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Sustainability / ESG

Do No Significant Harm

The DNSH criterion (Do No Significant Harm) requires that an economic activity classified as environmentally sustainable does not significantly harm any of the six environmental objectives of the EU Taxonomy.

The DNSH criterion (Do No Significant Harm) is a central building block of the EU Taxonomy Regulation (Regulation (EU) 2020/852). An economic activity only qualifies as environmentally sustainable if it makes a substantial contribution to at least one of the six environmental objectives while at the same time not significantly harming any of the others. In this way, the EU Taxonomy prevents a contribution to climate change mitigation from being achieved at the cost of serious damage elsewhere – for example to water, biodiversity or the circular economy.

The six environmental objectives of the EU Taxonomy are: climate change mitigation, climate change adaptation, the sustainable use and protection of water and marine resources, the transition to a circular economy, pollution prevention and control, and the protection and restoration of biodiversity and ecosystems. For every activity covered by the delegated acts, the DNSH requirements are set out in concrete technical screening criteria – ranging from climate risk assessments and emission limits to water consumption thresholds and requirements for waste avoidance and freedom from harmful substances.

In addition to the DNSH criteria, an activity must also comply with the so-called Minimum Safeguards, including the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights. The DNSH criterion is highly relevant in practice because the taxonomy alignment of turnover, capital expenditure (CapEx) and operating expenditure (OpEx) must be disclosed as part of CSRD reporting. Without documented DNSH evidence, an activity may be taxonomy-eligible but not taxonomy-aligned.

Legal Basis

Art. 17 in conjunction with Art. 3(b) Regulation (EU) 2020/852 (EU Taxonomy Regulation); technical screening criteria in the delegated acts (incl. Regulation (EU) 2021/2139)

Practical Example

An industrial company wants to report a new production facility as a taxonomy-aligned contribution to climate change mitigation because it produces energy-efficiently. The sustainability officer therefore reviews all DNSH requirements: she commissions a climate risk and vulnerability assessment, demonstrates compliance with emission limits for pollution prevention, documents water consumption below the thresholds, and proves the contribution to the circular economy through a waste management plan. Only once all six environmental objectives and the Minimum Safeguards are documented can the facility's share of turnover be reported as taxonomy-aligned in the sustainability statement.

FAQ

DNSH stands for „Do No Significant Harm" and means that an economic activity must not significantly harm any of the six environmental objectives of the EU Taxonomy. An activity can therefore only be considered sustainable if its contribution to one objective is not made at the expense of the others.
They are climate change mitigation, climate change adaptation, water and marine resources, the circular economy, pollution prevention, and the protection of biodiversity and ecosystems. For each objective, the delegated acts define concrete technical screening criteria.
An activity is taxonomy-eligible if it is generally listed in the Taxonomy. It is only taxonomy-aligned once it additionally makes a substantial contribution, meets the DNSH criteria and complies with the Minimum Safeguards. The DNSH criterion is therefore a mandatory prerequisite for alignment.

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