"The extension of the criteria's scope to include all investment-based insurance products (IBIPs) is an important step towards greater sustainability. Nevertheless, the decision to extend the scope was taken late in the process and for the industry to be able to provide a meaningful and substantial contribution towards developing the criteria, additional rounds of review and consultation are required," Insurance Europe explained.
Insurance Europe is also concerned that the proposed criteria are too strict and not adapted to the characteristics of insurance products. In particular, the industry is concerned that the obligation to segregate assets implies a ring-fencing requirement for these products. Insurers fear that this will not be possible in practice without compromising the risk-sharing principle of insurance and the marketability of these products.
The coherence between the Ecolabel criteria and the Taxonomy Regulation should be further enhanced, Insurance Europe added.