EU Taxonomy DNSH Appendix C

Appendix C applies only when the relevant EU Taxonomy technical screening criteria for an activity require compliance with Appendix C. The first step is therefore to identify the activity, assessed product or process, reporting period, applicable delegated-act section, and whether the pollution-prevention DNSH row points to Appendix C.

REACH is the EU Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation (EC) No 1907/2006. RoHS refers to Directive 2011/65/EU on restricting hazardous substances in electrical and electronic equipment. CLP is Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures; these names identify the separate chemicals rules referenced in the screening below.

The current Appendix C bars the activity from leading to the manufacture, placing on the market, or use of six groups: listed persistent organic pollutants, except substances present as an unintentional trace contaminant; mercury and mercury compounds, mixtures, and mercury-added products; listed ozone-depleting substances subject to stated exceptions; RoHS Annex II substances subject to listed exemptions; REACH Annex XVII substances outside the conditions in that annex; and specified candidate-list substances above 0.1% weight by weight unless the point (f) exception is documented.

Point (f) covers substances on their own, in mixtures, or in an article above 0.1% weight by weight when they meet the REACH Article 57 criteria and have been identified under Article 59(1) for at least 18 months. An operator may rely on the exception only after assessing and documenting both that no suitable alternative substance or technology is available on the market and that the substance is used under controlled conditions.

Regulation (EU) 2026/73 removed the separate paragraph that had extended a similar screen to other CLP hazard classes or categories. Do not continue that deleted Taxonomy screen as though Appendix C still required it. Separate duties under REACH, CLP, product law, permits, or other chemicals rules may still apply independently.

The Appendix C file should let a reviewer trace the conclusion from the activity and delegated-act section to the chemical inventory, point-by-point screen, concentration evidence, alternatives assessment, controlled-conditions evidence, and final approval.

The Taxonomy Regulation requires undertakings in scope of Article 8 disclosure to report how and to what extent their activities are associated with environmentally sustainable activities. Appendix C evidence should therefore be maintained in a form that supports the broader Taxonomy-alignment and KPI process, without turning an Appendix C page into a KPI calculator.

Treating Appendix C as a pass/fail label for the whole company overstates its effect. The check belongs to a specific Taxonomy activity and the manufacture, placing on the market, or use covered by the applicable criterion.

Another risk is applying the 0.1% point (f) threshold to every Appendix C category. Points (a) to (e) use their own linked legal lists, conditions, and exemptions. A third risk is keeping the deleted CLP hazard-class paragraph in a 2026 checklist because it appeared in the 2023 version.

Create an Appendix C decision record for each activity where the delegated act requires it. Keep the record narrow enough that it can be reviewed: activity, section, assessed item, substances checked, threshold result, exception evidence, owner, approval, and unresolved evidence requests.

If supplier or product evidence is incomplete, mark the Appendix C conclusion as unresolved. Do not substitute a policy statement or publish an unsupported alignment claim.