EU Taxonomy Complementary Climate Delegated Act

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The EU Taxonomy Complementary Climate Delegated Act (CCDA) was adopted to reflect the role of certain transitional activities within the EU Taxonomy, particularly those related to natural gas.

Several elements of the current CCDA criteria risk limiting investments in assets that could deliver substantial emissions reductions in the short to medium term, including in Member States relying on coal-to-gas switching as part of their decarbonisation strategies. Beyond their emissions abatement potential, such assets play a crucial role in guaranteeing Europe’s security of energy supply. Even though the CCDA includes in the current technical screening criteria a compliance pathway for plants replacing existing high emitting activities using solid or liquid fossil fuel, the overly restrictive criteria1 ends up discriminating among technologies.

Eurogas sets out below several recommendations that would improve the CCDA and address the identified shortcomings.

Key elements

• The rationale underpinning the GHG-emission thresholds across both existing Taxonomy criteria and potential revisions remains insufficiently aligned with technological realities and has not been supported by a comprehensive impact assessment. The tightening of energy-related technical screening criteria risks negatively affecting a successful transition to a low-carbon economy. The fact that the current thresholds are already a significant challenge to be met should form the basis of the reflection about any potential tightening.
• The prohibition on installing capacity above that of the replaced unit should be revised.
• CO2 and solid carbon capture use and storage should be fully recognised in the technical screening criteria, which refers only to blending with renewable and/or low-carbon gases.
• The requirement to commit to the use of renewable or low-carbon gases after 2035 should focus primarily on technical capability and emissions performance, rather than on the guaranteed availability of specific fuels.
• The requirement that the construction permit must be granted by 31 December 2030 sets arbitrarily and too early the cutoff date for transitional activities.
• The 55% relative GHG-reduction requirement should be adjusted to reflect realistic emission factors, with a threshold closer to 40%.
• The CCDA predates several important legislative developments. It is fundamental to ensure full alignment, especially regarding definitions, sustainability criteria and accounting methodologies for renewable and low-carbon gases to provide legal certainty, safeguard investor confidence and ensure coherent and credible decarbonisation signals across the EU framework.