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.

Use this FAQ to separate the legal trigger from the evidence file: covered substances, 0.1% w/w checks, suitable-alternative analysis, and controlled-conditions documentation.

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

Structured answer sets in this page tree.

Primary sources
2

Cited legal and guidance references.

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

DNSH Appendix C should be handled as a chemicals evidence question. The page below focuses on what the Commission and delegated-act text actually support: when Appendix C is triggered, which substance groups are in view, how the 0.1% w/w threshold is framed, and what evidence is needed when an operator relies on the absence of suitable alternatives and use under controlled conditions.

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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. The Commission FAQ describes it as covering the use and presence of chemicals, especially substances of very high concern and other hazardous substances referred to in EU chemicals legislation.

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 are covered by the Appendix C amendments?

The 27 June 2023 amendments revised the former "essential use for society" derogation. For point (f), the Commission FAQ says the focus is substances identified as substances of very high concern under REACH Article 57 and Article 59 procedures; those substances are found on ECHA's candidate list.

The paragraph added after point (f) covers substances meeting CLP criteria for the hazard classes or hazard categories mentioned in REACH Article 57. The Commission notes that the ECHA classification and labelling inventory includes harmonised classifications and self-classifications, and that self-classified entries may differ between undertakings and are not currently subject to verification or quality control.

  • Check REACH SVHC status against the ECHA candidate list when point (f) is relevant.
  • Check CLP hazard classification for substances covered by the paragraph added after point (f).
  • Record whether the conclusion relies on a harmonised classification, a supplier classification, or another documented classification source.
Citations
Commission FAQ on EU Taxonomy delegated acts

Commission FAQs 134 and 135 distinguish SVHCs under REACH from CLP hazard classes and categories mentioned in REACH Article 57, and point readers to ECHA's candidate list and C&L inventory.

Question 3

What evidence is needed for suitable alternatives and controlled conditions?

If a covered substance is present and an operator relies on the derogation, Appendix C is not satisfied by a bare statement that the substance is necessary. The Commission FAQ says operators have to assess and document that no other suitable alternative substances or technologies are available on the market and, if there are no such alternatives, that the substances are used under controlled conditions.

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 controlled conditions, 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 controlled conditions, 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 controlled conditions.
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 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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