Questions & Answers
Is it necessary to report radioactive waste from analytical devices and tracer applications?
- Waste
- radioactive waste
- datapoint, non-material
Background
The submitter provided the following background: ‘Reporting all radioactive waste according to 2022/70/Euratom would include radioactive tracers and analytical devices and sensors. Reporting of these wastes should be excluded because they are present in very small amounts and already locally reported under applicable legislation. Outside the EU, the definition of radioactive waste may also be different from 2022/70/Euratom.’
ESRS E5 paragraph 39 states: ‘The undertaking shall also disclose the total amount of hazardous waste and radioactive waste generated by the undertaking, where radioactive waste is defined in Article 3(7) of Council Directive 2011/70/Euratom as follows: “radioactive waste” means radioactive material in gaseous, liquid or solid form for which no further use is foreseen or considered by the Member State or by a legal or natural person whose decision is accepted by the Member State, and which is regulated as radioactive waste by a competent regulatory authority under the legislative and regulatory framework of the Member State’.
ESRS 1 paragraph 34 states: ‘When disclosing information on metrics for a material sustainability matter according to the Metrics and Targets section of the relevant topical ESRS, the undertaking:
(a) shall include the information prescribed by a Disclosure Requirement if it assesses such information to be material; and
(a) may omit the information prescribed by a datapoint of a Disclosure Requirement if it assesses such information to be not material and concludes that such information is not needed to meet the objective of the Disclosure Requirement.’
ESRS 2 paragraph 56 states: ‘The undertaking shall also include a table of all the datapoints that derive from other EU legislation as listed in Appendix B of this standard, indicating where they can be found in the sustainability statement and including those that the undertaking has assessed as not material, in which case the undertaking shall indicate “not material” in the table in accordance with ESRS 1 paragraph 35.’
Answer
It depends on materiality whether it is necessary to report radioactive waste.
The Disclosure Requirement of ESRS E5-5 – Resource outflow with the datapoints’ total amount of hazardous waste and radioactive waste (paragraph 39) is – as all the topical Disclosure Requirements – subject to double materiality and to the materiality of information as stipulated in ESRS 1 Chapter 3 – Double materiality as the basis for sustainability disclosures:
(a) Is the ‘waste’ subtopic material? – The undertaking shall only disclose the datapoints of the waste subtopic of ESRS E5 if considered material under double materiality (see ESRS 1 Chapter 3.3 Double materiality); and if so,
(b) does the datapoint provide material information? – The metrics required to be disclosed by ESRS E5-5 Waste, including ‘the total amount of hazardous waste and radioactive waste generated by the undertaking’, shall only be disclosed if such information is assessed to be material and may be omitted if not (ESRS 1 paragraph 34).
Accordingly, it depends on materiality whether radioactive waste from analytical devices and tracer applications shall be reported. See also ESRS 1 paragraphs 36 and 42 on establishing appropriate thresholds when disclosing metrics.
It is noted that the datapoints of ESRS E5 paragraph 39 derive from other EU legislation as listed in Appendix B of ESRS 2 and that ESRS 2 paragraph 56 applies. This means that, if applicable (i.e. the amount of radioactive waste is not material for reporting purposes), the undertaking shall flag that the amount of radioactive waste that is not material in accordance with ESRS 1 paragraph 35.
See also Question ID 952 –Metrics – rounding and decimals; materiality of information.
Relations
Paragraph | Content |
|---|---|
When disclosing information on metrics for a material sustainability matter according to the Metrics and Targets section of the relevant topical ESRS, the undertaking: | |
The undertaking shall include a list of the Disclosure Requirements complied with in preparing the sustainability statement, following the outcome of the materiality assessment (see ESRS 1 chapter 3), including the page numbers and/or paragraphs where the related disclosures are located in the sustainability statement. This may be presented as a content index. The undertaking shall also include a table of all the datapoints that derive from other EU legislation as listed in Appendix B of this standard, indicating where they can be found in the sustainability statement and including those that the undertaking has assessed as not material, in which case the undertaking shall indicate “Not material” in the table in accordance with ESRS 1 paragraph 35. | |
The undertaking shall also disclose the total amount of hazardous waste and radioactive waste generated by the undertaking, where radioactive waste is defined in Article 3(7) of Council Directive 2011/70/Euratom . | |
The undertaking shall also disclose the total amount of hazardous waste and radioactive waste generated by the undertaking, where radioactive waste is defined in Article 3(7) of Council Directive 2011/70/Euratom . | |
When disclosing information on metrics for a material sustainability matter according to the Metrics and Targets section of the relevant topical ESRS, the undertaking: | |
The undertaking shall include a list of the Disclosure Requirements complied with in preparing the sustainability statement, following the outcome of the materiality assessment (see ESRS 1 chapter 3), including the page numbers and/or paragraphs where the related disclosures are located in the sustainability statement. This may be presented as a content index. The undertaking shall also include a table of all the datapoints that derive from other EU legislation as listed in Appendix B of this standard, indicating where they can be found in the sustainability statement and including those that the undertaking has assessed as not material, in which case the undertaking shall indicate “Not material” in the table in accordance with ESRS 1 paragraph 35. | |
The undertaking shall also disclose the total amount of hazardous waste and radioactive waste generated by the undertaking, where radioactive waste is defined in Article 3(7) of Council Directive 2011/70/Euratom . | |
The undertaking shall include a list of the Disclosure Requirements complied with in preparing the sustainability statement, following the outcome of the materiality assessment (see ESRS 1 chapter 3), including the page numbers and/or paragraphs where the related disclosures are located in the sustainability statement. This may be presented as a content index. The undertaking shall also include a table of all the datapoints that derive from other EU legislation as listed in Appendix B of this standard, indicating where they can be found in the sustainability statement and including those that the undertaking has assessed as not material, in which case the undertaking shall indicate “Not material” in the table in accordance with ESRS 1 paragraph 35. | |
When disclosing information on metrics for a material sustainability matter according to the Metrics and Targets section of the relevant topical ESRS, the undertaking: | |
The undertaking shall include a list of the Disclosure Requirements complied with in preparing the sustainability statement, following the outcome of the materiality assessment (see ESRS 1 chapter 3), including the page numbers and/or paragraphs where the related disclosures are located in the sustainability statement. This may be presented as a content index. The undertaking shall also include a table of all the datapoints that derive from other EU legislation as listed in Appendix B of this standard, indicating where they can be found in the sustainability statement and including those that the undertaking has assessed as not material, in which case the undertaking shall indicate “Not material” in the table in accordance with ESRS 1 paragraph 35. |