For those companies and organizations seeking to participate in initiatives such as the Recovery, Transformation and Resilience Plan (PRTR) and access European funds, compliance with the DNSH (Do Not Significant Harm) principle has become an essential requirement.
What is the DNSH principle and what does it consist of?
The DNSH principle, derived from Regulation (EU) 2021/241, establishes the Recovery and Resilience Mechanism (RMRR) as a mandatory criterion for all actions carried out within the framework of the Next Generation EU funds.
In simple terms, it implies the obligation "not to cause significant harm to the environment."
This principle is based on six environmental objectives that serve as a basis for evaluating the environmental viability of the proposed actions.
The 6 environmental objectives of the DNSH principle are:
- Climate change mitigation: Regarding the production of greenhouse gases (GHG).
- Adaptation to climate change: Activities that cause an impact on the climate, people or environment.
- Sustainable use and protection of water and marine resources: Activities that generate problems in the good state of the marine environment or water resources.
- Circular economy: Imprudence in recycling, mass production of waste and exploitation of natural resources.
- Pollution prevention and control: Significant increase in polluting emissions into air, water or land.
- Protection and recovery of biodiversity and ecosystems: Activities harmful to ecosystems and natural habitats.
Importance of compliance with DNSH criteria
The MRR, aligned with the European Green Deal and the United Nations Sustainable Development Goals, attaches special importance to the ecological transition pillar.
The European Commission seeks to guarantee a global transition by evaluating national plans to avoid significant impacts on the environment.
Compliance with the DNSH criterion then becomes a determining factor to access financing, aligning with European sustainability goals.
How is DNSH compliance demonstrated in the Plan?
To demonstrate compliance with the DNSH principle, the PRTR (State Registry of Emissions and Polluting Sources) provides various indications:
- Absence of impact: The actions must provide a significant improvement in the final objective.
- Consideration of direct and indirect effects: Evaluate the possible impacts throughout the life cycle of the action and its subsequent effects.
- Reference to the Taxonomy Regulations: Incorporate the sustainability categories and criteria established in the taxonomy.
- Citation of the regulations in force: Commit to complying with current environmental regulations.
- Impact assessment tools: Have adequate tools to evaluate environmental impact.
- Verification tests: Provide evidence according to Annex II of the European Commission Technical Guide.
- Specific instructions for activities: Consult Annex IV of the Guide for details on specific activities.
The transversality of DNSH
The DNSH principle is not only a requirement in the planning phase; It must be reflected explicitly throughout the life cycle of the activity.
The presence of this principle is evidenced through the legal instruments of the Plan, such as regulatory bases, administrative and technical specifications, agreements, among others.
How do I know if I am DNSH compliant?
Annex II of the PRTR DNSH Guide provides a self-assessment questionnaire that allows companies and organizations to evaluate the level of compliance with the principle of do no harm.
This questionnaire addresses key aspects to determine whether the proposed actions are aligned with environmental objectives.
The DNSH principle is not only a bureaucratic requirement, but a crucial tool to ensure that investments promoted by the PRTR contribute positively to environmental sustainability.
Meeting these criteria is not only essential to access funding, but also to support the vision of a greener and more sustainable Europe in line with international commitments.
To meet these criteria, it is advisable to have the support and advice of a ESG Consulting committed to helping organizations achieve environmental, social and governance (ESG) excellence. specialized as Ecoterrae.
