EU taxonomy - Review of the environmental delegated act

MedTech Europe, the European association of medical technology manufacturers, including medical devices, diagnostics and digital health, welcomes the possibility to comment on the draft delegated regulation amending Delegated Regulation (EU) 2023/2486 as regards enhancing the usability of the technical screening criteria. We acknowledge the efforts of the European Commission to simplify the taxonomy.

The Programme for the Endorsement of Forest Certification (PEFC) welcomes the opportunity to contribute to the European Commissions review of the EU Taxonomy Environmental Delegated Act, aimed at updating and simplifying the technical screening criteria. The current draft texts introduce a number of welcome improvements, in particular efforts to enhance usability and streamline assessment requirements.

Legnica, 14 April 2026 ZPPM/21S/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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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 Environmental 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.

The current taxonomy settings, as well as the proposed amendments as of March 2026, disadvantage natural gas sources and infrastructure, which will remain crucial for the Czech Republics energy transition and for ensuring security of electricity and heat supply.

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.

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) 2023/2486 as regards enhancing the…

Opportunity Green welcomes the European Commissions's initiative to clarify the Taxonomy technical screening criteria and the opportunity to respond to this consultation on the draft TSCs. We have included our response in the attached document. Thank you for considering our evidence. We would welcome the opportunity to further support the Commission on this matter.

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.

EuroCommerce, representing European retailers and wholesalers, welcomes the opportunity to provide feedback regarding the consultation on the review of the EU taxonomy environmental 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.

EuropaBio welcomes the revision of the EU Taxonomy Delegated Acts as a key opportunity to strengthen the bioeconomy's role in achieving EU environmental objectives. EuropaBio supports completing an inclusive approach to feedstocks eligible for sustainable finance that ensures predictable access to sustainably sourced biomass across the entire bioeconomy, while appropriately recognising the specificities of biotech…

Waga Energy welcomes the European Commissions review of the EU Taxonomy Climate Delegated Act and the objective of improving clarity, usability and policy coherence. However, the current formulation of Article 5.10 (Landfill gas capture and utilisation) risks excluding high-impact methane abatement projects and creating inconsistencies with existing EU frameworks, notably the Renewable Energy Directive (RED II and…

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.

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) 2023/2486 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.

AMICE welcomes the European Commissions initiative to review the technical screening criteria (TSC) under the Climate and Environmental Delegated Acts and supports the overarching objective of simplifying the EU Taxonomy (EUT) framework, improving clarity of compliance pathways and enhancing its overall usability and proportionality.

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…

SEFA welcomes the opportunity to provide feedback on the review of the Taxonomy climate delegated act and mainly the technical screening criteria (TSC) for building renovation activities. SEFA has consistently engaged in previous consultations on the Taxonomy framework and has repeatedly emphasised two critical issues for EU building renovation investment that remain insufficiently addressed in the draft proposal: -…

We are a leading global manufacturer and supplier of steel pipe products and related services for the worlds energy industry and other industrial applications. Our manufacturing system integrates steelmaking, pipe rolling and forming, heat treatment, threading and finishing across 17 countries.

European Entrepreneurs CEA-PME welcomes the European Commissions initiative to revise the Environmental Delegated Act and its efforts to improve the usability of the EU Taxonomy, however, from an SME perspective, the current draft does not go far enough to make the framework fully workable in practice.

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 environmental 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…

We welcome the amendments to economic activity 2.4 Treatment of hazardous waste, notably the removal of the exclusion for metals and metal compounds and the explicit reference to NACE code C24.4. These changes appropriately recognise the strategic role of metals recycling in achieving EU circular economy objectives and securing the supply of secondary raw materials.

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.

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 environmental 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.

Climate Strategy (CS) welcomes the chance to contribute to the initiative to review the EU taxonomy climate delegated act to update and simplify the technical screening criteria. The CS response focuses on item 7.2.

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…

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.

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.

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.

International Airlines Group (IAG), one of Europes leading airline groups and continues to demonstrate leadership through investments in sustainable aviation fuel (SAF), fleet modernisation, operational efficiency, and innovation partnerships, alongside active engagement in EU climate and sustainable finance policy processes.

The current Technical Screening Criteria for aviation-related activities need updating to reflect the rapid development of innovative, low-emission propulsion technologies. Furthermore, to enhance the competitiveness of the European Union's aviation sector and support strategic autonomy, the revised criteria should explicitly recognise and prioritise European-developed, high-performance technologies, specifically in…

On behalf of the European Federation of Pharmaceutical Industries and Associations (EFPIA), we welcome the opportunity to contribute to the call for feedback on the review of the EU Taxonomy Environmental Delegated Act.

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.

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.

ANCE welcomes the efforts undertaken in the revision of the Climate and Environmental Delegated Acts under the EU Taxonomy, aimed at updating and simplifying the related technical screening criteria. It is positively noted that the European Union has acknowledged the challenges that have emerged during the implementation phase, whereby certain criteria have proven difficult to apply and, in some cases, have…

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.

Snam, European leader in energy infrastructure, welcomes the opportunity to contribute to the 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 HDH is grateful for the possibility of participating in this process. The EU taxonomy for sustainable activities has a strategic role to target investments towards solutions that support the EU’s 2030 climate and energy targets, advance the European Green Deal and strengthen Europe’s sustainable competitiveness.

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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, 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.

VDMA supports the objectives of the Environmental Delegated Acts but identifies substantial weaknesses in both the Circular Economy criteria (Annex II) and the DNSH requirements (Annex IV, Appendix C) that significantly limit practical applicability, legal certainty, and investment incentives for manufacturing companies.

The EU Taxonomy is as a foundational element of the EUs sustainable finance architecture and we acknowledge the Commissions ongoing efforts, aiming to enhance clarity, streamline assessment procedures, and improve consistency, without compromising environmental ambitions.

Landsvirkjun, the national power company of Iceland, welcomes the opportunity to provide feedback on the Commissions review of the EU Taxonomy Climate Delegated Act. Landsvirkjun supports the aim of the update to simplify the technical screening criteria. However, it is vital that consistency in the criteria is kept so work already done to fulfil the current criteria is not lost.

Bellona Europa welcomes the revision of the screening criteria under the EU Taxonomy and the opportunity to provide feedback. While we recognise the EU Taxonomy as key component of the EU sustainable finance framework, there are still two concerns about the changes proposed by the Commission, notwithstanding the effort in updating the criteria across all delegated acts.

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.

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.

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.

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.

This response is limited in scope to the EU Taxonomy activity 4.5 Electricity generation from hydropower. Swedenergy welcomes the Commissions intention to simplify the Do No Significant Harm (DNSH) criteria for hydropower and to better align them with the safeguards of the Water Framework Directive (WFD), as stated in recital 24.

ATEDY welcomes the opportunity to contribute to the consultation on the draft act reviewing the EU Taxonomy environmental delegated act. As a representative of the spanish gypsum industry, we wish to highlight several technical considerations that, in our view, are essential to ensure that the criteria are realistic, workable, and aligned with the actual conditions of the market and the regulatory framework…

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.

We appreciate the efforts of the European Commission to simplify the taxonomy and welcome several of the proposed changes. However, we are still concerned that some of the criteria in this draft delegated act will exclude entire sub-sectors of electric and electronic equipment, including and especially manufacture of electro-medical equipment (medical devices), from alignment with the EU Taxonomy.

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.

As EUPAVE, the representative organization for the concrete paving industry in Europe, we insist that some of the technical screening criteria dealing with the use of concrete for roads should be corrected improved. These former comments, already expressed in 2025n have not been taken into account in the amendments for the revised version of Annex II.

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.

Liquid Gas Europe (LGE) welcomes the opportunity to contribute to the European Commissions Call for Evidence on the review of the EU Taxonomy Climate and Environmental Delegated Acts. This review is timely, as the implementation of the Taxonomy has highlighted challenges related to complexity, usability, and consistency with existing EU legislation, particularly regarding technical screening criteria (TSC) and Do No…

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.

We welcome the initiative to possible revisions to the criteria of the EU Taxonomy, 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. A detailed opinion cand be found in the annexed document.

Plastics Recyclers Europe (PRE) would like to provide comments on Annex II, category Substantial contribution to the transition to a circular economy. Plastics Recyclers Europe (PRE) is an organisation representing the voice of European plastics recyclers, who reprocess plastic waste into high-quality material destined for the production of new articles.

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.

Dutch Green Building Council (DGBC) is primarily active in the Dutch construction industry. Therefore, the feedback on the revised version of the Climate Delegated Act (EU Taxonomy) focuses on paragraphs 7.1 through 7.7. General feedback DGBC The revised Climate Delegated Act includes additional references to EPBD IV, which is appreciated. However, for several measures, further references to EPBD IV could be added.

Air FranceKLM (AFKL) 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.

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.

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.

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.

We recognise the EU Taxonomy as a foundational element of the EUs sustainable finance architecture and acknowledge the Commissions ongoing efforts, aiming to enhance clarity, streamline assessment procedures, and improve internal consistency across environmental objectives and sectors, without compromising the level of environmental ambition.

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.

1. The proposal clearly states in recitals 18, 20 and 21 that it will be possible to use valid permits (IPPC) or the EIA process to demonstrate compliance with the DNSH criteria (water, pollution, biodiversity) when demonstrating DNSH with existing permits.

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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.

This draft amendment to Delegated Act (EU) 2021/2486 is an important and necessary step to improve the practical applicability of the EU Taxonomy. Businesses urgently need tangible and practical simplifications. The following feedback is intended to provide further suggestions for improvements to simplify the EU Taxonomy Regulation in practice.

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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).

INTRODUCTION 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).

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.

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.

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…

Société Générale welcomes the opportunity to respond to the European Commissions consultation and is supportive of the answer done at EBF level. SG supports a pragmatic and proportional approach for EU taxonomy alignment assessment allowing the use of proxies or estimates considering data availability and complexity of the analysis.

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 Commissions effort to improve the usability of the EU Taxonomy technical screening criteria under the Environmental Delegated Act. Clearer and more workable criteria can strengthen the effectiveness of the framework for both reporting entities and end-users of sustainability disclosures.

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…

Ladies and gentlemen, Thank you very much for the opportunity to participate in the public consultation on the revision of the EU Taxonomy criteria. The initiated revision of the technical screening criteria of the EU Taxonomy is to be warmly welcomed, especially in view of the objective of simplification and better practical applicability.

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Westenergy Ltd is a circular economy company owned by seven municipal waste management companies operating in Western Finland. Westenergys waste-to-energy plant located in the Vaasa region takes care of the residual waste management of more than 700 000 people by refining non-recyclable, source separated municipal waste into district heating, electricity and recovered materials.

Our main asks are the following: (1) Clarify the Scope: Explicitly state that manufacturers of intermediate components and industrial consumables are not covered by the Taxonomy, and ensure that sharing a NACE code with an eligible activity does not create a presumption of eligibility.

Veolia welcomes the European Commission's initiative to review the EU Taxonomy Environmental Delegated Act. We share the goal of reducing the reporting burden and associated administrative costs stemming from EU regulations, while fully supporting the overall direction of the Green Deal.

As Germanys leading trade and business association for the demolition and recycling industry, and the largest national association of its kind in Europe, the German Demolition Association (DA) e.V. generally welcomes the review of the taxonomy criteria.

FESI welcomes the Commissions intention to revise the Taxonomy Climate and Environmental Delegated Acts to simplify the technical screening criteria. However, further targeted changes would still be needed to make Taxonomy usable and proportionate for our sector.

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.

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 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.

ACI EUROPE welcomes the opportunity to provide feedback regarding Annex I to the draft Commission Delegated Regulation amending Delegated Regulation (EU) 2021/2139. Enclosed is ACI EUROPEs position, which focuses on three key recommendations.

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). VCI considers the withdrawal of the activities PPC 1.1 and 1.2 from the Environmental Delegated Act as a constructive step.

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.

Renault Group welcomes the Commission's aim to improve the usability of the Taxonomy. In this regard, we would like to point out the major difficulties encountered by the entire automotive industry when it comes to complying with the DNSH Pollution criterion relating to tyres, for several activities including CCM 6.5 and EC 5.4.

CEI-Bois has long recognised the strategic role of the EU Taxonomy for Sustainable Activities in directing investment towards solutions that support the EUs 2030 climate and energy goals, advance the European Green Deal, and strengthen Europes sustainable competitiveness.

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).

EUROFER members welcome the opportunity to contribute to the consultation to review the EU taxonomy environmental delegated act to update and simplify the technical screening criteria. We provided suggestions to further strengthen and support the effective implementation of Annex I to the Commission Delegated Regulation - amending Delegated Regulation (EU) 2023/2486 as regards enhancing the usability of the…

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. LKQ supports the proposed amendments to Annex II section 5.1 (repair, maintenance, refurbishment and remanufacturing), 5.2 (sale of spare parts), 5.3 (preparation for re-use of end-of-life products and product components) and 5.4…

Medicines for Europe, representing generic, biosimilar, and value-added medicines in Europe, welcomes the opportunity to contribute to the call for feedback on the review of the EU Taxonomy Environmental Delegated Act. Please find our submission attached.

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.

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Sanofi Response to the European Commission’s Public Consultation Review of the Technical Criteria of the European Taxonomy (Climate and Environment Delegated Acts) Sanofi welcomes the European Commission’s decision to remove pharmaceutical activities 1.1 Manufacture of active substances and 1.2 Manufacture of medicinal products from the scope of the Pollution objective.

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Statement by the Federal Association of German Leasing Companies on the European Commissions draft amendment to Delegated Regulation (EU) 2023/2486 regarding the improvement of the applicability of the technical assessment criteria We would like to thank you for the opportunity to comment on the European Commission's draft amendment to Delegated Regulation (EU) 2023/2486 regarding the improvement of the…

We are pleased to provide this feedback on the review of the EU Taxonomy Environmental Delegated Act. This contribution is the result of a joint effort by a small group of Master of Science students - details within the Annex 1 - in Accounting, Governance and Sustainability at the University of Bergamo, developed within the Accounting and Reporting for Sustainability module, which I convene.

Aqua Metering welcomes the opportunity to provide feedback on the draft Environmental Delegated Act under the EU Taxonomy framework. Aqua Metering represents European manufacturers of water metering technologies and systems.

ADR welcomes the continued evolution of the EU Taxonomy and the proposed revision of the Climate Delegated Act, recognising its objective to improve clarity, consistency and usability while preserving a high level of environmental ambition and enabling credible transition pathways for hardtoabate sectors such as aviation. A more detailed feedback can be found attached, a brief summary follows.

As already reported in our response dated of 2 May 2023 about the EU Taxonomy Environmental Delegated Act on circular economy criteria for buildings, the current technical screening criteria for the construction of new buildings do not adequately support the transition to a circular economy.

Mobivia, the European leader in automotive maintenance, equipment, and repair services, has submitted key recommendations on the draft environmental delegated act updating the technical screening criteria of the EU taxonomy.

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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The Federal Association for Bioenergy (BBE) welcomes the continued recognition of bioenergy in the draft Climate Delegated Act under the Taxonomy Regulation. The CBE also supports the European Commission’s efforts to improve clarity and consistency with existing EU legislation, in particular with the revised Renewable Energy Directive (RED III).

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UPSI-BVS is the leading professional association representing real estate developers and investors in Belgium. The real estate sector reaffirms its ambition to support the objectives of the Environmental Delegated Act and highlights key areas for improvement. In particular, UPSI-BVS emphasizes: 1.

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.

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…

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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.

Hello, Thank you for this consultation and the opportunity to give my opinion as an independent circular construction expert. I strongly oppose the majority of omnibus packages that aim to simplify European regulations, including this one.

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The ICCT appreciates the opportunity to provide input through this call for evidence. 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.

PEFC, as a voluntary forest certification system, welcomes the opportunity to contribute to the call for evidence regarding the review of the EU Taxonomy Climate Delegated Act. In our view, several challenges remain in the practical implementation of the current criteria and requirements. In this context, further simplification and, importantly, clarification of the criteria would be highly beneficial.

COGEN Europe welcomes the European Commissions initiative to review the EU taxonomy climate delegated act to update and simplify the technical screening criteria For regions and countries that have already made the switch from oil and coal to natural gas, CHP is an key enabler for transitioning towards a higher efficiency and more resilient energy system, as all energy carriers, including gas, gradually decarbonise.

As an organization that focuses on promoting and identifying energy transition solutions Noé21 welcomes the opportunity to comment on this call for evidence for Ref. Ares(2025)9618554 - 07/11/2025. We consider that the Taxonomy Delegated Acts have weakened the EUs Sustainable Finance framework while creating important obstacles to an agenda of accelerated expansion of sustainable technologies.

Subject: Comment on JRC125953 methodological and evidentiary shortcomings I would like to submit the following comments regarding the report Technical Assessment of Nuclear Energy with Respect to the Do No Significant Harm criteria of the EU Taxonomy (JRC125953). 1.

The DKB welcomes the call for evidence to revise Delegated Regulations (EU) 2021/2139 and (EU) 2023/2486. The DNSH and TSC require further clarification. This must operationalise the EU Taxonomy's environmental and climate objectives instead of watering them down.

ELO welcomes the opportunity to comment on the technical screening criteria of the EU Taxonomy Climate Delegated Act, as an effort to make it a more effective and accessible tool for boosting decarbonisation, the bioeconomy, and attracting investments for sustainable forest management.

This response exposes two critical flaws in the EU Taxonomys application to mortgages and renovation loans: 75% of banks green asset ratios consist of mortgages associated with already highly energy efficient properties; while only loans for renovations only represent 0,05%. This makes green asset ratios a highly unreliable indicator of a bank's sustainability efforts.

Key messages 1. Exempt retail exposures from DNSH (Do No Significant Harm) and MS (Minimum Safeguards) assessment While the revision of the CSRD will exempt most EU companies from Taxonomy reporting, banks will still be required to collect EU Taxonomy data from retail clients (e.g. mortgages, energy-efficient renovations, car loans.

Key messages 1. Exempt retail exposures from DNSH (Do No Significant Harm) and MS (Minimum Safeguards) assessment While the revision of the CSRD will exempt most EU companies from Taxonomy reporting, banks will still be required to collect EU Taxonomy data from retail clients (e.g. mortgages, energy-efficient renovations, car loans.

ECOS welcomes the opportunity to provide feedback to the European Commission on existing taxonomy criteria, in a view to foster their continuous improvement. The attachment to this response draws on the CSO and academic review published at https://science-based-taxo.org/.

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

Bioenergy Association of Finland welcomes the opportunity to contribute to the simplification of the Taxonomy technical screening criteria. Sustainable bioenergy plays a key role in the overall bioeconomy by valorising underutilised feedstock along the value chain and supplying reliable, around-the-clock energy.

Of course, we at the Anti-nuclear Committee are particularly critical of the inclusion of nuclear power (which has only gradually come to light) in the taxonomy. First described as a bridging technology, it is trying to play an ever-increasing role with ambitions as the main player, despite a modest contribution to energy production. It is about funding.

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Thank you for the opportunity to provide input to this consultation. Please find our detailed comments attached. Below we briefly outline the key points that are essential for the development and implementation of underground hydrogen storage, particularly in depleted gas reservoirs: 1) Ensure regulatory neutrality - Taxonomy eligibility must not depend on a RAB: Taxonomy criteria should not depend on inclusion in a…

European Shipowners input to the European Commissions review of the EU taxonomy climate delegated act Executive Summary: Strategic Role of Shipping for European Security European shipping is an asset for Europe and a cornerstone of the energy, food and supply chain security of the continent. European shipping controls 35% of the global tonnage.

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.

Finnish Energy supports the Commissions aim to improve the usability and clarity of Taxonomy. Revisions must not jeopardise the Taxonomy alignment of existing plants and new investments. Revisions should simply improve the usability of Taxonomy by simplifying and clarifying the current criteria where needed. We do not support tightening existing greenhouse gas (GHG) thresholds.

The Sustainable Energy Finance Association (SEFA) welcomes the opportunity to contribute to the review of the EU Taxonomy Climate and Environmental Delegated Acts from the perspective of practitioners originating, structuring and financing renovation and small-scale clean energy projects in Europes buildings.

GE Vernova welcomes the opportunity to provide its feedback on the initiative to review the EU taxonomy climate delegated act to update and simplify the technical screening criteria. GE Vernova strongly advocates for the adoption of favorable criteria for natural gas used to generate power and Small Modular Reactors (SMR) within the EU Taxonomy to support a balanced and pragmatic approach to the energy transition.

The European Federation of Green Roof and Living Wall Associations (EFB) welcomes the opportunity to comment on the review of the EU Taxonomy Climate and Environmental Delegated Acts. As the umbrella organisation representing national green roof and living wall associations across Europe, EFB promotes building-integrated green infrastructure (green roofs, living walls and façade greening) as essential nature-based…

The Austrian Federal Economic Chamber (WKÖ) welcomes the European Commission's initiative to improve the clarity, usability, legal certainty, and cost-effectiveness of the EU Taxonomy. The criteria of the delegated acts must be revised for their practicality and, above all, their feasibility coherence between the EU Taxonomy and other legislation.

The Austrian Federal Economic Chamber (WKÖ) welcomes the European Commission's initiative to improve the clarity, usability, legal certainty, and cost-effectiveness of the EU Taxonomy. The criteria of the delegated acts must be revised for their practicality and, above all, their feasibility coherence between the EU Taxonomy and other legislation.

The EU Taxonomy has not yet delivered its intended effect for the district heating and cooling (DHC) sector. While many DHC activities are formally eligible, outdated and overly complex criteria prevent meaningful alignment and therefore restrict access to sustainable finance.

Repsol welcomes the European Commissions initiative to review the Climate and Environmental Delegated Acts under the EU Taxonomy. As representatives of the refining and chemical sector, we recognize the Taxonomys critical role in guiding sustainable finance and supporting the EUs climate objectives.

IOGP Europe welcomes the review of the Climate and Environmental Delegated Acts. We support the Commissions objective to simplify the EU Taxonomy in line with the Competitiveness Compass and the Omnibus I simplification package, and we provide evidence focused on improving clarity, legal certainty and proportionality.

The EU Taxonomy is a foundational instrument for defining clearly and consistently what constitutes a sustainable economic activity within the European Union. By establishing a common classification system, it provides essential clarity, comparability, and credibility in a highly fragmented regulatory environment.

Dear Sir/ Madam, On behalf of our organisation, I am pleased to submit our contribution to the European Commissions public consultation on the revision of the Climate Delegated Act and the Environmental Delegated Act under Regulation (EU) 2020/852.

Dear Sir/ Madam, On behalf of our organisation, I am pleased to submit our contribution to the European Commissions public consultation on the revision of the Climate Delegated Act and the Environmental Delegated Act under Regulation (EU) 2020/852.

APPLiA is supporting the European Commission Delegated Act, amending the Taxonomy disclosures, and the climate and environment, now under scrutiny. It is a step towards more straightforward, clearer and simpler reporting requirements.

As an investor committed to financing the energy transition in the EU, LBP AM strongly endorses the principle of a taxonomy framework that is transparent, proportionate, and practically applicable to the realities of clean-energy deployment.

Summary of CLIA Recommendations in light of the Call for Evidence regarding the review of the EU taxonomy environmental delegated act: - Acknowledge that the review of the technical screening criteria in the Climate Delegated Act could be a first step towards removing some of the roadblocks to financing green transition.

Statkraft would like to thank the European Commission for the opportunity to provide feedback on the EU taxonomy climate delegated act. - Simplify and streamline Hydropower requirements to Do No Significant Harm Sustainable use and protection of water and marine resources (DNSH 3) - Substantial Contribution Criteria for all renewables should be identical.

The Dutch Fund and Asset Management Association (DUFAS) welcomes the opportunity to respond to the European Commissions Call for evidence for review of the Climate and Environmental delegated acts. In our response, we outline various elements of the framework that, from a global investor perspective, would benefit from further improvement.

Eurochambres welcomes the Commissions initiative to review the climate and environmental delegated acts of the EU Taxonomy. European businesses continue to struggle with the complex and burdensome requirements of the framework, particularly the Do No Significant Harm (DNSH) elements of the technical screening criteria.

Geothermal heating and cooling projects are currently recognized as sustainable investments under the Taxonomy. However, unlike other renewable energy sources, geothermal projects must comply with a lifecycle emissions threshold of less than 100 g COe/kWh, verified by an independent third party.

Insurance Europe supports the European Commissions ambition to use the EU Taxonomy to channel investments toward transition-critical activities and to underpin the European Green Deal. However, the current framework has not demonstrated its value for the insurance sector and instead creates disproportionate complexity without delivering meaningful analytical benefits.

Summary Call for Simplification Bekaert strongly supports the objectives of the EU Taxonomy but highlights the urgent need for simplification and clarification of its technical screening criteria. Current rules are mainly designed for end-product manufacturers and create disproportionate complexity for component* and intermediate-goods* producers that enable decarbonization across multiple sectors.

A2A would like to provide feedback on the technical screening criteria related to mitigation activities 5.1, 5.2 and 5.3. Mitigation, 5.1, Construction, extension and operation of water collection, treatment and supply Specific energy consumption is very dependent on the local situation: the circumstances under which drinking water is produced differ widely from groundwater extracted from very deep aquifers to water…

Please find attached FEDENE's contribution to the consultation. FEDENE is the French representative federation for energy efficiency services and heat decarbonization, covering the entire value chain, a sector that brings together over 1,500 businesses and 50,000 employees in France.

AMICE fully shares the EU Commissions initiative to review the EU Taxonomy Climate and Environmental Delegated Acts and welcomes the opportunity to provide its feedback on the update and simplification of the technical screening criteria. Please find attached our detailed position.

Heimar, an Icelandic listed real estate company, welcomes the opportunity to give feedback to the Call for Evidence on the EU Taxonomy Climate Delegated Act with focus on Construction and Real Estate Activities in Section 7.

Eurogypsum, the European association representing gypsum product manufacturers, welcomes the Commissions intention to update and simplify the technical screening criteria set out in the Delegated Acts of the EU Taxonomy. We believe the EU Sustainable Finance Taxonomy is a key instrument to channel investments into sustainable economic activities and reward the front-runners of the green transition.

In addition to comments submitted by CEE Bankwatch Network on the climate delegated act, the following suggestions are made for improving the technical screening criteria in the environmental delegated act with respect to the circular economy goals: 1.

1. Simplification OF DNSH CRITERIA (Do NOT cause SIGNIFICATIVE PERJUICIO) IN WATER FRASTRUCTURES Identified problem: The DNSH criteria for urban waste water treatment plants (UWWTPs) require comprehensive documentation on impacts on biodiversity, receiving water quality and air emissions, duplicating requirements already covered by the Integrated Environmental Authorisation (IEP) under Directive 2010/75/EU and…

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Summary Call for Simplification Bekaert strongly supports the objectives of the EU Taxonomy but highlights the urgent need for simplification and clarification of its technical screening criteria. Current rules are mainly designed for end-product manufacturers and create disproportionate complexity for component* and intermediate-goods* producers that enable decarbonization across multiple sectors.

Ecomate, as an ESG Rating Agency that supports European SMEs and corporations in measuring and reporting their sustainability, welcomes the opportunity to contribute to the revision of the EU Taxonomy Environmental Delegated Act.

The European Insulation Manufacturers Association (EURIMA) welcomes the opportunity to contribute to the European Commission's call for evidence on: Sustainable investment review of the EU taxonomy environmental delegated act. Please find the full contribution attached.

ESWET - the European Suppliers of Waste-to-Energy Technology represents companies that have built and supplied over 95% of the Waste-to-Energy (WtE) plants in operation in Europe. Its mission is to promote technologies that safely treat non-recyclable waste while recovering valuable energy and materials, contributing to Europes climate goals, resource efficiency, and energy resilience.

The European Insulation Manufacturers Association (EURIMA) welcomes the opportunity to contribute to the European Commission's call for evidence on: Sustainable investment review of the EU taxonomy climate delegated act. Please find the full contribution attached.

Eurogypsum, the European association representing gypsum product manufacturers, welcomes the Commissions intention to update and simplify the technical screening criteria set out in the Delegated Acts of the EU Taxonomy. We believe the EU Sustainable Finance Taxonomy is a key instrument to channel investments into sustainable economic activities and reward the front-runners of the green transition.

DHL Group welcomes the European Commissions initiative to review the Climate and Environmental Delegated Acts under the EU Taxonomy Regulation. The stated objectives reducing reporting burdens, improving clarity, and ensuring proportionate rules are essential to strengthen confidence in the EUs Sustainable Finance framework.

We welcome the Commissions objective of simplifying and clarifying the EU Taxonomy Technical Screening Criteria. In particular, the DNSH and Substantial Contribution criteria for climate change adaptation require clarification if the EU intends to effectively channel capital into resilience and climate loss prevention.

DIGITALEUROPE welcomes the European Commissions initiative to comprehensively review the taxonomy technical screening criteria in the climate and environmental delegated acts. Large swathes of companies struggle with implementation of the taxonomy due to its overly complex reporting requirements and usability challenges.

Enel welcomes the European Commissions initiative to review the EU Taxonomy Delegated Acts and appreciates the opportunity to contribute to the public consultation. Our recommendations aim to including renewable energy sales as eligible under the EU Taxonomy activities to complete the renewable energy value chain.

Siemens Healthineers is a leading provider of medical technology, principally active in the areas of imaging, diagnostics, cancer care and minimally invasive therapies augmented by digital technology and artificial intelligence.

The Confederation of Danish Industry welcomes and support the efforts to improve the clarity, usability, legal certainty and cost-effectiveness of the EU Taxonomy, in particular the EU taxonomy climate ((EU) 2021/2139) & environmental ((EU) 2023/2486) delegated acts. Attached, please find our comments.

Dear Sir/Madam, please find attached the contribution of Dassault Aviation in the framework of the “EU Taxonomy Review of Climate and Environmental Delegated Acts” initiative (Ref. Ares (2025) 9618554). Under that contribution, Dassault Aviation seeks: — the inclusion of the economic activity of manufacturing business aircraft in the European green taxonomy, – the creation of a legal definition of business aviation…

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Mobivia, groupe familial européen leader de léquipement, de lentretien et de la réparation automobile (Norauto, Midas, ATU, Carter-Cash, Auto5), remercie la Commission européenne pour la consultation sur le réexamen de lacte délégué relatif au volet environnemental de la taxonomie de lUE.

Dear Mr Berrigan, dear Mr Millerot, We would like to thank you for the opportunity to participate on your Call for Evidence to improve the technical screening criteria set out in the Climate Delegated Act (Delegated Regulation (EU) 2021/2139) and in the Environmental Delegated Act (Delegated Regulation (EU) 2023/2486) to the Taxonomy Regulation (Regulation (EU) 2020/852).

The European Local Fiber Alliance (ELFA) welcomes the Commissions initiative to review and refine the technical screening criteria of the EU Taxonomy. For our sector operators of Alternative fiber networks and the digital transport infrastructure that connects every region of Europe clarity, proportionality and coherence across European legislation are essential.

BRE (the Building Research Establishment) supports the Commissions objective to reduce complexity and address implementation challenges of the EU Taxonomy. We make two points one detailed and one broader point - in terms of the criteria and delivery of the Taxonomy relating to construction and real estate activity: Firstly a detailed point in regard to the Technical Screening Criteria for S7.1 Construction of new…

DIGITALEUROPE welcomes the European Commissions initiative to comprehensively review the taxonomy technical screening criteria in the climate and environmental delegated acts. Large swathes of companies struggle with implementation of the taxonomy due to its overly complex reporting requirements and usability challenges.

Dear Mr Berrigan, dear Mr Millerot, We would like to thank you for the opportunity to participate on your Call for Evidence to improve the technical screening criteria set out in the Climate Delegated Act (Delegated Regulation (EU) 2021/2139) and in the Environmental Delegated Act (Delegated Regulation (EU) 2023/2486) to the Taxonomy Regulation (Regulation (EU) 2020/852).

Medef supports the European Commission's review of the delegated acts relating to climate and environment in the EU taxonomy, as it provides an opportunity to address challenges and resolve inconsistencies. These relate to issues at several levels, including adjusting technical selection criteria, improving definitions, clarifying compliance requirements and removing redundant or disproportionate obligations.

ASECAP welcomes the opportunity to comment on the proposed review of the Climate and Environment Delegated Acts. Current technical screening criteria do not fully reflect toll road operators activities or their contribution to decarbonizing transport, internalizing external costs (as recognized in the Eurovignette Directive 1999/62/EC), improving road safety and deploying intelligent traffic management.

TIM welcomes the European Commissions call for evidence on the Climate and Environmental Delegated Acts in order to provide feedback on the technical alignment criteria. As a telecommunications company, we are mainly concerned with respect to data centers and data-driven digital solutions.

Accountancy Europe welcomes the opportunity to provide the accountancy professions input to the European Commissions (EC) call for evidence on the EU Taxonomy Climate and Environmental Delegated Acts technical screening criteria's practical implementation, including the Do No Significant Harm (DNSH) criteria.

The ABBL (The Luxembourg Bankers' Association) appreciate the opportunity to contribute to the ongoing consultation. Please find below our submission outlining ABBL views and recommendations regarding the "Have your Say" on the EU Taxonomy - Review of Climate and Environmental Delegated Acts.

REPORTING AS AN ENABLER As a manufacturer of industrial equipment used in multiple industries, we want to report as an enabler. However, non-existing guidelines for how to evaluate alignment as an enabler prevent this.

The ABBL (The Luxembourg Bankers' Association) appreciate the opportunity to contribute to the ongoing consultation. Please find below our submission outlining ABBL views and recommendations regarding the "Have your Say" on the EU Taxonomy - Review of Climate and Environmental Delegated Acts.

Please note that this is a summary of our contribution - the full answer can be found in the annex. Insurers support the ECs ambition to use the EUT to steer investments towards transition-critical activities, but major weaknesses in the insurance KPIs mean they are not reliable investment indicators.

AGFW e. V. is the leading association for energy-efficient supply of heating, cooling and combined heat and power in Germany. We welcome the EU Commission's initiative to review the EU Taxonomy Environmental Delegated Act and the Complementary Climate Delegated Act .

Our key messages are: a) the SC and DNSH thresholds in the Taxonomy need a thorough revision, as many of them are unrealistic, unachievable in practice, and do not reflect actual performance and, b) the DNSH concept should not continue spilling over into other pieces of EU legislation (Cohesion Funds, RRF, CEEAG...), where their vague application creates unnecessary barriers and blocks otherwise strategic…

SG is supportive of a pragmatic approach for DNSH or MSS assessment that would allow the use of proxies or estimates considering data availability and complexity of the analysis in specific cases such as retail loans. Our key messages are as follows: 1.Align methodology and scope of exposure subject to alignment analysis for both Financial Institution and Corporate.

Please find attached the detailed opinion of ITAD – Interessengemeinschaft der Thermische Abfallbehandlunganlagen in Deutschland e.V. on the consultation procedure on the review of the EU Taxonomy delegated acts. In essence, ITAD recommends the following actions: We recommend the following actions: 1.

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bpostgroup welcomes the opportunity to contribute to the revision of the EU Taxonomy environmental and climate delegated acts. As a provider of postal and logistics services, bpostgroup faces following challenges in its reporting for EU Taxonomy: 1.

Water Europe (WE) welcomes the EU Commissions efforts to simplify the Taxonomy framework. However, simplification must not weaken the data foundations that enable evidence-based decision-making, financial transparency, and the mobilisation of private capital for Europes water resilience.

HEXANA welcomes the European Commissions initiative to revise the sustainable investment taxonomy. This revision represents a timely opportunity for the EU to send a strong signal of commitment toward nuclear energy, thus building confidence for various stakeholders and driving the development of low-carbon nuclear power in line with the EUs objectives.

Please, see the attached file. In short: when it comes to the technical criteria, we do not believe the main problem is unclear rules, but rather a desire to ease the demands in the WFD and the Taxonomy. As stated in our input from the hearing in 2020 (Ref.

HEXANA welcomes the European Commissions initiative to revise the sustainable investment taxonomy. This revision represents a timely opportunity for the EU to send a strong signal of commitment toward nuclear energy, thus building confidence for various stakeholders and driving the development of low-carbon nuclear power in line with the EUs objectives.

The Ellen MacArthur Foundation welcomes the EU Commissions call to review the Climate and Environmental Delegated Acts, and supports the goal of enhancing their clarity, usability, and legal certainty. At the same time, any simplification of the EU Taxonomy must preserve environmental integrity and avoid disrupting the capital flows essential to achieving the EUs circular economy, climate, and nature objectives…

The French Federation of Mechanical Engineering Industries would like to submit suggestions regarding the Technical Screening Criteria for activity 3.6 Manufacture of other low-carbon technologies. Please find attached practical implementation considerations for this activity, along with comments on potential new activities in line with the March 2025 recommendations of the EU Platform on Sustainable Finance, for…

The EACB welcomes the opportunity to provide feedback on the EU Taxonomy screening criteria, and supports the continued simplification of reporting templates and the efforts to reduce unnecessary administrative burden for financial companies. The EU Taxonomy is a key instrument in financing the green transition, yet its application has proven to be complex and administratively burdensome in many respects.

The EACB welcomes the opportunity to provide feedback on the EU Taxonomy screening criteria, and supports the continued simplification of reporting templates and the efforts to reduce unnecessary administrative burden for financial companies. The EU Taxonomy is a key instrument in financing the green transition, yet its application has proven to be complex and administratively burdensome in many respects.

The French Federation of Mechanical Engineering Industries would like to submit suggestions regarding the activity 1.2 Manufacture of electrical and electronic equipment and activity 5.1 Repair, refurbishment and remanufacturing.

BREKO highly welcomes the European Commissions initiative to review the current framework of the EU Taxonomy, more specifically the Climate and Environmental Delegated Acts, aiming to improve the clarity, usability, legal certainty and cost-effectiveness of the EU Taxonomy. Please find our feedback in the attached document.

The call for evidences aim to reduce unnecessary reporting burdens is a positive step. The revision of Delegated Regulations (EU) 2021/2139 and 2023/2486 is an opportunity to improve the Taxonomys practical use through quantifiable metrics, voluntary metrics, reduced duplication, risk assessment and simplification.

The document attached recommends aligning EU regulations on sustainable finance and building energy performance, updating definitions for sustainable investments, and clarifying the TSC and DNSH principles. It calls for harmonized EPC benchmarks, periodic review of technical criteria, and national publication of energy demand parameters to ensure consistent application and support decarbonization goals.

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 Japan Business Council in Europe (JBCE) welcomes the opportunity to submit its opinion regarding the Do No Significant Harm (DNSH) principle. We submitted our initial opinion on DNSH during the EU Taxonomy Stakeholder consultation in 2023. JBCE very much welcomes the adoption of the Delegated Act on 4th July 2025, which makes the DNSH requirement (d) align with the requirement of the RoHS Directive.

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.

BNP Paribas welcomes the opportunity to respond to the Commissions call for evidence for the review of the EU Taxonomy Climate Delegated Act. We invite the Commission to address Taxonomy implementation challenges in the following areas.

SUEZ welcomes the opportunity to contribute to the revision of the EU Taxonomy environmental and climate delegated acts. While supporting the Taxonomys ambition to guide sustainable investments, SUEZ highlights challenges that could undermine its effectiveness, including overly complex criteria, heavy administrative workload, and misalignment of criteria and technical thresholds with operational realities.

BVI welcomes the EU Commissions initiative to update and simplify the technical screening criteria under the EU Taxonomy in order to reduce complexity and to enhance the Taxonomy relevance for investment decisions. Our remarks focus on the recommendations for real estate activities, in particular the activity 7.7 acquisition and ownership of buildings.

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.

BNP Paribas Leasing Solutions welcomes the opportunity to respond to the European Commissions call for evidence for the review of the EU Taxonomy Environmental Delegated Act. We invite the Commission to address the following implementation challenges for leasing companies, which feature particularly in DNSH for activities 5.1 Repair, refurbishment and remanufacturing and 5.3 Product-as-a-service and other circular…

The Fusion Industry Association (FIA) welcomes the opportunity to contribute to the European Commission's call for evidence on the comprehensive simplification of the technical screening criteria of the EU Taxonomy Regulation. We appreciate the importance of the EU Taxonomy as part of the EU Sustainable Finance Framework.

Interferry welcomes this opportunity to provide evidence in relation to the review of the EU taxonomy climate delegated act. In summary we find that the TSC within the Taxonomy are in part not realistic and in part not fit for purpose. We have outlined our detailed comments in the attached document.

As the Italian National Promotional Institution, CDP fosters sustainable development in Italy, promoting growth and employment, innovation, business competitiveness, infrastructure, and local development. As a financial institution disclosing information according to the EU Taxonomy, we share the following recommendations.

As the Italian National Promotional Institution, CDP fosters sustainable development in Italy, promoting growth and employment, innovation, business competitiveness, infrastructure, and local development. As a financial institution disclosing information according to the EU Taxonomy, we share the following recommendations.

As Wüest Partner we are an independent, owner-managed consulting firm. As impartial experts, we have been delivering decision-support tools for professional real estate players since 1985. We offer our clients in Switzerland, Germany, and France a wide range of services encompassing advice, valuations, data, applications, publications, and education.

ENGIE welcomes the Commission's efforts to improve the usability of the Taxonomy by simplifying the Technical Screening Criteria (TSC), removing unnecessary barriers and making proof of compliance easier while reducing the overall administrative burden.

We support the revision of the Taxonomy delegated acts with a focus on revising and simplifying the TSC and the DNSH criteria. Our contribution attached focuses on particular on the following points for the revision of the Climate delegated act: As regards activity 6.6 in the Climate delegated act, it asks that in view of the operational realities of Long-distance freight transport, to reassess the criterion which…

We welcome the Commissions initiative to review the EU Taxonomy Climate and Environmental Delegated Acts to improve clarity, usability, and cost-effectiveness. However, we express significant concern regarding the proposed process and the implications of simplification. 1.

Jernkontoret, the Swedish iron and steel producers association, submits comments regarding practical challenges in applying EU Taxonomy criteria and proposes improvements. The attachment includes specific remarks on Substantial Contribution (SC) and Do No Significant Harm (DNSH) criteria, general observations on Delegated Acts (DA), and comments on the EU Commission notice (C/2025/1373). 1.

1) It is crucial to ensure that the EU Taxonomy criteria are a tool for evaluating concrete investments rather than companies implementing them so that investments for transformation could be supported by financial institutions.

It is essential that revisions do not jeopardise the Taxonomy alignment of existing plants and new investments. Revisions should simply improve the usability of the Taxonomy by simplifying and clarifying the current criteria where needed. On horizontal issues, TSC should be made less detailed, hence more interpretable, also for investors. Some TSC also go beyond the current regulatory environment.

LASPIM, Association Française des Sociétés de Placement Immobilier, represents managers of unlisted real estate funds, with an overall stock of almost EUR 300 billion, who invest and manage real estate stocks. ASPIM members wished to respond to the consultation and propose adjustments for category ‘7.7 Acquisition and ownership of buildings’.

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It is essential that revisions do not jeopardise the Taxonomy alignment of existing plants and new investments. Revisions should simply improve the usability of the Taxonomy by simplifying and clarifying the current criteria where needed. On horizontal issues, TSC should be made less detailed, hence more interpretable, also for investors. Some TSC also go beyond the current regulatory environment.

The Confederation of Finnish Construction Industries RT is an advocacy organization representing construction contractors, specialized contractors, and the construction product industry. RT focuses on public, business, and industrial matters, as well as labor markets. We have over 3,000 member companies, the majority of which are small and medium-sized enterprises.

With reference to a Call for evidence held by the European Comission on EU Taxonomy - Review of Climate and Environmental Delegated Act, attached please find contribution of Polish Association of Heat Energy (Polskie Towarzystwo Energetyki Cieplnej).

The Chemicals Strategy for Sustainability (CSS) highlights the risks of chemical pollution and intrinsic hazardous properties of chemicals, posing as a planetary boundary threat. On the other hand, the new Chemicals European Industry Action Plan (CIAP) describes the chemical industry as a cornerstone of the EUs industrial resilience and competitiveness, crucial for the green and digital transition.

FuelsEurope welcomes the opportunity to contribute to the review of the EU Taxonomy Environmental Delegated Act. As the refining sector invests in technologies essential for decarbonisation, it is vital that the Taxonomy accurately reflects the activities needed for Europes transition.

Please find attached the Position of AEVERSU on the European Commission's initiative to review the delegated acts on climate and environmental taxonomy. AEVERSU is the association of waste to energy plant companies, which encompasses all plants in Spain and Andorra that convert non-recyclable municipal waste into energy.

Please find attached ArcelorMittals contribution to the call for evidence regarding the revision of the Taxonomy Climate Delegated Act. We thank the European Commission for the opportunity to provide input. Our comments and proposals focus on the key issues of particular relevance to the steel sector.

Key proposals 1. Exempt EU companies operating in EU from MS assessment. For MS, EU undertakings are already subject to extensive social, labour and human rights legislation, actively enforced by competent authorities; compliance can therefore be reasonably presumed, absent evidence to the contrary. 2.

CEZ Group believes,there must be no reduction of GHG thresholds,as it would discourage investments that are necessary for transitioning toward a low-carbon economy (risk investing into possibly non-aligned project).In the proposal of the SP we lack appropriate reasoning of lowered thresholds and IA.Any proposal must be based on scientific/technical evidence to prove its feasibility,be supported by references.

The current EU taxonomy settings disadvantage nuclear energy, which is and will remain a key part of the Czech energy mix. Nuclear power is classified only temporarily and under restrictive conditions; similar limitations apply to gas, which is crucial for the energy transition and security of supply.

According to the GdW, the following points should be taken into account when revising the taxonomy: 1) No higher efficiency requirements beyond the national NZEB to enable cost-effective new build and affordable rents. 2) Focusing the EU Taxonomy on improving the worst-performing buildings, linking it to the EPBD, which includes the ‘worst-first’ approach.

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Key proposals 1. Exempt EU companies operating in EU from MS assessment. For MS, EU undertakings are already subject to extensive social, labour and human rights legislation, actively enforced by competent authorities; compliance can therefore be reasonably presumed, absent evidence to the contrary. 2.

Leaseurope, the EU Federation representing the leasing and automotive rental industries, welcomes the opportunity to propose recommendations for the simplification of the EU Taxonomy DAs to improve usability. Leaseurope is concerned regarding the DNSH criteria for the environmental objective (5) pollution prevention control in relation to activities CCM 6.5 Transport by motorbikes, passenger cars and commercial…

The Confederation of European Forest Owners (CEPF) recognises the opportunity to contribute to the review and simplification of the climate delegated act of the EU taxonomy, and acknowledging the current lack of uptake among forest owners, CEPF would like to emphasise the benefits and practicality of building on existing tools and processes already in use.

(more detailed and comprehensive feedback in the file attached) UIP, the association representing the interests of wagon keepers and entities in charge of maintenance in Europe, would like to make several recommendations regarding the technical screening criteria for climate change mitigation for the economic activity 6.2. freight rail transport.

From International Network for Sustainable Energy, we welcome the opportunity to give our comments in advance of the EU Taxonomy on sustainable investments. We find that it is important to maintain the criteria for doing no significant harm, but we think the criteria has been wrongly interpreted in the case of nuclear energy and use of fossil gas.

Leaseurope, the EU Federation representing the leasing and automotive rental industries, welcomes the opportunity to propose recommendations for the simplification of the EU Taxonomy DAs to improve usability. Leaseurope is concerned regarding the DNSH criteria for the environmental objective (5) pollution prevention control in relation to activities CCM 6.5 Transport by motorbikes, passenger cars and commercial…

The Forest Stewardship Council (FSC) recommends the integration of sustainable forest management (SFM) certification as rigorous criteria (i.e., such as the credibility criteria by ISEAL) and robust third-party verified impact on natural ecosystems, as a tool to help demonstrate compliance with substantial contribution, do no significant harm (DNSH) and minimum social safeguards.

We welcome the Commission's initiative to review the EU Taxonomy Climate and Environmental Delegated Acts, aiming to improve their clarity, usability, and cost-effectiveness. However, we must express significant concerns regarding the proposed process and the potential implications of simplification. 1.

Confederation of Finnish Industries EK fully supports the Commissions review of the Climate and Environmental Delegated Acts of the Taxonomy, as it provides an ample opportunity to address experienced challenges and some inconsistencies: these concerns are related to issues at multiple levels, including adjustments to TSC, improvement of definitions, clarification of compliance requirements, and the removal of…

Bioenergy is currently one of the largest sources of renewable energy in the EU and a key driver of the Unions energy transition. It contributes significantly to decarbonization, energy security, and broader climate objectives, and will continue to play an essential role in achieving the EUs climate targets.

The Forest Stewardship Council (FSC) recommends the integration of sustainable forest management (SFM) certification as rigorous criteria (i.e., such as the credibility criteria by ISEAL) and robust third-party verified impact on natural ecosystems, as a tool to help demonstrate compliance with substantial contribution, do no significant harm (DNSH) and minimum social safeguards.

The Association of the Austrian Wood Industries welcomes the Commission's initiative to revise and simplify the delegated acts on the EU taxonomy. The delegated acts are quite difficult to apply and involve a high administrative burden for companies, especially SMEs. Please see comments in the enclosed file

(full submission attached) ABB supports the ambition of the EU Taxonomy framework to channel investments towards economic sectors and activities in line with climate change and environmental objectives. ABB welcomes the significant progress made in expanding EU Taxonomy to include many critical activities, such as the manufacturing of electrical equipment.