Feedback on the usability of the taxonomy - Orgalim response

Orgalim welcomes the EU to establish a better common understanding of what economic activity should be considered as environmentally sustainable and receive priority financing in support of the EU’s wider policy objectives. However, while the proposed taxonomy might help to identify better or more environmentally sustainable activities, it will in our view face limitations in terms of providing a final conclusion. Economic activities are diverse, national contexts of economic activities may differ from country to country and technology innovation, process development and innovation continuously evolve. A “one size fits all” approach will in our view neither be useful nor establish a fair level playing field.

Sufficient flexibility would have to be built into the taxonomy to allow its continuous evolution according to scientific findings, technological progress, innovation and case by case assessments. Also, consistency between the technical screening criteria to be developed by the TEG on Sustainable Finance and the pending draft regulation on establishing the taxonomy is at this stage not ensured as the legislative process is still pending. 

To read our recommendations in full, please download the position paper above.