On the 27th April 2020, we have submitted our answer to the Consultation on the Taxonomy, conducted prior to the draft of the Commission’s first delegated act on climate change mitigation and adaptation activities.

EFIEES welcomes the Regulation on Sustainable Finance and the latest TEG Report of March 2020. Yet, to guarantee the success and effectiveness of the Taxonomy, we reminded the Commission that a number of key issues still need to be better addressed and further clarified:

  • The delegated act should explain and state in a clearer way that activities that are compliant with the thresholds required by the Taxonomy at time when they are evaluated as eligible, can be considered as environmentally sustainable throughout their life-time.
  • When implementing reporting obligations, it is important to consider and explore the possibilities to include sustainable activities implemented a few years before the entry into force of the Taxonomy, which fail to meet the relevant Taxonomy-thresholds, while still considerably contributing to climate change mitigation.
  • The Heating & Cooling (H&C) sector, now covered by the Taxonomy, needs to be better addressed, by making eligible a number of energy efficiency solutions, both for H&C production and distribution, and allowing for full eligibility of waste heat recovery from any origin and for any user.
  • The impact of metrics and thresholds recently revised by the TEG, should be evaluated and adapted so that the Taxonomy could fulfil its role as an incentive for mobilising green investments, even in the post-Covid-19 economic context.
  • We welcome the inclusion of Energy Efficiency Services, such as energy management and Energy Performance Contracts, among the eligible professional services in buildings and we strongly recommend their further inclusion, which should also cover industry, in the forthcoming delegated act.
  • In setting technical criteria for climate change mitigation, we finally recommend the application of “Energy Efficiency First” as the guiding principle for emissions’ reduction.
Read our position/answer
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