How to apply the DNSH principle to photovoltaic systems: benefits, procedures, and incentives

In the context of ecological transition and sustainable development, the European Union has introduced the DNSH principle, an acronym for Do No Significant Harm, which means "not causing significant damage" to the environment. This is a fundamental criterion that businesses must comply with in order to implement projects compatible with the green transition and to access public incentives.

In this article, we analyze in detail what the DNSH principle is, how it applies to photovoltaic plants, and what the procedures and benefits related to its compliance are.

What it is and how it works

The DNSH principle has been defined by the EU Regulation 2020/852, better known as the "Green Taxonomy", which classifies sustainable economic activities. According to this regulation, every intervention must demonstrate that it does not cause significant harm to the environmental objectives set by the European Union.

In other words, it is not enough to reduce CO₂ emissions or save energy: to be considered truly sustainable, a plant must maintain an overall balance with the environment, avoiding negative impacts on natural resources and ecosystems.

Environmental objectives and requirements to be met 

The application of DNSH to photovoltaic plants means that, in order to obtain incentives and financing, it is necessary to demonstrate that the plant does not cause significant damage to the environment or the surrounding ecosystems. This translates into a series of technical and managerial criteria to be respected.

The six pillars of environmental sustainability

According to EU Regulation 2020/852, photovoltaic plants must be designed and managed so as not to cause harm to any of the following environmental objectives:

• Mitigation of climate change: contribute to the reduction of greenhouse gas emissions.

• Adaptation to climate change: design the plant to be resilient to extreme weather events.

• Sustainable use of water and marine resources: ensure that the project does not lead to excessive exploitation of water resources.

• Circular economy and waste management: promote recycling and sustainable management of materials and waste generated.

• Pollution prevention: avoid harmful emissions into air, water, and soil.

• Protection of biodiversity and ecosystems: protect local flora and fauna without harming natural habitats.

Best practices for sustainability

Compliance with these objectives translates into a series of good design and management practices, including:

• Carefully evaluate the location of the plant, avoiding environmentally sensitive areas.

• Use certified and low environmental impact components, compliant with European standards (CE marking, RoHS) and quality and environmental certifications (ISO 9001/14001/45001).

• Design the plant to facilitate maintenance and recycling of the modules at the end of their life, following WEEE guidelines.

• Adopt a waste management plan for the waste resulting from the installation and decommissioning of the plant.

• Ensure that the production of photovoltaic energy does not compromise local water resources or biodiversity.

These measures help ensure that the photovoltaic plant is indeed a sustainable photovoltaic plant, in line with European requirements.

How it impacts the incentive system

Required procedures and obligations

The DNSH principle plays a key role for those looking to access the incentives provided by the Transition Plan 5.0. To obtain these contributions, it is necessary to submit a substitute declaration that certifies the compliance of the plant with environmental requirements.

In practice:

1. The company must fill out the substitute declaration, attaching any technical reports and environmental impact analyses.

2. The Energy Services Manager (GSE) may require further verifications, such as life cycle assessments (LCA) or environmental assessment reports.

3. Compliance with these standards is particularly required for plants up to 1 MW, but it represents a general criterion also for larger projects.

Without this documentation, it is not possible to obtain public contributions, as the European Commission ties funding to compliance with the DNSH rules.

The benefits of respecting the principle

Ensuring that a photovoltaic plant complies with European environmental criteria offers various advantages, both economic and environmental:

• Access to public incentives, such as PNRR funds.

• Greater regulatory compliance, avoiding the risk of sanctions or bureaucratic blocks.

• Positive reputation for the company demonstrating environmental responsibility.

• Reduction of negative environmental impacts and increased durability of the plant itself, thanks to circular economy practices.

Frequently Asked Questions (FAQ)

What is DNSH?

It is a European principle that requires that every activity does not cause significant damage to the environment, applicable also to photovoltaic plants.

What documents are needed to demonstrate compliance with DNSH?

A substitute declaration is required, possibly supplemented by technical sheets, environmental analyses, and impact reports.

How does DNSH affect costs and implementation times?

Compliance with DNSH criteria may involve higher initial costs, but it ensures access to incentives and greater durability of the plant.