‘Do No Significant Harm’

The “do no significant harm” principle is related with one of the 6 European Commission’s priorities for 2019-24, “The European Green Deal45762-200. This priority translates the strategy of the European Commission (EC) to reach the compromises of the 2030 Agenda for Sustainable Development (the ‘2030 Agenda’), which is based on the Sustainable Development Goals (SDGs), and the compromises of the Paris Agreement 45762-200.

Besides promoting initiatives that directly and actively target those goals, the European Union (EU) wants to make sure all other projects will not hinder such goals. The Regulation (EU) 2020/852 sets the EU taxonomy for sustainable activities, which is a guide for people and companies to know if their activities can be considered sustainable. The “do no significant harm” principle means that activities cannot have the consequences set in Article 17, as follows:

(Beginning of quote)

Article 17

Significant harm to environmental objectives

1. For the purposes of point (b) of Article 3, taking into account the life cycle of the products and services provided by an economic activity, including evidence from existing life-cycle assessments, that economic activity shall be considered to significantly harm:

(a) climate change mitigation, where that activity leads to significant greenhouse gas emissions;

(b) climate change adaptation, where that activity leads to an increased adverse impact of the current climate and the expected future climate, on the activity itself or on people, nature or assets;

(c) the sustainable use and protection of water and marine resources, where that activity is detrimental:

    (i) to the good status or the good ecological potential of bodies of water, including surface water and groundwater; or
    (ii) to the good environmental status of marine waters;

(d) the circular economy, including waste prevention and recycling, where:

(i) that activity leads to significant inefficiencies in the use of materials or in the direct or indirect use of natural resources such as non-renewable energy sources, raw materials, water and land at one or more stages of the life cycle of products, including in terms of durability, reparability, upgradability, reusability or recyclability of products;
(ii) that activity leads to a significant increase in the generation, incineration or disposal of waste, with the exception of the incineration of non-recyclable hazardous waste; or
(iii) the long-term disposal of waste may cause significant and long-term harm to the environment;

(e) pollution prevention and control, where that activity leads to a significant increase in the emissions of pollutants into air, water or land, as compared with the situation before the activity started; or

(f) the protection and restoration of biodiversity and ecosystems, where that activity is:

    (i) significantly detrimental to the good condition and resilience of ecosystems; or
    (ii) detrimental to the conservation status of habitats and species, including those of Union interest.

2. When assessing an economic activity against the criteria set out in paragraph 1, both the environmental impact of the activity itself and the environmental impact of the products and services provided by that activity throughout their life cycle shall be taken into account, in particular by considering the production, use and end of life of those products and services.

(End of quote)

What does this mean for project proposals? It means that in the application form applicants have to show that their project activities do not match those set in Article 17. For example, if an activity would require coal to be burnt, then such activity will match point 1.(a) – therefore, it would violate the “do no significant harm” principle. What to do? Replace such activity or find a solution that does not imply burning coal.

The EU Taxonomy Compass 45762-200 is currently being developed to help people with this.

For more detailed information:

  • Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088 45762-200
  • EU taxonomy for sustainable activities | European Commission website 45762-200
  • Frequently asked questions: What is the EU Taxonomy and how will it work in practice? 45762-200

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