1 A “one threshold” divides the economic activities into “environmentally sustainable” and “not environmentally sustainable’s” approach is blind to geographical situations . A carbon-only approach is misleading in many instances (e.g. favoring plastics in packaging, diesel over gasoline or nuclear power generation); the green taxonomy should be complemented with a brown taxonomy .
2 AFME welcome progress made by the TEG on the taxonomy . Alignment of the system with existing requirements and national and union legislation is essential . consistency between the technical screening criteria and the pending draft regulation is not ensured as the legislative process is still pending .
3 It is very likely that there will be inconsistences between the existing 2050 roadmap(s key technologies) and the European mitigation taxonomy . That the classification is based on the potential of investment projects, and not on generic classes of projects, so to avoid a-priori judging certain assets or sectors as “non-sustainable”
4 The regulation’s criteria should be flexible enough to fit in energy mixes of different member states . The classifications should be based on a Life Cycle Analysis, ensuring a holistic approach on the impact of various technologies on the global climate .
5 CDC supports the goal of creating a common European framework for identifying green assets . CDC would welcome the opportunity to rely on such framework to assess and report on its environmentally sustainable activities . EFAMA has been supportive since the outset of a Commission proposal for a Taxonomy .
6 The NACE code classification system is in our experience not widely used by the financial sector . Across the 24 activities initially covered, the boundaries between sector, activity, processes, technology, product, project or assets are often blurred . There is a general lack of consistency between sectors and activities .
7 There are many arbitrary assumptions in the document relating notably to the thresholds which are not based on science or policy, which should be a minimum requirement for an impactful taxonomy . A clear indication does not necessarily mean that it is relevant . A major challenge which features throughout this consultation response is around access to data .

1 There is a need for more accurate and granular definition of activities/sectors . The industry’s greatest challenge is access to reliable and useful data .
2 The lack of clear disclosure requirements makes it difficult for both investors and civil society to assess if the bond actually deserves the 'green bond' label . Veolia is very keen to see such constructive development as the action plan for sustainable finance taking place .
3 A wide range of metrics are proposed – these should be qualified with explanations setting out why it is relevant to any given activity/industrial strategy . Additional questions remain about how to manage the companies not caught in scope, or non-EU companies .
4 Any project should be considered on its individually basis, regardless of the activity or sector taken into account the capacity to reduce GHG emissions . EPRA’s main concern is r. 12 (a) “significant greenhouse gas emissions” Any kind of manufacturing activity which is in transition to decarbonisation will continue to emit greenhouse gases .
5 EAPB wonders why biomass is exluded from NACE (D)? Will this, as well as ast heat networks be part of the Heat only generation in that phase?

1 A European taxonomy on sustainable economic activities, including climate related activities, could potentially lead AFD to align the eligibility criteria associated to its climate bonds programmatic framework . A more transition-oriented approach which would include more activities (with energy efficiency or CO2 reduction trajectory by sector) would be more helpful .
2 As currently drafted and cross-referenced, both regulatory proposals could create confusion for market participants . As representative of financial services users and retail investors, we strongly support this measure . Alignment with existing legislation and simplicity is paramount .
3 At this stage the proposed taxonomy, does not help to comply with the French disclosure obligations required by the Article 173 of the French Transition Law . Also, the taxonomy is not clearly providing any guidance with regards calculation of a green share of revenues, but intends to provide useful common definition of green activities .
4 As a listed company we must comply with all applicable national and international disclosure reporting requirements . Financial companies won't be held liable for any inaccurate information that they receive from investee companies or auditing companies, which then goes forward to financial products' information .
5 An investor survey was conducted by the GBP in 2018 which gleaned responses from 51 of the largest Green Bond investors globally . A broader approach is necessary and we support the wider sustainable finance initiative .

1 A taxonomy that de facto leads to a "blacklist" can trigger herding in the capital markets, resulting in large systemic risks . A narrow taxonomy will not be a suitable base for other regulations, such as for example the Disclosure regulation, where sustainable investments are defined more broadly .
2 A one-size-fits-all model will be very difficult. Albeit complex to implement, it must be further explored with guidance . We wonder who is to decide which value is to be used? At least some of the thresholds, metrics and ‘do no significant harm’ criteria are so EU specific, that we expect it to be challenging to use them outside of the EU .
3 The future social taxonomy needs to be carefully considered and thought about in advance . The EAPB believes the taxonomy should be sufficiently inclusive, not only of economic activities, but also of solutions that contribute broadly to decarbonization . For investment purposes, “grandfathering’s” of assets once accepted as green according to taxonomy .
4 Adopting a process instead of pre-defined criteria would allow for more regional adaptation and focus on issues relevant in the given context . Consideration should also be given to the impacts and the benefits of a single project without a priori hindering access to finance for certain assets/companies .
5 As it is designed now, the Regulation could potentially negatively impact the financing conditions for many activities, which can contribute to climate change mitigation and the transformation to a more sustainable economy . Natural gas, power-to-gas and hydrogen may become less attractive for investors .
6 The regulation should adopt of an inclusive approach that takes into consideration all technologies that could play a role in the energy transition . Activities aimed at reducing the GHG emissions of emissions-intensive sectors are of utmost importance and could be accorded a lighter treatment .
7 Investors are keen to use the taxonomy as a tool in corporate engagement activities . It needs to be ensured that the list is comprehensive and complete from the beginning, as well as its purpose .
8 The Taxonomy should avoid “one-size fits all” approach, as there are different local and regional circumstances which can significantly impact the meaning of the “sustainable activity” E.g. the need to use fertilizers depends on the area, species and other circumstances . For ‘somewhat green” activities it may for example be sufficient to fulfill some qualitative or simple quantitative criteria, while ‘exceptionally green’ activities could be expected
9 Given the global scope of sustainability issues, it is important that the EU taxonomy is adaptable to economic activities and investments on a global basis . EU institutions should promote actively the use of the taxonomy approach in third-countries with non-EU policymakers .
10 Article 4 of the Taxonomy says that investors shall identify the “share” of an investment that is ‘funding environmentally sustainable economic activities’ It would currently be difficult to identify the share of investment funded by these activities due to the lack of data .

1 The taxonomy needs to relate to already existing taxonomies in an appropriate and usable manner . Make a clear distinction between processes/activities (how) and products/services (what) More clarity is needed with regards to the territorial scope .
2 Classification of the economic sectors should give a clear guidance and avoid confusion that might come from the criteria currently used by independent certification entities . The taxonomy should also consider the different size of investments as the small-scale investments don’t have the same capability to make as detailed investigations as larger actors .
3 It is essential that the taxonomy is built on science-based criteria developed and monitored by experts in order to avoid dysfunctionality due to certain political or ethical beliefs . Taxonomy should provide for a flexible framework to ensure the evolution of the Taxonomy in line with market innovation and technological and scientific developments .
4 A clear focus on the climate targets with minimized environmental impact must influence the work on the taxonomy at all stages . Stricter metrics and fuller disclosure is required to prove climate additionality for these projects . Linking the EU’s policy objectives, and its energy, climate and environment objectives in times of implementing the Paris Agreement, is a strong market and investment signal that can trigger true change in the market if properly designed .
5 EU taxonomy will enable various types of rail projects (vehicle and infrastructure) to be eligible for green bond financing . Real estate is the biggest green bond sector in the Nordics .
6 An appropriate definition of sustainable taxonomy should allow integration subject to conditions yet to be determined . The taxonomy needs to promote more governance and social related aspects of sustainability such as local investments facilitated by cooperative banks .
7 The development of a decision tree could facilitate the classification of activities . The proposal should specify which other classification systems will be used in cases where NACE does not suffice . Practical implications should be well communicated .
8 An asset shortage limits the possibilities to launch mainstream products and promoting sustainability to consumers/investors . Any framework for investing in sustainable investments should primarily serve to facilitate investment of this type, improve transparency and improve transparency .
9 A more simplified approach could protect against greenwashing and encourage a stream of new green projects to be funded . A purely binary consideration between “green” & “brown” activities does not sufficiently represent the reality of economy & society . From the proposal it is not clear how to technically account for ‘greening” projects .
10 Higher degree of transparency is a must. how a company with several NACE codes should be treated and how information disclosed . According to article 4 the financial actors should publish information how the investment fulfills the set criteria in article 3 and Commission would be entitled to give more detailed reporting requirements .