EU taxonomy


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1 green, activities, sustainable, taxonomy, does, environmentally, activity, clear
2 taxonomy, existing, important, standards, flexibility, stage, investment, provide
3 sustainable, investments, eu, finance, climate, european, financial, investment
4 energy, renewable, low, production, technologies, carbon, climate, ghg
5 environmentally, activities, sustainable, considered, economic, provide, clear, welcome
6 nace, activities, sectors, codes, products, based, services, approach
7 criteria, data, assessment, complex, challenge, qualitative, clear, detailed

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 .

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