Questions & Answers
Shall the amount of microplastic that is generated due to tires wear be reported?
- Microplastics
- tires wear
Background
ESRS 1 paragraph 11 states: ‘In addition to the disclosure requirements laid down in the three categories of ESRS, when an undertaking concludes that an impact, risk or opportunity is not covered or not covered with sufficient granularity by an ESRS but is material due to its specific facts and circumstances, it shall provide additional entity-specific disclosures to enable users to understand the undertaking’s sustainability-related impacts, risks or opportunities. Application requirements AR 1 to AR 5 provide further guidance regarding entity-specific disclosures’.
ESRS 1 paragraph 25 states: ‘Performing a materiality assessment (see sections 3.4 Impact materiality and 3.5 Financial materiality) is necessary for the undertaking to identify the material impacts, risks and opportunities to be reported’.
IG 1 Materiality assessment paragraph 27 states: ‘ESRS 1 sets criteria for the materiality assessment, but not specific thresholds to determine when a matter or information is material or not. Therefore, the assessment requires the exercise of judgement. The undertaking needs to set thresholds based on the ESRS 1 criteria as well as its own specific facts and circumstances …’.
ESRS E2-4 paragraph 28 states: ‘The undertaking shall disclose the amounts of … (b) microplastics generated or used by the undertaking’.
ESRS E2-4 paragraph AR 20 states: ‘The information to be provided on microplastics under paragraph 28(b) shall include microplastics that have been generated or used during production processes or that are procured, and that leave the undertaking’s facilities as emissions, as products, or as part of products or services. Microplastics may be unintentionally produced when larger pieces of plastics like car tires or synthetic textiles wear and tear or may be deliberately manufactured and added to products for specific purposes (e.g. exfoliating beads in facial or body scrubs).’
IG 2 Value Chain paragraph 185 states for ESRS E2-4: ‘AR 20 refers to procurement of microplastics’.
Answer
It depends on the outcome of the undertaking’s materiality assessment, including how it applies appropriate thresholds to determine the information it discloses on metrics (see ESRS 1 paragraph 34).
The materiality assessment of microplastics should cover the whole value chain, including but not limited to own operations (see also ESRS E2 AR 20), and cover both primary microplastics (designed to be used in products or manufacturing) and secondary microplastics (generated from the breakdown of larger plastics, e.g. tires).
If the undertaking identifies microplastics as a material topic in its value chain, e.g. the downstream value chain, it shall provide, if needed (see ESRS 1 paragraphs 11 and AR 1 to 5), additional disclosures on an entity-specific basis to enable users to understand its impacts, risks and opportunities (see also IG 2: Value Chain paragraph 185).
If material, then according to ESRS E2-4 undertakings are to report on the amounts of microplastics that are unintentionally generated when larger pieces of plastics, such as car tires, wear and tear.
Please refer to ID 411 Microplastics for further clarifications on the value chain coverage.
Relations
Paragraph | Content |
|---|---|
The information to be provided on microplastics under paragraph 28(b) shall include microplastics that have been generated or used during production processes or that are procured, and that leave the undertaking’s facilities as emissions, as products, or as part of products or services. Microplastics may be unintentionally produced when larger pieces of plastics like car tires or synthetic textiles wear and tear or may be deliberately manufactured and added to products for specific purposes (e.g., exfoliating beads in facial or body scrubs). | |
microplastics generated or used by the undertaking. | |
The information to be provided on microplastics under paragraph 28(b) shall include microplastics that have been generated or used during production processes or that are procured, and that leave the undertaking’s facilities as emissions, as products, or as part of products or services. Microplastics may be unintentionally produced when larger pieces of plastics like car tires or synthetic textiles wear and tear or may be deliberately manufactured and added to products for specific purposes (e.g., exfoliating beads in facial or body scrubs). | |
microplastics generated or used by the undertaking. | |
microplastics generated or used by the undertaking. | |
The information to be provided on microplastics under paragraph 28(b) shall include microplastics that have been generated or used during production processes or that are procured, and that leave the undertaking’s facilities as emissions, as products, or as part of products or services. Microplastics may be unintentionally produced when larger pieces of plastics like car tires or synthetic textiles wear and tear or may be deliberately manufactured and added to products for specific purposes (e.g., exfoliating beads in facial or body scrubs). | |
microplastics generated or used by the undertaking. |