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GRI 303: Water and Effluents · 2018
Disclosure GRI 303-2

Management of water dischargerelated impacts

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 how it manages the impacts linked to the water it releases back into the environment. In practice, the focus is on the controls, processes and oversight used to reduce harm from discharges, rather than on describing water use in general. The organisation should make clear what it does to identify, prevent, limit and respond to any adverse effects associated with its wastewater or other water releases.

The practical emphasis is on the parts of the business where discharges can create material impacts, and whether management is applied consistently across operations or only at selected sites. A useful explanation would show how the organisation decides which locations, activities or discharge points need attention, and how it monitors performance and follows up where risks are higher.

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
Effluent quality floor State the lowest quality level set for wastewater leaving the site, including the key measures or limits used to define it. Discharge permit conditions, internal environmental standards, treatment plant operating criteria, or water quality target documents. Environment / EHS
How limits were set Explain the method used to decide the discharge quality floor, including the source of the criteria and any review or approval step. Standard-setting memo, engineering basis note, permit application pack, or approval record from environment management. Environment / EHS
No-local-rule sites Describe how discharge standards were chosen for sites where no local wastewater rule applies, including the fallback basis used. Corporate water standard, site compliance procedure, legal register, or location-by-location discharge assessment. Environment / EHS
Company water rules Describe any water quality rules or guidance created by the business itself and used for discharge control. Internal policy, technical standard, environmental manual, or water quality guideline issued by the company. Environment / EHS
Industry standards reviewed Describe any industry or trade standards that were taken into account when setting or checking discharge quality expectations. Sector code of practice, trade association guidance, technical benchmark note, or standards review log. Environment / EHS
Receiving water context Explain whether the condition of the water body receiving the discharge was taken into account when setting the standard. Receiving water assessment, catchment study, hydrology report, or discharge impact assessment. Environment / EHS
+ Show GRI 303-2 sub-elements (LRA working checklist)

How to prepare it

1Start by listing every site or operation that sends treated water out of the business, then decide which of those locations the disclosure will cover. Keep the scope note clear so reviewers can see what is in and what is left out.
2For each covered location, define the quality benchmark you used for the discharge. Record whether it came from a local rule, an internal company rule, a sector benchmark, or another basis, and keep the wording specific to each site where it differs.
3If a site has no local discharge rule, explain the method used to set the benchmark there. Also note any company-made water quality guidance and any industry benchmark you relied on, using enough detail for someone else to follow the logic.
4Check whether the receiving water environment was part of the decision. If it was, capture what aspect of that waterbody profile you looked at and how it influenced the benchmark or the final description.
5Gather the supporting records before drafting the disclosure: policy papers, technical notes, site-level approvals, legal or compliance references, and any assessment papers showing how the benchmark was chosen. Make sure the evidence matches the wording you plan to report.
6Prepare the final text by setting out the benchmark description and the method used to determine it, then add any exclusions, site-specific differences, or changes from prior reporting. Before filing, compare the draft with the official source to confirm you have covered every required point and have not added anything extra.
Request the data

Request the wastewater discharge standards evidence

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

What standards, methods, and site-level considerations are being used to manage wastewater discharge quality at our facilities?

Use your organisation’s own terms first, then map them to the reporting wording. For example, ask for wastewater, trade effluent, process water, or site discharge records if those are the terms used internally. Keep the request in operational language and check the source material before sign-off.

Weak request

Please provide the GRI 303-2 evidence for effluent discharge standards and the methodology for determining standards, including internal guidelines, sector-specific standards, and receiving waterbody considerations.

Why it fails: It uses framework language that many operational teams will not use day to day, so it is harder to action. It also bundles several ideas into a compliance-style ask without telling the owner what records to pull, which sites or systems to check, or what format to return.

Better request

Please send the wastewater or trade effluent discharge standards pack for [period] and [sites]. Include the current limits or site rules, how they were set, what we do at sites with no local discharge limit, any internal water quality guidance, any sector guidance used, and whether the receiving waterbody or outfall was considered. Please add the source file, version, and approver.

Formal email template
Subject: Request for wastewater discharge standards evidence for [reporting period]\n\nHi [name/team],\n\nI’m pulling together the evidence pack for our reporting on how we manage wastewater discharge quality at [sites/business unit in scope]. Could you please share the documents and a short summary covering:\n\n- the discharge quality limits or site rules currently used\n- how those limits or rules were set\n- how we set the approach at sites where there is no local discharge limit\n- any internal water quality guidance or site standards we use\n- any sector guidance or external benchmarks we took into account\n- whether the receiving waterbody or outfall conditions were considered\n\nPlease include the period covered, the sites in scope, the source system or file location, and the person who approved the approach. If you have multiple versions, please send the latest approved version and note any site differences.\n\nA possible LRA training template only — please adapt this to your organisation’s own language and check the source material before sign-off.\n\nThanks,\n[preparer name]
Short Teams / Slack version
Hi [name/team] — could you send the wastewater/trade effluent discharge standards pack for [period] for [sites]? Please include the limits or site rules used, how they were set, any internal guidance, any external/sector benchmarks used, and whether the receiving waterbody/outfall was considered. Also share the source file and approver. Please adapt to your own terms and check the source material before sign-off. Thanks.
Industry examples
Food and beverage manufacturing

Context. Sites discharge process water and cleaning water to sewer under local permits and site operating rules.

Adapted request. Please share the trade effluent and process water discharge pack for [period] across [sites]. Include the current site limits, how they were set, any internal hygiene or water quality rules, any industry guidance used, and whether the sewer or receiving water conditions were considered.

Example response. For Plant A and Plant B, the pack includes the permit extracts, the site discharge procedure, a technical note explaining how limits were set from permit conditions and internal engineering checks, and a memo confirming that sewer capacity and local receiving conditions were reviewed. Plant C has no local discharge limit, so the site used the corporate water quality guide and a benchmark from the sector association.

Mining / extractives

Context. Sites manage mine water and treated discharge to a nearby watercourse, with some remote locations lacking local discharge thresholds.

Adapted request. Please provide the mine water discharge standards pack for [period] for [sites]. Include the discharge limits or site operating rules, how they were determined, the approach used at remote sites with no local limit, any internal water quality guidance, any sector benchmark, and whether the river or catchment conditions were considered.

Example response. The response includes site discharge plans, lab-based limit summaries, a technical memo for remote sites showing how the benchmark was set using internal guidance and regional practice, and a note confirming that river flow and catchment sensitivity were reviewed before finalising the site rules.

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 which discharge-quality benchmarks were used, how each one was chosen, and how you dealt with sites that had no local discharge rules, including any company-made guidance, outside sector benchmarks and any assessment of the receiving water.

Context note

Set out what the figures mean by showing the standards used to manage effluent quality and how they differ by site, so readers can see whether the approach was locally driven or based on broader internal or sector practice.

Fluctuation statement

If the standards changed from one site or period to another, note whether that was because local rules differed, a different benchmark was selected, or the receiving water conditions led to a different approach.

Content index entry
GRI 303-2 Management of water dischargerelated impacts — [location / page] / [notes]
Download Centre

Preparation tools & forms

Professional preparation tools for GRI 303-2 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.

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Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
We set out the minimum water-quality thresholds we used for the discharge figure, and we kept the basis for those thresholds on file.The thresholds may be vague, incomplete, or not actually applied to the reported figure.Internal standard or procedure, approval records, and the working papers showing the thresholds used in preparing the figure.
We can show how those thresholds were chosen, including the reasoning and any approvals behind the decision.The selection process may be undocumented or appear arbitrary.Decision papers, meeting notes, sign-off records, and any supporting analysis used to justify the chosen thresholds.
Where a site had no local discharge rule to follow, we used our own documented approach for that location and kept the rationale.The site-specific approach may not be consistent, or may have been invented after the fact.Site-level methodology notes, internal guidance, location-by-location assessments, and evidence of management approval.
If we used an internal water-quality guide, we can produce the version in force and show how it was applied in the reporting period.The internal guide may be outdated, inconsistently applied, or not linked to the disclosed figure.Controlled copies of the internal guide, version history, implementation records, and samples showing use in the reported data.
Where we referred to industry practice, we kept evidence of which external benchmark we looked at and how it influenced our approach.The external benchmark may be mischaracterised, selectively used, or not relevant to the disclosed figure.Copies or references to the external benchmark, comparison notes, and records showing how it informed the final approach.
We considered the receiving water environment before finalising the figure, and we retained the assessment used in that review.The local water context may have been ignored or only considered informally.Environmental assessment, site discharge review, hydrology or receiving-water notes, and pre-publication review 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
The request goes to the site team or lab when the actual evidence sits with the permit lead, environmental manager, or whoever set the discharge limits.
Framework language only
People ask for answers in disclosure terms instead of the organisation’s own operational labels, so the source team cannot map the data back to their records.
Scope left vague
The team collects a broad water file without first fixing which facilities, outlets, or discharge points are in scope, so the set is incomplete or overbroad.
Wrong time basis
Data are pulled from a different reporting window or a mix of dates, which means the evidence does not line up with the period being reported.
Mixed counting basis
One pack combines site-level, outlet-level, and company-level information without separating them, so the same discharge control can be counted more than once or missed.
Source labels stripped
Original file names, register IDs, permit references, or lab sample tags are removed during consolidation, making it hard to trace each figure or statement back to its source.
Separate groups merged
Facilities with different local rules, internal limits, or no local discharge rules are rolled into one list even though they need to be checked and explained separately.
No evidence trail
The collector saves the final spreadsheet but not the supporting notes, version history, or sign-off record, so no one can show how the data were checked before use.

Where judgement is often needed

When sites join or leave the group mid-year
Set a clear cut-off for newly acquired or sold facilities, explain whether their discharge controls are included from the transaction date or another point, and keep the same approach across the reporting period unless you explain a change.
Where local discharge rules differ from site to site
If country or municipal limits are not comparable, describe the rule used to choose the site-level benchmark and say how you handled places with no local limit at all.
Using company-set water quality limits
If you rely on an internal benchmark rather than an external one, explain who set it, what it is based on, and how it sits alongside any local or sector guidance you also considered.
Bringing in sector guidance without treating it as the only test
State which industry guidance informed the site controls, and make clear whether it was used as a reference point, a gap-filler, or a stricter overlay on local expectations.
Deciding how far to look at the receiving water
Explain whether you assessed the river, lake, estuary, or other water body that takes the discharge, and if you did not use that context, say why it was not part of the site review.
Choosing between measured results and estimates
Where direct test results are missing or partial, disclose which figures are measured and which are estimated, the basis for any estimate, and any material assumptions used to fill gaps.
Handling facilities near the edge of the reporting scope
If a site is partly controlled, shared, or operationally borderline, state the rule used to decide inclusion and note any exclusions so readers can see how the boundary was drawn.
Aggregating sensitive site information
When site-level detail could reveal commercially sensitive or personal information, present the data at a higher level, explain the aggregation method, and keep the narrative consistent with the underlying evidence.
Rounding and presentation of small differences
Say how figures were rounded, keep the method consistent across sites and periods, and note when small changes are due to presentation rather than a real shift in discharge management.
Examples

Illustrative examples

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

Illustrative (synthetic) example — food processing

*Synthetic illustration only.* We set our discharge controls by starting with the legal limits that apply to each site, then tightening them where our own water team judged the local river or estuary to be more sensitive. For sites with no local rulebook, we used the same internal water-quality guide across the group, with extra checks where the receiving water was already under pressure. - Our minimum release conditions covered pH, temperature, suspended solids, nutrients and selected process chemicals; the exact thresholds varied by site and were approved through our environmental management process. - In 6 of 8 sites, the local permit was the main basis for the limit set; in the other 2 sites, we applied our internal guide because no local discharge limit existed. - We also looked at the waterbody taking the effluent: 5 sites discharged to rivers with low seasonal flow, 2 to estuarine waters and 1 to a municipal treatment system, and that profile influenced how strict we made the site controls. - Sector guidance for food and drink manufacturing was reviewed alongside the permit conditions, but we did not adopt any sector benchmark without checking it against site-specific conditions.

This example shows how a reporter can explain the basis for effluent controls, including internal rules, sector guidance and the condition of the receiving water, without using standard language.

Illustrative (synthetic) example — chemicals

*Synthetic illustration only.* Our discharge criteria were built from the permit conditions that apply at each plant, then aligned with a group-wide water standard that we wrote for operations in places without a local discharge framework. Where we had no local limit to follow, we used that internal standard and checked it against the nature of the water receiving the outflow. - The internal standard set minimum values for acidity, oil and grease, metals, and oxygen-demanding substances; it was created by our environmental specialists using past monitoring results, treatment capability and risk review. - We considered chemical-industry guidance on wastewater quality, but only as a reference point; it did not replace site controls or the group standard. - Of our 10 plants, 7 relied mainly on local permit conditions and 3 used the group standard because no local discharge requirement was in place. - The receiving waters were part of the decision: 4 plants discharged to small inland streams, 3 to larger rivers and 3 to a coastal outfall, and we applied tighter internal checks where dilution was lower or ecological sensitivity was higher.

This example shows a different way to describe the same disclosure, with emphasis on how internal criteria were developed and how the receiving water influenced the final limits.

Company reports

How companies report GRI 303-2

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

Yum China Holdings, Inc.
Hotels, Restaurants, Leisure, Tourism Services · China · 2025
Open report →
Yum China Holdings, Inc.’s 2025 Sustainability Report provides a description of emissions targets and the steps taken to achieve them, detailed on pages 45 and 46-51. The report also includes data on water discharge management and water withdrawal, referencing GRI 303 disclosures on page 51 and related information on page 53. However, there is no quotable evidence found for several narrative items (a-i, a-iii, a-iv), and the methodology or narrative for some disclosures remains unclear.
Marfrig Global Foods S.A.
Food Production — Animal Source · Brazil · 2024
Open report →
Marfrig Global Foods S.A.'s Integrated Report 2024 includes a covered datapoint on effluent management, stating that standards are met and that there is an online monitoring system for effluent (p.83). However, other narrative items related to this disclosure are not found or unclear, with no quotable evidence provided elsewhere in the report. This suggests limited detailed information on the broader aspects of the disclosure beyond the effluent monitoring system.
Aguas Andinas S.A.
Water Utilities · Chile · 2025
Open report →
Aguas Andinas S.A.'s 2025 Integrated Report covers several aspects related to service quality and environmental standards, including compliance with the Chilean Standard (NCh) 409 for service quality (p.118) and minimum quality standards for treated effluent discharge (p.284). The report also details relevant characteristics of main properties and concession areas, indicating ownership status (p.275), and references international sustainability reporting standards (p.83). However, there is no evidence found regarding certain narrative items (a-iii) and (a-iv), which remain unaddressed in the report.
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Scenarios to work through

A manufacturing site sends treated wastewater to a river where the local permit only covers a few pollutants. The team has also set extra internal limits for temperature and suspended solids because the river is already under pressure.

QWhat should the preparer decide to include when explaining how the discharge limits were set?
Reveal model answer →

A site in a country with no local wastewater discharge rules uses a group-wide standard that was written by the company’s environmental team. The standard was based on a review of similar operations and a benchmark from the sector.

QHow should the preparer explain the basis for the site’s discharge standard?
Reveal model answer →

A food-processing plant discharges into a small lake used for recreation and wildlife. The environmental team checked the lake’s sensitivity, seasonal flow, and existing nutrient levels before finalising the discharge limits.

QWhat judgement should the preparer make about the receiving waterbody information?
Reveal model answer →

A group has three facilities: one follows a municipal permit, one uses a company-made water quality guideline, and one in a specialist industry also aligns with a sector benchmark. The draft report lists the limits but not where each one came from.

QWhat should the preparer do before sign-off?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

GRI
GRI 303-2
within GRI 303: Water and Effluents
Open official source →
Primary
Related & explore
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