We do not support tightening existing greenhouse gas (GHG) thresholds. The priority should be to ensure consistent interpretation and proper application of current criteria. Tightening thresholds would not enhance implementation or competitiveness but rather increase administrative burden and uncertainty.
Before considering new thresholds, the Commission should carry out a full impact and life cycle assessment proving the feasibility of stricter limits under current technologies. Companies have only recently aligned their reporting with existing criteria, and constant revisions undermine legal certainty, delay investment decisions and slow the transition to climate neutrality.
Energy investments have long lifecycles. Revising GHG thresholds mid-project could create major practical and financial difficulties. Older solar panels or hydropower plants cannot be retroactively adjusted for new limits, so grandfathering must apply to preserve investor confidence.
For bioenergy, the GHG emission savings threshold should align with the Renewable Energy Directive (RED), recognised as the correct reference in EU case law. Since the Commission will evaluate RED III in 2026, revising the Taxonomy beforehand would be premature.
Tightening bioenergy threshold should not proceed without accurate modelling of the effects on feedstocks and installations. Stricter limits could reduce the use of low-value biomass fractions that should increase according to the cascade principle and limit the flexibility of CHP plants in regions with variable heat demand.
The description of bioenergy activities should be revised to more clearly reflect the purpose of the Taxonomy. The term “exclusively” used in the descriptions causes interpretative challenges among operators and it should be changed to indicate that the taxonomy accepts energy production with bioenergy regardless of any other fuels that may also be used. Also some of the bioenergy DNSH criteria should be clarified.
On hydropower, DNSH criteria are overly specific, and unnecessarily more stringent than other water-related activities of which the DNSH simply refer to the Water Framework directive (WFD). We therefore recommend that the DNSH criteria of hydropower be based on adherence to principles and requirements of the WFD as implemented in member states. Compliance with the WFD should be sufficient for DNSH alignment under Taxonomy also for pumped-hydropower storage connected to a river body.
For electricity transmission and distribution, the paragraph excluding infrastructure connected to plants emitting over 100g CO₂e/kWh should be deleted. DSOs and TSOs are legally obliged to connect all users and cannot influence the generation mix. Linking their Taxonomy eligibility to connected producers’ emissions creates unnecessary burdens and could even penalise renewable connections.
Electricity networks are neutral enablers of a cost-efficient and carbon-neutral transition.
Companies in Finland can operate with the existing sustainability criteria of nuclear energy. If the Commission reopens sustainability criteria for nuclear energy, nuclear should be reclassified from a transitional to a fully sustainable activity, with sunset clauses and the ATF requirement removed.
Electric boilers should be added to the Taxonomy under climate change mitigation. They cut emissions in district heating and industry by using renewable electricity and supporting system flexibility. Electric boilers use surplus renewable power, enable heat storage, and complement heat pumps by boosting temperatures with excess industrial heat, improving efficiency and reducing fossil fuel use.
Please see the attachment for more detailed proposals.
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