DNSH or the principle of not causing significant harm to the environment

In the post about”How to connect a renewable plant and not die trying” we were talking about the mandatory compliance with the DNSH principle, but what does it consist of? The acronym DNSH is defined as “the principle of not causing significant harm to the environment” (Do No Significant Harm). According to the European Green Deal, any of the research and innovation activities carried out within the European framework must NOT cause any harm to any of the six environmental objectives established in the EU Taxonomy Regulation (June 2020).

The six environmental objectives of the DNSH

The objectives on which the DNSH principle acts are:

• The mitigation of climate change: Refers to the excessive generation of GHG (Greenhouse Gas) emissions.
• Adaptation to climate change: If the activity leads to a greater adverse impact of the climate, on people themselves, assets or the nature of the environment.
• The sustainable use and protection of water and marine resources: When the activity causes problems with the good state of the marine environment or water resources.
• The circular economy: If imprudence occurs with regard to the use of materials, exploitation of natural resources preventing recovery, the generation of massive waste without the possibility of recycling that generates environmental problems...
• Pollution prevention and control: Activities that significantly increase pollutant emissions to air, soil or water.
• The protection and recovery of biodiversity and ecosystems

Is it mandatory?

The DNSH principle must be considered in the methodology and in the impact studies corresponding to any economic activity, including any product or service generated by the activity itself throughout its life cycle, from birth to the final use of each of the resources used. Despite its importance, compliance is NOT mandatory unless otherwise indicated, but it is HIGHLY recommended and possibly in the short term if required, as is the case in access contests.

DNSH within the EU Recovery and Resilience Mechanism

In February, the European Commission presented a guide for implementing the DNSH principle within the Recovery and Resilience Mechanism (MRR), which is part of NextGenerationEU's action instruments. This guide aims to help member States prepare recovery and resilience plans funded by this MRR, and that do not harm environmental objectives within the territory.

The guide establishes that the measures act under the evaluation framework of the DNSH principle and from here it outlines some principles to follow and a basic methodology to comply with the principle based on two points:

• Filter the six environmental objectives to identify those that require substantive evaluation
• Provide a substantive evaluation according to the DNSH principle for environmental objectives that require it.

Based on them, the preparation of the reports will be deepened. Respect for the DNSH principle is a precondition for the Commission and the Council to approve these plans. The two principles that economic activities must comply with yes or yes to be part of the MRR are:

• Contribute to at least one of the six environmental objectives listed in a significant way.
• Do not harm any of the environmental objectives mentioned above.

To access the financial aid provided by the MRR, this principle is especially important, which in turn shows us the path chosen by Europe to transform our economy in a sustainable and green way.

Evaluation of the DNSH principle

MITECO itself on its portal about Recovery and Resilience Plan provides a guide to Recommendations for the design and development of actions in accordance with the principle of not causing significant harm to the environment which includes a self-evaluation questionnaire and a Model Declaration responsible for compliance with the DNSH principle in the sense of Article 17 of the Regulation (EU) 2020/852.

To evaluate the concept of “significant harm” and justify proper compliance with the DNHS principle, a rigorous analysis of projects through environmental impact assessment is required. Do not hesitate to contact us for this purpose.