The Green Taxonomy
Thule Group’s 2022 Taxonomy reporting is based on the existing knowledge available on the taxonomy regulations. This is the second year of reporting and our qualified assessments and clarifications on the eligibility screening are listed here.
Thule Group has a high ambition in terms of minimizing our environmental footprint of our products, and production processes. However, our key production processes are not listed as a key sector within the taxonomy compass, nor are our key activities corresponding to activities listed within NACE (Statistical classification of economic activities in the European Community). Hence, this year’s taxonomy reporting has focused on the construction activities carried out in order to minimize our environmental footprint.
Thule Group has invested a total of 186 MSEK in the construction of new facilities and upgrades during 2022, out of a total of 610 MSEK in capital expenditures. Such investments aim to minimize the energy consumption of our sites, and enable the use of electrical vehicles through the installation of electric charging points at our sites.
Not all investments in facilities are taxonomy-aligned, but those that have been scrutinized to meet the taxonomy criteria amount to 20 percent of our total capital expenditures, with 123 MSEK worth of investments. Below are some clarifications on how we approached screening of activities for eligibility and taxonomy alignment.
During the screening process for construction of facilities in Poland, we had to review if the facilities are built on arable land or not. In Poland where most of the construction activities have been carried out, the Polish authorities classify the land into grades spanning from 1 to 6. On lands that have been classified from1 to 3 by the Polish authorities, no permits are granted for repurposing of the soil for industrial activities. Thule Group’s facilities are built on soil that has been classified mainly as grade 6, and some parts were classified as grade 4. Hence Thule Group has made the assessment that no valuable soil is used for its operations, hence allowing the construction of our facilities in Poland to meet the taxonomy criteria.
We have also reviewed the primary energy demand (PED) of newly constructed buildings. In order to be taxonomy-aligned, the building has to have a PED that is 10 percent below the threshold value stated by the local authorities. Our assessment indicates that the PED of the buildings fulfils the taxonomy criteria, based on the interpretation EU Commission Recommendation, 2016/1318, on the guidelines for nearly net-zero energy buildings, that energy produced on site reduces the primary energy needs and demands of the building. Therefore we have deducted the solar power produced on site from the overall PED calculation of the buildings. This is also the case for the Swedish facility in Hillerstorp, Sweden, where the solar energy production during 2022 accounts for 9 percent of the site’s total energy consumption.
When building the larger facilities in Poland, Thule Group has not conducted the air tightness testing due to the size of the buildings. However, the buildings have been assessed throughout the construction process, from a stringent quality perspective to safeguard that they are compliant with the rules and regulations of Polish building laws, which also takes into account thermal integrity and building air tightness.
In 2022, we also installed LED lights in several sites. However, the taxonomy criteria require companies to use the two highest classes of energy efficiency, i.e. A and B. In 2022, LED lights in class A and B were not available in the market. Therefore, even if Thule Group chose the best available options in the market, we were unable to include the LED lights as part of taxonomy eligible capital expenditures.
The taxonomy eligible OpEX has also increased from 0.6 percent to 3 percent in 2022. There is a possibility that it is due to improvements in the interpretation of the taxonomy regulation, and due to improvements in maintenance, and repair of energy efficient equipment, improvements in the repair and maintenance of instruments and devices for measuring, regulating and controlling energy performance of buildings, and maintenance and repair of renewable energy.
