No. A product name alone does not make a product Article 8. The product must actually promote environmental or social characteristics as described in SFDR.
Can a product name containing “sustainable”, “sustainability”, or “ESG” qualify a product as promoting environmental/social characteristics under Article 8?
Recital 21 of Regulation (EU) 2019/2088 makes it clear that sustainable financial products with various degrees of ambition as to “sustainability” have been developed to date. Accordingly, where such financial products do not have ‘sustainable investment’ as their objective, as referred to in Article 9, they are considered to fall under Article 8 of that Regulation. Article 8 and Article 9 SFDR are two distinct product categories: financial products that promote environmental or social characteristics or a combination of those characteristics, provided that the companies in which the investments are made follow good governance practices (hereinafter ‘financial products that promote environmental or social characteristics’), and financial products which have sustainable investment as their objective respectively. The two distinct product categories are key to determine the access of end investors to financial products that are ambitious enough to meet their sustainability preferences.
European Commission
