EU Sustainable Finance Taxonomy Regulation
What does the regulation mean for reporting life-cycle GHG emissions for buildings and construction-related sectors
The EU Sustainable Finance Taxonomy creates a classification system of sustainable activities and will help to transform investment and sustainability reporting to help the EU reach its target of carbon neutrality by 2050. Taxonomy is now legally binding.
The EU Sustainable Finance Taxonomy (shortened to the Taxonomy), or Regulation (EU) 2020/852 is a sustainability classification system for economic activities and sectors essential to climate change mitigation and adaptation.
Taxonomy was made legally binding on 3 June 2021 and technical screening criteria were issued 9 December 2021 for climate change mitigation and adaptation in Commission Delegated Regulation (EU) 2021/2139 of 4 June 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives.
It makes it possible to distinguish sustainable activities for the purposes of compliance and to identify sustainable investments. In essence, it provides sector-specific sustainability benchmarks.
The Taxonomy is an essential tool for all types of investors and financial market participants (asset owners, asset managers, insurance companies and banks) as well as listed companies and large companies operating in the Taxonomy-covered sectors with business in the European Union, and those raising a significant amount of funding from the European Union.
The Taxonomy is the underpinning technical method for a number of key regulations, as shown below.
Role of the Taxonomy
|Sustainable Finance Disclosure Regulation (SFDR)||Compulsory for financial market participants as of 10 March 2021|
|Green Bond Standard (GBS) and the EU Green Bond Framework||EU Taxonomy requirements used to define eligibility criteria|
|Non-Financial Reporting Directive (NFRD)||Supports reporting requirements|
|Task Force on Climate-related Financial Disclosures (TCFD)||Disclosures need to be aligned with the Taxonomy|
|European Green Deal||A tool to scale up sustainable investment to implement the EU Green Deal|
Read more about the growing number of other policies and legislation regulating embodied carbon in construction here.
In order to be Taxonomy-eligible, an economic activity must contribute substantially to at least one of the six environmental objectives of the European Green Deal and do no significant harm to the others, as well as meeting minimum social safeguards.
- Climate change mitigation
- Climate change adaptation
- Sustainable use and protection of water and marine resources
- Transition to a circular economy
- Pollution prevention and control
- Protection and restoration of biodiversity and ecosystems
The requirements have so far been regulated for climate change mitigation and adaptation, and are forthcoming for the rest. The technical screening criteria for the Taxonomy have been developed by the EU Technical Experts Group, and are continuously updated by the independent platform on sustainable finance.
The Taxonomy has been in force since 12 July 2020 and the screening criteria were set in law on 9 December 2021. Businesses are required to disclose their activities compliance for the calendar year 2021 with criteria for climate change mitigation or adaptation during 2022. Reporting needs to eventually cover all six environmental objectives, even if technical criteria for all are not present.
Taxonomy requirements for companies and financial market participants
The Taxonomy affects companies offering financial products, including pension funds, and non-financial companies with over 500 employees (as covered by the EU Non-Financial Reporting Directive), and EU member states setting public measures, standards or labels for green financial products or green corporate bonds.
All companies subject to the Taxonomy will need to describe how and what share of their activities are Taxonomy-aligned for the financial year 2021 to be reported during year 2022. For non-financial companies, the disclosure must include:
- the proportion of turnover aligned with the Taxonomy; and
- the amount of capital expense (capex) and, if relevant, operating expense (opex) aligned with the Taxonomy.
Financial market participants subject to the Taxonomy are required to complete their first disclosures for the activities that substantially contribute to climate change mitigation and/or adaptation, by the end of 2021. For each relevant product, the financial market participant is required to state:
- how and to what extent they have used the Taxonomy in determining the sustainability of the underlying investments;
- to which environmental objective(s) the investments contribute; and
- the proportion of underlying investments that are Taxonomy-aligned, expressed as a percentage of the investment, fund or portfolio. This disclosure should include details of the respective proportions of enabling and transition activities, as defined under the Regulation.
This article does not cover issuance of bonds under the Green Bond Standard, which can be carried out by both public and private organisations.
Screening criteria for climate change mitigation and adaptation
The Taxonomy focuses on seven main sectors, Manufacturing, Buildings, Energy, ICT, Agriculture, Water and Transport. The Taxonomy sets Do No Significant Harm (DNSH) requirements for each type of activity. Only the life-cycle emissions linked requirements are outlined below.
1. Construction of new buildings
Substantial contribution to climate change mitigation (criteria set in law)
* For buildings larger than 5000 m2, the life-cycle Global Warming Potential (GWP) of the building resulting from the construction has been calculated for each stage in the life cycle and is disclosed to investors and clients on demand. The methodology must follow EN 15978:2011 and cover the scope of Level(s) framework for indicator 1.2.
Substantial contribution to the transition to a circular economy (preliminary criteria)
A life cycle assessment of the entire building or of the renovation works has been calculated according to Level(s) and EN 15978, covering each stage in the life cycle and the results are disclosed to investors and clients on demand. The methodology must follow EN 15978:2011 and cover the scope of Level(s) framework for indicator 1.2.
The asset contains at least 30% (by weight) of recycled content, re-used content, re-manufactured content and/or by-products, provided that the CO2 emissions generated through the production process and the transportation of the recycled or re-used material are not higher than the CO2 emissions generated through the production process and the transportation of virgin material.
This refers to construction and real estate activities, also when used in other sectors.
2. Construction of civil engineering objects
Regulation issued on 3 June 2021 / C(2021) 2800 final has the following provisions
The infrastructure has been climate proofed in accordance with the appropriate climate-proofing practice that includes carbon footprinting and clearly defined shadow cost of carbon. Such carbon footprinting covers scope 1-3 emissions and demonstrates that the infrastructure does not lead to additional relative greenhouse gas emissions, calculated on the basis of conservative assumptions, values and procedures.
Technical screening criteria 9 December 2021 (EU) 2021/2139
These criteria do not contain specific provisions for infrastructure carbon management.
Substantial contribution to climate change mitigation
- Basic construction materials, including, cement, aluminium, iron and steel apply manufacturing GHG emissions thresholds compatible with the EU Emission Trading system mechanism using the physical measurement of emissions (2019/331)
- The manufacturing of energy efficiency equipment for buildings applies thresholds set using product category specific energy efficiency classes and U-values
A number of other key manufacturing sectors, including other low carbon technologies, hydrogen, organic basic chemicals and plastics in primary form apply a limit on life-cycle GHG emissions (refer to calculation method later)
4. Electricity, gas, steam and air conditioning supply
Substantial contribution to climate change mitigation
Most energy renewable energy generation mechanisms, including electricity from hydropower, geothermal energy, renewable non-fossil gaseous and liquid fuels, co-generation from geothermal energy, and production of heat/cool from geothermal energy apply a life-cycle GHG emissions limit of 100gCO2e/kWh (refer to calculation method later)
5. Innovative technologies
Substantial contribution to climate change mitigation
- Both near-market research, development and innovation as well as research, development and innovation for direct air capture of CO2 are also benchmarked based on life-cycle GHG emissions but no limits are set.
Meeting the Taxonomy screening criteria
The criteria are based on cumulative versions of the Taxonomy, including Annex I of the Delegated Act, published on 21 April 2021, Annex II to the Delegated Act published on 3 June 2021, and Part B – Annex: Full list of Technical Screening Criteria August 2021 (consultation version). The accounting criteria are as follows:
|New building construction
For climate change mitigation for buildings over 5000 m2, for transition to a circular economy for all buildings.
|The GWP calculated for each life cycle stage as kgCO2e/m2/a (of useful internal floor area) averaged for one year for a study period of 50 years. The data selection, scenario definition and calculations are in accordance with EN 15978:2011. The scope as defined in the Level(s) EU framework for indicator 1.2.||None currently||None currently|
|Civil Engineering Works
For climate change mitigation (3 June 2021 text only)
|The infrastructure has been climate proofed using carbon footprinting and clearly defined shadow cost of carbon. Such carbon footprinting covers scope 1-3 emissions and demonstrates that the infrastructure does not lead to additional relative greenhouse gas emissions, calculated on the basis of conservative assumptions, values and procedures.||None currently||Yes, must not grow relative emissions versus the status quo|
|Renewable energy generation
Including electricity from hydropower, geothermal energy, renewable non-fossil gaseous and liquid fuels, co-generation from geothermal energy, and production of heat/cool from geothermal energy.
Quantified life-cycle GHG emission savings are verified in line with Article 30 of Directive (EU) 2018/2001 where applicable, or by an independent third party.
|Third-party verification required||Mostly, < 100gCO2e / kWh|
Low carbon technologies, hydrogen, organic basic chemicals and plastics in primary form for climate change mitigation.
|Life-cycle GHG emissions calculated using Commission Recommendation 2013/179/EU tai ISO 14067:2018 tai ISO 14064-1:2018.||Third-party verification required||Varies by product|
How can One Click LCA help?
One Click LCA supports these Taxonomy-relevant sectors with the following tools:
- New building construction: One Click LCA for Buildings, EN 15978 and Level(s) tools, also with One Click LCA Carbon Designer
- Civil engineering works: One Click LCA for Infrastructure ja GHG-raportointi
- Manufacturing: One Click LCA EPD generaattorin, using ISO 14067
- Renewable energy generation: One Click LCA EPD Generator, using ISO 14067
Given that the Taxonomy thresholds are based on best practices, and they can be updated by the implementation advisory body, the Sustainable Finance Platform, for example, it is likely that more stringent requirements are issued in the coming years.
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