Do no significant harm principle – What does it mean for researchers?

Recently, sustainability has become a major consideration in research funding. While there are many ways to look at sustainability, the Sustainable Development Goals developed by the United Nations have become mainstream in many funders’ requirements. The SDG’s present clear and concrete goals to achieve sustainability and even come with indicators to monitor their success. They do, however, have limitations. First, they are not legally binding and second, advancing one goal might inadvertently hinder the progress of another. The EU now indirectly tackles this issue by presenting a new taxonomy regulation combined with the ‘'do no significant harm’ (DNSH) principle. Stemming from the various policy activities in support of the European Green Deal, the DNSH principle forces researchers to think about the possible negative impacts of their research.

In the Horizon Europe funding programme, and in research funding calls from the Academy of Finland and Business Finland, where the funds are allocated through Finland’s preliminary Recovery and Resilience Plan, applicants are expected to consider, where relevant, how the project methodology complies with the ‘do no significant harm’ principle. This means that the methodology should be designed in a manner which does not significantly harm any of the six environmental objectives of the EU Taxonomy Regulation. EU Taxonomy is a science-based classification system for determining whether an (economic) activity can be considered environmentally sustainable. It establishes six environmental objectives:

• 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
• The protection and restoration of biodiversity and ecosystems.

The EU sees that e.g., solving the climate crisis must not come at the expense of other environmental objectives. The Horizon Europe work programme has been designed to support research and innovation activities that respect climate and environmental priorities of the EU and cause no significant harm to them. However, at project level, reference to the DNSH principle is included in the application form (proposal part B) so that researchers have the possibility to present the credential of their project in relation to the DNSH principle. Compliance needs to be assessed both for activities carried out during the course of the project as well as the expected life cycle impact of the innovation at a commercialization stage (where relevant). The Commission expects that especially researchers planning activities in Clusters 4, 5, and 6 give the DNSH principle due consideration because of the increased potential of negative environmental outcomes and impacts of projects. Do note however, that even though the DNSH principle needs to be taken into consideration when assessing the methodology and impact of the project, compliance is not mandatory (and not an evaluation criteria) unless explicitly stated. Simply put, developing new technology for wind farms is substantially contributing to climate change mitigation, which is good. But on the other hand, it may also have negative impacts, especially if the novel technology leads to new farms situated badly and harming the biodiversity. Both aspects need to be taken into consideration and possible negative effects should be weighed up and mitigated. So, when elaborating the positive impacts of your research, you should also consider the possible negative ones.

The new requirement has been criticised for adding to bureaucratic overheads which contradicts the recent efforts to simplify the Horizon Europe application process. It is unclear what will be the real benefit of adding the DNSH principle to research funding applications. It also remains to be seen whether Academy of Finland (AoF) and Business Finland want to integrate the DNSH principle in all future funding applications, currently it only regards calls from the recovery funds. For example in the AoF funded Key Areas of Green and Digital Transition 2021 call a brief description (max. 1 page) of how the projects comply with the ‘Do No Significant Harm’ principle (DNSH), and a free-form commitment from the applicant to comply with the principle were required. Recently, the Finnish Environment Institute (SYKE) has published their Guidance to implement the “Do No Significant Harm” (DNSH) principle required by the EU funding facility for measures under the Finnish recovery and resilience plan. The paper presents approaches and methodologies for the DNSH assessment of funding applications designed particularly for investment projects as well as research, development and innovation projects.

As much as the DNSH requirement may seem redundant, the direction is right. Research plays a key role in solving our current grand challenges. The UN Global Sustainable Development Report 2019 set out six cross-cutting factors, which are relevant to all SDGs, the so-called entry points, and stated that progress on all the UN SDGs “will only be achieved if important trade-offs are addressed and transformed”. Researchers were called to focus on the cross-cutting factors instead of the individual sustainable development goals. These entry points are:

• Obstacles to human well-being and capabilities
• Sustainable and just economies
• Food systems and nutrition patterns
• Energy decarbonization with universal access
• Urban and peri-urban development
• Global environmental commons

Even though the entry points and EU taxonomy do not correlate 100%, the message is the same: you need to look at the big picture.