Swedish Enterprise on the technical screening criteria linked to environmental objectives 3–6

The Confederation of Swedish Enterprise presents overarching comments to the Platform’s proposals for technical screening criteria linked to environmental objectives 3–6, which are: Sustainable use and protection of water and marine resources; Transition to a circular economy; Prevention and limitation of environmental pollution; and Protection and restoration of biodiversity and ecosystems.

First, it is vital that the taxonomy commands a high level of credibility and legitimacy. Swedish Enterprise welcomes initiatives that support investment that contribute to sustainable development, facilitate climate adaption, and improve opportunities for companies that are in the forefront of sustainability. The EU taxonomy for sustainable activities is a key part of this. However, the taxonomy is so far incomplete and its significance for the green transition and for the economy is still unproven.

Swedish Enterprise opposes the integration of the technical screening criteria into other current or future regulations, as this would give the taxonomy a disproportionately large influence over what is considered sustainable or not. This is further well beyond the initially stated area of use.

Swedish Enterprise would like to emphasise the importance of unambiguous and realistic wordings of the objectives, in order to create incentives for fulfilment. As the objectives and criteria for the taxonomy are being developed, it is essential that continuous economic development and the ongoing and forthcoming transition of sectors are considered and supported. Swedish Enterprise also wants to highlight the importance of the objectives set within the taxonomy, which will be concluded through delegated acts, as a principle should be based on previously adopted objectives that have been settled in an open and transparent legislative process.

Unfortunately the process for developing criteria for the environmental objectives has not worked satisfactorily. The Platform’s proposals have been drafted in an extremely short period of time and by a small, selected group. When these types of important criteria are established – that can have a considerable impact on where investment is made in the future – it is vital that criteria are science-based, realistic, relevant, accurate, and clearly lead to the achievement of established objectives. To achieve this the business community needs to be able to participate to a greater extent in the process.

The Confederation of Swedish Enterprise urges the Commission to discuss the formulations of the objectives and the corresponding technical screening criteria with the wider business community before presenting its proposal.

In the consultation response below, Swedish Enterprise raises more detailed comments about proposed environmental objectives and technical screening criteria.