Guidance report on incorporating the objectives of the "do no significant harm" principle in R&I

The "Do No Significant Harm" (DNSH) principle originates from the EU Taxonomy Regulation (EU 2020/852), which requires that sustainable investments avoid adverse environmental impacts while pursuing specific goals. The Regulation defines six environmental objectives — (1) climate change mitigation, (2) climate change adaptation, (3) the sustainable use and protection of water and marine resources, (4) the transition to a circular economy, (5) pollution prevention and control, and (6) the protection and restoration of biodiversity and ecosystems—and stipulates that progress toward any one objective must not come at the expense of the others. This principle sits at the heart of both the EU's Sustainable Finance Disclosure Regulation (SFDR) and the Recovery and Resilience Facility (RRF) guidelines, serving as a cornerstone of credible, holistic sustainability.

This report begins by tracing the conceptual roots of DNSH in international law and examining how it is defined and operationalized across EU policy and research funding programmes. It further explores two key relationships that shape the principle's practical reach. First, it examines the relationship between DNSH and the Green Oath, arguing that while both instruments share the goal of embedding environmental responsibility into EU policymaking, they remain structurally misaligned — one operating as an ethical and aspirational political commitment, the other as a legal and technical compliance instrument — and that this tension creates a risk that formal procedural adherence to DNSH displaces rather than embodies the substantive environmental engagement the Oath was designed to cultivate. Second, it addresses DNSH's relationship to the precautionary principle, arguing that precaution should function as an upstream filter — activating harm scrutiny before evidence of damage is conclusive, and thereby transforming DNSH from a reactive procedural check into a genuinely protective mechanism capable of accounting for long-term, cumulative, and scientifically uncertain risks.

The report's central argument is that the persistent gaps between DNSH's formal requirements and its practical implementation are not merely technical failures. They reflect a deeper conceptual limitation: a narrow, quantitative conception of harm that systematically excludes cultural loss, irreversibility, distributive injustice, and the moral claims of non-human beings and Indigenous communities. Building on a critical analysis of DNSH's current limitations, the report integrates insights from the mapping of environmental and climate ethics in the context of sustainable transitions (Deliverable 1.1, WP1) and empirical evidence from participatory social labs (Deliverable 2.3, WP2). It further draws on environmental humanities, ecology, and transcultural perspectives — including Indigenous approaches and Eastern philosophical traditions — to broaden the conceptual understanding of harm. This expanded framework is complemented by a deductive semantic analysis of harm-related language in the Human Relations Area Files (e-HRAF), which illuminates cross-cultural patterns in how harm, responsibility, purity, and social order are articulated.