Disclosure focus
This disclosure asks an organisation to explain how it identifies and manages substances of concern in its activities, products and services, and what it is doing to reduce related risks and impacts. In practice, the report should make clear which substances are relevant, where they are used or present, and how the organisation tracks them through its own operations and, where relevant, its value chain.
The practical focus is breadth and consistency, not just a few highlighted sites or products. Readers should be able to see whether the organisation’s approach covers the full business, how it decides what is in scope, and whether the information reflects a systematic review rather than isolated examples.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official EFRAG source.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
＋ Show E2-5 sub-elements (LRA working checklist)
Split the figures by each substance involved.
Show how much was made in-house.
Show how much was bought in.
Show how much was let out.
Show how much was sold on.
Show how much was let out.
Show how much was used up.
List the components or products affected.
State any substance present above 0.1%.
Name the substances involved.
Link each item to the right classification.
State the hazard category for each item.
Record the amount in kilograms.
Record the amount in tonnes.
How to prepare it
1Set the reporting boundary first: decide which operations, products and materials are in scope for this disclosure, and keep that scope consistent across all figures and narrative points.
2Define the counting rules before you start collecting data: agree what you will treat as purchased, made, sold, emitted, used, and released, and how you will separate substances, hazard groupings, and the affected items they relate to.
3Gather the source records: pull together the underlying product, procurement, production, sales, emissions, inventory, and classification evidence needed to support each required data point, including the substance names, concentration information, and any mapping used to classify hazards.
4Build the reported outputs: prepare the quantities for each required category, and compile the related narrative fields so the figures and descriptions line up with the same scope, units, and classification basis.
5Record any exclusions or changes clearly: note where data is missing, where a method or boundary has changed, and how that affects comparability, so the reader can see what is included and what is not.
6Check the draft against the official source before sign-off: verify that every required item is covered, the wording reflects the source requirements without copying them, and the final submission matches the underlying evidence.
Request the data
Request the substances-in-products data from EHS / Product Stewardship
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Which substances of concern are present in our products, parts, materials, or supplied inputs, and what quantities, concentrations, and affected items do we need to evidence for the reporting period?
Use your organisation’s own names for product groups, material families, supplier records, and hazard lists first; then map them to the reporting categories in the pack. This is a training template only, so adapt the wording to how your teams actually track substances, components, and product lines, and check the source material before sign-off.
Weak request
Please provide the ESRS E2:E2-5 data for substances of concern / SVHC, including all required datapoints and any related evidence.
Why it fails: It uses framework language that many operational teams will not recognise, so the owner may not know which system, file, or business process to search. It also does not say whether the request is about purchased inputs, manufactured items, sold products, releases, or the internal naming used by the team, so the response is likely to be incomplete or hard to map.
Better request
Please send the substances-in-products extract for [reporting period] covering [business boundary]. Use your normal product, material, part, and substance names, and add a short mapping to our reporting labels. Include the item ID, substance name, quantity or weight, unit, concentration basis, affected product or component, hazard mapping, and any assumptions, gaps, or exclusions.
Industry examples
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
Start by stating how the figures were compiled, what each quantity covers, the unit basis used, and how substances were grouped, classified and matched to the relevant products or components.
Context note
Explain what the numbers mean in practice by linking the amounts procured, made, sold, used and released to the business activities they reflect, and by noting which substances and hazard groupings are most material.
Fluctuation statement
If any figure moved materially, describe the operational reason for the change, such as shifts in production, sourcing, sales, use patterns or release points, and note whether the change affected the substance mix or hazard profile.
Content index entry
E2-5 Substances of Concern (SoC / SVHC) — [location / page] / [notes]
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Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner, wrong language
The request goes to a team that does not hold the source records, and it is framed in ESRS terms instead of the business names people actually use.
Scope left vague
No one states which sites, product lines, suppliers, or legal entities are in scope, so different teams pull different populations.
Period basis not fixed
The team mixes current-period movements with stock at period end, so the figures do not all refer to the same timing basis.
Counting bases get mixed
Weights from procurement, production, sales, use, and release are combined without keeping each measure on its own basis.
Source labels are stripped out
The original substance names, hazard tags, and classification references are lost when data is copied into a spreadsheet or summary file.
Separate populations are merged
Items that should stay apart, such as procured, made, sold, used, or released quantities, are rolled into one total and cannot be traced back.
Breakdown by substance is missing
The team captures only a total weight and forgets to keep the split by individual substance, so the detail needed for the disclosure is unavailable.
Concentration and affected items not linked
The substance list is collected without tying each one to its concentration level and the components or products it affects.
Evidence trail is incomplete
The file has numbers but no source note, version history, or sign-off record, so nobody can show where the data came from or who checked it.
Where judgement is often needed
Set the reporting perimeter after acquisitions and disposals
Use the same group boundary logic you apply for the rest of the report, then explain whether newly bought or sold operations are included for the full year, part year, or excluded, so the weights for bought-in, made, sold and released substances are read on a like-for-like basis.
Choose one substance list when country rules differ
Where local product or chemical lists do not match, pick a single internal reference set for the period, describe any country-specific overlays, and say how you mapped local names or classifications into that set.
Decide how to treat borderline products and materials
State the rule you used for items just inside or outside the scope of your inventory, such as spare parts, packaging, intermediates, by-products or returned goods, and keep that rule consistent across procurement, production, sales and releases.
Fix the cut-off date and measurement basis
Explain whether the figures come from year-end stock, annual average, shipment dates or another cut-off, and keep the same timing basis across all weight fields so readers can compare the numbers properly.
Separate measured figures from estimates
If some weights come from lab results, supplier declarations or engineering estimates, say which parts are measured and which are modelled, and disclose the main assumptions used where direct measurement was not available.
Handle mixed products and multi-ingredient items consistently
For blends, assemblies and finished goods with several relevant substances, describe whether you report at product level, component level or substance level, and explain how you avoided double counting across the different weight fields.
Set a practical rounding rule
Choose a rounding approach that does not distort the totals, apply it consistently to all substance weights and percentages, and note any small differences between subtotals and totals caused by rounding.
Protect sensitive supplier or product detail through aggregation
If naming a substance, product line or supplier would expose confidential information, aggregate the data to the highest level that still shows the substance type, concentration and affected items, and say what has been grouped together.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Specialty chemicals
: we report the main substances we handle, how much passes through our operations, and where any releases occur, with the figures split by substance where relevant. We also show the substances of concern, their concentration above the stated cut-off, and the product or component areas they affect.
Illustrative only; figures are synthetic and internally consistent. This example shows how a chemicals reporter could present the requested substance-flow and hazard information in a compact quantitative format.
Illustrative (synthetic) example — Consumer electronics assembly
: we summarise the substances we bring in, make into products, sell, use in our own processes, and release, with a separate split for the named substances of concern. We also show the hazard groupings and the mass reported in tonnes and kilograms, using internally consistent figures.
Illustrative only; figures are synthetic and internally consistent. This example shows how an electronics assembler could present the requested substance-flow, concentration, and hazard-class information in a compact quantitative format.
How companies report E2-5 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Fluidra, S.A.
Electrical Equipment and Machinery · Spain · 2025
Fluidra, S.A.'s 2025 Integrated Annual Report provides specific quantitative data on Substances of Very High Concern (SVHC), including values for glutaraldehyde and melamine on page 130, with reported amounts such as "SVHC 11,500 15,300" and zero values for glutaraldehyde (p.130). The report also partially addresses recycled or reused material weights but does not provide headline values for these metrics (p.145). However, several expected narrative disclosures are missing or unclear, including detailed context on revenue percentages related to specific substances and comprehensive sustainability headline figures, limiting the clarity of the overall disclosure.
Endesa, S.A.
Electric Utilities / IPP / Energy Traders · Spain · 2025
Endesa, S.A.’s 2025 Consolidated Annual Report provides limited direct evidence related to the disclosure, with no quotable narrative items found throughout the report. The report includes references to sustainability and non-financial information statements (p.5), and mentions impacts, risks, and opportunities concerning biodiversity and ecosystems (p.181), but these are not elaborated with specific data or detailed disclosures. Overall, the report lacks clear, substantive coverage of the disclosure topic, with no concrete findings or metrics presented.
LANXESS Aktiengesellschaft
Chemicals · Germany · 2025
LANXESS Aktiengesellschaft's Corporate Sustainability Report 2025 includes some references to environmental data such as pollution of air, water, and soil with specific substances quantified in kilograms (p.52), and mentions a roadmap addressing substances of very high concern (SVHC) content exceeding 0.1% by 2026 (p.62). The report also lists various ESRS disclosure requirements and stakeholder group assessments, indicating some engagement with sustainability standards (pp.10, 19). However, no direct narrative or detailed quotable evidence specifically addressing the disclosure is found in the report, leaving key information unclear or missing.
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Scenarios to work through
A manufacturer buys 2.4 tonnes of a cleaning additive that is flagged internally as a substance of concern. In the same year, it uses 1.8 tonnes in production and 0.6 tonnes leaves the site in finished goods and waste streams.
QHow should the preparer decide which quantities to capture for the disclosure, and how should the totals be checked for consistency?
Reveal model answer →Hide answer ↑Record the amounts separately for what was bought, what was used in making products, and what left the site in products or releases, then make sure the figures reconcile to the same reporting period and substance set. If the same material appears in more than one stage, it should be counted in the correct bucket for that stage rather than blended into one total.
Why this matters · Keep procurement, use, and outward movement separate, and reconcile the numbers so the story of the material flow is internally consistent.
A product line contains a component with 0.12% of a listed hazardous ingredient by weight, but the ingredient is only present in one of three sub-assemblies. The team is unsure whether to name the substance and identify the affected parts.
QWhat should the preparer do when a concern substance is present above the threshold in only part of the product range?
Reveal model answer →Hide answer ↑Identify the substance by name, state the concentration level for the affected item, and point to the specific component or product that contains it. The disclosure should not imply that every product in the line is affected if only one part actually contains the material.
Why this matters · When only some items are affected, describe the substance, the level, and the exact product parts that contain it.
A site uses 14 tonnes of a process chemical during the year, but only 0.3 tonnes are emitted to air and water combined. The environmental team has the release data, while procurement holds the purchase records and production holds the batch logs.
QWhat judgement should the preparer make about the data needed for the disclosure, and how should the release figure be treated?
Reveal model answer →Hide answer ↑Bring together the records from the different teams so the report covers both the amount used and the amount released, using the same reporting boundary and period. The release figure should be shown as the quantity that actually left the site, not as the amount purchased or consumed in production.
Why this matters · Use cross-functional records to report both use and release, and keep the release figure tied to what actually entered the environment.
A company has three concern substances in its portfolio. One is bought in 5 tonnes, another is made on site in 800 kilograms, and a third is sold in finished goods but never handled as a raw input; the reporting team is unsure whether to present all of them in one line or split them by substance.
QHow should the preparer decide the level of breakdown for the disclosure?
Reveal model answer →Hide answer ↑Split the information by substance so each material can be traced through the relevant activity, rather than combining unlike substances into one undifferentiated figure. Where the same substance appears in more than one activity, show each activity separately and keep the units consistent with the underlying records.
Why this matters · Break the data down by substance and by activity so readers can see which material is involved and where it appears in the value chain.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
What data do I need to collect for E2-5 before I start drafting the disclosure?+−
The page says to prepare a defined set of datapoints, including purchased, made, sold, released, used and emitted weight, plus substance names, concentration, impacted items, hazard categories, a classification crosswalk, and tonnes/kilograms reported. Use that list as your starting checklist before drafting.
How do I use the step-by-step 'how to prepare' section for E2-5?+−
Use it as a practical workflow to move from scoping and data gathering to a draft disclosure. The page is designed to help you prepare the disclosure, not just describe it.
Who should own the E2-5 data collection in practice?+−
The page is aimed at sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can source, validate, and explain the underlying data. The page does not assign roles for you, so you need to map ownership internally.
What should I include in the E2-5 evidence pack for assurance readiness?+−
The page includes an evidence pack with five items to support assurance readiness. Use those items to show how the data was sourced, checked, and turned into the disclosure.
What are the five assurance claims I need to verify for E2-5?+−
The page says there are five assurance claims to verify, each with a claim, risk, and evidence angle. Use them to test whether the disclosure is supported by traceable evidence before sign-off.
What are the common reporting gaps or mistakes for E2-5 that I should avoid?+−
The page lists common reporting gaps and mistakes so you can spot weak points before finalising the disclosure. Use that section as a pre-submission quality check against missing data, inconsistent units, or unclear scope.
How do I turn the E2-5 data into a draft disclosure?+−
The page has a draft-output section with visualisation ideas, narrative starters, and a content-index line. Use those to convert the underlying data into a first-pass narrative and table structure.
Can I use the synthetic illustrative example disclosures to build my own E2-5 table?+−
Yes, the page includes synthetic illustrative examples, including a quantitative data table, to show how the disclosure can look in practice. Treat them as examples only and make sure your own figures stay internally consistent.
What does the classification crosswalk mean in the E2-5 datapoints list?+−
The page tells you to prepare a classification crosswalk as part of the datapoints, but it does not define the mapping for you. In practice, use it to connect your internal categories to the way you will report the data.
How should I handle tonnes reported versus kilograms reported in the E2-5 workbook?+−
The page flags both tonnes reported and kilograms reported as datapoints to prepare, so you need to keep units clear and consistent. Use the workbook to organise the figures and avoid mixing units without explanation.
What can I do with the Prep & Assurance workbook for E2-5?+−
The workbook is there to help you prepare the disclosure and get assurance-ready. Use it to organise the datapoints, track evidence, and work through the preparation steps.
How do I use the printable Library Card PDF for E2-5?+−
The printable Library Card is a companion download for quick reference while you prepare the disclosure. It is useful for checking the key datapoints, assurance points, and draft-output prompts without reopening the full page.
More questions this page can help with
E2-5 disclosure checklist: what should I gather before drafting the pollution data table?E2-5 purchased weight and made weight: how should I collect and separate these datapoints?E2-5 sold weight, released weight, used weight and emitted weight: how do I avoid mixing these measures?E2-5 substance names and substance concentration: what evidence should I keep?E2-5 impacted items and hazard categories: how do I document the source data?E2-5 classification crosswalk: how do I build one for internal reporting?E2-5 tonnes reported vs kilograms reported: how do I present units consistently?E2-5 assurance-ready evidence pack: what files should I include?E2-5 common mistakes in pollution disclosure data: what should I check before sign-off?E2-5 draft narrative starters: how do I turn the data into a short disclosure?E2-5 visualisation ideas: what charts or tables does the page suggest?E2-5 from company reports table: how can I use the linked examples for benchmarking?
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