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Dr Ross KurinkoLinkedIn
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15+ years on FTSE 100 & Fortune Global 500 disclosures
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ESRS E2: Pollution·Disclosure Requirement E2-5
Substances of concern and substances of very high concern
Practical guidance for preparing this disclosure. Use this card to identify the information to prepare, verify claims and organise supporting evidence. For exact requirements, always refer to the official European Commission source.
Published passport
Last reviewed 2026-07-24
Reviewed by
Dr Ross KurinkoLinkedIn
Strategic ESG Advisor · IFRS S1 & S2 / GRI / ESRS expert
GRI Certified Global Trainer · PhD, University of Cambridge · ESG-AI expert
15+ years on FTSE 100 & Fortune Global 500 disclosures
Canary Wharf, London
LRA educational guidance · Not issued or endorsed by European Commission
Standard
ESRS E2: Pollution
Disclosure Requirement E2-5 · 2026-5010-final
Last reviewed
2026-07-24
LRA educational guidance · Not issued or endorsed by European Commission
To prepare this disclosure
Disclosure focus
E2-5 provides role-based information on substances of concern (SoC) and substances of very high concern (SVHC). The applicable branch depends on whether the undertaking manufactures, formulates or imports substances, uses substances outside that branch, or handles articles containing SVHC.
Applicable chemical-sector manufacturers, formulators or importers report total weights of SoC and, separately, SVHC procured, manufactured, placed on the market and directly released into the environment. Other users report SVHC used in production or service delivery and directly released.
Manufacturers, importers or users of articles identify SVHC present above 0.1% weight by weight in procured articles or components and in articles or components placed on the market. Placing on the market is distinct from direct release to air, water or soil.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official European Commission source.
Before you start
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key information to prepare
| Preparation field | What to capture | Evidence hint | Owner |
|---|---|---|---|
| Applicability branch | Document which E2-5 role-based branch applies and why. | Dated source records, governance papers and approval evidence supporting applicability branch. | Sustainability reporting / Legal |
| SoC weights for applicable chemical-sector undertakings | Report total SoC weights procured, manufactured, placed on the market and directly released, using the categories in paragraph 18. | Dated source records, governance papers and approval evidence supporting soc weights for applicable chemical-sector undertakings. | Environment / Sustainability reporting |
| SVHC weights for applicable chemical-sector undertakings | Report total SVHC weights separately for the same paragraph 18 categories. | Dated source records, governance papers and approval evidence supporting svhc weights for applicable chemical-sector undertakings. | Environment / Sustainability reporting |
| SVHC used by other users | For undertakings under paragraph 19, report total SVHC used during production and service delivery. | Dated source records, governance papers and approval evidence supporting svhc used by other users. | Environment / Sustainability reporting |
| SVHC directly released by other users | For undertakings under paragraph 19, report total SVHC directly released into the environment. | Dated source records, governance papers and approval evidence supporting svhc directly released by other users. | Environment / Sustainability reporting |
| SVHC in procured articles | For paragraph 20 undertakings, identify SVHC above 0.1% weight by weight in procured components or articles. | Dated source records, governance papers and approval evidence supporting svhc in procured articles. | Environment / Sustainability reporting |
| SVHC in articles placed on the market | Identify SVHC above 0.1% weight by weight in components or articles placed on the market. | Dated source records, governance papers and approval evidence supporting svhc in articles placed on the market. | Environment / Sustainability reporting |
| Metric and unit | State the metric and unit of measurement. | Dated source records, governance papers and approval evidence supporting metric and unit. | Sustainability reporting |
| Relationship to material matters | Explain the metric's relationship to material impacts, risks or opportunities and to policies, actions or targets where relevant. | Dated source records, governance papers and approval evidence supporting relationship to material matters. | Sustainability reporting |
| Methodology and sources | Describe the measurement or calculation methodology, source data and significant assumptions. | Dated source records, governance papers and approval evidence supporting methodology and sources. | Sustainability reporting |
| Scope and boundary | State the reporting boundary, scope limitations and any applicable ESRS 1 relief. | Dated source records, governance papers and approval evidence supporting scope and boundary. | Sustainability reporting |
| Validation | State whether and how the metric was validated by an external body other than the assurance provider. | Dated source records, governance papers and approval evidence supporting validation. | Sustainability reporting |
| Comparatives and changes | Provide required comparative information and explain changes in definitions or methodologies where applicable. | Dated source records, governance papers and approval evidence supporting comparatives and changes. | Sustainability reporting |
＋ Show E2-5 sub-elements (LRA working checklist)
Document which E2-5 role-based branch applies and why.
Report total SoC weights procured, manufactured, placed on the market and directly released, using the categories in paragraph 18.
Report total SVHC weights separately for the same paragraph 18 categories.
For undertakings under paragraph 19, report total SVHC used during production and service delivery.
For undertakings under paragraph 19, report total SVHC directly released into the environment.
For paragraph 20 undertakings, identify SVHC above 0.1% weight by weight in procured components or articles.
Identify SVHC above 0.1% weight by weight in components or articles placed on the market.
State the metric and unit of measurement.
Explain the metric's relationship to material impacts, risks or opportunities and to policies, actions or targets where relevant.
Describe the measurement or calculation methodology, source data and significant assumptions.
State the reporting boundary, scope limitations and any applicable ESRS 1 relief.
State whether and how the metric was validated by an external body other than the assurance provider.
Provide required comparative information and explain changes in definitions or methodologies where applicable.
How to prepare it
Apply only the branch or branches relevant to the undertaking's role and keep substances, mixtures and articles distinct.
Collect and reconcile the records for: Applicability branch; SoC weights for applicable chemical-sector undertakings; SVHC weights for applicable chemical-sector undertakings; SVHC used by other users; SVHC directly released by other users; SVHC in procured articles; SVHC in articles placed on the market; Metric and unit; Relationship to material matters; Methodology and sources; Scope and boundary; Validation; Comparatives and changes.
Do not require all branches from every undertaking; directly released means released into the environment, including leaks and spills.
Draft the response using the defined terms shown in the disclosure focus; do not substitute broader internal labels.
Review the final wording against every requirement and the supporting governance or data records before sign-off.
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 legal applicability assessment, substance and article inventory, SoC/SVHC classification, procurement, manufacture, market-placement, use and environmental-release records and GDR-M methodology.
Use the organisation's own role and document names, but preserve the defined ESRS terms and the scope described above.
Better request
Provide the legal applicability assessment, substance and article inventory, SoC/SVHC classification, procurement, manufacture, market-placement, use and environmental-release records and GDR-M methodology.
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
Reconcile weights to the correct substance category and role and apply the 0.1% weight-by-weight test to articles where required.
Context note
Explain scope limitations and estimation methods under applicable ESRS provisions; do not use full-business coverage as an unsupported requirement.
Download Centre
Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
| Claim | Risk | Evidence to check |
|---|---|---|
| Applicability branch is reported accurately and completely. | The response omits, misclassifies or overstates applicability branch. | Dated source records, governance papers and approval evidence supporting applicability branch. |
| SoC weights for applicable chemical-sector undertakings is reported accurately and completely. | The response omits, misclassifies or overstates soc weights for applicable chemical-sector undertakings. | Dated source records, governance papers and approval evidence supporting soc weights for applicable chemical-sector undertakings. |
| SVHC weights for applicable chemical-sector undertakings is reported accurately and completely. | The response omits, misclassifies or overstates svhc weights for applicable chemical-sector undertakings. | Dated source records, governance papers and approval evidence supporting svhc weights for applicable chemical-sector undertakings. |
| SVHC used by other users is reported accurately and completely. | The response omits, misclassifies or overstates svhc used by other users. | Dated source records, governance papers and approval evidence supporting svhc used by other users. |
| SVHC directly released by other users is reported accurately and completely. | The response omits, misclassifies or overstates svhc directly released by other users. | Dated source records, governance papers and approval evidence supporting svhc directly released by other users. |
| SVHC in procured articles is reported accurately and completely. | The response omits, misclassifies or overstates svhc in procured articles. | Dated source records, governance papers and approval evidence supporting svhc in procured articles. |
| SVHC in articles placed on the market is reported accurately and completely. | The response omits, misclassifies or overstates svhc in articles placed on the market. | Dated source records, governance papers and approval evidence supporting svhc in articles placed on the market. |
| Metric and unit is reported accurately and completely. | The response omits, misclassifies or overstates metric and unit. | Dated source records, governance papers and approval evidence supporting metric and unit. |
| Relationship to material matters is reported accurately and completely. | The response omits, misclassifies or overstates relationship to material matters. | Dated source records, governance papers and approval evidence supporting relationship to material matters. |
| Methodology and sources is reported accurately and completely. | The response omits, misclassifies or overstates methodology and sources. | Dated source records, governance papers and approval evidence supporting methodology and sources. |
| Scope and boundary is reported accurately and completely. | The response omits, misclassifies or overstates scope and boundary. | Dated source records, governance papers and approval evidence supporting scope and boundary. |
| Validation is reported accurately and completely. | The response omits, misclassifies or overstates validation. | Dated source records, governance papers and approval evidence supporting validation. |
| Comparatives and changes is reported accurately and completely. | The response omits, misclassifies or overstates comparatives and changes. | Dated source records, governance papers and approval evidence supporting comparatives and changes. |
Evidence pack to prepare
Common reporting gaps
Applying all fields to every undertaking.
Reporting product weight instead of SoC or SVHC weight.
Using sold instead of placed on the market.
Combining market placement with environmental release.
Duplicating released and emitted weights.
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Framework references
Relevant ESRS requirements and related disclosures
Available framework references and nearby disclosures relevant to preparing this requirement.
ESRS
E2-5
within ESRS E2: Pollution
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