JBCE Feedback on the Review of the EU Taxonomy Environmental and Climate Delegated Acts

15/04/2026

The Japan Business Council in Europe (JBCE) welcomes the opportunity to provide its views on the review of the EU Taxonomy Environmental Delegated Act and Climate Delegated Act, continuing its engagement following previous contributions during the 2023 and 2025 stakeholder consultations.

JBCE supports the adoption of the Delegated Act on 4 July 2025, particularly the alignment of the “Do No Significant Harm” (DNSH) criteria with the RoHS Directive and the removal of provisions that could create market confusion due to differences in CLP classifications. These changes are considered to better reflect industry practices and improve regulatory clarity.

At the same time, JBCE highlights the need to address remaining challenges to ensure a coherent and practical framework. In this context, JBCE’s position focuses on an approach that:

• clearly defines “assessment” and “documentation” requirements under Appendix C point 7, including scope, methodology, evidentiary thresholds, and supply chain responsibilities
• ensures that DNSH obligations related to SVHCs remain consistent with the intent and scope of the REACH Regulation and do not create impractical requirements for global supply chains
• recognizes all exemptions under the RoHS Directive, including future ones, as taxonomy-aligned based on consistent scientific and technical criteria

Through these points, JBCE aims to support a more predictable and workable EU Taxonomy framework aligned with existing legislation and industry realities.

 

Asuka Yui, Hiroshi Odani

Policy Manager

Corporate Sustainability, Environment & Energy

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Download document: position paper