Questions & Answers

Question-ID: 440

Release Date: Apr 30, 2024


Questions & Answers

The amount of each pollutant to air, water and soil shall be consolidated over the facilities. Does this mean one single/consolidated value for each pollutant into all categories? Or does this mean one value for emissions into air, one value for emissions into water and one for emissions into soil?

Key Terms
  • Pollutant disaggregation

Background

ESRS E2-4 paragraph 28 (a) states: ‘The undertaking shall disclose the amounts of . . . each pollutant listed in Annex II of Regulation (EC) No 166/2006 of the European Parliament and of the Council (European Pollutant Release and Transfer Register “E-PRTR Regulation”) emitted to air, water and soil, with the exception of emissions of GHGs which are disclosed in accordance with ESRS E1 Climate Change’.

ESRS E2-4 paragraph 29 states: ‘The amounts referred in paragraph 28 shall be consolidated amounts including the emissions from those facilities over which the undertaking has financial control and those over which it has operational control. The consolidation shall include only the emissions from facilities for which the applicable threshold value specified in Annex II of Regulation (EC) No 166/2006 is exceeded’.

ESRS E2-4 paragraph AR 22 states: ‘The information required under this Disclosure Requirement shall be provided at the level of the reporting undertaking. However, the undertaking may disclose additional breakdown including information at site level or a breakdown of its emissions by type of source, by sector or by geographical area’.

Regulation (EC) No 166/2006, Article 5 (1)(a) on ‘Reporting by operators’: ‘The operator of each facility that undertakes one or more of the activities specified in Annex I above the applicable capacity thresholds specified therein shall report the amounts annually to its competent authority, along with an indication of whether the information is based on measurement, calculation or estimation, of . . . releases to air, water and land of any pollutant specified in Annex II for which the applicable threshold value specified in Annex II is exceeded’.

Answer

In line with the reporting requirements according to the E-PRTR Regulation, undertakings are to disclose the emissions of each pollutant as separate annual amounts for each environmental medium, i.e. released to air, released to water and released to soil. Consolidation refers to the aggregation of pollutant emissions across the different facilities that the undertaking financially or operationally controls (ESRS E2 paragraph 29). The consolidation shall include only the emissions from facilities for which the applicable threshold value specified in Annex II of Regulation (EC) No 166/2006 is exceeded. The following example illustrates an undertaking that operates two industrial facilities in which the threshold values specified in Annex II of Regulation (EC) No 166/2006 are exceeded:

Pollutant

Releases to air
(kg/a)

Releases to water (kg/a)

Releases to soil/land* (kg/a)

Nitrogen oxides (NOx/NO2)
(threshold value 100.000 kg/a)

xxx

-

-

Chlorides (as total Cl)
(threshold value 2 million kg/a)

-

yyy

zzz

*Please note that ESRS E2 uses the terms “emissions” and “soil” whereas the E-PRTR-Regulation uses the terms “releases” and “land”. The terms can be understood interchangeably as regards the disclosures required by ESRS E2 paragraph 28 (a).

In the example, the nitrogen oxide and chlorides represent the consolidated amount from the two facilities.

An undertaking may also disclose additional breakdowns of its emissions by type of source, by sector or by geographical area (ESRS E2 paragraph AR22 and ESRS 1 chapter 3.7 Level of disaggregation).


Relations

Paragraph
Content
2023 ESRSESRS E2 - POLLUTION...Appendix A - Application RequirementsAR 22.

The information required under this Disclosure Requirement shall be provided at the level of the reporting undertaking. However, the undertaking may disclose additional breakdown including information at site level or a breakdown of its emissions by type of source, by sector or by geographical area.

2023 ESRSESRS E2 - POLLUTION...Metrics and targets28. (a)

each pollutant listed in Annex II of Regulation (EC) No 166/2006 of the European Parliament and of the Council (European Pollutant Release and Transfer Register “E-PRTR Regulation”)emitted to air, water and soil, with the exception of emissions of GHGs which are disclosed in accordance with ESRS E1 Climate Change ;

2023 ESRSESRS E2 - POLLUTION...Disclosure Requirement E2-4 – Pollution of air, water and soil29.

The amounts referred in paragraph 28 shall be consolidated amounts including the emissions from those facilities over which the undertaking has financial control and those over which it has operational control. The consolidation shall include only the emissions from facilities for which the applicable threshold value specified in Annex II of Regulation (EC) No 166/2006 is exceeded.

2023 ESRSESRS E2 - POLLUTION...Appendix A - Application RequirementsAR 22.

The information required under this Disclosure Requirement shall be provided at the level of the reporting undertaking. However, the undertaking may disclose additional breakdown including information at site level or a breakdown of its emissions by type of source, by sector or by geographical area.

2023 ESRSESRS E2 - POLLUTION...Disclosure Requirements29.

The amounts referred in paragraph 28 shall be consolidated amounts including the emissions from those facilities over which the undertaking has financial control and those over which it has operational control. The consolidation shall include only the emissions from facilities for which the applicable threshold value specified in Annex II of Regulation (EC) No 166/2006 is exceeded.

2023 ESRSESRS E2 - POLLUTION...Disclosure Requirement E2-4 – Pollution of air, water and soil28. (a)

each pollutant listed in Annex II of Regulation (EC) No 166/2006 of the European Parliament and of the Council (European Pollutant Release and Transfer Register “E-PRTR Regulation”)emitted to air, water and soil, with the exception of emissions of GHGs which are disclosed in accordance with ESRS E1 Climate Change ;

2023 ESRSESRS E2 - POLLUTIONAppendix A - Application RequirementsAR 22.

The information required under this Disclosure Requirement shall be provided at the level of the reporting undertaking. However, the undertaking may disclose additional breakdown including information at site level or a breakdown of its emissions by type of source, by sector or by geographical area.

2023 ESRSESRS E2 - POLLUTION...Disclosure Requirements28. (a)

each pollutant listed in Annex II of Regulation (EC) No 166/2006 of the European Parliament and of the Council (European Pollutant Release and Transfer Register “E-PRTR Regulation”)emitted to air, water and soil, with the exception of emissions of GHGs which are disclosed in accordance with ESRS E1 Climate Change ;

2023 ESRSESRS E2 - POLLUTION...Disclosure Requirements29.

The amounts referred in paragraph 28 shall be consolidated amounts including the emissions from those facilities over which the undertaking has financial control and those over which it has operational control. The consolidation shall include only the emissions from facilities for which the applicable threshold value specified in Annex II of Regulation (EC) No 166/2006 is exceeded.

2023 ESRSESRS E2 - POLLUTION...Metrics and targetsAR 22.

The information required under this Disclosure Requirement shall be provided at the level of the reporting undertaking. However, the undertaking may disclose additional breakdown including information at site level or a breakdown of its emissions by type of source, by sector or by geographical area.