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GRI 305: Emissions · 2016
Disclosure GRI 305-7

Nitrogen oxides (NOx), sulfur oxides (SOx), and other significant air emissions

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official GRI source.

Dr Ross Kurinko, GRI Certified Trainer
Reviewed by Dr Ross Kurinko · GRI Certified Trainer LRA educational guidance · Not issued or endorsed by GRI
To prepare this disclosure
Disclosure focus

This disclosure asks an organisation to explain the significant air emissions it releases from its activities, beyond greenhouse gases. In practice, that means identifying the main pollutants that matter for the business, such as nitrogen oxides, sulfur oxides and any other material air emissions, and reporting them in a way that is clear and comparable. The focus is on what is actually emitted, not on general air-quality ambitions or controls alone.

The practical question is how complete the reporting is across the organisation. A robust response should cover the relevant parts of the business where these emissions occur, rather than only selected flagship sites, unless the organisation can clearly explain any limits in coverage. The emphasis is on material sources, consistent measurement or estimation, and a transparent picture of where the emissions come from and how significant they are.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner
Estimation basis Record why an estimate was needed and the method used to derive the figure when no default figure was available. Working papers showing the estimate method, inputs used, and the reason a default figure could not be applied. Reporting / data owner
Emission categories List the types of air emissions that are treated as significant for the reporting period. Emissions inventory, environmental register, or permit records showing which emission types were flagged as significant. Environment / EHS
Significant emissions Capture the actual significant air emission figures for the period, by the relevant emission type. Monitoring results, calculation sheets, or site reports that reconcile to the reported emission totals. Environment / EHS
Emission factor source State where the emission factors came from, including the source document or database used. Reference list, calculation workbook, or methodology note naming the factor source used in the calculations. Environment / EHS / Sustainability reporting
Calculation method Describe the standards, methods, assumptions, and any tools used to calculate the figures. Method statement, calculation protocol, assumptions log, and tool output or model file used for the calculation. Environment / EHS / Sustainability reporting
+ Show GRI 305-7 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first: confirm which operations, sites, or activities are in scope for the air-emissions disclosure, so the rest of the work is built on the same perimeter.
2Agree the emissions list and the categories you will report, using a clear internal definition of what counts as significant so the team applies the same test throughout.
3Gather the underlying support for each figure, including the source of any emission factors and the records that show where those factors came from.
4Prepare the reported content itself: compile the emissions figures or, where the disclosure is narrative, the written explanation needed for each required item.
5If you had to estimate because no default figure was available, record the method used to build the estimate and note any assumptions, standards, or calculation tools applied.
6Check the draft against the official source before sign-off, and make sure any exclusions, changes in approach, or estimation basis are clearly documented and traceable.
Request the data

Request the air-emissions calculation pack from EHS / Operations

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

What evidence do we have for the main air-emissions categories, how they were calculated, and what factors, methods, and assumptions were used?

Use your organisation’s own labels first (for example, site emissions, stack data, permit pollutants, or air-quality metrics), then map them to the reporting disclosure. Keep the request in the language the operational owner already uses, and only translate into framework terms when you prepare the reporting pack.

Weak request

Please provide the GRI 305-7 evidence for significant air emissions, including categories, emission factors, methodologies, assumptions, and estimation basis.

Why it fails: This uses framework language that many operational owners will not recognise, so it is harder to action and easier to answer incompletely. It also does not tell the owner what internal records, systems, or working papers to pull together.

Better request

Please send the air-emissions pack for [period] for [sites/boundary]: the internal pollutant categories we track, the figures behind them, any estimates and why they were needed, the factor source, and the method, assumptions, and tool used. Please attach the source files or system references so we can trace each number back to the working record.

Formal email template
Subject: Request for air-emissions data and supporting evidence for [reporting period]

Hi [name/team],

Could you please share the data pack for our air-emissions reporting for [reporting period] across [boundary/sites]? I’m looking for the figures, the source records, and the working papers behind them.

Please include:
- the list of emission categories we track internally for this area;
- the reported figures for each category and the source records used;
- the basis used where a direct figure was not available and an estimate was needed;
- the source of any emission factors used;
- the methods, assumptions, and calculation tools applied;
- any notes on exclusions, adjustments, or data quality issues.

If it is easier, you can return this in your own format and I will map it into the reporting pack. Please also include the file links or system references so we can trace each figure back to source.

Thanks,
[preparer name]
Short Teams / Slack version
Hi [name/team] — could you send over the air-emissions data pack for [period] for [sites/boundary]? Please include the figures, source files, any estimates and why they were used, plus the factor source, method, assumptions, and tool used. Your own working format is fine — I’ll map it into the reporting pack. Thanks.
Industry examples
Manufacturing

Context. A plant team tracks boiler stacks, process vents, and backup generators in an environmental log.

Adapted request. Please share the plant air-emissions pack for [period] covering boiler stacks, process vents, and generators. Include the site log extracts, any estimated values and the reason for them, the factor source, and the spreadsheet or system used to calculate the figures.

Example response. The team returns a table by site and source, with measured stack data for two boilers, estimated generator emissions for one outage period, the factor source name and version, the calculation workbook, and notes on operating hours and control settings.

Transport / Logistics

Context. A fleet team monitors exhaust-related pollutants from company vehicles and depot equipment.

Adapted request. Please send the fleet and depot emissions pack for [period]. Include the vehicle and depot categories we use internally, the figures by source, any proxy or estimated values, the factor source, and the method or tool used to build the totals.

Example response. The team provides a fleet summary by vehicle class and depot equipment, flags estimated depot figures where meter data was missing, lists the database used for factors, and attaches the fleet calculator with assumptions on mileage and fuel use.

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

Explain how the emissions figures were built, including any estimates used where a default value was unavailable, the factor source, and the main calculation tools, assumptions, and working methods applied.

Context note

Set out what the reported emissions mean in practice by identifying the significant air pollutants and showing how the total and its main components were derived.

Fluctuation statement

If the figures moved materially, describe whether the change came from different activity levels, a revised estimate, or a change in the factor source, assumptions, or calculation approach.

Content index entry
GRI 305-7 Nitrogen oxides (NOx), sulfur oxides (SOx), and other significant air emissions — [location / page] / [notes]
Download Centre

Preparation tools & forms

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Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
We used estimates only where direct figures were not available, and we documented the basis for each estimate.The assurer may find that estimates were used without a clear rationale, or that the method behind them was not recorded well enough to test.Working papers showing why an estimate was needed, the calculation approach used, input data, assumptions, and any sign-off on the estimate basis.
We grouped the disclosed air releases into the categories we used internally for reporting, and we can show how each source was assigned.The assurer may question whether the grouping is complete, whether sources were placed in the right category, or whether any material source was left out.A category mapping, source inventory, internal reporting taxonomy, and reconciliation between the source list and the published breakdown.
The published emissions total is built from the underlying source data we collected for the period, with no known material gaps left unaddressed.The assurer may probe whether the total is complete, whether any sites or activities were omitted, and whether the underlying data is reliable enough to support the figure.Source registers, site returns, consolidation schedules, completeness checks, exception logs, and evidence of review of missing or unusual items.
We can trace the emission factors we applied back to named references and versioned source material.The assurer may ask whether the factors came from a credible source, whether the right version was used, and whether the factor set matches the activity data period.A factor library or schedule showing source name, publication date or version, the factor values used, and evidence of approval or update control.
We prepared the calculation using documented methods, assumptions, and tools, and we checked the output before publication.The assurer may challenge whether the method was applied consistently, whether assumptions were reasonable, whether the tool was configured correctly, and whether the final numbers were reviewed.Method notes, assumption logs, tool settings or model files, calculation sheets, review notes, and evidence of pre-publication checks and sign-off.

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

No named data owner
The team asks the wrong person for the figures, so no one with the actual emissions records confirms what was collected.
Using framework language instead of site terms
People ask for the data in reporting jargon, and the plant or fleet team cannot map it to the labels they use day to day.
Scope not pinned down
The collection request does not say which sites, assets, or activities are in range, so different teams pull different populations.
Wrong time basis
The data pull uses a different reporting period or cut-off date from the rest of the pack, so the numbers do not line up.
Mixing unlike calculation bases
Actual readings, estimates, and modelled values are merged without separating how each figure was built.
Source labels get stripped out
The original factor names, file titles, or system tags are lost during consolidation, so the team cannot trace where each input came from.
Separate groups are combined
Emissions from different business units or operating contexts are rolled together even though they should be kept apart for collection.
Evidence trail is incomplete
The file set has no clear note of the source, method, assumptions, or tool used, so reviewers cannot follow the calculation path.
No approval record
The final dataset is circulated without a visible check or sign-off trail, so no one can show who reviewed the numbers before use.

Where judgement is often needed

Choosing the reporting cut-off after a buy-in or sale
Set a clear cut-off date for adding or removing sites or activities, then explain whether the figures reflect the period before or after the change and how any partial-year data were handled.
Reconciling different local pollutant labels
Where country-level rules or site permits use different names or groupings, map them to your own internal categories and disclose the mapping so readers can see what was counted together.
Deciding whether a nearby site is in scope
If a facility, contractor operation, or shared asset sits on the edge of your operational control, state the rule used to include or exclude it and apply that rule consistently.
Selecting the measurement basis for each source
If some emissions are directly measured and others are modelled or estimated, explain which sources use which approach and why that mix was necessary.
Using substitute figures when site data are missing
When default values are unavailable and estimates are used instead, describe the basis for those estimates and the assumptions behind them.
Picking the emission-factor source
If more than one factor set could be used, identify the source chosen, note any site- or country-specific differences, and explain why that source was preferred.
Setting the calculation method and tool version
State the standards, assumptions, and calculation tools used, including the version or model set, so another preparer could understand how the numbers were built.
Handling very small amounts and rounding
Agree a rounding rule before finalising the figures, apply it consistently across pollutants and sites, and make sure the rounded totals still reconcile to the underlying data.
Protecting sensitive site-level information
If detailed figures could identify a small site, team, or process, aggregate the data to a level that protects privacy while still showing the relevant emission category and explain the aggregation choice.
Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — manufacturing

*Synthetic example only.* We estimated our annual air releases where site meters did not provide a direct reading, using production volumes, fuel use and lab test data as the starting point. Our significant releases were nitrogen oxides at 42.0 tonnes, sulphur oxides at 6.0 tonnes and particulate matter at 1.8 tonnes; the figures were built from emission factors taken from supplier technical sheets, national inventory guidance and equipment manuals, with activity data checked against maintenance logs and utility invoices. - We used a mass-balance approach for one process line and a factor-based method for the rest, with conversion steps and spreadsheet checks documented in our internal calculation workbook. - The estimates were applied only where no default site figure was available, and each value was rounded to one decimal place after the underlying calculations were completed.

Illustrative only: shows how a reporter can explain which air pollutants were material, how the numbers were derived, what sources supplied the factors, and what methods and assumptions supported any estimates.

Illustrative (synthetic) example — food processing

*Synthetic example only.* For the year, we reported the main air releases from our boilers, ovens and refrigeration systems, using direct measurements where available and estimates where plant data were incomplete. Our significant releases were carbon dioxide at 1,260 tonnes, methane at 18 tonnes and ammonia at 4 tonnes; the emission factors came from government conversion tables, manufacturer data and peer-reviewed technical references, then were applied in our carbon-accounting spreadsheet. - Where a default plant figure was missing, we estimated from fuel purchase records, operating hours and refrigerant top-up logs, with engineering judgement used only to fill gaps that could not be measured directly. - The calculation basis, assumptions, unit conversions and review steps were recorded in our internal methodology note, and the final values were reconciled to utility bills and maintenance records before reporting.

Illustrative only: shows a second plausible reporter using a different mix of air pollutants, with a clear explanation of estimation basis, factor sources, and the calculation approach used to produce the disclosed figures.

Company reports

How companies report GRI 305-7

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

GeelongPort
Water Transportation — Ports and Services · Australia · 2025
Open report →
GeelongPort’s Sustainability Report 2025 provides specific data on emissions, including nitrogen oxides (NOx), sulfur oxides (SOx), and other significant air emissions on page 87, and reports a Scope 2 greenhouse gas emission reduction of 1692.31 tonnes of CO2 due to the BREP implementation on page 75. Additional references to greenhouse gas emissions intensity and Scope 3 emissions data appear on pages 76, 86, and 90, indicating some coverage of emissions metrics and assurance activities. However, the report lacks clear narrative explanations or methodological details for these emissions data, as no quotable evidence was found for narrative or methodology sections.
Globalvia
Ground Transportation — Highways and Railtracks · Spain · 2025
Open report →
Globalvia’s 2025 Sustainability Report provides detailed coverage of its greenhouse gas (GHG) emissions, including Scope 1, 2, and 3 emissions, with specific data presented on pages 48, 50, 99, and 118. The report includes quantitative values for direct (Scope 1) emissions, showing a decrease from 2,551 tCO2eq in 2023 to 1,896 tCO2eq in 2025 (p.50), and references the use of the GHG Protocol for calculating its carbon footprint (p.48). However, the report lacks clear narrative or methodological explanations for these disclosures, as no quotable evidence on methodology or narrative context was found.
ASE Technology Holding Co., Ltd.
Semiconductors · Taiwan · 2024
Open report →
ASE Technology Holding Co., Ltd.'s 2024 CSR Report provides specific data on environmental impacts, including reductions in air pollution, waste, water resource consumption, and water pollution (p.36), as well as detailed greenhouse gas emissions figures covering Scope 2 and indirect emissions totaling 144 tCO2e (p.243). The report also quantifies emissions from purchased goods and services at nearly 15 million tCO2e using the SimaPro tool (p.127). However, the report lacks clear narrative or methodological explanations regarding emissions calculation or reduction strategies, and no information was found on certain narrative items or methodologies (no page).
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Scenarios to work through

A facilities team has measured stack emissions for two boilers and used a published factor set for a third unit because no site-specific default was available. The draft note also lists the pollutants it treats as material for the year.

QHave you explained both how the estimate was built where default figures were missing, and which air pollutants you are treating as material?
Reveal model answer →

An operations manager has given the reporting team a spreadsheet of annual emissions, but the only note on the calculation is “industry database used”. The team also has a separate memo describing the plant, fuel mix, and conversion steps.

QWhat extra detail do you need before you can finalise the disclosure?
Reveal model answer →

A site reports nitrogen oxides and sulfur oxides from combustion equipment, but it also has a small release of another pollutant from a process vent. The team is unsure whether to include that third pollutant because it is not one of the main combustion gases.

QShould the disclosure stay limited to the two combustion-related pollutants, or also cover the other material release?
Reveal model answer →

A preparer has drafted a narrative that says the company used a recognised calculation package and a set of internal assumptions, but it does not say which assumptions were applied to which source. The same draft also omits any explanation of how estimated values were derived for one furnace.

QCan this be signed off as it stands, or does it need more detail?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

GRI
GRI 305-7
within GRI 305: Emissions
Open official source →
Primary
Related & explore
FAQ

Questions this page answers

How do I use the GRI 305-7 page to draft the disclosure from scratch?+
What data do I need to collect for GRI 305-7 before I can write the disclosure?+
How should I decide the scope and methodology for the GRI 305-7 emissions disclosure?+
Who should own the GRI 305-7 data collection and sign-off in practice?+
What should I put in the evidence pack for GRI 305-7 assurance readiness?+
What are the common mistakes to avoid when reporting GRI 305-7 emissions?+
How do I use the Prep & Assurance workbook for GRI 305-7?+
What can I take from the synthetic example disclosure for GRI 305-7?+
How do I turn the GRI 305-7 data into a draft narrative and content-index line?+
Can I reuse my GRI 305-7 emissions data for ESRS E1 (Climate Change)?+
What is the printable Library Card in the GRI 305-7 download centre for?+
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