Commission delegated regulation – EU Sustainable Finance - EU classification system for green investments

ClientEarth's feedback on the EU Taxonomy draft delegated regulation emphasizes the need for science-based thresholds, the exclusion of fossil gas and hazardous chemicals, and the prevention of corporate lobbying from watering down environmental standards.

• ClientEarth supports the 100gCO2e/KWh life-cycle GHG emissions threshold for electricity generation from gaseous and liquid fuels but urges the Commission to ensure this threshold decreases every 5 years to align with a net-zero 2050 trajectory.
• The document argues that fossil gas should be directly excluded from the technical screening criteria to prevent 'fossil gas lock-in' and to reflect that burning fossil fuels is not sustainable by any reasonable standard.
• ClientEarth expresses concern that intensive lobbying by the fossil fuel gas industry may compromise the Taxonomy's credibility as a science-based market standard, potentially re-orienting capital toward long-lived gas infrastructure rather than genuinely sustainable investments.
• The organization contends that the draft delegated regulation's approach to chemicals is too weak, specifically citing the inclusion of aromatics production, styrene production, Vinyl Chloride monomer (VCM) production, and certain chlorine production as activities that should be withdrawn.
• ClientEarth criticizes the 'do no significant harm' (DNSH) criteria for chemicals and plastics for focusing only on the production process and ignoring the environmental impact of the products throughout their life cycle, which violates Article 17 of the Taxonomy Regulation.
• Regarding plastics manufacturing, ClientEarth requests that chemical recycling only be supported for degraded and contaminated plastics and only if it demonstrates substantial environmental improvement over virgin fossil fuel feedstock and mechanical recycling.
• The document warns that using the Taxonomy as a general benchmark in other EU initiatives, such as the Just Transition Fund, could create loopholes allowing unsustainable activities to be deemed sustainable if a thorough gap analysis is not conducted.

APA

ClientEarth (2020). Commission delegated regulation – EU Sustainable Finance - EU classification system for green investments. https://www.clientearth.org/media/zxalcczz/taxonomy-draft-delegated-act-public-consultation-003.pdf

Chicago

ClientEarth. Commission delegated regulation – EU Sustainable Finance - EU classification system for green investments. 2020. https://www.clientearth.org/media/zxalcczz/taxonomy-draft-delegated-act-public-consultation-003.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Commission delegated regulation – EU Sustainable Finance - EU classification system for green investments |date=December 2020 |url=https://www.clientearth.org/media/zxalcczz/taxonomy-draft-delegated-act-public-consultation-003.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2020commission, author = {{ClientEarth}}, title = {{Commission delegated regulation – EU Sustainable Finance - EU classification system for green investments}}, publisher = {ClientEarth}, year = {2020}, month = dec, url = {https://www.clientearth.org/media/zxalcczz/taxonomy-draft-delegated-act-public-consultation-003.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }