The DNSH principle (Do No Significant Harm) has become a key element of Taxonomy's environmental regulation, as it focuses on avoiding significant negative impacts on the environment and society. The European Taxonomy Regulation for Sustainable Activities is one of the most important initiatives of the European Union to address the challenges of climate change and the transition towards a sustainable economy.
What is the DNSH principle?
The DNSH (Do No Significant Harm) principle is a fundamental concept in the Taxonomy regulation (EU 2020/852), which establishes a set of criteria to determine whether an economic activity can be considered sustainable or not. This regulation is directly related to compliance with ESG criteria. To meet the Taxonomy regulation, it is mandatory to comply with the DNSH principle, along with two other principles (substantial contribution and minimum social safeguards).
Specifically, the DNSH is developed in Article 17 of the Taxonomy regulation and refers to the assessment of the environmental and social impacts of economic activities, with the objective of ensuring that no significant harm is caused. It is a precautionary principle that focuses on avoiding negative impacts, rather than trying to repair them after they have occurred.
Moreover, compliance with the DNSH is crucial for obtaining European aid, especially in the case of Spain, where it is channelled through the Recovery, Transformation and Resilience Plan, promoted by the next Generation EU funds. Compliance with DNSH is a mandatory criterion for all actions included in this plan.
The 6 environmental objectives of the DNSH
The way in which the Taxonomy regulation determines whether an activity is considered sustainable or not is on the basis of 6 environmental objectives or technical selection criteria.
DNSH considers that significant harm is being done to these objectives when:
| Environmental objective | It is considered that significant harm is being done |
| 1. Mitigation of climate change | When the activity results in considerable greenhouse gas emissions. |
| 2. Adaptation to climate change | When the activity causes an increase in the adverse effects of current and future predicted climatic conditions. |
| 3. Sustainable use and protection of water and marine resources | When the activity is detrimental to the good status or good ecological potential of water bodies or the good ecological status of marine waters. |
| 4. Transition to a circular economy |
When the activity generates significant inefficiencies in the use of materials or in the direct or indirect use of natural resources in one or more phases of the life cycle of the products. Or that the activity results in a significant increase in the generation, incineration, or disposal of waste, except for the incineration of non-recyclable hazardous waste. Or that long-term waste disposal may cause significant and long-term harm to the environment. |
| 5. Prevention and control of pollution | When the activity results in a significant increase in the emissions of pollutants into the atmosphere, water, or soil, compared to the situation existing before the start of the activity. |
| 6. Biodiversity protection and recovery | When the activity is largely detrimental to the good conditions and resilience of ecosystems, or detrimental to the conservation status of habitats and species, particularly those of interest to the Union. |
The regulation also states that, when assessing an economic activity, the environmental impact of both the activity itself and the products and services generated must be considered throughout their life cycle, especially in terms of production, use and end-of-life.
Measurement of pH in contaminated waters
It should be noted that we will have to meet 5 of the 6 environmental objectives at the level of “do no significant harm” (DNSH), as for one of the objectives we will have to make a substantial contribution.
How DNSH is applied in the building industry
As stated in the article on Taxonomy in the building industry, the Taxonomy regulation differentiates between 4 different types of activities in the building industry. The most important and the ones we focus on are the first three: construction of new buildings (NC), renovation of existing buildings (RH) and Acquisition and Ownership of Buildings (EX).
The DNSH principle should be applied as follows in these three types of sector activities:
NC: New Construction / RH: Refurbishment / EX: Existing Buildings
| ENVIRONMENTAL OBJECTIVE | NC | RH | EX |
| MITIGATION OF CLIMATE CHANGE | |||
| 1. The primary energy demand does not exceed the threshold set in relation to the requirements for nearly zero-energy buildings (CTE HE) and must be certified by an energy efficiency certificate (EEC). | ✔ | ✔ | ✔(*) |
| ADAPTATION TO CLIMATE CHANGE | |||
| 1. Climate risk assessment | ✔ | ✔ | ✔ |
| 2. Vulnerability analysis against climate risks | ✔ | ✔ | ✔ |
| 3. Application or planning of solutions | ✔ | ✔ | ✔ |
| 4. Alignment of solutions with third parties | ✔ | ✔ | ✔ |
| 5. Alignment of solutions with other strategies and use of nature-based solutions (NBS) or blue or green infrastructure | ✔ | ✔ | ✔ |
| SUSTAINABLE USE AND PROTECTION OF WATER AND MARINE RESOURCES | |||
|
1. Reduce the water use of sanitary fixtures (non-residential buildings only) ▪ Taps for washbasins and kitchens: 6 l/min ▪ Showers: 8 l/min ▪ Toilets: 6/3.5 litres ▪ Urinals: 2 litres/cup/hour and discharge volume of 1 litre |
✔ | ✔ | ✖ |
| 2. Protect the quality and water use on site | ✔ | ✖ | ✖ |
| TRANSITION TO A CIRCULAR ECONOMY | |||
| 1. 70% (by weight) of non-hazardous construction and demolition waste must be reused, recycled, or recovered (including backfilling) | ✔ | ✔ | ✖ |
| 2. Application of the EU Construction and Demolition Waste Management Protocol | ✔ | ✔ | ✖ |
| 3. The buildings are designed to be more resource-efficient, adaptable, flexible, and deconstructed | ✔ | ✔ | ✖ |
| PREVENTION AND CONTROL OF POLLUTION | |||
| 1. Use of components and construction materials without hazardous substances | ✔ | ✔ | ✖ |
| 2. Use of components and construction materials in contact with occupants, with limited emissions of formaldehyde and VOCs | ✔ | ✔ | ✖ |
| 3. Investigation of contaminants in potentially contaminated sites | ✔ | ✖ | ✖ |
| 4. Reduction of noise, dust, and pollutant emissions during construction or maintenance work | ✔ | ✔ | ✖ |
| PROTECTION AND RECOVERY OF BIODIVERSITY AND ECOSYSTEMS | |||
| 1. Biodiversity Strategy or Biodiversity Management Plan | ✔ | ✖ | ✖ |
| 2. Land management | ✔ | ✖ | ✖ |
(*) In the case of the DNSH for Climate Change Mitigation of Existing Buildings (EX), its application is different from that of new buildings and retrofitting. In their case, the DNSH is complied with from the following points:
- The building is not intended for the extraction, storage, transport or manufacture of fossil fuels.
- Buildings constructed before 31 December 2020: energy performance certificate class A, or the building must be in the top 30% of the most energy-efficient buildings in the national or regional bulding stock in terms of primary energy demand by differentiationt at least between residential and non-residential buildings.
- Buildings constructed after 31 December 2020: they must comply with the requirements of CTE DB-HE for new buildings.
In conclusion, understanding how to apply the DNSH principle is essential to comply with the Taxonomy regulation, which in turn relies on ESG criteria. The business fabric must adapt its business model to ensure it advances in line with these regulations and commits to long-term sustainability. Zero Consulting provides all the necessary calculations to evaluate and justify compliance with the requirements established in the Taxonomy regulation and ESG criteria.
