EUU, Alm.del - 2024-25 - Bilag 345: Notat samt høringssvar vedr. revision af de delegerede retsakter under EU-taksonomien

Europaudvalget 2024-25
EUU Alm.del Bilag 345
Offentligt

MINISTER FOR INDUSTRY,

BUSINESS AND FINANCIAL

AFFAIRS

Response from the Danish Government to the Commission’s

omni-

bus simplification package to Commission Delegated Regulation on

the EU Taxonomy

Thank you for the opportunity to respond to the public consultation on

the Commission’s Delegated Regulation on the EU Taxonomy, as part

of the omnibus simplification package.

Denmark supports an ambitious approach to sustainable finance

–

a cor-

nerstone in

the green transition and in supporting the EU’s commitment

to reach the objectives of the European Green Deal.

The EU Taxonomy is a key element

of the EU’s sustainable finance

framework and a useful transparency tool. It helps direct investments to

the economic activities most needed for the transition, in line with the

European Green Deal objectives. However, regulatory and market de-

velopments call for a simplification and improvement of reporting re-

quirements to strengthen European competitiveness and support capital

flows to the green transition and sustainable development. The dele-

gated regulation under the EU Taxonomy helps preventing greenwash-

ing by providing a common language for what is considered sustainable.

Consistency across regulation and balance between benefits and

burdens

Ensuring consistency across regulation should be a particular focus in

the simplification of the Delegated Regulation on the EU Taxonomy.

Ensuring consistency between the Corporate Sustainability Reporting

Directive (CSRD), the Corporate Sustainability Due Diligence Di-

rective (CSDDD), the Sustainability-related disclosure in the financial

services sector (SFDR), and the EU Taxonomy is of particular im-

portance. This also includes a full alignment between the EU Taxonomy

and the Capital Requirement Regulation (CRR) concerning the calcula-

tion of the Green Asset Ratio (GAR) for credit institutions.

It is essential to find the right balance between investor protection and

the need for credible data, on the one hand, and to avoid disclosure re-

quirements, which do not create sufficiently added value for investors

and consumers, on the other hand.

Reporting

The content and presentation of information to be disclosed in accord-

ance with the Delegated Regulation should be simplified and improved

to reduce undue reporting burdens and duplicative reporting. Denmark

particularly supports the proposal for a simplification of the general re-

porting templates (resulting in a reduction of reported data points).

MINISTRY OF INDUSTRY,

BUSINESS AND FINANCIAL

AFFAIRS

Slotsholmsgade 10-12

DK-1216 Copenhagen K

Denmark

Tlf.

Fax

+45 33 92 33 50

+45 33 12 37 78

CVR-nr. 10092485

EAN nr. 5798000026001

[email protected]

www.em.dk

EUU, Alm.del - 2024-25 - Bilag 345: Notat samt høringssvar vedr. revision af de delegerede retsakter under EU-taksonomien

Denmark also supports the introduction of a 10 pct. de minimis thresh-

old (resulting in a reduction of undertakings that need to assess their

activities). However, it is crucial that the simplification does not lead to

a lack of transparency regarding significant environmental impacts.

The simplification and improvement should be done in a balanced way

which does not compromise the purpose of the Taxonomy Regulation,

and the essential elements associated with environmentally sustainable

economic activities. Simplification should not reduce transparency to

such an extent that it hinders companies, investors, and authorities from

effectively accessing and interpreting sustainability data.

DNSH criteria for pollution prevention and control regarding use and

presence of chemicals

Denmark supports a revision of the do no significant harm (DNSH) cri-

teria for pollution prevention and control regarding use and presence of

chemicals

Denmark does not support option 1 or option 2 as it does not

fully solve the issue of reducing the administrative burden and creating

a level playing field.

We propose that there should be only one criterion for European compa-

nies, based on whether businesses in the EU comply with the REACH

candidate list—answered with a simple yes or no. Otherwise, it would

lead to increased administrative burdens for companies, which is not ac-

counted for in Option 1 or Option 2.

In this complex legal area, we urge the Commission to be mind-

full of burdens associated with new regulation or changes to existing

regulation. It should be ensured that benefits and burdens of new re-

quirements are balanced. Hence, we call on the Commission to conduct

impact assessments, including of the burdens and the environmental

consequences, but it is essential

that they don’t delay the process.

The

current principles and transparency requirements should remain.

We are at your disposal for any questions or comments you might have,

and we look forward to a fruitful dialogue.