We welcome several important improvements included in the proposal. These include a stricter "do no significant harm" (DNSH) framework for biodiversity-particularly the clarification that activities requiring compensatory measures (offsets) cannot qualify-as well as strengthened circular economy criteria for plastic packaging and new safeguards preventing construction on sensitive land such as wetlands, peatlands, Natura 2000 grasslands and forest areas.
At the same time, we raise a number of concerns and recommendations. These relate in particular to the relaxation of DNSH criteria for hazardous substances and substances of very high concern (SVHCs), the risk of under-reporting physical climate risks in the climate adaptation screening process, and gaps in biodiversity safeguards-such as the absence of DNSH criteria for renovation activities in real estate.
In addition, we underline the practical challenges related to data availability and administrative burden, particularly for SMEs and non-listed companies. We call for clearer and more standardized indicators, greater reliance on existing documentation, and improved guidance to ensure consistent application.
We encourage the European Commission to address these points when finalising the amendments, in order to maintain the level of ambition and ensure the Taxonomy remains a robust and workable framework for sustainable investment.
