FESE welcomes the opportunity to provide input on the third draft of the Technical Report on the product scope and criteria for the EU Ecolabel for financial products.
Currently there are various national Ecolabels in place with diverging requirements. We believe that having a harmonised Ecolabel for European products would facilitate cross-border trading in sustainable financial products. We consider that the proposal for an Ecolabel would have the biggest impact if it is achievable by a large number of asset managers. Pressure on companies to match the thresholds will lead to a reorientation of financial flows.
We consider that the link to the EU Taxonomy in the Technical Report overall appears understated, whilst the expectation would be for the Ecolabel to build on this framework, at least for those activities that are currently covered and refer to the DNSH criteria and social safeguards in the exclusion criteria.
Further clarity is also needed regarding whether sustainability-linked bonds are within scope of the Ecolabel or not, as these are not explicitly mentioned. For our detailed views, please see the full response here.