To cope with the impacts of the COVID-19 pandemic, governments have taken supportive measures, including the EU Recovery and Resilience Fund (RRF) and National Recovery and Resilience Plans (NRPs). In this post, we explore the DNSH principle, central to the NRP, and its role in post-pandemic recovery in Europe.
DNSH: significance and why it is important
The concept of DNSH, "DoNo Significant Harm"-that is, "Do Not Cause Significant Harm"-is at the heart of the European Union's Recovery and Resilience Fund (RRF ) and member states' National Recovery and Resilience Plans (NRPs). But what exactly does DNSH mean?
DNSH is a principle that ensures that any measures or projects undertaken as part of recovery plans do not have significant negative impacts on environmental factors. In other words, it aims to prevent harm and promote sustainability in the recovery process.
To certify adherence to DNSH, member states are required to conduct a comprehensive assessment of their projects, evaluating their potential impact on various aspects such as climate change, sustainable resource use and pollution prevention. This assessment is essential in determining the eligibility of projects for funding under the DNSH.
For example, if a project proposed by a member state does not meet DNSH criteria, it can be rejected or modified to mitigate any damage. This ensures that only projects in line with the principles of sustainability and resilience receive financial support.
By incorporating the DNSH principle into the NRP, the European Union aims to ensure that recovery efforts actually contribute to a greener and more sustainable future for Europe.
DNSH's 6 criteria to be met
Regulation (EU) 241/2021, which establishes the Recovery and Resilience Facility, stipulates that only those projects that adhere to the DNSH principle, defined in Regulation (EU) 2020/852, known as the "Taxonomy Regulation," can be funded in the National Plans.
This regulation classifies sustainable economic activities according to their impact on six environmental objectives. According to Article 17 of the Taxonomy Regulation, an economic activity causes significant harm if:
- Causes significant greenhouse gas emissions;
- worsens the negative effects of current and future climate on the activity itself or on people, nature or property;
- harms the good ecological status or potential of water bodies, both surface and groundwater, and the good ecological status of marine waters;
- causes inefficiencies in the use of materials or natural resources, significantly increases the generation, incineration, or disposal of waste (excluding the incineration of non-recyclable hazardous waste), or if the long-term disposal of waste would harm the environment;
- If it significantly increases emissions of pollutants into the air, water or soil;
- significantly harm the condition and resilience of ecosystems or the conservation status of habitats and species, including those of Union interest.
Based on the impact the projects have on the six environmental objectives seen above, the project is classified into one of four scenarios:
- Zero or Negligible Impact: The intervention has no significant effect on the environmental objective;
- Full Support: The intervention fully supports the environmental objective;
- Substantial Contribution: The intervention contributes significantly, but not totally, to the environmental objective;
- Comprehensive DNSH Assessment Required: The intervention requires a thorough analysis to determine whether or not it meets the DNSH principle.
DNSH PNRR assessment: how is it done?
Simplified Approach
Used when an intervention falls within the first three scenarios for a single environmental objective. Administrations provide a concise justification explaining why the intervention has a limited risk of environmental harm and has the potential to contribute to the green transition.
In-depth analysis and conditions to be met
Required for investments and reforms in sectors at higher risk of environmental impact, such as energy, transport, or waste management. This approach is also required for interventions that aim to make a significant contribution to climate change mitigation. In this case, a more detailed analysis is conducted to ensure that the intervention is in line with the DNSH principle.
DNSH: what should PA providers do?
If you are a public administration supplier, or if you are a public administration and need to evaluate a supplier, it is mandatory to comply with the requirements imposed by the DNSH principle.
WEEE Platform Enrollment
The question being asked of providers is exactly the following, declined in two slightly different forms:
- Is the bidder duly registered with the WEEE platform, as a producer and/or distributor?
or - is enrollment in the WEEE platform as a producer and/or distributor and/or supplier available?
How to answer this question?
What is called the WEEE platform here is nothing more than the National Registry of Manufacturers of Electrical and Electronic Equipment.
If you are a supplier of electrical and electronic equipment, you will have requirements to be compliant and therefore be able to participate in the tender.
To find out more, read the "Do you have an obligation?" page or contact us now!
