What "Substantial Contribution" Means
An activity substantially contributes to an environmental objective when it makes a meaningful positive impact - not a trivial one. The Taxonomy Regulation defines this differently for each objective, and the delegated acts translate those definitions into measurable thresholds.
For climate change mitigation (the most common objective), an activity substantially contributes if it:
- Generates, transmits, stores, or enables renewable energy
- Improves energy efficiency
- Increases clean or climate-neutral mobility
- Switches to renewable materials
- Increases carbon capture and storage
- Reduces GHG emissions to levels consistent with long-term climate targets
The key word is "consistent with long-term climate targets." The criteria are designed to identify activities performing at a level compatible with net zero by 2050.
Technical Screening Criteria: The Actual Numbers
The delegated acts translate "substantial contribution" into concrete, measurable thresholds. Here are some examples from the Climate Delegated Act:
| Activity | Threshold for Substantial Contribution (Mitigation) |
|---|---|
| Electricity from solar PV | No threshold - automatically qualifies |
| Electricity from wind | No threshold - automatically qualifies |
| Electricity generation (general) | Lifecycle emissions below 100g CO2e/kWh |
| Cement - grey clinker | Below 0.722 tCO2e/tonne of clinker (transitional) |
| Cement - from grey clinker | Below 0.469 tCO2e/tonne of cement (transitional) |
| Steel - BF-BOF (hot metal) | Below 1.331 tCO2e/tonne of product |
| Steel - EAF carbon steel | Below 0.209 tCO2e/tonne (min 90% scrap input) |
| Steel - EAF high alloy | Below 0.266 tCO2e/tonne (min 70% scrap input) |
| Aluminium smelting | Below 100g CO2e/kWh indirect; max 15.5 MWh/tonne Al |
| Passenger cars | 0g CO2/km tailpipe (from 2026) |
| Building renovation | At least 30% reduction in primary energy demand |
| New buildings | Primary energy demand at least 10% below NZEB standard |
| New buildings >5,000 m2 | Same as above + lifecycle GWP must be calculated and disclosed |
These thresholds are reviewed periodically. Some tighten over time (e.g., passenger cars moving to zero tailpipe from 2026).
Two Special Categories
The taxonomy recognises that not every green activity is already zero-carbon. It creates two special categories:
Transitional Activities (Article 10(2))
Activities for which no low-carbon alternative exists yet, but which are performing at the best available level. Think of heavy industry processes that cannot currently run on renewable energy alone.
Requirements:
- Emissions correspond to the best performance in the sector
- Must not hamper the development of low-carbon alternatives
- Must not lead to carbon lock-in (asset life must allow transition)
- Criteria are reviewed every three years
Enabling Activities (Article 16)
Activities that don't directly contribute to an objective but enable other activities to do so. A company manufacturing wind turbine components is an enabler - the turbines generate clean energy, but the manufacturing itself may have emissions.
Requirements:
- Must directly enable another activity to make a substantial contribution
- Must not lead to asset lock-in
- Must have a substantial positive environmental impact based on lifecycle analysis
Transitional and enabling activities are marked as such in the delegated acts. Companies must disclose which of their aligned activities fall into these categories. This prevents a company from appearing fully "green" when it is actually in transition or enabling.
Key Takeaways
- 1Substantial contribution is defined through specific, measurable technical screening criteria in the delegated acts - not through vague 'green' claims
- 2Thresholds vary by activity: solar PV qualifies automatically, while cement must emit below 0.469 tCO2e/tonne of clinker
- 3Transitional activities have no low-carbon alternative yet but must perform at the sector's best level - criteria tighten every three years
- 4Enabling activities don't directly contribute but make it possible for others to do so - wind turbine manufacturing enables clean energy generation