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

Educational material. It does not replace the applicable delegated act, national law, legal advice or an assurance conclusion.

Pollution information rarely sits in one sustainability database. Stack data may be held by site engineers, wastewater loads by utilities teams, spill records by EHS, chemical classifications by product stewardship, substances in articles by procurement and product-data systems, and fines or provisions by legal and finance. The reporting team can consolidate these records, but it cannot replace the accountable source owners.

Revised E2 combines the topic-specific metrics with the general ESRS 2 architecture. Policies are disclosed through GDR-P, actions and resources through GDR-A, targets through GDR-T, methods through GDR-M and current and anticipated financial effects through SBM-3. A complete article or disclosure therefore should not treat E2-4 and E2-5 as an isolated environmental table.

Source anchor: revised ESRS E2 objective, paragraphs 1-6; E2-1 to E2-5; ESRS 2 GDR-P/A/M/T and SBM-3.

The first implementation task is to build a universe of relevant pollutants and substances. It should combine regulatory lists, permits, monitoring programmes, chemical inventories, safety data sheets, product bills of materials, procurement records, complaints, incidents, site history and sector knowledge. The universe is broader than the final disclosure: it is the controlled population from which material pollutants and substances are selected.

E2-4 requires information on material pollution emitted from the undertaking's own operations. The reporting population should be linked to the approved site and source register. For each material pollutant, the organisation should capture the environmental medium, source, site, mass, unit, measurement route, reporting period, data-quality classification and evidence.

Air-emission data may come from continuous emission monitoring, periodic stack testing, material or fuel balances, equipment run-hours, supplier specifications or engineering estimates. The metric should be a mass for the reporting period. Concentration and permit compliance remain useful context but cannot substitute for the total release where a mass metric is required.

Completeness controls should cover permitted stacks, emergency vents, combustion units, process emissions and material fugitive releases. Where the same pollutant is reported under an industrial permit, an emissions-trading scheme and an E-PRTR/IEPR submission, the undertaking should document differences in facility coverage, thresholds, gases, methods, units and timing.

Water-pollution data should distinguish direct discharge to a receiving water, discharge to sewer or third-party treatment, accidental release and any transfer reported under a regulatory system. A concentration result becomes an annual load only when combined with a defensible flow volume and period. The organisation should retain laboratory methods, detection limits, sample representativeness and treatment assumptions.

Only emissions from own operations enter the E2-4 paragraph 15 metric. Under E2 AR 3, transfers of water pollutants to external treatment plants qualify as pollution in the downstream value chain; where material, they are reported as entity-specific disclosures under ESRS 1 paragraphs 11 and 12 rather than added to the E2-4 total.

Soil pollution is often incident- or site-specific rather than a routine annual flow. The inventory should capture spills, leaks, deposition, contaminated land, remediation and substances remaining in soil. Historical contamination may still create current impacts, liabilities or remediation obligations even when the original release predates the reporting period. The disclosure should distinguish a current-period emission from a legacy condition and explain the related action or provision.

A material accident register should connect the event date, location, pollutant, estimated quantity, affected medium, immediate response, investigation, remediation, regulator notification, complaints, legal status and financial consequences. A low-mass release can be material because it affects a sensitive location, causes serious harm, triggers a prolonged shutdown or creates significant liabilities.

The E-PRTR and the evolving Industrial Emissions Portal provide valuable pollutant lists, facility data and reporting thresholds. Revised E2 recognises those thresholds as information that may support the managerial materiality assessment. It also makes clear that they do not automatically decide whether a pollutant is material under ESRS.

Regulatory and ESRS datasets can differ legitimately. A permit may apply to one installation, while the ESRS statement covers the group. A regulatory threshold may omit a pollutant below the reporting trigger even though the release is material at a sensitive location. A regulatory submission may use a calendar or verification process different from the sustainability close. The answer is not to force the numbers to match; it is to reconcile and explain the differences.

Figure 1. ESRS E2 pollutant data lineage and regulatory reconciliation. Original LRA practitioner visual.

Revised E2 does not itself prescribe a hierarchy of measurement methods. Under ESRS 2 GDR-M paragraph 49(a), the undertaking discloses for each metric the calculation methodology and sources and, where relevant, the estimation methodology, including significant assumptions and limitations. As recommended practice rather than an E2 requirement, a useful hierarchy is direct continuous measurement, then representative periodic measurement, validated mass balance, activity data with a recognised factor and, finally, engineering or proxy estimation. The appropriate method depends on the pollutant, source and decision use.

A defensible estimate identifies the source population, formula, activity driver, factor, period, uncertainty and reason direct measurement was unavailable. It is reviewed by the technical owner and included in an improvement plan. A vague statement that 'some sites were estimated' does not allow a reviewer to understand how much of the metric is affected or whether the estimate is biased.

E2-4 paragraph 16 requires two separate amounts: the primary microplastics manufactured or used in the undertaking's products and, separately, the primary microplastics directly released into the environment. Primary microplastics are those intentionally produced and added to products. The final standard has no separate metric for microplastics placed on the market, and the undertaking should not assume that the waste register captures these flows.

Losses from tyre wear, textile washing, pellet handling or the breakdown of larger plastic items are secondary microplastics and fall outside the paragraph 16 metric. Where they are material, they are assessed in the double materiality assessment and, if needed, reported as entity-specific information.

Identify polymers, particle-size criteria and products or processes within the definition of primary microplastics.

Map quantities manufactured by the undertaking and quantities used in its products.

Identify capture, recycling, treatment, destruction and disposal pathways.

Estimate direct releases using measurements, loss rates, mass balances or engineering assumptions.

Document uncertainty and avoid counting the same mass as both manufactured and used without a clear flow relationship.

For the amount manufactured or used in products, formulation, bill-of-materials and production data are usually more relevant than site monitoring. For direct release, process-loss, wastewater and abatement data become central. The method should explain whether the release figure is measured or estimated and present both amounts in mass units (E2 AR 1).

E2-5 sets requirements by role. Under paragraph 18 and AR 4, undertakings in the chemical sector - manufacturers, formulators and importers of substances, for example in NACE Rev.2.1 C20, C21 where applicable, C20.3 to C20.5 or wholesale G46.85 - disclose the total weight of SoC and, separately, of SVHC that they procured, manufactured, placed on the market and directly released into the environment. Under paragraph 19, other users of substances disclose only the total weight of SVHC used during production and service delivery and the total weight of SVHC directly released. Under paragraph 20, manufacturers, importers and users of articles disclose the names of SVHC present above 0.1% w/w in procured components or articles and in components or articles placed on the market. AR 5 requires SVHC reported under paragraphs 18 or 19 to be grouped by CLP hazard class, avoiding double counting in the totals.

A central chemical master should connect the substance identifier, classification, supplier, site, quantity, reporting role, product or article, reporting period and evidence.

ESRS 1 paragraphs 125 to 127 phase in parts of E2-5. 'Other undertakings' may omit quantitative SoC information for their first three financial years of reporting and SVHC information as users of articles for their first year; 'wave-one' undertakings may omit them for financial years before 2030 and 2028 respectively.

REACH, the Candidate List, CLP classifications, safety data sheets, SCIP information and supplier declarations are important inputs. They may contain different units and thresholds. The reporting team should not simply copy a regulatory database total without checking the ESRS definition, the undertaking's role, the materiality conclusion and double counting across purchase, use, production and sales.

Paragraph 20 is a standalone requirement, not a substitute for a weight disclosure. Manufacturers, importers and users of articles that contain SVHC disclose the names of the SVHC present in a concentration above 0.1% w/w, as per Article 33 of REACH, separately for procured components or articles and for components or articles placed on the market. The evidence should support the threshold test, product population, supplier declarations and SCIP or Article 33 communications.

The E2 metrics should be connected to management response. Policies may address prevention, substitution, safer design, permit compliance, incident response and supplier requirements. Actions may include abatement equipment, process redesign, closed-loop systems, chemical substitution, remediation or supplier engagement. Targets should state the pollutant or substance, boundary, baseline, target year, measurement method and whether the target is absolute or intensity-based.

Current and anticipated financial effects are reported through ESRS 2 SBM-3, with E2 information supporting the analysis. Pollution can affect operating costs, capex, provisions, fines, remediation, insurance, shutdowns, permit availability, product reformulation, revenue and access to markets. Finance should map each material E2 IRO to the relevant financial statement line, management forecast or qualitative effect, and should distinguish recognised amounts from anticipated effects.

Figure 2. ESRS E2 topic-specific data owner map. Original LRA practitioner visual.

Arcwell begins with a pollutant universe from permits, E-PRTR filings, stack tests, wastewater permits, chemical inventories and incidents. The materiality assessment identifies volatile organic compounds, nitrogen oxides, zinc in wastewater, the legacy soil contamination and the polymer additive as material. An E-PRTR threshold is not met for zinc at one site, but the discharge is still material because it enters a sensitive receiving water and is linked to permit-renewal risk.

Air emissions are measured or calculated by source. The company reconciles E-PRTR totals to the ESRS site population and explains that one smaller plant is below the regulatory reporting threshold but remains in the ESRS total. Zinc loads are calculated from laboratory concentration and metered flow. The legacy site is presented as a contamination condition with remediation action and provision, not as a current-year soil-emission mass.

Zinc-bearing effluent sent to a municipal treatment plant is treated as a downstream value-chain transfer and reported as entity-specific information. For microplastics, product stewardship maps the tonnes of the primary microplastic additive used in Arcwell's products and, separately, the estimated tonnes directly released. The release estimate uses a validated mass balance and wastewater-capture efficiency. Arcwell is not in the chemical sector, so its register reports the weight of SVHC used in production and directly released, grouped by CLP hazard class, and names the SVHC above 0.1% w/w in procured components and in products placed on the market. Supplier gaps are disclosed through the methodology and improvement plan.

Illustrative excerpt (hypothetical figures - adapt to facts): “Material emissions from our own operations in 2027 were 412 tonnes of volatile organic compounds and 268 tonnes of nitrogen oxides to air, both calculated from stack measurements and solvent mass balances, and 1.9 tonnes of zinc to water, calculated from laboratory concentrations and metered discharge volumes. These totals include one site below the E-PRTR reporting threshold; a reconciliation to our regulatory filings is provided in the methodology note. Emissions to soil comprised 0.4 tonnes of solvent released in a tank-seal failure in March, which we report as an environmental accident. Zinc-bearing effluent transferred to a municipal treatment plant is reported separately as an entity-specific downstream value-chain disclosure. We used 86 tonnes of primary microplastics (a polymer additive) in our products; separately, an estimated 0.7 tonnes were directly released into the environment through process wastewater, based on a validated mass balance and measured capture efficiency. As a user of substances outside the chemical sector, we used 540 tonnes of SVHC in production and directly released 0.2 tonnes, presented by CLP hazard class in the table below. Supplier declarations were unavailable for 12% of procured mixtures by weight; these were estimated from safety data sheets.”

Why it is stronger: the wording names material pollutants and media, distinguishes measured and calculated data, explains the regulatory reconciliation, separates an accident from routine flows, presents primary microplastics used in products and released separately, and quantifies a supplier-data limitation. A complete report would also provide the detailed E2-5 hazard-class table and any paragraph 20 SVHC names required by the undertaking's facts.