Disclosure focus
It also reports primary microplastics manufactured or used in products and the amounts directly released into the environment. Microplastics are part of E2-4 but not part of its official title.
Material pollutants are determined through managerial assessment that considers the undertaking's activities, sector, applicable E-PRTR and IEPR pollutants and other pollutants measured or monitored. A regulatory threshold is not automatically the reporting cut-off.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official European Commission source.
Prepare
What to collect before drafting
Tick each field as the evidence lands. Owners are the teams that usually hold the source files.
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Material pollutant
Environment / Sustainability reportingIdentify each material pollutant and the managerial-assessment basis for inclusion.
Evidence Dated source records, governance papers and approval evidence supporting material pollutant.
Watch for The published response for material pollutant is incomplete or does not match the supporting records.
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Receiving medium
Environment / Sustainability reportingIdentify whether the emission is to air, water or soil.
Evidence Dated source records, governance papers and approval evidence supporting receiving medium.
Watch for The published response for receiving medium is incomplete or does not match the supporting records.
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Amount emitted
Environment / Sustainability reportingReport the amount emitted during the reporting period in the relevant mass unit.
Evidence Dated source records, governance papers and approval evidence supporting amount emitted.
Watch for The published response for amount emitted is incomplete or does not match the supporting records.
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Environmental accidents
Environment / Sustainability reportingInclude emissions resulting from environmental accidents where applicable.
Evidence Dated source records, governance papers and approval evidence supporting environmental accidents.
Watch for The published response for environmental accidents is incomplete or does not match the supporting records.
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Primary microplastics manufactured
Environment / Sustainability reportingReport the amount of primary microplastics manufactured.
Evidence Dated source records, governance papers and approval evidence supporting primary microplastics manufactured.
Watch for The published response for primary microplastics manufactured is incomplete or does not match the supporting records.
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Primary microplastics used in products
Environment / Sustainability reportingReport the amount of primary microplastics used in products.
Evidence Dated source records, governance papers and approval evidence supporting primary microplastics used in products.
Watch for The published response for primary microplastics used in products is incomplete or does not match the supporting records.
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Microplastics released
Environment / Sustainability reportingReport the amount of microplastics directly released into the environment.
Evidence Dated source records, governance papers and approval evidence supporting microplastics released.
Watch for The published response for microplastics released is incomplete or does not match the supporting records.
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Metric and unit
Sustainability reportingState the metric and unit of measurement.
Evidence Dated source records, governance papers and approval evidence supporting metric and unit.
Watch for The published response for metric and unit is incomplete or does not match the supporting records.
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Relationship to material matters
Sustainability reportingExplain the metric's relationship to material impacts, risks or opportunities and to policies, actions or targets where relevant.
Evidence Dated source records, governance papers and approval evidence supporting relationship to material matters.
Watch for The published response for relationship to material matters is incomplete or does not match the supporting records.
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Methodology and sources
Sustainability reportingDescribe the measurement or calculation methodology, source data and significant assumptions.
Evidence Dated source records, governance papers and approval evidence supporting methodology and sources.
Watch for The published response for methodology and sources is incomplete or does not match the supporting records.
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Scope and boundary
Sustainability reportingState the reporting boundary, scope limitations and any applicable ESRS 1 relief.
Evidence Dated source records, governance papers and approval evidence supporting scope and boundary.
Watch for The published response for scope and boundary is incomplete or does not match the supporting records.
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Validation
Sustainability reportingState whether and how the metric was validated by an external body other than the assurance provider.
Evidence Dated source records, governance papers and approval evidence supporting validation.
Watch for The published response for validation is incomplete or does not match the supporting records.
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Comparatives and changes
Sustainability reportingProvide required comparative information and explain changes in definitions or methodologies where applicable.
Evidence Dated source records, governance papers and approval evidence supporting comparatives and changes.
Watch for The published response for comparatives and changes is incomplete or does not match the supporting records.
Before you start
- Use own operations and the applicable ESRS reporting boundary; do not substitute a policy or action narrative for emission amounts.
- Entity-specific pollutant context may be added where material, but pollution policies and actions belong to E2-1 and E2-2.
- Have the supporting records and the final response been reconciled?
How to prepare it
Request the data
Request the disclosure evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Provide the pollutant inventory, managerial assessment, measured or calculated emission amounts by medium, accident records, microplastics data and GDR-M methodology evidence.
Use the organisation's own role and document names, but preserve the defined ESRS terms and the scope described above.
Better request
Provide the pollutant inventory, managerial assessment, measured or calculated emission amounts by medium, accident records, microplastics data and GDR-M methodology evidence.
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
Use consistent mass units, document estimation methods and include relevant pollutants even where a regulatory reporting threshold is not exceeded.
Context note
Explain estimation uncertainty, scope limitations and applicable reliefs without converting internal thresholds into ESRS requirements.
Download Centre
Preparation tools & forms
Download preparation tools for E2-4 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
Material pollutant is reported accurately and completely.
Risk The response omits, misclassifies or overstates material pollutant.
Evidence to check Dated source records, governance papers and approval evidence supporting material pollutant.
Receiving medium is reported accurately and completely.
Risk The response omits, misclassifies or overstates receiving medium.
Evidence to check Dated source records, governance papers and approval evidence supporting receiving medium.
Amount emitted is reported accurately and completely.
Risk The response omits, misclassifies or overstates amount emitted.
Evidence to check Dated source records, governance papers and approval evidence supporting amount emitted.
Environmental accidents is reported accurately and completely.
Risk The response omits, misclassifies or overstates environmental accidents.
Evidence to check Dated source records, governance papers and approval evidence supporting environmental accidents.
Primary microplastics manufactured is reported accurately and completely.
Risk The response omits, misclassifies or overstates primary microplastics manufactured.
Evidence to check Dated source records, governance papers and approval evidence supporting primary microplastics manufactured.
Primary microplastics used in products is reported accurately and completely.
Risk The response omits, misclassifies or overstates primary microplastics used in products.
Evidence to check Dated source records, governance papers and approval evidence supporting primary microplastics used in products.
Microplastics released is reported accurately and completely.
Risk The response omits, misclassifies or overstates microplastics released.
Evidence to check Dated source records, governance papers and approval evidence supporting microplastics released.
Metric and unit is reported accurately and completely.
Risk The response omits, misclassifies or overstates metric and unit.
Evidence to check Dated source records, governance papers and approval evidence supporting metric and unit.
Relationship to material matters is reported accurately and completely.
Risk The response omits, misclassifies or overstates relationship to material matters.
Evidence to check Dated source records, governance papers and approval evidence supporting relationship to material matters.
Methodology and sources is reported accurately and completely.
Risk The response omits, misclassifies or overstates methodology and sources.
Evidence to check Dated source records, governance papers and approval evidence supporting methodology and sources.
Scope and boundary is reported accurately and completely.
Risk The response omits, misclassifies or overstates scope and boundary.
Evidence to check Dated source records, governance papers and approval evidence supporting scope and boundary.
Validation is reported accurately and completely.
Risk The response omits, misclassifies or overstates validation.
Evidence to check Dated source records, governance papers and approval evidence supporting validation.
Comparatives and changes is reported accurately and completely.
Risk The response omits, misclassifies or overstates comparatives and changes.
Evidence to check Dated source records, governance papers and approval evidence supporting comparatives and changes.
Evidence pack to prepare
Common reporting gaps
- Using a management narrative instead of amounts.
- Putting microplastics in the official title.
- Treating regulatory thresholds as the reporting rule.
- Separating narrative fields as official datapoints.
- Using unrelated pollution evidence from company reports.
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Check your text
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Peer comparison uses examples on this card, not prevalence in the report corpus.
Advice, not assurance
Framework references
Relevant ESRS requirements and related disclosures
ESRS
E2-4
within ESRS E2: Pollution
Guides that settle this question
Related & explore
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