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ESRS E2 Pollution – requirements explained simply

ESRS E2 Pollution explained: pollutants, microplastics and substances of concern.

Last updated: Nov 7, 2026

ESRS E2 at a glance

01 What?: ESRS E2 is the topical standard on pollution. It covers five sub-topics: pollution of air, water and soil, microplastics, and substances of concern, including substances of very high concern. It may be material, among others, for manufacturing companies and the chemical industry, but also for many companies that fall under the Industrial Emissions Directive. Reporting covers the sub-topics that are material in the materiality assessment.
02 Which information is required?: ESRS E2 has 5 disclosure requirements. Besides policies, actions and targets, there are two metrics: first, which pollutants the company emits to air, water and soil and how much primary microplastics it manufactures, uses or releases; second, which substances of concern it procures, manufactures, uses, places on the market or releases.
03 What is not included: Greenhouse gases such as methane (CH4) and nitrous oxide (N2O) are also pollutants, but they are reported under E1. The consequences of pollution, for example for biodiversity or affected communities, belong in the respective topical standards.
04 Who reports which substances?: This depends first on the materiality assessment, then on the company’s role. For a company that manufactures or imports substances in quantities for which REACH requires registration with the European Chemicals Agency (ECHA), the standard is often material. Manufacturers and importers must register, not users.

What you need to know about ESRS E2

What ESRS E2 is about

ESRS E2 is guided by the EU’s zero pollution action plan and chemicals strategy and builds on existing EU law, for example the Industrial Emissions Directive, the E-PRTR pollutant register and REACH. Reporting to the E-PRTR continues for reporting year 2026; from reporting year 2027, reporting goes to the Industrial Emissions Portal, which replaces it. The disclosures should show users of the sustainability statement which pollutants the company releases, how it prevents, controls and reduces these emissions, and which risks arise from substances of concern, including through future restrictions.

The 5 disclosure requirements at a glance

The disclosure requirements show how the company manages pollution (E2-1 to E2-3) and how much it releases or uses (E2-4 and E2-5).

E2-1 Policies: the policies to prevent and reduce pollution, for example on emissions, substances or microplastics
E2-2 Actions and resources: which actions the company takes and plans, and which resources are allocated to them
E2-3 Targets: which targets the company has set to reduce pollution
E2-4 Pollution of air, water and soil: which material pollutants its own operations release and in what amounts, including through environmental accidents, and how much primary microplastics the company manufactures, uses in products or releases directly
E2-5 Substances of concern: amounts of substances of concern and substances of very high concern, and the names of substances of very high concern in articles. What exactly is reported depends on the company’s role

Materiality in a group

Materiality is assessed for the whole group, regardless of its legal structure. If pollution is relevant only for individual subsidiaries, reporting may be limited to them. A typical example is a conglomerate with a single subsidiary in the chemical industry: the disclosures may be limited to that subsidiary’s emissions and substances. The other activities may be excluded from a metric only if they do not significantly drive the impacts, risks or opportunities and the exclusion does not impair faithful representation. If this relief is used, this must be disclosed.

Pollutant emissions in practice

Emissions are reported in mass units, for example in tonnes or kilograms.

Identifying material pollutants: the basis is a managerial assessment by activity and sector. Helpful are the pollutant lists that apply to the company, that is, those of the E-PRTR and of the Industrial Emissions Portal, which replaces it from reporting year 2027, and substances that are measured anyway. The release thresholds of the Industrial Emissions Portal are a guide, not a limit: even small amounts of very hazardous substances can be material and should be recorded
Taking existing measures into account: for potential impacts, implemented policies and actions to prevent and mitigate count if they can reasonably be assumed to effectively reduce severity or likelihood. Planned actions do not count. Actual emissions are assessed as they occurred in the reporting year. Information about impacts and how they are managed can be material regardless of how effectively the topic is managed. The fact that certain emissions are low thanks to effective management can itself be material information

Substances of concern: who reports what?

What is to be reported depends on the company’s role. Substances of concern are substances with a harmonised classification under the CLP Regulation in certain hazard classes, for example carcinogenic or chronically hazardous to the aquatic environment, as well as the substances of very high concern on the REACH Candidate List.

Chemical industry (manufacture, formulation and wholesale of chemicals): the total amounts of substances of concern and, separately, of substances of very high concern that are procured, manufactured, placed on the market or released directly, including through leaks and spills, each reported on its own
Other companies that use substances: only the substances of very high concern that are used in production and services or released directly
Manufacturers, importers and users of articles: the names of substances of very high concern contained above 0.1 % by weight in procured components or articles or in components or articles placed on the market, as under the information duty in REACH

For the amounts, substances of very high concern are grouped by hazard class, without double counting in the totals. Information that is already reported under other legislation, for example under the Industrial Emissions Directive or to the E-PRTR, can be used.

Phase-ins

Unlike E4 or the social standards S2 to S4, E2 cannot be deferred as a whole. The only exception: wave-one undertakings that, at the balance sheet date, do not exceed at least one of the two thresholds (EUR 450 million net turnover or an average of 1,000 employees) may omit all topical standards for 2026 if they already apply the new set. They must, however, state whether pollution is material. If it is, they must briefly describe how their business model and strategy take account of the impacts, their targets and progress, policies and actions, and disclose relevant metrics. In addition, there are two phase-ins of its own for E2, both on substances:

Amounts of substances of concern: wave one from financial year 2030, other undertakings after the first 3 reporting years
Substances of very high concern in articles: users of articles in wave one report from 2028, other undertakings after the first reporting year. Manufacturers and importers of articles get no deferral

The general phase-ins, for example for anticipated financial effects, also apply to E2. The periods count from the first mandatory year; earlier voluntary reporting does not count.

Typical data sources inside the company

Much of the data already exists, especially where authorities require reports anyway:

Permits and reports to authorities, for example under the Industrial Emissions Directive or to the E-PRTR (from reporting year 2027 to the Industrial Emissions Portal), provide pollutants, limit values and reported amounts
Environmental management systems such as ISO 14001 or EMAS provide environmental aspects, measurements, environmental accidents, targets and actions
Chemicals management with the hazardous substances register, safety data sheets and registrations under REACH provides substances, classifications and amounts
Purchasing and product development provide supplier declarations on substances of very high concern in articles as well as formulations, including on microplastics

How it relates to the VS standard

In its Basic module, the VS standard asks only for the pollutant emissions to air, water and soil that are already reported to authorities or recorded in the environmental management system. If they are already published, a reference is enough. It contains no metrics of its own on substances of concern and microplastics.

Typical mistakes

These points often come up in practice:

Basing materiality only on thresholds and overlooking small amounts of very hazardous substances
Overlooking substances of very high concern in procured articles. The disclosure also applies to companies that only use articles
Double counting substances. A substance can belong to several hazard classes. In the breakdown of substances of very high concern by hazard class it appears in each of them, but in the totals it counts only once

Frequently asked questions about ESRS E2

Are all greenhouse gases excluded from E2?

The seven greenhouse gases (CO2, CH4, N2O, HFCs, PFCs, SF6 and NF3) are reported under E1, not under E2. Other air pollutants connected to climate change, by contrast, belong to E2, for example ozone-depleting substances, nitrogen oxides (NOx) and sulphur oxides (SOx).

Which microplastics do you have to report?

The metric covers only primary microplastics, that is, particles that are intentionally produced and added to products, for example microbeads or glitter in cosmetics. You report how much of them you manufacture or use in products and, separately, how much is released directly into the environment. Secondary microplastics form when larger plastic items break down, for example from packaging. They are not part of the metric. If their impacts are material, you disclose policies, actions and targets on them and, where the standard is not sufficient, entity-specific disclosures, including metrics.

Can E2 be material if we hardly release any pollutants ourselves?

Yes. The materiality assessment also covers the upstream and downstream value chain, for example pollutants at suppliers or during the use of your own products. The pollutant emissions metric, however, refers only to your own operations. For the value chain, the focus is on policies, actions and targets. If transfers of pollutants in wastewater to external treatment plants are material, an entity-specific disclosure on them is expected.

How to put this into practice with NetCero

Further resources

Sources

This page explains the legal position in simplified form and is not legal or tax advice. The linked legal texts, as currently in force, are authoritative.

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