EU taxonomy

SEA Europe comments on the EU sustainable finance platform’s draft report

On 3 August 2021, the EU Sustainable Finance Platform published a draft report by its Technical Working Group (TWG) for a call for feedback on preliminary recommendations on technical screening criteria for the remaining four environmental objectives of the EU taxonomy. The present paper contains the SEA Europe position and comments on the Platform’s draft report and recommendations.
SEA Europe’s high concerns and comments relate to the following elements of the draft report:

1. The proposed exclusion of cruises and mega-yachts as activities “non substantially contributing” to the remaining four environmental objectives of the EU taxonomy;
2. The proposed exclusion of vessels “transporting fossil fuels”;
3. The proposed pollution control’s Technical Screening Criteria (air emissions).
4. The proposed DO NOT SIGNIFICANT HARM CRITERIA (DNSH), namely the use of the tailpipe approach to ship emissions.
   By way of general comment, furthermore, SEA Europe wishes to question the rationale behind the taxonomy criteria’s exclusive focus on the product rather than the manufacturing process, i.e. why manufacturing is assessed by the emissions produced by the products and not based on the emissions of the manufacturing process.