Question-ID: 648

To better address the issue addressed by the submitter, it was agreed to change the question received from ‘If a company sells articles containing substances of concern and substances of very high concern, shall the total amount of the products containing those substances be reported or the total amount of the substances within those products?’ to the question above.

E2-5 paragraph 34 concerns the production and procurement of substances of concern, including when these leave the facilities of the manufacturing undertaking as products as well as ‘… total amounts of substances of concern that are generated or used during the production or that are procured, and the total amounts of substances of concern that leave its facilities as emissions, as products, or as part of products or services split into main hazard classes of substances of concern’.

E2-5 paragraph 32 states: ‘The undertaking shall disclose information on the production, use, distribution, commercialisation and import/export of substances of concern and substances of very high concern, on their own, in mixtures or in articles’.

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’.