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.

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 permits measured, calculated and estimated data, while prioritising higher-quality methods. The undertaking should disclose the method and important assumptions under GDR-M. A practical hierarchy is direct continuous measurement, representative periodic measurement, validated mass balance, activity data with a recognised factor, and 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.

Microplastics require a separate pathway analysis. The undertaking should determine whether it produces primary microplastics, uses them as an input, directly emits them during operations or places them on the market in products or mixtures. It should not assume that the waste register captures these flows. Wear, loss, washing, handling and wastewater pathways may be relevant even when no microplastic product is sold.

Identify polymers, particle-size criteria and products or processes within the reporting definition.

Map quantities purchased, produced, used, incorporated into products, placed on the market and directly released.

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

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

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

For microplastics placed on the market, product and sales data may be more relevant than site monitoring. For direct release, process-loss, wastewater and abatement data become central. The method should explain whether the metric represents actual release, theoretical content in products or another required role-specific quantity.

E2-5 requires a role-specific view of substances of concern and substances of very high concern. An undertaking may produce, procure, use, distribute or commercialise a substance, mixture or article. Those roles drive the relevant quantities and evidence. A central chemical master should therefore connect the substance identifier, classification, supplier, site, quantity, business role, product or article, reporting period and evidence.

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.

Where a substance is present in an article and a mass total is not meaningful or practicable under the specific E2 requirement, the undertaking may need to identify the substance name and the affected article category instead. The evidence should support the threshold test, product population, supplier declaration and any estimation of the number or mass of affected articles.

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.

For microplastics, product stewardship maps tonnes produced, tonnes placed on the market and estimated direct process loss. The loss estimate uses a validated mass balance and wastewater-capture efficiency. The SoC/SVHC register combines purchase and production quantities by role and maps substances to the applicable hazard classes. Supplier gaps are disclosed through the methodology and improvement plan.

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 microplastic production and release separately, and quantifies a supplier-data limitation. A complete report would also provide the detailed E2-5 role and hazard-class information required by the undertaking's facts.