The German association of industrial energy consumers (VIK e.V.) welcomes an opportunity to provide feedback on the Draft delegated regulation, which is based on the empowerments set out in the Taxonomy Regulation.
This paper investigates several issues, which from the perspective of the German energy-intensive industry can result in unclear interpretations, and therefore, raise difficulties throughout the application and implementation of proposed delegated regulation. These issues include an impact on future investment activities, tax increases and new production costs, unclarity of the ‘do no significant harm’ criteria and exclusion of the variety of the transitional technologies. Finally, the paper highlights selected examples of the technical screening criteria for certain production activities, which are important to include in the current annexes.