Framework and application of the EU Taxonomy

As a community of states, the European Union (EU) has set itself the target of becoming climate neutral by 2050 as part of the European Green Deal. The EU Environment Council raised this target during the reporting period, aiming for a 90 % reduction in emissions by 2040 in comparison to the base year 1990. One major objective in this regard is to channel capital into sustainable investments via the EU Action Plan on Sustainable Finance. In order to support this goal, the EU Taxonomy Regulation came into force in mid 2020. It is a uniform and legally binding classification system that defines which economic activities in the EU can be deemed “environmentally sustainable”. Company-specific information on the results of this classification must be reported annually. In June 2021, the Climate Delegated Act was passed, which establishes the economic activities and technical screening criteria for the first two of the six environmental objectives. This was followed in June 2023 by the Environmental Delegated Act, which included classifications for environmental objectives three to six. The following six environmental objectives are listed in Article 9 of the Taxonomy Regulation:

• Climate change mitigation

• Climate change adaptation

• The sustainable use and protection of water and marine resources

• The transition to a circular economy

• Pollution prevention and control

• Protection and restoration of biodiversity and ecosystems

Stipulations on sustainable economic activities within the meaning of the environmental objectives are set out in the description of the economic activity in the delegated acts; here, those economic activities are listed which can generally be considered sustainable.

Definition of sustainable economic activities

With regard to the classification of an economic activity as “environmentally sustainable” under the EU Taxonomy, it is necessary to distinguish between taxonomy eligibility and taxonomy alignment. The first step is to check whether an economic activity is described in the Climate Delegated Act or in the Environmental Delegated Act and thus taxonomy-eligible. Only economic activities which are taxonomy-eligible can then be identified as taxonomy-aligned and therefore sustainable. This requires these economic activities to fulfil three conditions: they must make a material contribution to one of the six environmental objectives and they must not cause significant harm to any of the other environmental objectives in any way, i.e. have a negative impact on them. Furthermore, these activities must fulfil minimum safeguards, such as compliance with human rights.

Application of the EU Taxonomy

As a result of Section 315b (1) HGB and Art. 8 (1) Taxonomy Regulation, HHLA is obliged to comply with the requirements set out in the Taxonomy Regulation. Under the provisions of the Taxonomy Regulation, the share of taxonomy-eligible economic activities within revenue, capital expenditure and operating expenses was reported in the 2021 reporting period. Disclosure of the share of taxonomy-aligned economic activities has been required since the 2022 financial year. In 2021 and 2022, the shares disclosed related to environmental objectives 1 and 2. From 2024 onwards, the changes resulting from the legal acts to amend the Climate Delegated Act (objectives 1 and 2) and the economic activities of the Climate Delegated Act for objectives 3 to 6 were also included. As part of the EU Omnibus procedure, Delegated Regulation (EU) 2026/73 came into force on 28 January 2025, introducing, among other measures, materiality thresholds for reportable economic activities and modified reporting templates. For the 2025 reporting period, HHLA is exercising the option available for first-time application and is reporting without applying Delegated Regulation (EU) 2026/73.

All of HHLA’s fully consolidated affiliates are included in these analyses for the EU Taxonomy.