We use privacy-by-default, cookieless analytics.

Optional analytics cookies are used only if you accept them.

Read our Terms of Use and Privacy Policy.

FAQDNSHAppendix C

EU Taxonomy Regulation DNSH Appendix C chemicals evidence

Appendix C is the generic do no significant harm (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.

Back to main artifactReview sources
Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
4 sections3 primary sources
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% weight-by-weight (w/w) rule for specified substances on the candidate list under REACH, the Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation. It removes the additional broad hazard-class paragraph introduced in 2023 under the Classification, Labelling and Packaging (CLP) Regulation.

Search this module

Find a question or answer quickly

4 of 4 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.
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 (POPs) Regulation, mercury rules, the Ozone Regulation, the Restriction of Hazardous Substances (RoHS) rules, 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.
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 .
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.

Research workflow
Open Research Copilot

Answer EU Taxonomy implementation questions with cited source material.

Explore next step
Talk to Sorena
Discuss EU Taxonomy implementation

Review scope, source evidence, and next implementation steps with Sorena.

Explore next step
Question 4

Questions and answers

When does Appendix C apply?

Appendix C applies only when the activity-specific technical screening criteria point to it. It is the generic DNSH test for pollution prevention and control where the activity refers to the use or presence of chemicals, so teams should confirm the exact economic activity and annex section first.

Which chemicals are in scope?

The current Appendix C has six points covering specified substances under the POPs Regulation, mercury rules, the Ozone Regulation, RoHS, REACH Annex XVII, and REACH candidate-list procedures. Point (f) applies above 0.1% w/w to substances meeting REACH Article 57 criteria and identified under Article 59(1) for at least 18 months. Regulation (EU) 2026/73 removed the former additional broad CLP hazard-class paragraph.

What evidence should we keep if we rely on the derogation?

Keep documentation showing 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 . Retain the risk assessment, risk management measures, exposure and emissions controls, and any REACH authorisation documents that support the conclusion.

Primary sources

References and citations

Commission Delegated Regulation (EU) 2026/73
eur-lex.europa.eu4 citations
Referenced sections
  • Current binding Appendix C text from 1 January 2026, including points (a) to (f), updated legal references and exceptions, the point (f) 0.1% w/w rule, and removal of the former broad CLP hazard-class paragraph.
  • Current binding text replacing Appendix C in the Climate and Environmental delegated acts from 1 January 2026.
  • Current binding Appendix C text listing points (a) to (f), retaining the 0.1% w/w candidate-list substance rule and omitting the former additional CLP hazard-class paragraph.
Show 1 more
  • Current binding point (f) retains the no-suitable-alternative and controlled-conditions exception for candidate-list substances above 0.1% w/w.
"Appendix C to Annex I to Delegated Regulation (EU) 2021/2139 is replaced"
More quoted passages
"GENERIC CRITERIA FOR DNSH TO POLLUTION PREVENTION AND CONTROL REGARDING USE AND PRESENCE OF CHEMICALS"
"in a concentration above 0,1 % weight by weight (w/w)"
"no other suitable alternative substances or technologies are available on the market"
Commission Delegated Regulation (EU) 2023/2485
eur-lex.europa.eu3 citations
Referenced sections
  • Official delegated act amending Appendix C to Annexes I and II of Delegated Regulation (EU) 2021/2139, including point (f), deletion of point (g), the new paragraph after point (f), and application timing.
  • Delegated act amending Appendix C and describing it as generic DNSH criteria for pollution prevention and control.
  • The delegated act replaced the essential-use framing with no suitable alternatives and controlled-conditions language.
"above 0,1 % weight by weight"
More quoted passages
"generic DNSH criteria"
"used under controlled conditions"
Commission FAQ on EU Taxonomy delegated acts
finance.ec.europa.eu3 citations
Referenced sections
  • Commission FAQ publication explaining the Appendix C amendments, covered substances, ECHA lookup tools, derogation evidence, controlled conditions, essential-use status, and 0.1% w/w threshold application.
  • Commission FAQ 133 explains that Appendix C sets generic DNSH criteria for pollution prevention and control relating to use and presence of chemicals.
  • Commission FAQs 136 and 137 explain the current derogation conditions and the evidence expected for suitable alternatives and controlled conditions.
"generic DNSH criteria"
More quoted passages
"use and presence of chemicals"
"absence of suitable alternatives"

Related guides

EU Taxonomy 2026 simplification: what should teams do?

cited FAQ on EU Taxonomy 2026 simplification, Regulation (EU) 2026/73, Article 8 reporting, DNSH evidence, and limits on unsupported claims.

EU Taxonomy activity evidence packs: what to retain

A practical FAQ on EU Taxonomy activity evidence packs: eligibility, alignment, DNSH, minimum safeguards, KPI traceability, and cited-source review records.

EU Taxonomy Article 8 Scope FAQ

Practical FAQ on EU Taxonomy Article 8 scope, including who reports, which KPI framework applies, and what evidence teams should retain.

EU Taxonomy auditor evidence: what to keep for alignment review

Practical FAQ on EU Taxonomy auditor evidence: what evidence supports eligibility, alignment, DNSH, minimum safeguards, and Article 8 KPI disclosures.

EU Taxonomy CapEx Plans FAQ: Article 8 CapEx KPI

Practical FAQ on EU Taxonomy CapEx plans under Article 8, Annex I Section 1.1.2.2, management-body approval, timing, activity-level evidence, and KPI restatement.

EU Taxonomy delegated act changes: what teams should check

FAQ on handling EU Taxonomy delegated act changes: official source checks, application dates, affected criteria, disclosures, DNSH evidence, and review records.

Show all related guides (37)

EU Taxonomy eligibility vs alignment: what is the difference?

Eligibility means an activity is covered by Taxonomy delegated acts; alignment means it also meets Article 3 conditions, technical screening criteria, DNSH, and minimum safeguards.

EU Taxonomy Financial KPIs and Green Asset Ratio (GAR) FAQ

FAQ on EU Taxonomy Article 8 financial undertaking KPIs, credit institution Green Asset Ratio (GAR), reporting dates, exclusions, and qualitative disclosures.

EU Taxonomy gas and nuclear activities: when can they align?

Explain how the EU Taxonomy Complementary Climate Delegated Act treats specified gas and nuclear activities, alignment criteria, DNSH evidence, and separate disclosures.

EU Taxonomy minimum safeguards FAQ: Article 18 evidence

FAQ on EU Taxonomy minimum safeguards under Article 18: who must comply, which OECD, UNGP, ILO and human-rights evidence to keep, and common reporting mistakes.

EU Taxonomy non-financial KPIs: turnover, CapEx and OpEx

Article 8 FAQ for non-financial undertakings reporting EU Taxonomy turnover, CapEx and OpEx KPIs, with evidence and source checks.

EU Taxonomy Six Environmental Objectives | Article 9 FAQ

Plain-English FAQ on the six EU Taxonomy environmental objectives in Article 9 and how teams should map activities, DNSH checks, safeguards, and evidence.

EU Taxonomy Activity Eligibility Workflow

Build an EU Taxonomy activity eligibility workflow that maps economic activities to delegated-act descriptions before alignment, DNSH, and Article 8 KPI reporting.

EU Taxonomy Applicability Test for Eligibility and Alignment

Test EU Taxonomy applicability by separating Article 8 reporting scope, Taxonomy eligibility, Taxonomy alignment, DNSH, minimum safeguards, and KPI evidence.

EU Taxonomy Article 8 disclosure templates

Cited EU Taxonomy templates for Article 8 reporting, covering non-financial KPIs, financial undertaking annexes, eligibility and alignment evidence, GAR inputs, and publication checks.

EU Taxonomy Article 8 KPI disclosure workflow

Prepare EU Taxonomy Article 8 KPI disclosures: calculate turnover, capital and operating expenditure ratios, collect bank inputs, and review templates before publication.

EU Taxonomy Article 8 Scope and Reporting Entities

Determine which financial and non-financial undertakings report under EU Taxonomy Article 8, which annexes apply, and what evidence supports the reporting boundary.

EU Taxonomy CapEx Plan Evidence Workflow

Build an EU Taxonomy CapEx plan evidence workflow for Article 8 CapEx KPI reporting, management-body approval, milestones, amendments, allocation, and restatement controls.

EU Taxonomy CapEx Plan Evidence: Article 8 checklist

Build evidence for EU Taxonomy CapEx plans under Article 8, Annex I Section 1.1.2.2 and the Disclosures Delegated Act.

EU Taxonomy compliance guide: eligibility, alignment and Article 8 KPIs

Practical EU Taxonomy compliance guide for mapping eligible activities, testing alignment, collecting DNSH and minimum-safeguards evidence, and preparing Article 8 disclosures.

EU Taxonomy deadlines and Article 8 compliance calendar

EU Taxonomy calendar covering Article 8 reporting phases, 2026 disclosure changes, environmental objective dates, and evidence review gates.

EU Taxonomy Delegated Act Change Tracker

Track adopted and proposed EU Taxonomy delegated-act changes by source, status, affected criteria, Article 8 disclosure impact, owner, and evidence update.

EU Taxonomy Delegated Acts Tracker

Track EU Taxonomy delegated acts by legal status, objective, reporting impact, activity scope, DNSH criteria, Article 8 disclosures, and owner follow-up.

EU Taxonomy DNSH and Minimum Safeguards evidence guide

EU Taxonomy DNSH and minimum safeguards guide covering Article 3 alignment, Article 17 harm tests, Article 18 procedures, evidence, and KPI controls.

EU Taxonomy DNSH Appendix C: chemicals evidence guide

Current EU Taxonomy Appendix C chemicals guide covering the 2026 replacement criteria, listed substances, legal exemptions, the candidate-list substance threshold, and evidence records.

EU Taxonomy Eligibility vs Alignment

Compare EU Taxonomy eligibility and alignment under Article 8: what each term means, what evidence is needed, which KPIs are affected, and why eligibility is not proof of sustainability.

EU Taxonomy Eligibility vs Alignment Explained

Explain EU Taxonomy eligibility and alignment under Article 8, the Disclosures Delegated Act, Article 3, technical screening criteria, DNSH, and safeguards.

EU Taxonomy FAQ: eligibility, alignment, DNSH, safeguards, and Article 8

EU Taxonomy FAQ hub for eligibility, alignment, technical screening criteria, DNSH, minimum safeguards, Article 8 KPIs, delegated acts, and evidence records.

EU Taxonomy GAR and financial undertaking KPIs

EU Taxonomy Article 8 financial undertaking KPI guide covering GAR, sector KPIs, 2026 denominator rules, materiality options, exclusions, and evidence.

EU Taxonomy GAR KPI workflow for credit institutions

Prepare EU Taxonomy Green Asset Ratio stock and flow disclosures with current rules for covered assets, exclusions, materiality, and evidence.

EU Taxonomy Minimum Safeguards: Article 18 and evidence

Understand how Article 18 minimum safeguards fit into EU Taxonomy alignment, which international standards they reference, and what evidence supports the assessment.

EU Taxonomy Penalties and Fines: Article 22 Disclosure Risk

EU Taxonomy Article 22 explains who sets penalties for Articles 5, 6, and 7 financial product disclosures and how to research the applicable national rule.

EU Taxonomy Regulation Checklist for Eligibility and Alignment

A cited EU Taxonomy checklist for mapping eligible activities, testing alignment, documenting DNSH and minimum safeguards, and preparing Article 8 KPI disclosures.

EU Taxonomy Regulation requirements: eligibility, alignment, KPIs

Understand the core EU Taxonomy requirements: Article 3 alignment tests, eligible activities, DNSH, minimum safeguards, Article 8 KPIs, and evidence to keep.

EU Taxonomy screening criteria and documentation guide

How to document EU Taxonomy eligibility, alignment, technical screening criteria, DNSH, minimum safeguards, and Article 8 KPI disclosures without overstating the evidence.

EU Taxonomy vs CSRD: Article 8 Reporting Comparison

Compare EU Taxonomy Article 8 disclosures with current Accounting Directive sustainability-reporting scope, evidence, KPIs, assurance, and reuse limits.

EU Taxonomy vs SFDR: Scope, KPIs, and Evidence

Compare EU Taxonomy activity tests and Article 8 KPIs with SFDR entity and product disclosures, evidence, publication channels, and limits on data reuse.