---
title: "EU Taxonomy gas and nuclear activities: when can they align?"
canonical_url: "https://www.sorena.io/artifacts/eu/taxonomy-regulation/faq/gas-and-nuclear-activities"
source_url: "https://www.sorena.io/artifacts/eu/taxonomy-regulation/faq/gas-and-nuclear-activities"
author: "Sorena AI"
description: "Explain how the EU Taxonomy Complementary Climate Delegated Act treats specified gas and nuclear activities, alignment criteria, DNSH evidence, and separate disclosures."
published_at: "2026-07-16"
updated_at: "2026-07-24"
keywords:
  - "EU Taxonomy gas activities"
  - "EU Taxonomy nuclear activities"
  - "Complementary Climate Delegated Act"
  - "Regulation EU 2022/1214"
  - "gas nuclear taxonomy alignment"
  - "EU Taxonomy"
  - "natural gas"
  - "nuclear energy"
  - "DNSH"
  - "Article 8"
---
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---

# 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.

*FAQ* *Taxonomy* *EU*

## EU Taxonomy Regulation gas and nuclear activities

The EU Taxonomy does not classify all gas or nuclear activity as sustainable. Delegated Regulation (EU) 2022/1214 added specified activities that can qualify only when their detailed technical screening, DNSH, minimum-safeguards, and disclosure conditions are met.

Use the exact activity and criteria in the Complementary Climate Delegated Act; a sector label, fuel type, technology name, or policy description is not enough to prove alignment.

The Complementary Climate Delegated Act has applied since 1 January 2023. It added six activity descriptions: three for nuclear energy and three for fossil gas. Only an activity that matches one of those descriptions and meets every applicable criterion can be reported as Taxonomy-aligned.

## Definitions

### Complementary Climate Delegated Act

The Complementary Climate Delegated Act is Commission Delegated Regulation (EU) 2022/1214. It added technical screening and disclosure rules for three specified nuclear-energy activities and three specified fossil-gas activities under the EU Taxonomy, with application from 1 January 2023.

**Why it matters here:** The act does not classify every gas or nuclear activity as aligned. The exact activity description, dates, thresholds, substantial-contribution criteria, DNSH criteria, minimum safeguards, and separate Article 8 disclosures all remain relevant.

Sources:

- [Commission Delegated Regulation (EU) 2022/1214](https://eur-lex.europa.eu/eli/reg_del/2022/1214/oj/eng?ref=sorena.io)

### Transitional economic activities

**Term:** transitional activities

Transitional activities are activities for which there is no technologically and economically feasible low-carbon alternative, where the activity supports the transition to a climate-neutral economy, has greenhouse-gas emissions corresponding to the best performance in its sector or industry, does not hamper low-carbon alternatives, and does not lock in carbon-intensive assets beyond their economic lifetime.

**Why it matters here:** The covered gas and nuclear activities must still match the delegated-act activity description and meet every applicable criterion. Calling an activity transitional does not by itself establish eligibility or alignment.

Sources:

- [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32020R0852&ref=sorena.io)
- [Commission Delegated Regulation (EU) 2022/1214](https://eur-lex.europa.eu/eli/reg_del/2022/1214/oj/eng?ref=sorena.io)

## Does the EU Taxonomy treat gas and nuclear energy as automatically aligned?

No. Eligibility only means that an economic activity matches one of the activity descriptions added by Delegated Regulation (EU) 2022/1214. Alignment still requires the four Article 3 conditions: substantial contribution to at least one environmental objective, no significant harm to the other objectives, compliance with Article 18 minimum safeguards, and compliance with the applicable technical screening criteria.

The nuclear sections cover pre-commercial advanced technologies with minimal fuel-cycle waste, new nuclear installations whose construction permit is issued by 2045, and modifications of existing installations intended to extend safe operation where the project is authorised by 2040. The gas sections cover electricity generation, high-efficiency cogeneration, and heat or cooling in an efficient district system.

These are transitional activities under Article 10(2), not a finding that every gas or nuclear activity is sustainable. Match the operating facts to Sections 4.26 to 4.31 and use the criteria that apply to the reporting period.

- Identify the exact operating, construction, modification, generation, or related activity before selecting criteria.
- Record why the activity description matches; do not use a NACE code or sector label as the only eligibility evidence.
- Test every substantial-contribution and DNSH criterion in the applicable annex section.
- Complete the minimum-safeguards assessment for the undertaking carrying out the activity.
- Keep partial, conditional, or unresolved results out of the aligned KPI numerator.

Sources for this answer:

- [Complementary Climate Delegated Act (Regulation (EU) 2022/1214)](https://eur-lex.europa.eu/eli/reg_del/2022/1214/oj/eng?ref=sorena.io) - Binding source for the six activity descriptions, activity-specific criteria, and separate Article 8 disclosures.
- [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32020R0852&ref=sorena.io) - Articles 3 and 10 establish the cumulative alignment conditions and the meaning of a transitional activity.

## What must nuclear activities show?

Nuclear alignment depends on project, operator, and Member State evidence. The common criteria cover nuclear-safety and radioactive-waste law, decommissioning and waste-management funds, disposal capacity for very low-, low-, and intermediate-level waste, and a detailed plan for a high-level-waste disposal facility to operate by 2050.

For electricity generation, life-cycle greenhouse-gas emissions must be below 100 g CO2e/kWh and independently verified using a method permitted by the act. The project must also meet its section's permitting date, safety, accident-tolerant-fuel, reporting, water, waste, pollution, and biodiversity conditions.

- Section 4.26: research, development, demonstration, and deployment of licensed advanced nuclear technologies with minimal fuel-cycle waste.
- Section 4.27: construction and safe operation of new nuclear installations with a construction permit issued by 2045, plus their safety upgrades.
- Section 4.28: electricity generation from existing nuclear installations and specified modifications authorised by 2040 to extend safe operation.
- Verify the Member State's transposition and compliance evidence, project notification or authorisation, required funds, disposal facilities and plans, five-year reporting commitments, and site-specific safety evidence.
- Do not use a national nuclear programme, licence, or low-carbon label as a substitute for the complete Taxonomy criteria.

Sources for this answer:

- [Complementary Climate Delegated Act (Regulation (EU) 2022/1214)](https://eur-lex.europa.eu/eli/reg_del/2022/1214/oj/eng?ref=sorena.io) - Annex I inserts Sections 4.26 to 4.28, including permit dates, the 100 g CO2e/kWh life-cycle threshold, independent verification, safety, funding, and waste-disposal conditions.

## What must fossil-gas activities show?

Each gas activity has a route based on life-cycle greenhouse-gas emissions below 100 g CO2e/kWh or, for facilities whose construction permit is granted by 31 December 2030, a transition route with additional conditions. The transition route includes direct emissions below 270 g CO2e/kWh or annual direct emissions averaging no more than 550 kg CO2e per kW of capacity over 20 years.

The transition route also requires evidence that renewable alternatives are not available at sufficient scale, that the facility replaces a more emissions-intensive solid or liquid fossil-fuel activity, that capacity does not exceed the replaced capacity by more than 15%, that it enables a 55% lifetime reduction in greenhouse-gas emissions, and that it switches fully to renewable or low-carbon gaseous fuels by 31 December 2035. The precise section adds further efficiency, cogeneration, district-heating, verification, and DNSH conditions.

- Section 4.29: construction or operation of electricity generation facilities using fossil gaseous fuels.
- Section 4.30: construction, refurbishment, and operation of high-efficiency cogeneration of heat or cooling and power from fossil gaseous fuels.
- Section 4.31: construction, refurbishment, and operation of fossil-gas heat or cooling generation connected to an efficient district heating and cooling system.
- Keep permit dates, replaced capacity and fuel, emissions calculations, independent verification, fuel-switch plan, operating records, and DNSH evidence at facility level.
- If one transition-route condition is missing or still only an unsupported intention, do not report the activity as aligned.

Sources for this answer:

- [Complementary Climate Delegated Act (Regulation (EU) 2022/1214)](https://eur-lex.europa.eu/eli/reg_del/2022/1214/oj/eng?ref=sorena.io) - Annex I inserts Sections 4.29 to 4.31, including the emissions routes, 31 December 2030 permit cut-off, replacement conditions, and 31 December 2035 fuel-switch deadline.

## What evidence should a gas or nuclear alignment file contain?

Build the evidence file at project, activity, and site level. Start with the delegated-act section and version used. Map every criterion to a named record, calculation, permit, plan, technical study, operating record, contractual commitment, or independent assessment. For a future deadline or continuing condition, record the owner, monitoring frequency, and event that would require reassessment.

Do not collapse substantial contribution and DNSH into one generic engineering opinion. The reviewer should be able to see which criterion each document supports, the measurement period and boundary, assumptions or data limitations, and whether the evidence existed at the disclosure reference date.

- Activity record: asset, site, operator, activity description, delegated-act section, objective, and reporting period.
- Criteria matrix: one row per substantial-contribution and DNSH condition, with result, evidence, owner, reviewer, and expiry or review date.
- Technical file: calculations, lifecycle or emissions data where required, permits, safety and waste records, and referenced plans or approvals.
- Minimum-safeguards file: due-diligence procedures and any unresolved human-rights, labour-rights, anti-bribery, taxation, or fair-competition issue considered in the conclusion.
- Change log: amendments to the delegated acts, asset design, fuel or technology, operating conditions, permits, and public claims.

Sources for this answer:

- [Complementary Climate Delegated Act (Regulation (EU) 2022/1214)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022R1214&ref=sorena.io) - Binding activity-specific criteria for the evidence matrix.
- [Commission Notice on the Climate Delegated Act (C/2023/267)](https://eur-lex.europa.eu/eli/C/2023/267/oj/eng?ref=sorena.io) - Official interpretation of evidence collection, activity descriptions, and technical screening criteria under the Climate Delegated Act.

## How should gas and nuclear activities appear in Article 8 disclosures?

Article 8 disclosures must identify whether the undertaking carries out, funds, or has exposures to the covered nuclear and gas activities and separately show the required eligible and aligned proportions. Regulation (EU) 2026/73 shortened the wider reporting templates but retained separate gas- and nuclear-related information.

Reconcile each activity-level decision to the relevant turnover, CapEx, OpEx, asset, exposure, investment, or underwriting calculation. Preserve excluded and non-aligned amounts so the disclosure does not imply that one covered activity makes an entire entity, asset, fund, or portfolio aligned.

- Use the gas- and nuclear-related templates and indicators required for the reporting undertaking.
- Reconcile the separate disclosures to the underlying Article 8 KPI workbook and activity register.
- Explain estimation, allocation, data gaps, and changes in method in the accompanying information.
- Keep eligible and aligned amounts distinct and avoid describing either as whole-company certification.
- Recheck the current consolidated delegated acts before each reporting lock.

Sources for this answer:

- [Complementary Climate Delegated Act (Regulation (EU) 2022/1214)](https://eur-lex.europa.eu/eli/reg_del/2022/1214/oj/eng?ref=sorena.io) - Binding source for the separate public-disclosure treatment added for covered gas and nuclear activities.
- [Article 8 Disclosures Delegated Act (Regulation (EU) 2021/2178)](https://eur-lex.europa.eu/eli/reg_del/2021/2178/oj/eng?ref=sorena.io) - Binding source for Article 8 KPI methodology and accompanying information.
- [Commission Delegated Regulation (EU) 2026/73](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R0073&ref=sorena.io) - Current binding amendment to Article 8 presentation and templates, including retained gas- and nuclear-related disclosure fields.

## Primary sources

- [Complementary Climate Delegated Act (Regulation (EU) 2022/1214)](https://eur-lex.europa.eu/eli/reg_del/2022/1214/oj/eng?ref=sorena.io) - Primary legal source for the six gas and nuclear activities, their technical screening criteria, and separate Article 8 disclosures.
- [Regulation (EU) 2020/852 (Taxonomy Regulation)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32020R0852&ref=sorena.io) - Primary framework for Article 3 alignment, transitional activities, DNSH, minimum safeguards, and Article 8 disclosure.
- [European Commission: EU Taxonomy implementing and delegated acts](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/taxonomy-regulation_en?ref=sorena.io) - Official register for checking delegated acts and later amendments before reusing an assessment.
- [Commission Delegated Regulation (EU) 2026/73](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R0073&ref=sorena.io) - Current amendment to Taxonomy disclosures and specified screening criteria, applicable from 1 January 2026.

## Topic Guides

- [DNSH Appendix C under the EU Taxonomy: chemicals evidence FAQ](/artifacts/eu/taxonomy-regulation/faq/dnsh-appendix-c.md): Practical FAQ on the current EU Taxonomy DNSH Appendix C chemicals criteria, including listed substances, the 0.1% w/w SVHC threshold, alternatives, and controlled conditions.
- [EU Taxonomy 2026 simplification: what should teams do?](/artifacts/eu/taxonomy-regulation/faq/2026-simplification.md): cited FAQ on EU Taxonomy 2026 simplification, Regulation (EU) 2026/73, Article 8 reporting, DNSH evidence, and limits on unsupported claims.
- [EU Taxonomy Activity Eligibility Workflow](/artifacts/eu/taxonomy-regulation/activity-eligibility-workflow.md): 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 activity evidence packs: what to retain](/artifacts/eu/taxonomy-regulation/faq/activity-evidence-packs.md): A practical FAQ on EU Taxonomy activity evidence packs: eligibility, alignment, DNSH, minimum safeguards, KPI traceability, and cited-source review records.
- [EU Taxonomy Applicability Test for Eligibility and Alignment](/artifacts/eu/taxonomy-regulation/applicability-test.md): 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](/artifacts/eu/taxonomy-regulation/templates.md): 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](/artifacts/eu/taxonomy-regulation/kpis-and-disclosure-workflow.md): cited workflow for EU Taxonomy Article 8 KPI disclosures, covering turnover, CapEx, OpEx, GAR dependencies, templates, contextual information, and publication checks.
- [EU Taxonomy Article 8 Scope and Reporting Entities](/artifacts/eu/taxonomy-regulation/scope-and-reporting-entities.md): 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 Article 8 Scope FAQ](/artifacts/eu/taxonomy-regulation/faq/article-8-scope.md): cited 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](/artifacts/eu/taxonomy-regulation/faq/auditor-evidence.md): Practical FAQ on EU Taxonomy auditor evidence: what evidence supports eligibility, alignment, DNSH, minimum safeguards, and Article 8 KPI disclosures.
- [EU Taxonomy CapEx Plan Evidence Workflow](/artifacts/eu/taxonomy-regulation/capex-plan-evidence-workflow.md): 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](/artifacts/eu/taxonomy-regulation/capex-plan-evidence.md): Build evidence for EU Taxonomy CapEx plans under Article 8, Annex I Section 1.1.2.2 and the Disclosures Delegated Act.
- [EU Taxonomy CapEx Plans FAQ: Article 8 CapEx KPI](/artifacts/eu/taxonomy-regulation/faq/capex-plans.md): 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 compliance guide: eligibility, alignment and Article 8 KPIs](/artifacts/eu/taxonomy-regulation/compliance.md): 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](/artifacts/eu/taxonomy-regulation/deadlines-and-compliance-calendar.md): EU Taxonomy calendar covering Article 8 reporting phases, 2026 disclosure changes, environmental objective dates, and evidence review gates.
- [EU Taxonomy Delegated Act Change Tracker](/artifacts/eu/taxonomy-regulation/delegated-act-change-tracker.md): 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 act changes: what teams should check](/artifacts/eu/taxonomy-regulation/faq/delegated-act-changes.md): FAQ on handling EU Taxonomy delegated act changes: official source checks, application dates, affected criteria, disclosures, DNSH evidence, and review records.
- [EU Taxonomy Delegated Acts Tracker](/artifacts/eu/taxonomy-regulation/delegated-acts-tracker.md): 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](/artifacts/eu/taxonomy-regulation/dnsh-and-minimum-safeguards.md): 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](/artifacts/eu/taxonomy-regulation/dnsh-appendix-c.md): Current EU Taxonomy Appendix C chemicals guide covering the 2026 replacement criteria, listed substances, legal exemptions, the SVHC threshold, and evidence records.
- [EU Taxonomy Eligibility vs Alignment](/artifacts/eu/taxonomy-regulation/taxonomy-eligibility-vs-alignment.md): 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](/artifacts/eu/taxonomy-regulation/taxonomy-eligibility-vs-alignment-explained.md): Explain EU Taxonomy eligibility and alignment under Article 8, the Disclosures Delegated Act, Article 3, technical screening criteria, DNSH, and safeguards.
- [EU Taxonomy eligibility vs alignment: what is the difference?](/artifacts/eu/taxonomy-regulation/faq/eligibility-vs-alignment.md): 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 FAQ: eligibility, alignment, DNSH, safeguards, and Article 8](/artifacts/eu/taxonomy-regulation/faq.md): EU Taxonomy FAQ hub for eligibility, alignment, technical screening criteria, DNSH, minimum safeguards, Article 8 KPIs, delegated acts, and evidence records.
- [EU Taxonomy Financial KPIs and Green Asset Ratio (GAR) FAQ](/artifacts/eu/taxonomy-regulation/faq/financial-kpis-and-gar.md): FAQ on EU Taxonomy Article 8 financial undertaking KPIs, credit institution Green Asset Ratio (GAR), reporting dates, exclusions, and qualitative disclosures.
- [EU Taxonomy GAR and financial undertaking KPIs](/artifacts/eu/taxonomy-regulation/gar-and-financial-undertaking-kpis.md): 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](/artifacts/eu/taxonomy-regulation/gar-kpi-workflow.md): Prepare EU Taxonomy Green Asset Ratio stock and flow disclosures with current rules for covered assets, exclusions, materiality, and evidence.
- [EU Taxonomy minimum safeguards FAQ: Article 18 evidence](/artifacts/eu/taxonomy-regulation/faq/minimum-safeguards.md): 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 Minimum Safeguards: Article 18 and evidence](/artifacts/eu/taxonomy-regulation/minimum-safeguards.md): Understand how Article 18 minimum safeguards fit into EU Taxonomy alignment, which international standards they reference, and what evidence supports the assessment.
- [EU Taxonomy non-financial KPIs: turnover, CapEx and OpEx](/artifacts/eu/taxonomy-regulation/faq/non-financial-kpis.md): Article 8 FAQ for non-financial undertakings reporting EU Taxonomy turnover, CapEx and OpEx KPIs, with evidence and source checks.
- [EU Taxonomy Penalties and Fines: Article 22 Disclosure Risk](/artifacts/eu/taxonomy-regulation/penalties-and-fines.md): 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](/artifacts/eu/taxonomy-regulation/checklist.md): 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](/artifacts/eu/taxonomy-regulation/requirements.md): 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](/artifacts/eu/taxonomy-regulation/screening-criteria-and-documentation.md): How to document EU Taxonomy eligibility, alignment, technical screening criteria, DNSH, minimum safeguards, and Article 8 KPI disclosures without overstating the evidence.
- [EU Taxonomy Six Environmental Objectives | Article 9 FAQ](/artifacts/eu/taxonomy-regulation/faq/six-environmental-objectives.md): 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 vs CSRD: Article 8 Reporting Comparison](/artifacts/eu/taxonomy-regulation/taxonomy-vs-csrd.md): 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](/artifacts/eu/taxonomy-regulation/taxonomy-vs-sfdr.md): Compare the EU Taxonomy and the SFDR link points that appear in Taxonomy materials: activity classification, Article 8 KPIs, product disclosures, data reuse, and evidence limits.

*Recommended next step*

*Placement: after evidence section*

## Turn EU Taxonomy criteria into an evidence workflow

Connect each gas or nuclear activity conclusion to the exact criteria, evidence owner, reporting KPI, and reassessment trigger before publishing it.

- [Open Research Copilot](/solutions/research-copilot.md): Answer activity-specific EU Taxonomy questions with cited source material.
- [Discuss EU Taxonomy implementation](/contact.md): Review activity boundaries, criteria evidence, and Article 8 disclosure treatment with Sorena.


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