EU taxonomy - Review of the environmental delegated act

The European Steel Association, EUROFER, supports the European Commissions comprehensive sustainable finance strategy, aimed at redirecting capital flows toward sustainable and inclusive growth. However, this goal can only be met if the EUs sustainable finance taxonomy recognises the specific needs of hard-to-decarbonise sectors such as steel.

Overview Regarding the assessment of compliance with DNSH criteria, we have interpreted these criteria by conducting the analysis on a site-by-site basis; other companies may have conducted it more broadly. It will be appreciated that the new text specify the methods for analyzing compliance with DNSH criteria in the field.

GIE welcomes the European Commissions initiative to review and update the Climate and Environmental Delegated Acts of the EU Taxonomy. This revision is an important opportunity to improve the clarity, usability, and coherence of the TSC, and to ensure full alignment with the EUs evolving climate, industrial, and carbon management policies.

The Federal Office for the Safety of Nuclear Waste Management (BASE) advises the Federal Ministry for the Environment, Climate Protection, Nature Conservation and Nuclear Safety (BMUKN) on radioactive waste management and nuclear safety. It performs supervisory and licensing functions as well as activities as a specialised authority. BASE conducts and coordinates research in the Office’s thematic areas.

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Valmets views on EU taxonomy development 1. The EU Taxonomy is essential framework for assessing sustainable economic activities and promoting the selected environmental objectives in industry. Without the Taxonomy, each company would need to set its own sustainability criteria leading to complexity and inconsistency. 2.

The Swedish Construction Federation welcomes the review of the EU taxonomy, noting that current climate and environmental delegated acts are difficult to apply and administratively burdensome for construction companies.

Europacable, the voice of Europes leading wire and cable manufacturers, welcomes the European Commissions initiative to review the EU taxonomy climate delegated act and environmental delegated act to update and simplify the technical screening criteria. Within the context of the ongoing calls for evidence, we would like to contribute with the attached document.

The German Property Federation (ZIA) welcomes the European Commission's initiative to review the EU Taxonomy's Climate Delegated Act and thus the technical screening criteria (TSC). Given the high proportion of EU-wide CO emissions of more than one third, the Climate Taxonomy has the potential to play a key role in the building sector to mobilise the capital necessary for decarbonisation.

Europacable, the voice of Europes leading wire and cable manufacturers, welcomes the European Commissions initiative to review the EU taxonomy climate delegated act and environmental delegated act to update and simplify the technical screening criteria. Within the context of the ongoing calls for evidence, we would like to contribute with the attached document.

SEOPAN welcomes the open consultation by the European Commission on the revision of the Climate and Environmental Taxonomy Delegated Acts to update and simplify the technical screening criteria and contribute to a clearer and more consistent application of the Taxonomy. We set out general comments in the attached file and then specified them for some activities.

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SEOPAN welcomes the open consultation by the European Commission on the revision of the Climate and Environmental Taxonomy Delegated Acts to update and simplify the technical screening criteria and contribute to a clearer and more consistent application of the Taxonomy. We set out general comments in the attached file and then specified them for some activities.

Filed in Spanish · English published by the European Commission

SEOPAN welcomes the open consultation by the European Commission on the revision of the Climate and Environmental Taxonomy Delegated Acts to update and simplify the technical screening criteria and contribute to a clearer and more consistent application of the Taxonomy. More general comments are detailed in the attached file and later specified for some activities.

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(See 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.

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 European Semiconductor Industry Association (ESIA), representing the European leadership in semiconductor research, design, and manufacturing, would like to make recommendations for the review of the climate delegated act . Semiconductors (or chips) are at the core of Europes clean and digital transitions.

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.

SEOPAN welcomes the open consultation by the European Commission on the revision of the Climate and Environmental Taxonomy Delegated Acts to update and simplify the technical screening criteria and contribute to a clearer and more consistent application of the Taxonomy. More general comments are detailed in the attached file and later specified for some activities.

Filed in Spanish · English published by the European Commission

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 International Union of Property Owners (UIPI), representing owner-occupiers, private landlords and, to some extent, listed real estate companies, welcomes the European Commissions initiative to review the Climate and Environmental Delegated Acts.

The Union of Entrepreneurs and Employers welcome an opportunity to provide feedback regarding review of the EU taxonomy climate delegated act to update and simplify the technical screening criteria. ZPP is actively supporting the goal of providing Poland with a clean and stable source of energy that will accelerate the countrys energy transformation, strengthen energy security, increase competitiveness of industry…

The International Union of Property Owners (UIPI), representing owner-occupiers, private landlords and, to some extent, listed real estate companies, welcomes the European Commissions initiative to review the Climate and Environmental Delegated Acts.

Siemens main recommendations: 1. Scope: Recognise the role of energy efficiency solutions for industrial processes to foster EUs decarbonization, resilience and competitiveness objectives and include relevant activities in the Taxonomy scope. 2.

Siemens main recommendations: 1. Scope: Recognise the role of energy efficiency solutions for industrial processes to foster EUs decarbonization, resilience and competitiveness objectives and include relevant activities in the Taxonomy scope. 2.

We welcome the opportunity to provide feedback on the EU Taxonomy Climate Delegated Act and Environmental Delegated Act, and we appreciate the Commissions intention to simplify, clarify and improve the technical screening criteria. We acknowledge that the EU Taxonomy can play a valuable role as a common reference framework for sustainable investments.

We welcome the opportunity to provide feedback on the EU Taxonomy Climate Delegated Act and Environmental Delegated Act, and we appreciate the Commissions intention to simplify, clarify and improve the technical screening criteria. We acknowledge that the EU Taxonomy can play a valuable role as a common reference framework for sustainable investments.

The machinery and plant engineering sector welcomes the European Commissions initiative to revise the technical screening criteria (TSC) under the EU Taxonomy. This revision is urgently needed because the current TSC disadvantages our industry.

Please find below some general comments from PGE Polska Grupa Energetyczna to the call for evidence on the review of Climate and Environmental Delegated Acts under the EU Taxonomy. For detailed comments please see the attached document.

Please find below some general comments from PGE Polska Grupa Energetyczna to the call for evidence on the review of Climate and Environmental Delegated Acts under the EU Taxonomy. For detailed comments please see the attached document.

Finance Finland (FFI) represents banks, life and non-life insurers, employee pension companies, finance houses, fund management companies and securities dealers operating in Finland. Our members also include providers of statutory insurance lines, which account for much of Finnish social security. FFI thanks the European Commission for this opportunity to provide feedback on the EU Taxonomy.

Concrete Europe does not support the inclusion of the activity "Use of Concrete in Civil Engineering" in Annex II of the Climate Change Delegated Act, as proposed by the Platform on Sustainable Finance (PSF) recommendation.

La Poste proposes adjustments to the revision of the technical and DNSH criteria for Taxonomy Delegated Acts in order to better reflect the operational realities of the postal sector and simplify reporting, in particular as regards transport and the circular economy: — The creation of a dedicated postal activity bringing together different modes of freight transport (6.4, 6.5, 6.6) to simplify reporting and reflect…

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As Eurometaux, the non-ferrous metals industry association, we support the EU taxonomy's goal to channel investments towards sustainable economic activities and support economic sectors in their transition. If well designed, the EU Taxonomy Regulation (EU/2020/852) can incentivize financial flows towards activities aligned with climate and environmental objectives, provided that the criteria are fit for purpose and…

The European Geothermal Energy Council (EGEC) welcomes the European Commissions initiative to review the Climate and Environmental Delegated Acts of the EU Taxonomy legislation. We strongly support the objectives of simplification, reduction of administrative burden, and alignment of Taxonomy with the EUs industrial and climate ambitions.

Commission Delegated Regulation (EU) 2021/2139 should remove the requirement for activity 4.13 Production of biogas and biofuels for use in transport and production of bioliquids and 5.7 Biowaste anaerobic treatment for banning or restricting the use of food and feed crops, as it goes beyond the obligations under RED II and RED III.

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The Polish Electricity Association (PKEE), representing Polands leading energy companies, welcomes the European Commissions initiative to review the Climate Delegated Act (CDA) and the Environmental Delegated Act (EDA) under the EU Taxonomy Regulation ((EU) 2020/852).

Key messages & proposals We strongly support the goal of simplifying the technical screening criteria, enhancing clarity and coherence, and reducing unnecessary complexity while maintaining robust environmental standards and the overall integrity of the EU Taxonomy framework.

Key messages & proposals We strongly support the goal of simplifying the technical screening criteria, enhancing clarity and coherence, and reducing unnecessary complexity while maintaining robust environmental standards and the overall integrity of the EU Taxonomy framework.

The Green Building Council of Australia (GBCA) welcomes the opportunity to respond to the European Commissions Call for Evidence. We support the Commissions objective to improve usability of the EU Taxonomy framework by addressing practical challenges, including the interpretative difficulties of the Technical Screening Criteria (TSC) and the recognition of high quality green building certifications (such as Green…

The EU Taxonomy helps investors channel capital towards sustainable activities by providing a common language to guide such investments . In 2024, over half of EU-based asset owner PRI signatories reported using the EU Taxonomy to identify sustainability outcomes connected to their investments .

On behalf of the European Federation of Pharmaceutical Industries and Associations (EFPIA), we welcome the opportunity to contribute to the call for evidence in for the review of Climate Delegated Act. EFPIA represents the biopharmaceutical industry operating in Europe, bringing together 36 national associations, 40 leading pharmaceutical companies and a growing number of small and medium-sized enterprises.

On behalf of the European Federation of Pharmaceutical Industries and Associations (EFPIA), we welcome the opportunity to contribute to the call for evidence in for the review of Environmental Delegated Act. EFPIA represents the biopharmaceutical industry operating in Europe, bringing together 36 national associations, 40 leading pharmaceutical companies and a growing number of small and medium-sized enterprises.

Orano thanks the European Commission for its efforts to simplify the reporting requirements related to the EU taxonomy, and wishes to share its views on the necessary updates of the taxonomy framework, espacially as regards the inclusion of nuclear fuel cycle activities. Please find our detailed answer attached.

WE Data Europe welcomes the opportunity to provide feedback on the Climate Delegated Act and recommends updating the technical screening criteria of Activity 3.5 to reflect recent technological and regulatory developments.

Renewables Norway organises the largest hydropower producers in Norway. We find that there is need for simplification of the Do No Significant Harm (DNSH) criteria 3 for hydropower. Hydropower constitutes the backbone of Norways electricity system The EU Taxonomy plays a vital role in enabling sustainable finance and guiding investments toward environmentally sound activities.

Nucleareuropes response to this consultation focuses on the Technical Screening Criteria relating to the following economic activities: 4.26: Pre-commercial stages of advanced technologies to produce energy from nuclear processes with minimal waste from the fuel cycle.

Established in 1969, Faerch is a leading provider of circular, rigid food packaging with integrated recycling capabilities, and leads the market with the post-consumer recycled content in our polyethylene terephthalate (PET) plastic trays. Headquartered in Holstebro, Denmark, we employ 5,500 people across 25+ plants in Europe.

Nucleareuropes response to this consultation focuses on the Technical Screening Criteria relating to the following economic activities: 4.26: Pre-commercial stages of advanced technologies to produce energy from nuclear processes with minimal waste from the fuel cycle.

The General Aviation Manufacturers Association (GAMA) welcomes the Commissions initiative to review and refine the Climate Delegated Act (CDA). This review offers a crucial opportunity to correct an unintended gap in the scope of the existing CDA, which excludes almost the entirety of general aviation and business aviation manufacturing and operations from the EU Taxonomy.

Please find the feedback of the German Association of the Automotive Industry (VDA) in the document attached. The German Association of the Automotive Industry (Verband der Automobilindustrie / VDA) represents the interests of the German automotive sector at a national, European, and international level.

WE Data Europe welcomes the opportunity to provide feedback on the Environmental Delegated Act and recommends clarifying the technical screening criteria for Activity 2.1 to ensure consistent application of consumer-level water metering in multi-unit buildings.

T&E welcomes the possibility to put forward its recommendations ahead of the revision of EU Taxonomy technical screening criteria (TSCs) for transport. Overall T&E believes that simplification efforts must not weaken existing ambitious rules, stressing that the Omnibus proposal risks confusion, reduced investment certainty, and a race to the bottom that rewards laggards and penalises first movers.

Telefonica welcomes the European Commissions initiative to review and simplify the EU Taxonomy Climate Delegated Act. Considering the points raised during the Information and technology Reality Check session on 26/09/25, we have the following recommendations: - Simplify technical screening criteria in line with current simplification efforts on other activities.

Polskie Elektrownie Jądrowe sp. z o.o. (PEJ) welcomes an opportunity to provide feedback in call for evidence regarding review of the EU taxonomy climate delegated act to update and simplify the technical screening criteria. Detailed PEJ's position is attached.

The German insurance industry welcomes the possibility to give feedback for the EU Commissions (EC) Call for Evidence on the EU-Taxonomy. German (re)insurers support the ECs original idea of the Taxonomys framework. Despite the limited results of the Underwriting KPI, the Taxonomy made sustainability an important topic for the industry. This is evident in annual reports, process adaptations and product developments.

Please find attached the EUDCA (European Data Centre Association) recommendations. The EUDCA represents the interests of the European data centre community. Established in 2011, the EUDCA is the voice of the industry, with a diverse membership which includes European and international data centre operators, equipment suppliers, and a network of national trade associations.

We welcome the Commissions initiative to simplify and clarify the Climate and Environmental Delegated Acts. Based on our experience working with digital monitoring and verification in land-use and nature-based activities, we would like to highlight several points that may support the objectives outlined in the Call for Evidence. 1.

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.

Elia Group, as a leading European transmission system operator (TSO), strongly supports the EU Taxonomy Regulation and the associated Climate Delegated Act. The Groups main operating entities Eurogrid/50Hertz and Elia Transmission Belgium (ETB), view these regulations as essential drivers of systemic change, enabling a just and transparent energy transition aligned with the EU Green Deal and climate neutrality…

Further Simplifications required: In its statement, Deutsches Aktieninstitut welcomes the EU Commissions objective of reducing regulatory burdens arising from the regulation and its delegated acts. For the Technical Screening Criteria (TSC) and the Do-No-Significant-Harm (DNSH) criteria, we advocate (a.o.) for adjustments in the sectors of traffic and transport as well as new buildings and manufacture of low carbon…

The German insurance industry welcomes the possibility to give feedback for the EU Commissions (EC) Call for Evidence on Taxonomy. German (re)insurers support the ECs original idea of Taxonomys framework. Despite the limited results of the Underwriting KPI, the Taxonomy made sustainability an important topic for the industry. This is evident in annual reports, process adaptations and product developments.

EPRA represents the listed real estate sector in Europe, with 290 members managing over 930 billion in assets. Our members, including major REITs, are committed to advancing the European Green Deal and support a sustainable finance framework that fosters growth and competitiveness.

The BDE Federation of the German Waste Management, Water and Circular Economy Management Industry values the EU Taxonomy system as an important contribution to the transition of the European industry towards a sustainable and circular economy.

Handicraft Chamber of Ukraine (HCUMSMES.UA)Contribution to the Review of the EU Taxonomy Environmental Delegated The HCU welcomes the opportunity to contribute to the revision of the Environmental Delegated Act. HCU is the national competence centre for craft activities, small-scale industry (SSI), MSMEs, VET/skills development, reintegration, circular economy and rural/local economic ecosystems.

The BDE Federation of the German Waste Management, Water and Circular Economy Management Industry values the EU Taxonomy system as an important contribution to the transition of the European industry towards a sustainable and circular economy.

EUTurbines welcomes the intent of the European Commission to simply the Taxonomy and reduce the reporting burden for companies via a targeted adaptation of the technical screening criteria of the Climate Delegated Act.

We welcome the possibility to give our comments to the EU Taxonomy Climate Delegated Act with focus on the criteria for nuclear activities. Firstly, we want to clarify that nuclear energy is not sustainable due to a wide range of reasons (amongst others unsolved nuclear waste management especially for HLW, severe adverse impacts in case of severe accidents).

The European Automobile Manufacturers' Association (ACEA) appreciated the Commission's initiative to review the Climate and Environment Delegated Acts of EU Taxonomy. We have identified a few key areas where improvement is not only possible, but needed. Please see attached our position:

The German Banking Industry Committee (GBIC) welcomes the European Commissions initiative to improve the usability and proportionality of the EU Taxonomy by revising the delegated acts on climate and environmental objectives.

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

The European Business Aviation Association (EBAA) welcomes the Commissions review of the EU Taxonomy Climate Delegated Act (CDA). We see this as a crucial opportunity to correct an unintended gap that has left most general and business aviation aircraft (19 seats or fewer) outside the scope of the Taxonomy.

ITG BREEAM SPAIN according to BRE (the Building Research Establishment) raises two points in response to this call for evidence relating to Annex 1 of the Climate Delegated Act, Section 7.1 (P.166) covering construction and real estate activities - construction of new buildings.

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

Pohjolan Voima (PVO), one of Finlands largest energy producers, thanks the European Commission for the opportunity to contribute feedback on the review of the EU Taxonomy Climate Delegated Act (EU) 2021/2139. In line with the Commission's commitment to technology neutrality, PVO would like to highlight instances where the Taxonomy criteria could be simplified to better align with EU legislation and uphold the…

EUFUA welcomes the opportunity to contribute to the review of the EU Taxonomy Environmental Delegated Act. As a Brussels-based institutional platform supporting Ukraines economic recovery, green transition and alignment with the EU acquis, we represent municipalities, SMEs, sectoral organisations and expert groups engaged in reconstruction and future integration into the EU Single Market.

Bioenergy Europe welcomes the opportunity to contribute to the simplification of the Taxonomy technical screening criteria. To achieve Europes energy and climate goals it is pivotal to ensure regulatory stability and consistency among interconnected policy files.

The World Green Building Council (WorldGBC) welcomes the European Commissions review of the EU Taxonomy Climate and Environmental Delegated Acts and emphasises the need for simplification while maintaining alignment with evolving regulatory and market conditions. A full response with references and literature is attached.

Utilitalia, the national Federation representing 400 major Italian utilities operating in the water, energy, and environmental services sectors, welcomes the opportunity to contribute to the review of the Climate and Environmental Delegated Acts and the corresponding Technical Screening Criteria (TSC).

Utilitalia, the national Federation representing 400 major Italian utilities operating in the water, energy, and environmental services sectors, welcomes the opportunity to contribute to the review of the Climate and Environmental Delegated Acts and the corresponding Technical Screening Criteria (TSC).

Cefic welcomes the review of the Climate and Environmental Delegated Acts of the EU Taxonomy, as it gives the opportunity to address existing concerns. Cefic acknowledges significant challenges with the technical screening criteria (TSC) given their impracticability and/or by placing an excessive administrative burden upon companies: Climate Delegated Act Impracticability of the TSC on mechanical and chemical…

Cefic welcomes the review of the Climate and Environmental Delegated Acts of the EU Taxonomy, as it gives the opportunity to address existing concerns. Cefic acknowledges significant challenges with the technical screening criteria (TSC) given their impracticability and/or by placing an excessive administrative burden upon companies: Climate Delegated Act Impracticability of the TSC on mechanical and chemical…

Mitigation, 3.6. Manufacture of low carbon technologies As an intralogistics solution, the battery-powered material handling equipment manufactured by Jungheinrich enables the reduction in greenhouse gas emissions during the use phase in other industries, such as logistics, retail or wholesale. Thus, it is taxonomy-eligible according to economic activity 3.6.

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 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). Since 2017, the AFD Group has committed to aligning 100% of its financing with the Paris Agreement.

The EPMF welcomes the Commissions initiative to amend the technical screening criteria (TSC) and enhance the clarity and practical usability of the EU Taxonomy. Constructive dialogue with industry remains essential to ensuring a fit-for-purpose framework that applies proportionate rules while supporting meaningful progress toward the green transition and the EU Circular Economy.

Zero Waste Europe welcomes the initiative of the European Commission to revise the Climate and Environmental Delegated Acts with the aim of improving clarity, usability and legal certainty. While simplification is valuable, it must always preserve environmental ambition.

The testing, inspection and certification (TIC) sector, as a key enabler of the EU Taxonomy, would like to share its suggestions for the ongoing revision of the review of the Climate and Environmental Delegated Acts, with the clear objective of improving usability and simplification.

Summary of Technical Implementation Remarks on the Review of the EU Taxonomy This document presents a practitioner's perspective on the implementation challenges of the EU Taxonomy's Technical Screening Criteria (TSC), particularly for "Pollution Prevention." Current TSC are deemed difficult to scale and automate, affecting both industrial entities and the financial sector's ability to assess cumulative risk.

EuropaBio welcomes the revision of the EU Taxonomy Delegated Acts as a key opportunity to strengthen the bioeconomys role in achieving EU environmental objectives. To maximise impact, the review should: 1) Adopt a more inclusive approach to feedstocks eligible for sustainable financing mechanisms 2) Distinguish biotechnology from conventional processes, as highlighted in the EU Bioeconomy Strategy More details…

CO2 Value Europe is the association representing the Carbon Capture and Utilisation (CCU) community in Europe and working for the recognition of CCU as an essential pathway to reach EU climate goals. Next to the simplification of the technical screening criteria that will indeed bring more clarity, it is also very important that the Taxonomy includes further economic activities, in particular Carbon Capture and…

In Hafslunds view, the DNSH-3 criteria for hydropower should be clarified to ensure that compliance with relevant EU sectoral legislation and government decisions thereunder is the determining criteria for recognizing hydropower as sustainable under the EU taxonomy Delegated Regulation (EU) 2023/2485.

Concrete Europe does not support the inclusion of the activity "Use of Concrete in Civil Engineering" in Annex II of the Climate Change Delegated Act, as proposed by the Platform on Sustainable Finance (PSF) recommendation.

EDFI welcomes the Commissions review of the Taxonomy Climate and Environmental Delegated Acts, aimed at simplifying the TSC, addressing implementation challenges and improving usability. While the review focuses primarily on the workability of the TSC, EDFI considers it important to highlight that these criteria interact with wider structural issues - such as the GAR framework and the lack of mandatory EU-aligned…

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 and emphasize the need to clarify DNSH criteria 3 for hydropower.

Dear Sir or Madam, Please find attached the contribution submitted by Assarmatori the Italian Shipowners Association to the public consultation on the technical screening criteria under the EU Taxonomy Regulation. Should you require any further information or clarification, we remain at your full disposal. Sincerely, [name removed]

ePURE supports the objective of the EU Taxonomy Regulation to guide financial flows towards sustainable growth and accelerate the transition to a climate-neutral economy. However, in the context of the current review of the EU taxonomy climate delegated act, we wish to highlight persistent inconsistencies with sectoral legislation as well as concerns regarding the process and methodology used to define…

ePURE supports the objective of the EU Taxonomy Regulation to guide financial flows towards sustainable growth and accelerate the transition to a climate-neutral economy. However, in the context of the current review of the EU taxonomy climate delegated act, we wish to highlight persistent inconsistencies with sectoral legislation as well as concerns regarding the process and methodology used to define…

The EU Taxonomy is intended to define criteria for environmentally sustainable economic activities and to guide investments toward the EUs green transition. The biomass-derived chemicals sector plays a central role in enabling a sustainable, circular, and competitive European economy by providing renewable, high-performance materials.

Cefic welcomes the review of the Climate and Environmental Delegated Acts of the EU Taxonomy, as it gives the opportunity to address existing concerns. Cefic acknowledges significant challenges with the technical screening criteria (TSC) given their impracticability and/or by placing an excessive administrative burden upon companies: Climate Delegated Act Impracticability of the TSC on mechanical and chemical…

EBA welcomes the opportunity to provide its feedback on the ongoing revision of the Taxonomy. For the purpose of this consultation, EBA has prepared a position paper aimed at outlining the key issues identified by our sector within the current technical screening criteria, while also putting forward concrete suggestions for improvement.

EBA welcomes the opportunity to provide its feedback on the ongoing revision of the Taxonomy. For the purpose of this consultation, EBA has prepared a position paper aimed at outlining the key issues identified by our sector within the current technical screening criteria, while also putting forward concrete suggestions for improvement.

For Economic Activity CCM 6.5 of Annex I Pollution Prevention & Control, among others this involves requirements related to rolling resistance and rolling noise. The effort required to prove compliance with tire requirements is disproportionate to the actual benefits, leads to misunderstandings on investor and stakeholder level and creates double regulation with a high level of additional bureaucratic effort.

A regulatory framework that enables the chemical industry to RE-carbonise seized by using sustainable feedstocks will pave the way for sustainable materials and products for society as a whole. Apart from climate emission reductions, this can become a much needed growth engine, strengthening European competitiveness in the global market, and a way to reduce the dependency on fossil imports.

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Veolia welcomes the Commissions intent to review the EU taxonomy environmental 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.

Veolia welcomes the Commissions intent 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.

Opportunity Green welcomes the European Commissions initiative to clarify the Taxonomys technical screening criteria and the opportunity to respond to this Call for Evidence. 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.

Climate & Company welcomes the review of the EU Taxonomy Climate and Environmental Delegated Acts. The EU Taxonomy is an important tool for steering capital toward sustainable activities, but its implementation faces significant challenges.

For coherence, the Taxonomy Climate criteria for anaerobic digestion should be modified to allow phosphorus recovery as per the criteria of the Taxonomy Environment (Circular Economy) criteria. The Climate criteria (2021/2139) currently require that digestates from eligible AD processes are used as fertilising materials, meeting the requirements of the EU Fertilising Products Regulation 2019/1009 CMCs 4-5: - pages…

ESPP welcomes the Phosphorus recovery from waste water (Taxonomy Environment criteria 2023/2486 Annex II $2.1) coherent with the inclusion of phosphate rock on the EU list of Critical Raw Materials (CRM Act 2024/1252) and with the principle of phosphorus reuse and recycling targets of art. 20 of the revised Urban Waste Water Treatment Directive (2024/2049).

Corbion welcomes the opportunity to provide input on the EU Taxonomy and supports its objective of directing capital toward truly sustainable activities. However, the Environmental Delegated Act currently limits eligibility to bio-waste, excluding sustainably sourced primary biomass, which risks slowing innovation and investment in the EU bioeconomy. 1.

CEWEP - Confederation of European Waste-to-Energy Plants represents owners and operators of European Waste-to-Energy plants. Waste-to-Energy (WtE) is an essential public-service infrastructure that treats residual, non-recyclable waste, supports high recycling quality by removing contaminants and treating residues from the recycling process, and recovers materials and energy that would otherwise be lost.

EuroCommerce, representing European retailers and wholesalers, welcomes the opportunity to provide feedback regarding the proposed changes to the EU Taxonomy Climate and Environmental Delegated Acts. Retailers and wholesalers welcome the proposal to amend the EU Taxonomy Regulation to simplify reporting and the opportunity to share feedback with the Commission.

Comment on Article 5.10 Landfill gas capture and utilisation (EU Taxonomy Climate Delegated Act, Regulation (EU) 2021/2139) Waga Energy welcomes the opportunity to contribute to the review of the EU Taxonomy technical screening criteria. We submit comments specifically on Article 5.10, with the objective of improving clarity, coherence with EU Waste Directives, and practical applicability.

Dear European Commission FISMA team, Thank you for the opportunity to provide feedback on the EU Taxonomy environmental and climate delegated acts. As actors in the real estate sector, we welcome the Commissions efforts to improve clarity and usability. Our comments focus mainly on part 3 of the Environmental Delegated Act, with targeted links to part 7 of the Climate Delegated Act where criteria overlap. 1.

Orgalim, Europe's technology industries, would like to submit is suggestions on Technical Screening Criteria Manufacture of electrical and electronic equipment, 1.2. Please find attached the detailed recommendations for this activity for your consideration.

EFPA is the leading professional standards body for financial advisors and planners in Europe, with more than 100,000 certificate holders across 13 countries, including over 10,000 ESG Adviser certificate holders. EFPA responds to this consultation in that capacity. We welcome the opportunity to contribute to this important and timecritical consultation.

Please find below UFEs proposals concerning nuclear and hydropower activities in relation to the Technical Screening Criteria set out in the EU Taxonomy Climate DA. High-level radioactive waste: Economic activities 4.26, 4.27 & 4.28, article 1 (f) require that The Member State has a documented plan with detailed steps to have in operation, by 2050, a disposal facility for high-level radioactive waste.

newcleos response to this consultation focuses on the following economic activities: 4.26: Pre-commercial stages of advanced technologies to produce energy from nuclear processes with minimal waste from the fuel cycle. 4.27: Construction and safe operation of new nuclear power plants, for the generation of electricity or heat, including for hydrogen production, using best-available technologies.

On the Climate Delegated Act: While EU Taxonomy compliance is often seen as best practice, it has become almost mandatory in practice as many organizations and administrations base their criteria on it. This makes addressing inconsistencies, legal uncertainty, and complex screening criteria essential.

On the Environmental Delegated Act: While EU Taxonomy compliance is often seen as best practice, it has become almost mandatory in practice as many organizations and administrations base their criteria on it. This makes addressing inconsistencies, legal uncertainty, and complex screening criteria essential.

ANIA, the Italian Insurance Association, deems important to revise the EU Taxonomy framework, with respect to the delegated regulations. ANIA welcomes the objective of simplification introduced by the European Commission in the sustainability Omnibus package and the simplification introduced by the European Commission in the Delegated Act amending the Disclosure Delegated Act, that represents a first step in the…

Hansgrohe welcomes the opportunity to contribute to the review of the EU Taxonomys Environmental Delegated Act, which establishes the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to the sustainable use and protection of water and marine resources, to the transition to a circular economy, to pollution prevention and control or to…

Hansgrohe welcomes the opportunity to contribute to the review of the EU Taxonomys Climate Delegated Act, which establishes the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and determines whether that economic activity causes no significant harm to any of the other…

The Union of Agricultural Producers and Forest Owners (MTK) want to thank for the opportunity to comment 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. Only in this way can taxonomy achieve broad usability and impact.

Covestro 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 . As a leading materials company committed to sustainability and the circular economy, we provide our perspectives on how the technical screening criteria can be streamlined while maintaining environmental integrity and…

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 EEM NL Hub consists of 22 members and 19 affiliated members, representing over 90% of the mortgage originators in the Netherlands and many more institutions active in the Dutch mortgage market. The Dutch mortgage market is the 3rd largest residential mortgage market in the EU. The below observations all relate to the CDA from the perspective of financing residential real estate - section 7.

The Real estate sector reinforces that it is aiming to reach a higher ambition for Taxonomy alignment. Clarity for the Financial sector towards Real Estate is key for us and therefore having a common language and a common target is essential. In this respect we have introduced some comments to improve the impact of the taxonomy on the evolution of the cities. Within a full range of recommendations, we highlight: 1.

Cerame-Unie, representing the European ceramic industry, welcomes the opportunity to provide feedback on the Environmental Delegated Act of the EU Taxonomy. Increasing the use of secondary raw materials in ceramic construction products is essential to strengthening circularity across the industry.

LAfep, the voice of Large French Companie, considers that the Taxonomy should be made voluntary and, as a cross-sectoral association, also insists on the following points : 1. Better support transition It is necessary to develop a framework for recognising contributions to the ecological transition. The European Taxonomy focuses on sustainable activities and not enough on activities in transition.

This initiative will review the EU Taxonomy Environmental Delegated Act to update and simplify the technical screening criteria. Including gas and nuclear in the environmental taxonomy is a huge mistake both because of the CO2 pollution of the gas, and because of the emission of waste and the large use of water, the cooling of the reactor is not considered at all in the MRS.

Filed in Italian · English published by the European Commission

Generali welcomes the Commissions objectives defined in the Call for Action. The following proposals are aligned with the Commissions objectives: 1. Underwriting (Activity 10.1) The underwriting TSC should be refined to ensure consistency with wider EU initiatives (e.g. Resilience Framework, New Adaptation Strategy) and with the evolution of NatCat schemes in the EU.

(Please find attached a more detailed and comprehensive version of our contribution) - Snam welcomes the ECs review of the Climate and Environmental Delegated Acts of the EU Taxonomy, an important opportunity to improve the clarity, usability and coherence of the TSC and consistency with evolving EU policies.

(Please find attached a more detailed and comprehensive version of our contribution) - Snam welcomes the ECs review of the Climate and Environmental Delegated Acts of the EU Taxonomy, an important opportunity to improve the clarity, usability and coherence of the TSC and consistency with evolving EU policies.

EEW Energy from Waste GmbH backs the EU Taxonomy as a key tool for the green transition. The current Call for Evidence is a chance to refine technical screening criteria (TSC) for better alignment with EU goals. Effective waste management, including energy recovery, provided by Waste-to-Energy (WtE) offers significant environmental benefits, which are increasingly recognized by authorities.

The ENGAGE for ESG Consortium is aware of the multiple challenges faced by lending institutions to assess the EU Taxonomy alignment of their residential mortgage and renovation loans. The ENGAGE Consortium is convinced that there is room for simplification in the Taxonomy so that an effective and harmonised framework is established and enforced.

The decision to include nuclear energy in the EU Taxonomy was a correct and science-based step, recognizing the essential role of nuclear power in achieving climate neutrality. The Joint Research Centres (JRC) assessment concluded that nuclear energy does not cause more harm to human health or the environment than other electricity production technologies already included in the Taxonomy.

Call for Evidence EU Taxonomy Review (Climate & Environmental Delegated Acts) EERA Response to the European Commission The European Electronic Recyclers Association (EERA), representing Europes leading professional Waste Electrical and Electronic Equipment (WEEE) treatment, depollution and resource recovery operators, welcomes the opportunity to contribute to the European Commissions review of the Climate and…

As the HVAC sector plays a central role in the decarbonisation of buildings, it is essential that the ongoing review process ensures that the screening criteria for the manufacture of mechanical ventilation systems remain technically clear, measurable, and aligned with existing energy labelling legislation.

Land & Forestry Holdings Austria expressly welcomes the simplification efforts during the revision of the Delegated Acts on the Taxonomy Regulation (Regulation (EU) 2020/852). In particular, the technical screening criteria for the activities in Chapter 1.3 Forest management, both as regards climate change mitigation and climate change adaptation, of Delegated Regulation (EU) 2021/2139 (Climate Law Act) are, in our…

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The German Environment Agency has contributed to the development of the EU Taxonomy since its beginning, and welcomes the opportunity to give feedback. The EU Taxonomy was developed to provide corporates and financial market participants with standardized guidance on the sustainability or transitional nature of an economic activity.

We welcome the opportunity to submit our comments on the delegated act of the EU taxonomy in the field of climate in particular on the technical criteria for nuclear activities. Nuclear power cannot be classified as sustainable for environmental, safety, and social reasons.

The German steel association (Wirtschaftsvereinigung Stahl) welcomes the EU Commissions initiative to revise the Delegated Acts of the EU Taxonomy. As a sector undergoing a profound transition towards climate-neutral production while facing global overcapacity, high investment needs and increasing regulatory pressure, a clear, workable and proportionate Taxonomy framework is essential.

The Energy Efficient Mortgage Label Foundation (EEMLF) welcomes the opportunity to provide its feedback to the European Commission's Call for Evidence in the context of the Review of the EU Taxonomy Environmental Delegated Act. Please find attached our full position.

INREV, the European Association for Investors in Non-Listed Real Estate Vehicles, welcomes the opportunity to support the Commissions review of the EU Taxonomy Climate and Environmental Delegated Acts. Our membership consists of long-term real estate fund managers and institutional investors who play a central role in financing the transition of Europes building stock.

INREV, the European Association for Investors in Non-Listed Real Estate Vehicles, welcomes the opportunity to support the Commissions review of the EU Taxonomy Climate and Environmental Delegated Acts. Our membership consists of long-term real estate fund managers and institutional investors who play a central role in financing the transition of Europes building stock.

INREV, the European Association for Investors in Non-Listed Real Estate Vehicles, welcomes the opportunity to support the Commissions review of the EU Taxonomy Climate and Environmental Delegated Acts. Our membership consists of long-term real estate fund managers and institutional investors who play a central role in financing the transition of Europes building stock.

Sanofi has been compliant with the European Taxonomy since 2021. The entry into force of the objective on pollution since the 2023 financial year and the application of the criteria of activity 1.2 Manufacture of medicinal products reveal major obstacles.

Filed in French · English published by the European Commission

The current EU Taxonomy requirements are in our view too restrictive and lack clear guidance for implementation in practice and the evidence needed. Regarding substantial contribution, for example the development stage prior to construction for wind, solar and other clean energy assets is excluded.

Nordic Ecolabelling highlights a Report only once approach when demonstrating Taxonomy compliance. This would boost competitiveness as it would make it easier for European companies to operate at the European market. We therefore suggest that alignment with the Taxonomy can be verified by an officially recognized ISO 14024 type I Ecolabel certificate, such as EU Ecolabel and Nordic Swan Ecolabel.

The European Confederation of Woodworking Industries (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.

atomstopp_atomkraftfrei leben!, Austria is pleased to respond to the Call for Evidence in the following submission. The Taxonomy Regulation (EU) 2020/852 is a key instrument for directing capital flows towards sustainable economic activities and preventing greenwashing. Its effectiveness depends fundamentally on the credibility and scientific integrity of its criteria.

Innargi welcomes the European Commissions initiative to review the Climate and Environmental Delegated Acts of the EU Taxonomy legislation. We strongly support the objectives of simplification, reduction of administrative burden, and alignment of Taxonomy with the EUs industrial and climate ambitions.

Greiner Packaging supports the EUs ambition to advance a circular economy through the Packaging and Packaging Waste Regulation (PPWR) and the EU Taxonomy Environmental Delegated Act. However, their requirements for recyclability, design-for-recycling, and recycled content are misaligned, creating uncertainty for compliance and investment.

European Boating Industry (EBI) represents the recreational boating and nautical tourism sector in Europe, spanning boatbuilders (motorboats, sailing boats, yachts, personal watercraft), engine and equipment manufacturers, refit and maintenance yards, dealers, importers, marinas, yacht harbours, charter and rental services, water sports companies and related businesses.

European Boating Industry (EBI) represents the recreational boating and nautical tourism sector in Europe, spanning boatbuilders (motorboats, sailing boats, yachts, personal watercraft), engine and equipment manufacturers, refit and maintenance yards, dealers, importers, marinas, yacht harbours, charter and rental services, water sports companies and related businesses.

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.

The European Mortgage Federation-European Covered Bond Council (EMF-ECBC) welcomes the opportunity to provide its feedback to the European Commissions Call for Evidence in the context of the Review of the EU Taxonomy Environmental Delegated Act. Please find attached our full position.

EurEau, the European Federation of National Associations of Water Services, welcomes the opportunity to share its views, concerns and suggestions on the water related activities included in the Taxonomy Environmental and Climate Delegated Regulations.

EurEau, the European Federation of National Associations of Water Services, welcomes the opportunity to share its views, concerns and suggestions on the water related activities included in the Taxonomy Environmental and Climate Delegated Regulations.

The EU Taxonomy Regulation has created a framework for classifying economic activities, including those in the real estate sector, as sustainable. In the area of climate protection, the energy performance certificate has established itself as a key assessment tool.

The revision of the EU Taxonomy Climate Delegated Act (CDA) is the right occasion to correct some long-standing major inconsistencies with relevant EU legislation on biofuels: as highlighted in the Commissions call for evidence, inconsistencies, gaps in alignment with updated EU legislation and overly complex technical screening criteria are among the major issues mentioned by stakeholders affecting the usability of…

As a specialist provider of asset management, operations and optimisation services across solar PV, battery energy storage, biomethane production and low carbon heat networks, we support a taxonomy framework that is clear, proportionate and aligned with practical implementation realities in the clean-energy sector. 1.

As part of the ongoing review of the EU Taxonomy Climate Delegated Act, KGHM Polska Miedź S.A. stresses the need to establish realistic technical screening criteria (TSCs), based on reliable data and technologies available on an industrial scale. Copper, in line with the CRMA, has been identified as a strategic raw material essential for the EU’s economic and energy security.

Filed in Polish · English published by the European Commission

As a specialist provider of asset management, operations and optimisation services across solar PV, battery energy storage, biomethane production and low carbon heat networks, we support a taxonomy framework that is clear, proportionate and aligned with practical implementation realities in the clean-energy sector. 1.

As part of the ongoing review of the EU Taxonomy Environmental and Climate Delegated Act, KGHM Polska Miedź S.A. stresses the need to establish realistic technical screening criteria (TSCs), based on reliable data and available technologies. Copper, in line with the CRMA, has been identified as a strategic raw material, essential for the EU’s economic and energy security.

Filed in Polish · English published by the European Commission

At the UN Global Compact Spain, an organization committed to promoting the Ten Principles and advancing business contributions to the 2030 Agenda, we welcome the review process of the Environmental Taxonomy Delegated Act. We believe this update represents a key opportunity to strengthen clarity, consistency, and trust in information related to sustainable economic activities.

Contribution of the United Nations Global Compact Spain to the public consultation on the revision of the EU Taxonomy Environmental Delegated Act At the UN Global Compact Spain, an organization committed to promoting the Ten Principles and advancing business contributions to the 2030 Agenda, we welcome the review process of the Environmental Taxonomy Delegated Act.

In response to the call for feedback, PLK welcomes the opportunity to present its comments on the revision of the DA for the EU taxonomy. In our view, the current wording of the legal acts requires updating and simplification in several aspects, in order to ease the burden and adapt the regulations to the actual realities of businesses.

In the view of the Federal Chamber of Labour, it is essential that the following four points be taken into account in the revision of the Taxonomy Regulation and the delegated acts: 1) Avoid greenwashing: Strict criteria must be maintained to prevent greenwashing and to clearly define sustainable economic activities.

Filed in German · English published by the European Commission

The European Landscape Contractors Association (ELCA) likes to reflect on the call for evidence on the review of the delegated acts Climate and Environment in the EU Taxonomy. ELCA represents national associations of landscape garden companies in 23 EU member states and has associate representation in Canada, Japan, Norway, Saudi-Arabia, Singapore, Switzerland, Türkiye and the United Kingdom.

General guidance on the TSC from a bank’s perspective: The evidence of conformity assessment should be simplified and standardised. Banks’ counterparties must be able to produce simplified, standardised and audit-proof evidence, such as expert opinions that exempt banks from substantive testing.

Filed in German · English published by the European Commission

This initiative will review the EU Taxonomy Environmental Delegated Act to update and simplify the technical screening criteria. They are not possible for the environmental taxonomy for gas and nuclear, as they are more expensive than renewable and environmentally non-neutral energy, as RMS nuclear also releases waste that has not yet been reprocessed.

Filed in Italian · English published by the European Commission

Strengthening the EU Taxonomy with CRREM CRREM is a leading example of successful European climate innovation. Originating from the EUs Horizon 2020 program, it has grown from a research initiative into the worlds most widely adopted framework for climate alignment and transition-risk assessment in real estate.

MSCI* welcomes the opportunity to respond to the European Commissions Call for Evidence. We support the Commissions objective to improve usability of the EU Taxonomy framework by addressing practical challenges, including the interpretative difficulties of the Technical Screening Criteria (TSC). We recognise the Taxonomys essential role in supporting the green transition by defining sustainable activities.

The study on the alignment of electric buses highlighted the consideration of tires within the taxonomy exclusively through the DNSH pollution angle, based on their energy classes in terms of external rolling noise and rolling resistance. The RATP Group respectfully requests that electric bus tires also be assessed under the taxonomy through the perspective of the circular economy.

Zero Waste Europe (ZWE) welcomes the European Commissions initiative to revise the Climate and Environmental Delegated Acts. We strongly support efforts to enhance clarity, usability, and legal certainty within the EU Taxonomy. However, we underline that simplification must not come at the expense of environmental integrity.

Polluter Pays Principle in Road Transport not considered Currently Commission Delegated Regulation (EU) 2023/2486 does not consider the polluter pays principle enshrined in the Treaty on the Functioning of the European Union, Article 191.

Currently Commission Delegated Regulation (EU) 2023/2486 does not consider the polluter pays principle enshrined in the Treaty on the Functioning of the European Union, Article 191. Whereas the Commission Delegated Regulation (EU) 2023/2486 features an Annex pollution prevention and control; Whereas the Taxonomy Regulation 2020/852 explicitly defines pollution prevention and control in Article 14 as: (a) preventing…

CZGA strongly disagree with the PSF's recommendation to lower GHG thresholds for substantial contribution and do no significant harm (DNSH) for all energy activities. Suggested revision lacks a sound scientific basis and doesn´t reflect the best performance achievable under real world conditions.

Review of the EU taxonomy environmental delegated act Comment We welcome the possibility to give our comments to the EU Taxonomy Climate Delegated Act with focus on the criteria for nuclear activities. Firstly, we want to clarify that nuclear energy is not sustainable due to a wide range of reasons (amongst others unsolved nuclear waste management especially for HLW and uranium tailings, severe adverse impacts in…

Vattenfall is committed to net zero and see the EU taxonomy as one tool that can and should support this transition (in 2024 Vattenfall had 88% aligned Capex) All fossil free energy sources play vital a role in the transition together with distribution, storage and flexibility solutions. The taxonomy should be as technology neutral as possible.

The attached document presents the consolidated feedback of the Belgian Green Building Council (BGBC) on the EU Taxonomy Technical Screening Criteria related to construction and real estate activities. This work was carried out in close collaboration with all our members, representing the entire Belgian building ecosystemincluding real estate and construction stakeholders, financial institutions, and academic…

As EUPAVE, the representative organization for the concrete paving industry in Europe, we believe that some of the technical screening criteria dealing with the use of concrete for roads could be improved. So, we would like to make some specific comments on the following sections: §3.4 (p.

Nuclear Transparency Watch calls on the European Commission to: 1 - Exclude nuclear energy from the EU Taxonomy due to its unsustainable and high-risk nature. 2 - Strengthen transparency by requiring verifiable, science-based evidence for all technical screening criteria. 3 - Enforce compliance with EU and Euratom laws on nuclear safety, waste management, and public participation.

Proxima Fusion welcomes the Commissions initiative to refine and simplify the technical screening criteria of the Climate and Environmental Delegated Acts. This review offers an opportunity to address emerging technologies whose characteristics differ materially from existing categories within the Taxonomy.

EMPA considers the revision of the Climate and Environmental Delegated Acts an important opportunity to strengthen both clarity and environmental integrity within the EU Taxonomy. Shellfish farming is inherently based on the sustainable use of natural ecosystems and is fully exposed to the consequences of climate change.

The Izba Gospodarcza Ciepłownictwo Polskie requests amendments to the following provisions of point. 4.30 for high-efficiency gas cogeneration cases correlated with paragraph. 4 of Article 46 GBER by amending points (iv) and (vii) as proposed below: 4.30.

Filed in Polish · English published by the European Commission

MBB Feedback on the EU Taxonomy Public Consultation 25/11/25 The Malta Business Bureau (MBB) welcomes the opportunity to provide feedback on the revision of the Climate and Environment Delegated Acts linked to the EU Taxonomy framework. Overall, we support the proposed simplification measures aimed at reducing administrative burdens and improving reporting processes.

WISE and Greenpeace Netherlands are happy with the fact that the Commission is reviewing the delegated act under the Taxonomy Regulation, however is more than baffled by the tone of the call for evidence. It is clear that the Commission has only listened to the nuclear industry and the pro-nuclear alliance among the Member States, when formulating this call.

We welcome the possibility to give our comments to the EU Taxonomy Climate Delegated Act with focus on the criteria for nuclear activities. Firstly, we want to clarify that nuclear energy is not sustainable due to a wide range of reasons (amongst others unsolved nuclear waste management especially for HLW and uranium tailings, severe adverse impacts in case of severe accidents), and nuclear is far from being best in…

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. See the EUROMOT feedback on Taxonomy review for Marine Inland Waterway vessels.

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. See the EUROMOT feedback on Taxonomy review for Marine Seagoing Ships.

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.

The World Shipping Council (WSC) thanks the European Commission for the opportunity to participate in this call for evidence and to suggest adjustments to specific technical screening criteria, improved definitions, clearer requirements for proving compliance with criteria, removal of duplicative or disproportionate requirements, and clearer references to related EU rules.

We take a critical view of the fact that heat generation from geothermal energy (Section 4.22 Generation of heat/cooling from geothermal energy) must first prove through a life cycle assessment (LCA) that it makes a significant contribution to climate protection and sustainability.

Reclaim Finance notes the relevance of the recommendations published by the Platform on Sustainable Finance in the report "Advancing sustainable finance: Technical criteria for new activities & first review of the Climate Delegated Act" (April 2025).

Hallo, I deal with DNSH in projects related to the Recovery Fund in Italy. I support the procedure responsibles for the acquisition of goods and services. For each procedure, we have three taxonomies to take into account: NACE, CPV (Common Procurement Vocabulary), and the taxonomy related to sustainable activities.

The economic analysis in the context of sustainable finance and the decarbonisation of EU Taxonomy, enshrined in Regulation (EU) 2020/852, is a key economic tool for reorienting capital flows towards environmentally sustainable economic activities under the European Green Deal.

Filed in Czech · English published by the European Commission

Engineering, building, comissioning and servicing of plants, that are essential for the production of eligible activities, should also be eligible and hence either be included as a stand-alone economic activity or at least be included in the technical screening criteria. Example: Recycling plants and components thereof.

his paper is aimed at gathering the feedback of Atlante Marine and Bureau Veritas Marine & Offshore on the EU Taxonomy for Shipping. As daily users of the EU Taxonomy, BVS and Atlante Marine have identified flaws in its wording. We participated to DG MOVE's call for feedback allowing us to share the issues identified and some ideas for improvement. Here, we publish the feedback paper on Taxonomy for shipping.

Sysav believe that the EU Taxonomy should be one of many drivers for sustainable financing. However, under the current EU Taxonomy framework, carbon capture and storage (CCS) and carbon capture and utilisation (CCU) at waste-to-energy (WtE) plants is effectively excluded from being classified as sustainable (except for hazardous waste incineration).

Fransylva (Federation of Private Forests of France) acknowledged the opportunity to contribute to the revision and simplification of the EU Taxonomy Climate Delegated Act. Noting the current low uptake by forest owners, Fransylva wishes to highlight the advantages and practicality of building on existing tools and processes.

Filed in French · English published by the European Commission

The EU Taxonomy is not inherently technically challenging; it is legally challenging. The majority of the technical requirements can be achieved through existing frameworks and national legislation that already align with EU directives. The difficulty lies primarily in legal interpretation, inconsistencies, and the risk of contradictory guidance from the Commission.