On Thursday, 1 June 2023, the European rail sector co-signed a joint statement in response to the European Commission’s proposal in amending the Taxonomy Climate & Disclosures Delegated Acts. The joint statement was sent to relevant Commissioners managing the EU Taxonomy.
The statement has been jointly prepared by the following associations: Alliance of Passenger Rail New Entrants (ALLRAIL), Community of the European Railways and Infrastructure Companies (CER), European Rail Infrastructure Managers (EIM), European Rail Freight Association (ERFA), International Union of Wagon Keepers (UIP) and European Rail Supply Industry (UNIFE).
In this joint statement, the European rail sector suggests major improvements to the European Commission’s proposal, by focusing on the following crucial points:
Eligibility of rail components: need for a broader definition
It is vital that the rail infrastructure supply industry can report their infrastructure components in one activity and to avoid splitting into two activities. All constituents listed in the TSIs (Technical Specifications for Interoperability) should be in the scope of the EU Taxonomy.
Disclosure and the Single Path principle: to be efficient and avoid double counting
Companies should apply the “single path principle”; in other words, to avoid contradictions, if the Climate Delegated Act covers an activity, it should not be covered by the Environmental Delegated Act, or vice-versa.
A level playing field addressing the sustainable mobility challenges
A level playing field in the EU Taxonomy based on climate objectives, with a coverage equally stringent for all transport modes, is vital.
Do No Significant Harm (DNSH) Criteria: keep the previous definition and achieve coherent policy & Appendix C – Pollution Prevention and Control: stick to the existing legal framework
Implementing the Do No Significant Harm (DNSH) criteria of Appendix C (Pollution Prevention and Control) goes beyond the current scope of restriction of the REACH Regulation. It only refers to the definitions of the applicable regulations without replicating the current restriction perimeter.
The European rail sector hopes the final proposal from the Commission, which is expected in the coming weeks, will include its comments.
The rail sector’s environmental assets and energy efficiency are vital to transitioning to a low-carbon economy and reducing the EU’s dependency on imported fossil fuels. And to channel investments towards greener projects and financing solutions, the EU Taxonomy’s regulatory framework must enable fair, verifiable and reliable comparability between the different economic activities and modes of transport.
European rail sector’s joint statement on the revised Taxonomy Delegated Acts
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