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London Reporting Academy ESRS E2 · Pollution · Disclosure Requirement E2-5

Applicable from FY2027

This revised ESRS edition applies from reporting year 2027. For reporting years 2024–2026, use the ESRS 2023 edition.

Substances of concern and substances of very high concern

E2-5 · mandatory · narrative disclosure

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.

Start preparing ↓ Official European Commission source ↗

Disclosure focus

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.

Prepare

What to collect before drafting

Tick each field as the evidence lands. Owners are the teams that usually hold the source files.

  • Applicability branch

    Sustainability reporting / Legal

    Document which E2-5 role-based branch applies and why.

    Evidence Dated source records, governance papers and approval evidence supporting applicability branch.

    Watch for The published response for applicability branch is incomplete or does not match the supporting records.

  • SoC weights for applicable chemical-sector undertakings

    Environment / Sustainability reporting

    Report total SoC weights procured, manufactured, placed on the market and directly released, using the categories in paragraph 18.

    Evidence Dated source records, governance papers and approval evidence supporting soc weights for applicable chemical-sector undertakings.

    Watch for The published response for soc weights for applicable chemical-sector undertakings is incomplete or does not match the supporting records.

  • SVHC weights for applicable chemical-sector undertakings

    Environment / Sustainability reporting

    Report total SVHC weights separately for the same paragraph 18 categories.

    Evidence Dated source records, governance papers and approval evidence supporting svhc weights for applicable chemical-sector undertakings.

    Watch for The published response for svhc weights for applicable chemical-sector undertakings is incomplete or does not match the supporting records.

  • SVHC used by other users

    Environment / Sustainability reporting

    For undertakings under paragraph 19, report total SVHC used during production and service delivery.

    Evidence Dated source records, governance papers and approval evidence supporting svhc used by other users.

    Watch for The published response for svhc used by other users is incomplete or does not match the supporting records.

  • SVHC directly released by other users

    Environment / Sustainability reporting

    For undertakings under paragraph 19, report total SVHC directly released into the environment.

    Evidence Dated source records, governance papers and approval evidence supporting svhc directly released by other users.

    Watch for The published response for svhc directly released by other users is incomplete or does not match the supporting records.

  • SVHC in procured articles

    Environment / Sustainability reporting

    For paragraph 20 undertakings, identify SVHC above 0.1% weight by weight in procured components or articles.

    Evidence Dated source records, governance papers and approval evidence supporting svhc in procured articles.

    Watch for The published response for svhc in procured articles is incomplete or does not match the supporting records.

  • SVHC in articles placed on the market

    Environment / Sustainability reporting

    Identify SVHC above 0.1% weight by weight in components or articles placed on the market.

    Evidence Dated source records, governance papers and approval evidence supporting svhc in articles placed on the market.

    Watch for The published response for svhc in articles placed on the market is incomplete or does not match the supporting records.

  • Metric and unit

    Sustainability reporting

    State 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.

  • Relationship to material matters

    Sustainability reporting

    Explain 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.

  • Methodology and sources

    Sustainability reporting

    Describe 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.

  • Scope and boundary

    Sustainability reporting

    State 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.

  • Validation

    Sustainability reporting

    State 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.

  • Comparatives and changes

    Sustainability reporting

    Provide 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

  • Apply only the branch or branches relevant to the undertaking's role and keep substances, mixtures and articles distinct.
  • Do not require all branches from every undertaking; directly released means released into the environment, including leaks and spills.
  • Have the supporting records and the final response been reconciled?
＋ Show E2-5 sub-elements (LRA working checklist)

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

Download preparation tools for E2-5 with free verified email access for 24 hours. Source-report links remain public.

Free · Email access
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 ↧

Check

For each claim, check the evidence

  • Applicability branch is reported accurately and completely.

    Risk The response omits, misclassifies or overstates applicability branch.

    Evidence to check Dated source records, governance papers and approval evidence supporting applicability branch.

  • SoC weights for applicable chemical-sector undertakings is reported accurately and completely.

    Risk The response omits, misclassifies or overstates soc weights for applicable chemical-sector undertakings.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates svhc weights for applicable chemical-sector undertakings.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates svhc used by other users.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates svhc directly released by other users.

    Evidence to check Dated source records, governance papers and approval evidence supporting svhc directly released by other users.

  • SVHC in procured articles is reported accurately and completely.

    Risk The response omits, misclassifies or overstates svhc in procured articles.

    Evidence to check 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.

    Risk The response omits, misclassifies or overstates svhc in articles placed on the market.

    Evidence to check Dated source records, governance papers and approval evidence supporting svhc in articles placed on the market.

  • 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

  • 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

ESRS

E2-5

within ESRS E2: Pollution

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Guides that settle this question

ESRS E2 Pollution: Air, Water, Soil, Microplastics and Substances of Concern →

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