Health and Global Policy Institute (HGPI) submitted a comment in response to the public call for comments on the Annex 1 Appended Table (Green List) of the Green Bond and Green Loan Guidelines, conducted by the Ministry of the Environment.

The Ministry of the Environment established the Green Bond Guidelines in March 2017, in line with international principles (the Green Bond Principles of the International Capital Market Association (ICMA)), with the aim of ensuring the credibility of the environmental benefits of green bonds and green loans and of promoting their uptake in Japan. The “Green List,” the Appended Table to Annex 1 of these Guidelines, organizes and presents the green projects eligible for green bonds and green loans as examples of green use of proceeds. Since its establishment in July 2022, it has undergone successive revisions to reflect market, policy, and technological developments, and efforts continue to enrich it further—particularly to broaden its reach to new fundraisers and fields. This year’s call for comments was held from June 12 to July 17, 2026, and sought a wide range of opinions on what should be added to the Green List with respect to (i) specific examples of use of proceeds (sub-categories), (ii) examples of specific indicators for calculating environmental benefits, and (iii) examples of negative environmental impacts.

Climate change is a pressing issue that has serious impacts on people’s health. Amid the rapid rise in temperatures in recent years in particular, measures against heat-related health harm are growing in importance in health care and welfare settings. Minor category 8-5 “Health” of the Green List covers such measures against extreme heat, but this domain presents a distinctive difficulty. Here, a tension exists whereby efforts that are indispensable to preventing health harm may, through reliance on mechanical air conditioning and the like, conversely increase greenhouse gas emissions and thereby exacerbate climate change. From the perspective of “planetary health,” which regards the health of people and of the planet as one, HGPI considers it important that the Green List, too, incorporate a viewpoint that reconciles short-term health protection with long-term decarbonization, and it submitted its comments accordingly.

Key Points of the Comments

[Minor category (Examples of Use of Proceeds)]
As specific project examples under Minor category 8-5 “Health,” include efforts that seek to reconcile the urgent objective of preventing heat-related health harm with the long-term objective of decarbonizing facilities—such as efforts by medical and other institutions toward obtaining ZEB Ready certification, the adoption of cooling equipment using low-GWP (global warming potential) refrigerants, and the installation of renewable energy equipment.

[Indicators of Environmental Benefits]
As indicators for calculating environmental benefits in reporting and the like, add (i) the proportion of facility and support-service users who have risk factors for severe or fatal heatstroke—such as living alone, underlying medical conditions, the absence or non-use of air conditioning, and low income—and to whom support has actually reached, and (ii) the reduction in the number of annual heat-related excess deaths.

[Negative impacts]
In addition to the “increase in greenhouse gas emissions” arising from the installation and use of equipment, explicitly note the “concern that entrenching (locking in) reliance on air-conditioning-based responses may delay the transition to low-carbon measures against heat.”

[Other]
Ensure that the Green List reflects efforts and indicators that make visible—and seek to reconcile—both short-term health protection and long-term decarbonization. In addition, expand the eligible projects, currently limited to measures against heat, in the future to encompass the broader health impacts of climate change, such as the expanding distribution of disease vectors and changes in air quality and allergens.

Background and Grounds for the Proposal

As grounds for its comments, HGPI showed that the harm is concentrated among specific at-risk groups. Older adults account for more than 80 percent of heatstroke deaths, and data from Tokyo’s 23 wards report that approximately 85 percent of those who died of heatstroke indoors were not using air conditioning (including cases where none was installed). From the standpoint of substantively reducing harm, it is important to evaluate not merely the total volume of support but whether support is reaching those at high risk—the “heat-vulnerable.” HGPI also showed that deaths recorded as heatstroke represent only a portion of the health harm caused by heat; in reality, heat-related excess deaths through cardiovascular and respiratory diseases are said to far exceed them. To grasp the full picture of the health harm associated with climate change, it is essential to focus not only on heatstroke deaths in the narrow sense but also on such excess deaths.

With respect to negative impacts, HGPI presented the perspective of “maladaptation” noted by the Intergovernmental Panel on Climate Change (IPCC). While large-scale reliance on mechanical air conditioning to prevent health harm serves immediate health protection, through its “lock-in” it risks making the long-term shift to more sustainable, low-carbon forms of heat adaptation—such as the passive cooling of buildings and greening—difficult over the long term. HGPI proposed that the negative impacts should describe not merely the concern of increased emissions but also the long-term concern that the transition to low-carbon options is impeded.

The Green List is a guide for channeling funds, through green finance, toward projects that deliver clear environmental benefits. Minor category 8-5 “Health” is an item in which preventing health harm and reducing greenhouse gas emissions can be structurally in tension; reflecting in the Green List efforts and indicators that make visible the reconciliation of the two would help promote flows of funds that advance decarbonization while protecting health under a changing climate. HGPI hopes that this proposal will contribute to the development of green finance that serves the realization of planetary health.

HGPI will continue to contribute to the advancement of planetary health through the provision of knowledge and the facilitation of dialogue, and will pursue policy recommendations and collaboration with relevant organizations.

For more details on the call for comments on the Annex 1 Appended Table (Green List) of the Green Bond and Green Loan Guidelines, please see here (in Japanese only).