The objective of this paper is to highlight the role of enzymes as key enablers in the green transition, including the European Commission’s sustainability ambitions in the EU Taxonomy and Sustainable Finance (SF).
The paper recommends key elements to be amended in the draft technical screening criteria developed for the manufacture of chemicals and chemical products by the Sustainable Finance Platform (SFP). AMFEP welcomes the Commission’s objective of a taxonomy of sustainable investments. The work to develop a common definition of what constitutes a sustainable investment is crucial to incentivise investments in sustainable solutions contributing to the six environmental and climate objectives of the EU Green Deal.
The report on preliminary recommendations on technical screening criteria for environmental objec-tives 3-6 of the EU taxonomy published on 30 March 2022 by the SFP (herein after the Draft Criteria), however, overlooks the documented positive environmental benefits of enzymes. Therefore, AMFEP would like to highlight the enormous contribution which enzymes have brought and will continue bringing to the EU for realising their green ambition.
What is the problem?
The current Draft Criteria excludes enzyme production from the definition of environmentally sustain-able activities under provision 2.1 “Manufacture of chemicals”. This exclusion is based solely on the fact that enzymes will be regarded as “substances of concern” (SoC) as they meet the classification criteria for respiratory sensitisation. However, enzymes have for decades been used safely by workers due to product design and guidance, and no consumer incidents have been reported in Europe for the last 50 years.
In addition, the preliminary recommendations set out in the draft Report of the SFP’s Technical Work-ing Group (TWG), published on 3 August 2021, excludes the production of enzyme-based chemical products from the definition of environmentally sustainable activities (2.4 “Manufacture of Chemical Products”).
Excluding biologically produced enzymes from the criteria due to this SoC listing would conflict with other EU objectives in the EU Bioeconomy Strategy and related objectives for replacing chemicals with safe, bio-based, and sustainable alternatives. In addition, enzymes are critical and irreplaceable to achieve the aim of the Draft Criteria, “Substantial contribution to pollution prevention and control”.
Therefore, we encourage the EU to take a similar approach and recognise enzymes for their key role in reducing waste and effluents as well as the use of water, energy and raw materials, and derogate them from the exclusion of respiratory sensitisers from the criteria – as was done in EU Ecolabel and Nordic Ecolabel criteria for various products. Enzymes are already derogated from the exclusion of respiratory sensitisers from the criteria under 2.6 “Finishing of Textiles” in the Draft Criteria5 for the same reason.
Given the long history and ample evidence that enzymes are already used as substitutes for hazardous chemicals in a wide range of industrial and consumer products, contributing to the goals of the Taxonomy, AMFEP recommends that enzymes are derogated from the exclusion of “Substances of Concern” (SoCs) and products under activities 2.3 on the “Manufacture of Chemicals” and 2.4 on the “Manufacture of Chemical Products”20. Failure to do so will discourage investments in safe and sustainable alternatives to chemicals and go against the environmental objective of Pollution Prevention and Control. Enzymes, and the broader Bioeconomy, are key enablers in the green transition and should therefore be recognized as such in the EU Taxonomy.
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