CSRD Pollution Reporting (ESRS E2)
ESRS E2 covers emissions of pollutants to air, water, and soil — including conventional air pollutants, water effluents, soil contamination, and substances of very high concern under REACH. For industrial companies, the data already exists in regulatory compliance records. The challenge is consolidating it for CSRD disclosure.
ESRS E2 covers emissions of pollutants to air, water, and soil — including conventional air pollutants, water effluents, soil contamination, and substances of very high concern under REACH. E2-1 Policies related to pollution: Description of pollution prevention and control commitments — emission reduction targets for conventional pollutants, zero discharge commitments for specific substances, alignment with EU Industrial Emissions Directive (IED) best available technique (BAT) standards.
What ESRS E2 requires
E2-1 Policies related to pollution: Description of pollution prevention and control commitments — emission reduction targets for conventional pollutants, zero discharge commitments for specific substances, alignment with EU Industrial Emissions Directive (IED) best available technique (BAT) standards.
E2-2 Actions and resources: Specific pollution reduction investments — abatement technology installation, process substitution to eliminate hazardous substances, wastewater treatment upgrades, contaminated land remediation.
E2-3 Targets: Pollutant-specific reduction targets by medium (air, water, soil) and timeline. Targets should reference baseline emission levels and specify the measurement methodology.
E2-4 Pollution of air, water, and soil metrics: Quantitative emissions of significant pollutants — NOx, SOx, particulate matter, VOCs, heavy metals (lead, mercury, cadmium, arsenic), persistent organic pollutants; water effluent quality parameters (nitrogen, phosphorus, BOD, suspended solids); and soil contamination area where applicable.
E2-5 Substances of concern: Total amount of SVHCs (Substances of Very High Concern under REACH) used in operations or incorporated in products; phase-out timelines; substitution progress.
E2-6 Anticipated financial effects: Remediation liabilities for contaminated land; regulatory penalty exposure; capital cost of pollution control upgrades; insurance costs related to pollution risk.
Using E-PRTR data for ESRS E2-4
The European Pollutant Release and Transfer Register (E-PRTR) is the EU-wide register of pollutant emissions from industrial facilities — publicly searchable at prtr.ec.europa.eu. Companies subject to the EU Industrial Emissions Directive (IED) already submit annual E-PRTR returns covering the exact pollutants required by ESRS E2-4.
Pollutants covered by both E-PRTR and ESRS E2-4: NOx, SOx, particulate matter (PM10), carbon monoxide (CO), volatile organic compounds (VOCs), heavy metals (lead, mercury, cadmium, arsenic, chromium, nickel, copper, zinc), persistent organic pollutants (dioxins, PCBs, HCBs), and water pollutants (nitrogen, phosphorus, BOD, heavy metals in effluent).
For ESRS E2-4 data collection: extract your annual E-PRTR submission data and reformat for ESRS disclosure. The E-PRTR reports in tonnes per year — the same unit ESRS E2-4 requires. For facilities below E-PRTR reporting thresholds, use permit compliance monitoring data from your environmental management system.
Multinational companies: E-PRTR covers EU facilities. For non-EU facilities, use national equivalent pollutant registers (US TRI, UK NI Waste Survey, etc.) or facility-level environmental monitoring data. Disclose the data sources and coverage in your E2 methodology note.
Substances of concern — ESRS E2-5 in practice
ESRS E2-5 requires disclosure of substances of concern — primarily SVHCs under REACH but also substances on equivalent international hazard lists (Stockholm Convention POPs, Minamata Convention mercury compounds, Rotterdam Convention chemicals).
SVHC identification: The REACH SVHC candidate list (published at echa.europa.eu) contains 240+ substances as of 2026 — carcinogens, mutagens, reproductive toxins, persistent/bioaccumulative/toxic substances, and endocrine disruptors. Check your chemical inventory against the current candidate list.
For E2-5 disclosure: total amount of SVHCs used in your operations or present in products sold (in tonnes per year); for each significant SVHC, its intended use and the reason it has not yet been substituted; and the timeline for substitution or phase-out.
Substitution plans: ESRS E2-5 is more than a disclosure requirement — it implicitly requires having a plan to phase out SVHCs. Companies with no substitution programme for materials on the SVHC candidate list face increasing regulatory risk (REACH authorisation requirements) and assurer scrutiny.
For companies claiming SVHCs are not material: document the assessment. If your sector uses significant quantities of SVHCs (chemicals manufacturing, semiconductor fabrication, surface treatment, rubber and plastics), a non-materiality conclusion requires careful justification.
Frequently asked questions
Does ESRS E2 cover GHG emissions?
No — GHG emissions are exclusively covered by ESRS E1. ESRS E2 covers conventional pollutants — NOx, SOx, particulate matter, heavy metals, persistent organic pollutants, and substances of concern. The two standards are complementary but separate — do not mix GHG and conventional pollutant disclosures.
We are a service company — do we need to report ESRS E2?
Assess before excluding. Pure service businesses (professional services, financial services, software) typically have minimal pollution materiality. However, data centres (cooling chemicals, electronic waste), laboratories (chemical waste, solvent use), and companies with significant facilities (backup generators, fuel storage) may have material E2 exposure. Document the materiality assessment.
How do we value E2-6 remediation liabilities for contaminated land?
Use your existing financial statement contaminated land provisions where available — these represent the best available estimate of remediation cost and are already audited. For sites where environmental provisions exist in the financial statements, reference and cross-check with the E2-6 disclosure. For unprovisioned but known contamination, disclose the qualitative risk and the status of assessment work.