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, the applicable delegated-act section, and whether the pollution-prevention DNSH row points to Appendix C.

Where it applies, Appendix C addresses chemicals in substances, mixtures, articles, final products, outputs, manufacturing, placing on the market, use, and presence. The 2023 amendment replaced the earlier essential-use framing with a test based on documented lack of suitable alternatives and use under controlled conditions.

For substances meeting the Article 57 criteria of REACH and identified under Article 59(1), Appendix C point (f) uses a concentration above 0.1% weight by weight and requires an assessment and documentation where an operator relies on the exception.

The added paragraph after point (f) extends the same 0.1% weight-by-weight concentration framing to other substances that meet specified CLP hazard classes or categories linked to Article 57 of REACH. In both cases, the exception depends on documenting that no suitable alternative substances or technologies are available on the market and that the substances are used under controlled conditions.

A defensible Appendix C file should let a reviewer trace the conclusion from the activity and delegated-act section to the chemical inventory, concentration screen, hazard classification, 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.

The most common overstatement is treating Appendix C as a pass/fail label for the whole company. It is narrower than that: the check belongs to a specific Taxonomy activity and to the substances, mixtures, articles, final products, outputs, market placement, or use covered by the applicable criterion.

Another risk is citing the old essential-use concept without explaining the 2023 amendment. The captured source says that, pending further guidance on horizontal principles for essential use of chemicals, the concept was replaced with criteria intended to be easier to verify: no suitable alternatives on the market and controlled conditions.

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 rather than substituting a policy statement. A narrow unresolved status is more useful than a broad unsupported alignment claim.