fuel.

The European Dredging Association (EuDA) welcomes the changes to annexes I and II on Chapter 6.16, whereby 'dredging of waterways' is an eligible activity for the EU taxonomy. This opens up the range of possibilities and solutions that can be provided by the European Dredgers: from hard (grey) to soft (green) solutions.

The Taxonomy Climate Delegated Act recognises that the manufacture of energy efficient HVACR equipment is a sustainable activity that contributes to climate change mitigation. However, many HVACR products do not have Substantial Contribution Criteria because not covered by an EU Energy Labelling measure.

Hansgrohe welcomes the opportunity to comment on the EU Taxonomy's draft revised Climate and Environmental Delegated Acts. As a leading manufacturer of water- and energy-efficient sanitary tapware, we view the EU Taxonomy as an important driver of sustainable innovation and market transformation. We acknowledge, however, that certain aspects of the EU Taxonomy remain complex.

Embuild is the main professional federation representing the construction sector in Belgium. It brings together more than 16.000 companies active across building, civil engineering, and specialised construction activities. Hereunder are Embuild's key messages: 1. The delegated act anticipates European requirements that have not yet been transposed into national law.

EVIA presents the following recommendations for (1) residential ventilation units and (2) non-residential ventilation units. 1) EVIA welcomes the amendment to Annex I section 3.5 for ventilation systems which refers to the "highest two significantly populated classes of energy efficiency", as EVIA recommended.

Nordic Ecolabellinghighlightsa Report only once approach whendemonstratingTaxonomy compliance. This wouldboost competitivenessas it would make it easier for European companies tooperateattheEuropean market. We thereforesuggest thatalignment with the Taxonomy can be verified by an officially recognized ISO 14024 type I Ecolabel certificate, such as EU Ecolabel and Nordic Swan Ecolabel.This would also be in line with…

Brv (Bundesverband Reifenhandel und Vulkaniseur-Handwerk e.V.), representing the independent German retreading industry in Germany, welcomes the planned adjustments related to retreaded tyres. In particular, the clarification that retreaded tyres are exempted from the required requirements if they are not (yet) covered by Regulation (EU) 2020/740 and are not registered in the EPREL database finally provides the…

Filed in German · English published by the European Commission

BIPAVER (Bureau International Permanent des Associations de Vendeurs et Rechapeurs de Pneumatiques), the association representing the independent European Retreading Industry, welcome the proposed amendments regarding retreaded tyres.

This submission highlights the structural misalignment between the current project-based compliance approach of the EU Taxonomy and the characteristics of industrialized modular construction (MMC). We respectfully propose the consideration of a framework that enables system-level certification and production-based verification pathways, reflecting the standardized and repeatable nature of such construction systems.