The DNSH-principle aims to avoid investments or reforms that would cause significant harm to the environment and to encourage economic activities that are aligned with the environmental policies and strategies of the European Union. This principle is increasingly applied in projects financed by the European Union and the Belgian authorities. 

Are you a public authority and does your financial instrument fall within the scope of the DNSH-principle? 

Are you a company and do you have to demonstrate that your project or service complies with the DNSH-principle and does not cause significant harm to the environment?

Find out more about the DNSH-principle and its application:

 

What is the DNSH-principle?

The 'Do No Significant Harm' DNSH-principle aims to ensure that projects do not cause significant harm to the six environmental objectives defined in the EU Sustainable Investment Regulation  (2020/852).


An activity is considered to cause significant harm to: 

  1. the environmental objective of mitigating climate change, if it leads to significant greenhouse gas (GHG) emissions; 
  2. the environmental objective of adapting to climate change, if it leads to an increased adverse impact of the current climate and the expected future climate, on the activity itself or on people, nature or assets; 
  3. the environmental objective of sustainable use and protection of water and marine resources, if it is detrimental to the good status or the good ecological potential of bodies of water, including surface water and groundwater, or to the good environmental status of marine waters; 
  4. the environmental objective of the circular economy, including waste prevention and recycling, if it leads to significant inefficiencies in the use of materials or in the direct or indirect use of natural resources, or if it significantly increases the generation, incineration or disposal of waste, or if the long-term disposal of waste may cause significant and long-term environmental harm; 
  5. the environmental objective of pollution prevention and control, if it leads to a significant increase in emissions of pollutants into air, water or land;
  6. the environmental objective of protecting and restoring biodiversity and ecosystems, if it is significantly detrimental to the good condition and resilience of ecosystems, or detrimental to the conservation status of habitats and species, including those of Union interest. 
What is the scope of the DNSH-principle?

The DNSH principle must be respected and its compliance must be demonstrated when a decision has been taken by a public authority to that effect. This applies to the following instruments:

  1. Measures of the National Recovery and Resilience Plan financed by the European Recovery and Resilience Facility, as well as those financed by the federal budget following a government decision to that effect.  

    Indeed, Article 5.2. of Regulation (EU) 2021/241 establishing the Recovery and Resilience Facility (RRF), the main instrument of NextGenerationEU, makes the DNSH principle a horizontal principle of the Recovery and Resilience Plans (RRP). Therefore, all measures in Belgium's RRP must be DNSH compliant in order to receive funding from the European Commission. In Belgium, the federal government has decided to apply the DNSH principle to all infrastructure investments and policies financed by the federal recovery plan. 

    The same applies to the REPowerEU programme, the European Union's emergency plan to end its dependence on Russian fossil fuels and combat the climate crisis. The RePowerEU programme builds on the Recovery and Resilience Facility and complements national RRPs. The DNSH principle must therefore also be respected by investments made under this programme. The application of the DNSH principle in REPowerEU is described in a Commission guidance document.
     
  2. A wide range of European programmes (included in the so-called 'Common Provisions' Regulation (EU) 2021/1060) also recommend the application of the DNSH principle. The 8 funds covered by this common regulation are:
  • the European Regional Development Fund (ERDF),
  • the European Social Fund plus (ESF+),
  • the Cohesion Fund,  the Just Transition Fund (JTF),
  • the European Maritime, Fisheries and Aquaculture Fund (EMFAF), 
  • the Asylum, Migration and Integration Fund (AMI),
  • the Internal Security Fund (ISF), 
  • The Border Management and Visa Instrument (BMVI).

It is expected that the application of the DNSH principle will be further extended in the future.​

Who are the stakeholders involved?

Public authorities must ensure that the DNSH-principle is included in all documents related to a call for projects or a public tender (memorandum or tender document, grant agreement, etc.) that is subject to the DNHS-obligation.

Private companies responding to a call for proposals that is subject to the DNSH-obligation, must carry out a self-evaluation using the form provided by the public authority. Such evaluation must demonstrate that the project does not cause significant harm to the six environmental objectives and determine the corresponding conditions to be respected during the implementation of the project. The assessment should consider the entire life cycle of the project, covering the production, use and end-of-life phases, considering the direct and most important indirect impacts of the project.

All stakeholders are invited to document compliance with the DNSH provisions as best as they can. Indeed, European funding is subject to compliance with the DNSH-principle, which may be audited by the European authorities.

What is the role of the DNSH Federal Centre of Expertise?

The DNSH Federal Centre of Expertise within the FPS Public Health, Safety of the Food Chain and Environment supports the federal public authorities in their application of the DNSH principle by developing methodological tools and training. Moreover, it offers direct assistance to the federal authorities should they have any questions, especially concerning the DNSH evaluation.

The expertise centre does not assist private companies in preparing their DNSH self-evualuation.

 Contact details: dnsh@health.fgov.be

The Interfederal DNSH network

The Federal Planning Bureau coordinates an inter-federal network of SPOCs in which the federal authorities, regions and communities are represented.

The interfederal network, through regular meetings, exchange of good practices and training, ensures the consistency of the interpretation and implementation of the DNSH regulations among the different institutional entities.  

Legislation

The "Do No Significant Harm" (DNSH) principle is one of the key principles established by the "Taxonomy 2020" regulation (Regulation (EU) 2020/852), which is the basis for the classification of sustainable economic activities.
 
In the framework of the EU Recovery and Resilience Plan (RRP), the DNSH principle must be respected for all measures in the national plans according to Article 5.2. of the Regulation (EU)2021/241  establishing the Recovery and Resilience Facility (RRF). The European Commission's Technical Guidance (2021/C 58/01) is intended to assist national authorities in applying the DNSH principle when developing their RRP.
 
For Belgium's RRP, details on the implementation and monitoring of the plan, including specific milestones and targets related to the DNSH principle, can be found in the European Council Implementing Decision and its annexes as well as in the Operational Arrangements

FAQ

For more information about the DNSH principle, see this FAQ.