What is DNSH

DNSH stands for "do no significant harm". To understand what this term fully covers, we need first to introduce sustainable activities. The EU Sustainable Taxonomy has been introduced as a classification system allowing to determine what can be considered as a sustainable activity according to several horizontal criteria.

A sustainable activity is expected to be significantly contributing to the environmental objectives AND it should also not harm any of those 6 objectives:

1. Climate change mitigation
2. Climate change adaptation
3. Sustainable use & protection of water & marine resources
4. Pollution prevention & control
5. Transition to a circular economy
6. Protection and restoration of biodiversity & ecosystems

These 6 objectives can be explained as follows. An activity is considered to DO significant HARM to:

1. climate change mitigation if it leads to significant greenhouse gas (GHG) emissions;
2. climate change adaptation 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 This means specifically that significant harm to the objective of climate change adaptation can be done by either (i) not adapting an activity to the adverse impacts of climate change when that activity is at risk of such impacts (such as a building in a flood-prone area), or (ii) by maladaptation, when putting in place an adaptation solution that protects one area (“people, nature or assets”), while increasing risks in another area (such as building a dyke around a plot in a flood plain which results in shifting the damages to a neighboring plot that is not protected);
3. the 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 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. pollution prevention and control if it leads to a significant increase in emissions of pollutants into air, water or land;
6. the protection and restoration of 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.

Areas where DNSH is applicable

At programming stage, the Horizon Europe Work Programme has been co-created to support research and innovation activities that respect climate and environmental priorities of the Union and cause no significant harm to them.

At project level, the reference to the DNSH principle in the Horizon Europe Work Programme is included in the application form (proposal part B template) to offer researchers the possibility to present the credential of their projects in relation to the DNSH principle. Applicants can refer to the DNSH principle when presenting their research methodology and the expected impacts of the project, to show that their project will not carry out activities that make a significant harm to any of the six environmental objectives of the EU Taxonomy Regulation listed above (Part B Standard Application Form).

Pillar I – Excellent Science

The principle is not applicable.

Pillar II – Global Challenges

In line with Recovery and Resilience Facility’s (RRF) requirement and the European Green Deal objectives, research and innovation activities should comply with the ‘DNSH’ principle, as defined in Articles 3(b) and 17 of the EU Taxonomy Regulation 16 established to determine whether an economic activity is environmentally sustainable. Compliance with the ‘DNSH principle needs to be assessed both for activities carried out during the course of the project as well as the expected life cycle impact of the innovation at a commercialisation stage. The robustness of the compliance must be customised to the envisaged TRL of the project. In particular, the potential harm of Innovation Actions contributing to the European Green Deal will be monitored throughout the project duration. Horizon Europe projects will play an important role to help economic operators reach or go beyond the standards and thresholds set up in the Regulation as technical screening criteria and to keep them up-to-date. Alignment of research and innovation activities with EU Taxonomy technical screening criteria will also be piloted in selected topics with the aim to facilitate their later access to green finance to foster the market uptake of the innovative technologies and solutions they developed.

References on the DNSH principle are included in the Work Programme 23-24 in the general introduction and not anymore in specific clusters of pillar 2 (4,5 and 6) nor in the Missions WP (except Climate Mission) as was the case in the Work Programme 21-22. It can be specifically mentioned in a call topic.

However, evaluators will not score applications in relation to their compliance with the DNSH principle unless explicitly stated in the call topic. Evaluators are asked in one addional question whether the proposal is compliant with the DNSH principle and provide comments in the case the answer to the question is 'Partially', 'No' or 'Cannot be assessed'. The answer to this question will be used for monitoring purposes and for a proper follow up in the case the project is funded.

Pillar III: Innovative Europe  - European Innovation Council (EIC)        

Projects must comply with the ‘DNSH’ principle of the EU Sustainable Finance Taxonomy. This means in particular that EIC funding will not be awarded to projects that contravene the objectives of the Green Deal, as is written down in the briefing of experts, evaluators of Horizon Europe projects (slide 34).

Further reading

• (1) programme-guide_horizon_en.pdf (europa.eu) p39
• EU taxonomy regulation
• Technical Guidance on DNSH evaluations for specific cases:
  • Commission Delegated Regulation (EU)
  • Information from European Union Institutions, Bodies, Offices and Agencies