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ESRS E2: Pollution · 2026-5010-final
Disclosure Requirement E2-4

Pollution (Air, Water, Soil, Microplastics)

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official EFRAG source.

Dr Ross Kurinko, Sustainability Reporting Trainer
Reviewed by Dr Ross Kurinko · Sustainability Reporting Trainer LRA educational guidance · Not issued or endorsed by EFRAG
To prepare this disclosure
Disclosure focus

This disclosure asks an organisation to explain how it identifies, manages and reports pollution-related matters across the business, not just at a few visible locations. In practice, it is about showing where pollution risks and impacts arise in relation to air, water, soil and microplastics, and how the organisation responds through policies, controls, monitoring and actions.

The practical focus is on coverage and completeness: whether the reporting captures the full footprint of relevant operations, sites, activities and value chain touchpoints, rather than only flagship facilities. It should help a reader understand which parts of the organisation are included, where the main pollution issues sit, and how the organisation prioritises prevention, reduction and remediation.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official EFRAG source.

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner
Air emission narrative A plain description of what the organisation releases into the air from its operations, covering the main substances or groups of substances and the relevant activity or source. Environmental monitoring logs, stack test reports, emissions inventory, site environmental records. Environment / EHS
Water emission narrative A plain description of what the organisation discharges to water, including the main substances or groups of substances and the discharge point or activity that creates them. Wastewater sampling results, discharge permits, treatment plant logs, environmental monitoring records. Environment / EHS
Soil emission narrative A plain description of what the organisation releases to land or soil, including the main substances or groups of substances and the activity or incident that caused them. Incident reports, spill logs, remediation records, site environmental assessments. Environment / EHS
Pollutant types The specific pollutants or pollutant groups that are included in the organisation’s reporting for releases to air, water or soil. Emissions register, pollutant inventory, permit schedules, laboratory analysis sheets. Environment / EHS
Accidental release details A description of unplanned releases, including what was released, where it happened, and the basic circumstances of the event. Spill incident reports, emergency response logs, corrective action records, insurance or claims files. Environment / EHS
Microplastics made The organisation’s own output of microplastics, with a clear description of the material or product stream that creates them. Product formulation records, manufacturing specifications, process chemistry files, R&D documentation. Product stewardship / R&D
Microplastics used The microplastics the organisation uses in its operations or products, with the relevant material type and where it is used. Bill of materials, procurement specifications, formulation sheets, supplier declarations. Procurement / Product stewardship
Microplastics released The microplastics that leave the organisation’s control and enter the environment, with the activity or pathway that causes the release. Wastewater monitoring, effluent testing, emissions studies, environmental fate assessments. Environment / EHS
Secondary microplastic sources The materials, products or processes that create microplastics through breakdown, wear or fragmentation, and the main source categories involved. Product design files, wear studies, lifecycle assessments, material composition records. Product stewardship / R&D
Microplastic description A short qualitative explanation of the organisation’s microplastic-related activity, including what is happening and why it matters for reporting. Internal technical notes, product stewardship assessments, environmental impact summaries. Product stewardship / Sustainability
Lifecycle impact note A plain explanation of how the product’s full life cycle affects microplastic generation, use or release, from design through disposal. Lifecycle assessment, product design review, end-of-life studies, supplier impact notes. Product stewardship / Sustainability
Tonnes measure The amount reported in tonnes, with the underlying quantity, unit conversion and reporting period clearly identified. Weight logs, production records, conversion worksheets, consolidated reporting file. Finance / Sustainability reporting
Kilograms measure The amount reported in kilograms, with the underlying quantity, unit conversion and reporting period clearly identified. Weight logs, production records, conversion worksheets, consolidated reporting file. Finance / Sustainability reporting
Pollutant list The named pollutants that fall within the reporting set, using the same names and grouping as the source inventory. Permit register, emissions inventory, laboratory results, environmental compliance tracker. Environment / EHS
Reporting threshold The cut-off used to decide which pollutants are included, with the basis for the threshold and how it is applied. Methodology note, permit conditions, internal reporting rules, calculation workbook. Environment / EHS
Monitoring coverage The sites, operations or discharge points that are covered by monitoring, and any parts of the business that are outside that scope. Monitoring plan, site register, discharge map, environmental sampling schedule. Environment / EHS
Treatment transfers Any wastewater or waste transfers sent for treatment, including the receiving treatment route and the reason for the transfer. Waste transfer notes, wastewater routing logs, treatment contractor records, manifests. Operations / Environment
Transfer volumes The quantity moved for treatment, with the unit, period and measurement basis clearly stated. Transfer logs, weighbridge tickets, meter readings, contractor invoices. Operations / Environment
Treatment destination Where the transferred material went for treatment, including the receiving facility or treatment type. Waste transfer notes, contractor certificates, treatment facility records, routing documentation. Operations / Environment
＋ Show E2-4 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first. Decide which sites, operations, products and activities are in scope for air, water and soil emissions, accidental releases, and any microplastic-related items you need to cover.
2Agree the definitions you will use. Fix what you will count as each pollutant type, each microplastic category, each transfer to treatment, and each destination so the team applies the same rules throughout.
3Gather the underlying records. Pull together monitoring results, incident logs, waste or transfer records, lab outputs, and any internal registers that support the figures or the narrative for each required item.
4Build the disclosure content. Prepare the numbers where a quantity is needed, and write the explanations where the item calls for a description of sources, thresholds, monitoring coverage, or product-life effects.
5Record any gaps, exclusions or methodology changes. Note what was left out, why it was left out, and whether the approach changed from the prior period so the reported information can be understood in context.
6Check the draft against the official source before sign-off. Confirm every required item is covered, the wording matches the underlying evidence, and the final version still reflects the current reporting basis.
Request the data

Request pollution and spill data from EHS / site operations

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

What pollution releases, spill events, and microplastic-related information do we need from operations for the reporting period?

Use your organisation’s own labels first, then map them to the reporting disclosure. For example, ask for site emissions, discharge logs, spill records, waste-water records, or process-loss records if those are the terms your teams already use. Keep the request in operational language and only translate into the reporting wording when you prepare the final pack.

Weak request

Please provide the ESRS E2:E2-4 data for pollution, including emissions to air, water and soil, pollutant types, accidental releases, microplastics produced, used and released, secondary microplastics, and transfers to treatment.

Why it fails: This uses framework wording that many operational teams will not recognise, so the owner may not know which logs, registers, or systems to search. It also bundles several different evidence types without saying how to pull them from day-to-day records.

Better request

Please send the environmental incident, discharge, and release records for [reporting period] for [sites / business units]. We need any air releases, water discharges, soil contamination events, spill records, pollutant lists, microplastic-related materials, and any transfers to treatment, with the source file or system, quantity, unit, and short explanation for each line.

Formal email template
Subject: Request for pollution and spill data for [reporting period]

Dear [name],

We are preparing the sustainability reporting pack and need your help with the environmental data for [reporting period] across [sites / business units].

Please send the information you hold on:
- releases to air, water, and soil;
- pollutant types involved;
- any accidental releases or spill events;
- any microplastic-related materials we produce, use, or release;
- sources of secondary microplastics, where relevant;
- any transfers to treatment, including volumes and destination.

Please use your normal site or operational records and include the source file or system for each item. If a field is not available, please note that clearly rather than leaving it blank.

For each line, please include the period covered, site, description, quantity, unit, and any short note needed to explain the figure.

A possible LRA training template is attached below for adaptation to your organisation. Please check the official source before sign-off.

Many thanks,
[preparer name]
[team]
[contact details]
Short Teams / Slack version
Hi [name] — could you send the site environmental data for [reporting period]?

We need releases to air / water / soil, spill or incident records, pollutant types, and any microplastic-related figures we hold. Please include the source file/system, site, quantity, unit, and a short note for anything unusual.

If something is not available, please flag it rather than leaving it blank. Thanks.
Industry examples
Manufacturing

Context. A plant uses solvents, has stack monitoring, wastewater discharge records, and a spill log.

Adapted request. Please pull the plant environmental register for [reporting period], including stack releases, wastewater discharges, soil incidents, spill events, and any process materials that may create or contain microplastics. For each item, include the site, line or area, pollutant name, quantity, unit, monitoring method, and the source record.

Example response. A table listing stack emissions by line, discharge volumes by outfall, one soil spill event with clean-up status, and a note that no microplastic-related materials were used or released during the period.

Retail / Distribution

Context. A distribution network has fuel handling, vehicle wash water, and contractor-managed waste transfer records.

Adapted request. Please share the depot environmental and incident logs for [reporting period], including any fuel or chemical spills, wash-water discharges, soil impacts, and any materials or packaging that could shed microplastics. Also include any transfers of contaminated material to treatment and the destination used.

Example response. A summary showing two minor fuel spills, wash-water sent to the on-site treatment unit, and contractor transfer notes for contaminated absorbents, with no recorded microplastic production or use.

Draft your disclosure

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

State which substances and microplastic flows were included, explain how you defined each category in practice, and note the units, boundaries and basis used to compile the figures.

Context note

Explain what the reported emissions, accidental releases and microplastic figures indicate about the company’s environmental footprint, including which pathways or materials are most significant.

Fluctuation statement

If the figures moved materially from the prior period, point to the operational, sourcing, process or incident-related reasons that best explain the change.

Content index entry
E2-4 Pollution (Air, Water, Soil, Microplastics) — [location / page] / [notes]
Download Centre

Preparation tools & forms

Professional preparation tools for E2-4 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.

Free · Community members
01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧
Go deeper · E2-4
Learn to prepare this disclosure end-to-end

This guide covers one Disclosure Requirement. The ESRS / CSRD Reporting course walks the full European workflow — double materiality, datapoints, evidence and assurance — with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
We based the coverage figure on the operations and activities we actually reviewed for the period, and we documented any exclusions or boundary choices before finalising the number.An assurer will test whether the coverage basis was chosen consistently, whether any parts of the business were left out without a clear reason, and whether the reported figure could be overstated or understated by boundary decisions.Boundary memo or reporting scope paper; list of included and excluded sites, entities or activities; management sign-off on scope decisions; reconciliation between the coverage figure and source population.
For the microplastic-related figure, we separated the different streams we tracked and kept the working papers that show how each amount was built up from source records.An assurer will probe whether the figures were split correctly, whether the same quantity was counted twice, and whether the underlying records support the reported amounts.Calculation workbook; source data extracts; product or process records showing the separate streams; review notes confirming no double counting; approval trail for the final numbers.
We prepared the emissions figure from our own-operations records for the reporting year, and we kept incident logs so any accidental releases were captured in the total.An assurer will check whether the figure covers the right period and operational perimeter, whether accident-related releases were included, and whether any material source was missed.Operational emissions register; incident and spill logs; site reports; consolidation schedule for the reporting year; evidence of management review of completeness.
We expressed the amounts in the unit that best fits the substance or stream, and we kept the conversion basis where the source data arrived in another unit.An assurer will test whether the chosen unit is appropriate, whether conversions were done correctly, and whether the same basis was used consistently across the disclosure.Unit-conversion schedule; source records showing original units; calculation checks; reviewer sign-off on the chosen presentation unit.
We used the same mass basis throughout the table, and we checked that each line item was presented on a comparable footing before publication.An assurer will probe for inconsistent units, mixed bases, or presentation choices that make the figures hard to compare or easy to misread.Final disclosure draft; internal consistency review; spreadsheet checks showing common units; evidence of cross-footing or tie-out to source data.
We carried out a management review to decide which pollutant releases were material, using our activities, sector profile, and the monitoring inputs we had available.An assurer will examine whether the materiality judgement was reasoned and documented, whether the right operational and sector factors were considered, and whether the inputs used were complete and current.Materiality assessment paper; list of pollutants considered; monitoring data and threshold references used in the review; management approval or challenge notes.

Evidence pack to prepare

Common reporting gaps

The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.
Common gaps

Mistakes to avoid when collecting the data

Wrong owner
The request goes to the wrong team because it is framed in framework language instead of the plant, lab, waste, or EHS terms people actually use.
Unclear boundary
Data is pulled from some sites or activities but not others because nobody first fixed which operations, locations, and subsidiaries sit inside the reporting boundary.
Wrong period basis
Figures are mixed across different cut-off dates or reporting windows, so the dataset does not line up to one consistent period.
＋ Show 5 more

Where judgement is often needed

Setting the reporting perimeter after a buy-in or sale
Decide whether to include sites and activities only from the date they came into, or left, the group during the period, and explain the cut-off used so readers can see how the totals were built.
Reconciling local pollutant names and categories
Where country-level permits, lab labels, or internal registers use different names for the same substance, map them to one group in a consistent way and disclose the mapping rule you applied.
Drawing the line for shared or borderline operations
For joint sites, leased assets, contractors, or other near-boundary activities, state the practical rule used to decide what sits inside the organisation’s own footprint and what sits outside it.
＋ Show 6 more
Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — speciality chemicals

We summarise the main substances we sent to air, water and land during the year, naming the pollutant groups involved and noting one small accidental spill to soil that was contained on site. - Air: 12.4 tonnes in total, including 7.1 tonnes of nitrogen oxides, 3.0 tonnes of volatile organic compounds and 2.3 tonnes of sulphur oxides. - Water: 4.8 tonnes in total, made up of 2.6 tonnes of suspended solids, 1.4 tonnes of chemical oxygen demand load and 0.8 tonnes of ammonia compounds. - Soil: 1.2 tonnes in total, all from the contained spill noted above; no other land-based discharge was recorded. - Microplastics: we produced 0.9 kg, used 1.6 kg in our process aids, and released 0.2 kg; the released amount came from wear in polymer-coated equipment and filter media. - Secondary microplastics: these arose mainly from abrasion of conveyor belts and packaging film; they are described here as a by-product of normal handling and transport, and their life-cycle effect is linked to product use, maintenance and end-of-life handling.

Illustrative only; figures are synthetic and internally consistent. The narrative covers releases to air, water and soil, the pollutant groups involved, one accidental release, microplastics produced/used/released, and the origin and life-cycle context of secondary microplastics.

Illustrative (synthetic) example — food packaging manufacturing

Our year-end summary shows the main pollutant loads we sent to air and water, a small land release from an incident, and the microplastic figures linked to our operations. - Air: 6.0 tonnes overall, comprising 2.5 tonnes of particulate matter, 1.9 tonnes of nitrogen oxides and 1.6 tonnes of non-methane organic compounds. - Water: 2.7 tonnes overall, including 1.1 tonnes of suspended solids, 0.9 tonnes of phosphorus compounds and 0.7 tonnes of cleaning-agent residues. - Soil: 0.4 tonnes in total, all from one accidental release during tank maintenance; the event was isolated and remediated. - Microplastics: 0.3 kg produced, 2.1 kg used, and 0.1 kg released; the released fraction came from trimming losses and abrasion of plastic liners. - Secondary microplastics: these were generated mainly by cutting, friction and weathering of packaging materials; in plain terms, they are a by-product of how our products are made, handled, used and eventually discarded.

Illustrative only; figures are synthetic and internally consistent. The narrative covers emissions to air, water and soil, pollutant types, an accidental release, microplastics produced/used/released, and the sources, description and product-life-cycle impact of secondary microplastics.

Company reportsReal published reports
Compare side by side →Get it free

How companies report E2-4 in practice

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

UPM-Kymmene Oyj
Forest and Paper Products · Finland · 2024
Open report →
UPM-Kymmene Oyj's 2024 Annual Report provides specific data on emissions to water, reporting total biological oxygen demand (BOD7) of 5,200 tonnes and chemical oxygen demand (COD) of 56,600 tonnes for 2024 on page 91. However, no quotable evidence was found in the report regarding other narrative items related to this disclosure. The report includes some greenhouse gas emissions data on other pages, but these are not directly linked to the water emissions disclosure.
Bakkafrost P/F
Food Production — Animal Source · Faroe Islands · 2025
Open report →
Bakkafrost P/F’s Integrated Annual Report 2025 provides detailed coverage of its greenhouse gas (GHG) emissions, including Scope 1 direct emissions reported according to the GHG Protocol (p.92) and Scope 3 emissions, particularly from purchased goods and services, with specific figures given for total gross indirect emissions and category 1 upstream emissions (p.93-94). The report also states a target to reduce Scope 3 GHG emissions per tonne of product sold by 52% by 2030 from a 2020 base year (p.23). However, while emissions data and reduction targets are presented, the report lacks quotable evidence on other narrative aspects of the disclosure, such as detailed management approaches or qualitative descriptions (no pages).
Grifols, S.A.
Pharmaceuticals / Biotech / Life Sciences · Spain · 2024
Open report →
Grifols, S.A.'s 2024 Integrated and Sustainability Annual Report provides specific data on greenhouse gas emissions, including total location-based emissions of 121,581 and 128,709 t CO2 eq with a 6% decrease noted on page 55. The report also details gross Scope 1 emissions at 106,289 and 106,459 t CO2 eq with a slight decrease of 0.2% on page 54, and mentions zero emissions from regulated emission trading schemes on page 55. However, the report lacks quotable evidence on other narrative items related to emissions or sustainability disclosures, with no additional detailed commentary or context found elsewhere in the document.
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Scenarios to work through

A plant has a small solvent leak that reached a drainage channel and then a nearby stream. The operations team also logged routine stack emissions from the same site, and the reporting team is unsure whether to separate the incident from the normal discharge inventory.

QHow should the preparer decide what to describe for the different release routes, and what should be kept distinct in the write-up?
Reveal model answer →

A factory uses a polymer additive that can break down into tiny plastic fragments during production and later in product use. The team can list the additive, but it is unclear whether the report should also explain where the fragments come from and how the product’s life cycle contributes to them.

QWhat should the preparer include when deciding whether to cover microplastic information in the narrative?
Reveal model answer →

A site sends wastewater sludge to an external treatment facility, while another stream goes to a different destination for recovery. The preparer has volumes for both streams, but the internal records do not yet show which destination each load went to.

QWhat decision should the preparer make before finalising the disclosure on transfers to treatment or disposal?
Reveal model answer →

A laboratory monitors several substances, but only some are tracked because of legal limits, while others are watched under internal thresholds. The team is unsure whether the disclosure should mention the list of substances, the trigger levels used, and which parts of the business are covered by monitoring.

QHow should the preparer decide what to explain about the monitoring approach?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

ESRS
E2-4
within ESRS E2: Pollution
Open official source →
Primary
Related & explore
Go deeper · E2-4
Learn to prepare this disclosure end-to-end

This guide covers one Disclosure Requirement. The ESRS / CSRD Reporting course walks the full European workflow — double materiality, datapoints, evidence and assurance — with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

FAQ

Questions this page answers

How do I use the E2-4 Pollution page to draft the disclosure from scratch?+
What data do I need to collect for E2-4 Pollution before I can write the disclosure?+
How should I set the scope and methodology for the E2-4 Pollution data?+
Who should own the E2-4 Pollution inputs in my organisation?+
What should I include in the evidence pack for E2-4 Pollution assurance?+
What are the common mistakes to avoid when reporting E2-4 Pollution?+
How do I use the Prep & Assurance workbook for E2-4 Pollution?+
What is the printable Library Card PDF for E2-4 Pollution used for?+
Can I use the synthetic example disclosure on the E2-4 Pollution page as a template?+
How do I turn E2-4 Pollution data into a draft narrative and content-index line?+
More questions this page can help with
E2-4 Pollution checklist for sustainability managers: what should I gather before drafting?E2-4 Pollution assurance readiness: what evidence should I keep for review?How do I complete the E2-4 Pollution workbook step by step?What are the E2-4 Pollution datapoints for air, water, soil and microplastics?How do I document monitoring coverage and reporting threshold for E2-4 Pollution?What should the E2-4 Pollution narrative cover if I have accidental release details?How do I avoid common mistakes in the E2-4 Pollution disclosure draft?Where can I find example wording for E2-4 Pollution narrative starters?How do I use the from-company-reports table on the E2-4 Pollution page?What should an assurance reviewer look for in an E2-4 Pollution evidence pack?How do I record pollutant lists and transfer volumes for E2-4 Pollution?Can the E2-4 Pollution page help me assign owners for each data input?
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