CONSULTATION | Only a science-based Taxonomy supports investing in sustainability
On 3 May 2023, DUFAS responded to the European Commission' consultation on the EU Taxonomy Delegated Acts as published on 5 April 2023. We believe that the European Union (EU) Taxonomy is an important and useful supporting tool for asset managers pursuing environmentally sustainable investments. Although the EU Taxonomy affects asset managers less directly than SFDR, several key challenges within the Sustainable Finance Framework could be tackled with an effective implementation of a science-based Taxonomy.
New activities and criteria should be science-based
To achieve a green and sustainable economy, the EU needs a large-scale transition involving many sectors and economic activities. To ensure that the EU Taxonomy is an objective classification of green activities, we urge that the inclusion of new activities and technical screen criteria are science-based. This is particularly important for activities whose inclusion may be more controversial such as air transport and manufacture of plastic packing goods.
Green activities and targeting high pollution sectors are both important but could be more distinct
The EU Taxonomy consists of a broad array of activities that can be labelled green. However, we note that this blurs the distinction between intrinsically green activities and activities focusing on strongly reducing negative impacts. Both are important for the transition to a sustainable economy, but acknowledging the difference within the Taxonomy could further clarify and substantiate the inclusion of different activities. This could be achieved within the Taxonomy by, for example, using the categories of enabling and transitional activities for activities focusing on reducing negative impacts.
Agriculture as missing economic activity
The activities related to the protection and restoration of biodiversity and ecosystem are highly limited, with agriculture as the main activity not included in the Taxonomy. Although currently a large source of negative environmental impacts, it is highly relevant as a potential solution to multiple objectives. We again strongly emphasize the importance of science-based criteria, especially for agriculture, to ensure the effectiveness of the EU Taxonomy.
More information
Would you like to respond, or should you have any questions? We would be pleased to hear from you. Please feel welcome to e-mail Ivan aan den Toorn, DUFAS policy advisor sustainability.
