2026 Revised ESRSESRS E2

Objective

  1. 1.

    The objective of this Standard is to set out Disclosure Requirements (DRs) related to pollution, particularly with respect to the sub-topics specified in paragraph 6 of this Standard. If not all the sub-topics prescribed by this Standard are to be reported following the materiality assessment, paragraph 30 of ESRS 1 General Requirements applies.

  2. 2.

    The sustainability statement shall provide information in relation to ESRS E2 Pollution if this topic relates to material impacts, risks and opportunities. Such information shall cover all the reporting areas listed in paragraph 5 of ESRS 1 General Requirements.

  3. 3.

    The DRs in this Standard complement the provisions in ESRS 2 General Disclosures, which require the undertaking to disclose information about topics related to material impacts, risks and opportunities, in particular:

    1. (a)

      ESRS 2 SBM 3 Interaction of material impacts, risks and opportunities with strategy and business model, and financial effects; and

    2. (b)

      ESRS 2 IRO 2 Material impacts, risks and opportunities and disclosure requirements included in the sustainability statement.

  4. 4.

    In this Standard, each DR is introduced by a disclosure objective except for policies, actions and targets, for which the provisions in ESRS 2 GDR-P, GDR-A and GDR-T provide the necessary framing for the relevant DRs.

  5. 5.

    This Standard takes account of EU regulatory frameworks, including: the EU Action Plan ‘Towards a Zero Pollution for Air, Water and Soil’; the Chemicals Strategy for Sustainability ‘Towards a Toxic-Free Environment’; the Kyiv Protocol on Pollutant Release and Transfer Registers; the E-PRTR (Regulation (EC) No 166/2006 on the European Pollutant Release and Transfer Register) and the IEPR amendments (Regulation (EU) 2024/1244 on the Industrial Emissions Portal); the IED (Directive 2010/75/EU on the Industrial Emissions Directive) and the IED 2.0 amendments (Directive (EU) 2024/1785 on the Industrial and Livestock Rearing Emissions); the REACH (Regulation (EC) No 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals) and REACH-SPM amendments (Commission Regulation (EU) 2023/2055 on Synthetic Polymer Microparticles); and the CLP (Regulation (EC) No 1272/2008 on the Classification, Labelling and Packaging of Substances and Mixtures).

  6. 6.

    This Standard sets out DRs with respect to the following sub-topics: pollution of air, pollution of water and pollution of soil; microplastics; and substances of concern (SoC), including substances of very high concern (SVHC).

  7. 7.

    Pollution of air, pollution of water, and pollution of soil refer to the undertaking’s emissions to air, water and soil, as well as to the prevention, control and reduction of such emissions. Emissions to water include emissions to freshwater and to seawater.

  8. 8.

    DRs on SoC, including SVHC, set disclosure requirements to provide users with an understanding of the related actual impacts or potential impacts, also considering possible restrictions on their production, use, distribution and commercialisation.

  9. 9.

    Context-specific considerations are particularly important in relation to pollution. If material impacts, risks or opportunities are related to specific geographies, it is important to consider appropriate aggregation or disaggregation of the reported information, e.g. by site, area with water stress or other level in accordance with ESRS 1 General Requirements, Chapter 3.3.2 Level of Aggregation, Disaggregation.

Interaction with other ESRS

  1. 10.

    Social and environmental topics interact with each other. The main points of interaction between ESRS E2 Pollution and the other topical standards are the following.

    1. (a)

      ESRS E1 Climate Change addresses emissions to air from the following seven greenhouse gases (GHGs): carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulphur hexafluoride (SF6) and nitrogen trifluoride (NF3). These GHG emissions are not addressed in ESRS E2 Pollution.

    2. (b)

      ESRS E3 Water addresses the use of water resources, including through the volume of water discharge. However, pollutants, including microplastics, emitted to water are addressed in ESRS E2 Pollution.

    3. (c)

      ESRS E4 Biodiversity and Ecosystems addresses pollution as a direct driver of biodiversity and ecosystem change, addressing the impacts of pollution on biodiversity and ecosystems, while emissions of pollutants are addressed in ESRS E2 Pollution.

    4. (d)

      ESRS E5 Resource Use and Circular Economy addresses resource use and the transition to a circular economy but does not address emissions of pollutants generated by waste or by resource extraction, transformation and use, which are covered by ESRS E2 Pollution.

    5. (e)

      ESRS S3 Affected Communities addresses the undertaking’s pollution-related impacts, as they may affect people and communities.

Disclosure Requirements

Impact, risk and opportunity management

Disclosure Requirement E2-1 – Policies related to pollution

  1. 11.

    The undertaking shall disclose its pollution-related policies in accordance with the provisions of ESRS 2 GDR-P.

Disclosure Requirement E2-2 – Actions and resources related to pollution

  1. 12.

    The undertaking shall disclose its key pollution-related actions and resources allocated to the implementation of those actions in accordance with the provisions of ESRS 2 GDR-A.

Metrics and targets

Disclosure Requirement E2-3 – Targets related to pollution

  1. 13.

    The undertaking shall disclose its pollution-related targets in accordance with the provisions of ESRS 2 GDR-T.

Disclosure Requirement E2-4 – Pollution of air, water and soil

  1. 14.

    The objective of this DR is to enable users to understand the undertaking’s emissions of pollutants to air, water and soil, and its manufacturing, use, and release into the environment of microplastics.

  2. 15.

    The undertaking shall disclose the amounts of material emissions of pollutants to air, water and soil from its own operations, including due to environmental accidents, in the reporting period.

  3. 16.

    The undertaking shall disclose the amounts of primary microplastics manufactured or used in its products, and separately, those directly released into the environment.

APPLICATION REQUIREMENTS – ARs

  1. AR 1

    for paras. 15 and 16 (Pollution of air, water and soil)

    The pollutants and primary microplastics shall be presented in relevant mass units, e.g. tonnes or kilogrammes.

  2. AR 2

    for para. 15 (Pollution of air, water and soil)

    Material emissions of pollutants shall be identified through a managerial assessment that considers the undertaking’s activities and sector of operation. The pollutants listed in Annex II of Regulation (EC) No 166/2006 (E-PRTR), Regulation (EU) 2024/1244 (IEPR) and subsequent amendments that apply to the undertaking, together with other pollutants that the undertaking measures or monitors, are a valuable input for this assessment. When determining whether the emission of a specific pollutant is material, the undertaking can consider the thresholds for releases in Annex II of Regulation (EU) 2024/1244.

  3. AR 3

    for para. 15 (Pollution of air, water and soil)

    Transfers of water pollutants to external treatment plants qualify as pollution within the undertaking’s downstream value chain. When they are material, the undertaking is expected to report on transfers as entity-specific disclosures (see ESRS 1 General Requirements, paragraphs 11 and 12).

Disclosure Requirement E2-5 – Substances of concern and substances of very high concern

  1. 17.

    The objective of this DR is to enable users to understand the undertaking’s material impacts, risks and opportunities linked to the manufacturing, trading or use of SoC and SVHC, including risks arising from changes in regulations.

  2. 18.

    Manufacturers of substances, formulators of substances or importers of substances, whether on their own or in mixtures, shall disclose the total weight of SoC, and separately, the total weight of SVHC that they:

    1. (a)

      procured as substances on their own or in mixtures;

    2. (b)

      manufactured as substances on their own or in mixtures;

    3. (c)

      placed on the market as substances on their own or in mixtures; and

    4. (d)

      directly released into the environment (air, water, and soil), including unintentional releases from leaks or spills.

  3. 19.

    Users of substances, whether on their own or in mixtures, shall disclose:

    1. (a)

      the total weight of SVHC that they used during production and during the delivery of services; and

    2. (b)

      the total weight of SVHC that they directly released into the environment.

  4. 20.

    Manufacturers of articles, importers of articles or users of articles that contain SVHC shall disclose the names of the substances that are present in a concentration above 0.1% weight by weight (w/w), as per Article 33 of Regulation (EC) No 1907/2006 (REACH), in:

    1. (a)

      procured components or articles; and

    2. (b)

      components or articles placed on the market.

APPLICATION REQUIREMENTS – ARs

  1. AR 4

    for paras. 18 and 19 (SoC and SVHC)

    The requirements in paragraph 18 apply only to undertakings operating in the chemical sector, namely manufacturing chemical substances (e.g. NACE Rev.2.1 C20 and, if applicable, C21), formulating chemical mixtures (e.g. NACE Rev.2.1 C20.3, C20.4, C20.5) or operating in the wholesale of chemical substances (e.g. NACE Rev.2.1 G46.85). These requirements do not apply to undertakings whose main activity is the manufacture of non-chemical products.

    The requirements in paragraph 19 apply only to undertakings that are outside the scope of paragraph 18.

  2. AR 5

    for paras. 18 and 19 (SoC and SVHC)

    Undertakings reporting under paragraphs 18 or 19 shall present SVHC grouped by hazard class (as per CLP Regulation 1272/2008/EC). This implies that a single substance needs to be counted under all applicable hazard classes. However, in the total amounts of procured, manufactured, sold and released substances, double counting shall be avoided.

  3. AR 6

    for paras. 18 and 19 (SoC and SVHC)

    The substances shall be presented in tonnes or kilogrammes, or other mass unit relevant to the quantity and types of pollutants being released.

  4. AR 7

    for paras. 18, 19 and 20 (SoC and SVHC)

    The information provided under this DR may refer to information the undertaking is already required to report under other legislation (e.g. Directive 2010/75/EU, Regulation (EC) No 166/2006, their subsequent amendments, etc.)

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