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FAQDNSHAppendix C

EU Taxonomy Regulation DNSH Appendix C chemicals evidence

Appendix C is the generic DNSH test for pollution prevention and control where an activity refers to the use or presence of chemicals.

This FAQ explains the current criteria after Regulation (EU) 2026/73: listed substance groups, the point (f) 0.1% w/w test, suitable-alternative analysis, and controlled-conditions evidence.

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Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Questions
3

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

is a chemicals evidence test that applies only when an activity-specific criterion points to it. Regulation (EU) 2026/73 replaced Appendix C from 1 January 2026. The current text retains the 0.1% w/w rule for specified REACH candidate-list substances but removes the additional broad CLP hazard-class paragraph introduced in 2023.

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3 of 3 questions
Question 1

What is DNSH Appendix C under the EU Taxonomy?

Appendix C to Annexes I and II of Delegated Regulation (EU) 2021/2139 sets generic DNSH criteria for pollution prevention and control where an activity's technical screening criteria refer to that appendix. Regulation (EU) 2026/73 replaced those appendices and the corresponding appendices in the Environmental Delegated Act from 1 January 2026.

A team should therefore start by checking the activity-specific technical screening criteria. Appendix C is relevant only when that activity points to it, for example through a pollution prevention and control DNSH criterion requiring compliance with Appendix C.

  • Confirm the exact economic activity and annex section before applying Appendix C.
  • Keep the Appendix C review tied to the activity's DNSH pollution prevention and control criterion.
  • Do not turn Appendix C into a generic chemicals policy claim unless the activity-specific criteria actually call it up.
Citations
Question 2

Which substances does the current Appendix C cover?

The current Appendix C points (a) to (f) cover specified substances under the Persistent Organic Pollutants Regulation, mercury rules, the Ozone Regulation, RoHS, REACH Annex XVII, and REACH candidate-list procedures. Each point has its own conditions or exceptions, so a substance inventory should record the legal list and exception used rather than applying one generic prohibition.

Point (f) covers substances, whether on their own, in mixtures, or in an article, above 0.1% weight by weight that meet REACH Article 57 criteria and have been identified under Article 59(1) for at least 18 months. The extra paragraph that formerly extended screening to other substances based only on specified CLP hazard classes is not in the Appendix C text replaced by Regulation (EU) 2026/73.

  • Check each current point (a) to (f) against the legislation and exceptions named in that point.
  • For point (f), record candidate-list identification, the date of identification, the 18-month condition, concentration, and whether the substance is on its own, in a mixture, or in an article.
  • Do not continue the deleted broad CLP-only screen as if it remained part of Appendix C, although other applicable chemicals law and activity-specific criteria still need separate review.
Citations
Question 3

What evidence is needed for suitable alternatives and controlled conditions?

If a point (f) substance is present above 0.1% w/w and an operator relies on the exception, Appendix C is not satisfied by a bare statement that the substance is necessary. The current text requires the operator to assess and document that no other suitable alternative substances or technologies are available on the market and that the substance is used under .

For suitable alternatives, the Commission FAQ treats an alternative as suitable only if it is safer, technically feasible, economically feasible for the operator, and available. For , the FAQ points to risk assessment and management processes that minimise emissions, exposures, and resulting risks in line with existing legal requirements.

  • Document the safer, technically feasible, economically feasible, and available tests for each rejected alternative.
  • Where a REACH Annex XIV authorisation is relied on, retain the authorisation number, authorisation decision, and required compliance documents.
  • For , retain the risk assessment, risk management measures, exposure and emissions controls, and evidence of compliance with relevant legal requirements.
  • Do not rely on the 'essential use' concept as the current Appendix C derogation test; the Commission FAQ says the current conditions remain absence of suitable alternatives and use under .
Citations
Recommended next step

Turn Appendix C into an evidence file

Map the activity trigger, substance list, article and mixture threshold checks, suitable-alternative analysis, and controlled-conditions evidence before treating an activity as Taxonomy-aligned.

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Primary sources

References and citations

Commission Delegated Regulation (EU) 2023/2485
eur-lex.europa.eu
Referenced sections
  • The delegated act replaced the essential-use framing with no suitable alternatives and controlled-conditions language.
"used under controlled conditions"
Commission Delegated Regulation (EU) 2026/73
eur-lex.europa.eu
Referenced sections
  • Current binding point (f) retains the no-suitable-alternative and controlled-conditions exception for candidate-list substances above 0.1% w/w.
"no other suitable alternative substances or technologies are available on the market"
Commission FAQ on EU Taxonomy delegated acts
finance.ec.europa.eu
Referenced sections
  • Commission FAQs 136 and 137 explain the current derogation conditions and the evidence expected for suitable alternatives and controlled conditions.
"absence of suitable alternatives"
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