Summary
The position paper addresses the challenges posed by Appendix C of the EU Taxonomy’s “Do No Significant Harm” (DNSH) criteria on Pollution Prevention and Control (PPC). While supporting the EU’s sustainability goals, cefic argues that the current technical screening criteria (TSC) are overly complex, impractical, and impose excessive administrative burdens on the chemical industry. The paper calls for a more proportionate and workable approach, aligned with existing EU regulations such as REACH. Cefic proposes specific amendments to improve clarity, reduce legal uncertainty, and ensure the criteria are easier to implement and verify, in line with the EU’s goal to reduce corporate reporting burdens by 25%.
Key Takeaways:
- Amendments are needed to align terminology and avoid misinterpretation of manufacturing processes involving restricted substances.
- The concept of “controlled conditions” should be clarified to prevent overly strict and inconsistent interpretations.
- Paragraph f) bis should be deleted due to its disproportionate scope and lack of reliability in classification standards.