ESRS E2 Pollution
ESRS E2 is the topical CSRD reporting standard requiring disclosures on the pollution of air, water and soil as well as on substances of concern, substances of very high concern and microplastics.
ESRS E2 Pollution is one of the topical environmental standards within the European Sustainability Reporting Standards (ESRS) that apply under the Corporate Sustainability Reporting Directive (CSRD). The standard requires reporting undertakings to disclose transparently their impacts, risks and opportunities relating to pollution. It covers the pollution of air, water and soil, the handling of substances of concern and substances of very high concern, and microplastics.
Like all topical ESRS, E2 follows the double materiality principle: an undertaking must report under E2 only where its materiality assessment has identified pollution as a material topic. Where this is the case, it must disclose policies, actions and targets (ESRS E2-1 to E2-3) as well as quantitative metrics on emissions to air, water and soil (E2-4), on substances of concern (E2-5) and on the potential financial effects (E2-6). The data points are closely linked to the EU Pollutant Release and Transfer Register (E-PRTR) and to the Zero Pollution Action Plan of the European Green Deal.
ESRS E2 is closely connected to other environmental standards, in particular E3 (water and marine resources), E4 (biodiversity and ecosystems) and E5 (resource use and circular economy), because pollution often affects the same protected assets. At the same time, E2 provides important reference points for the EU Taxonomy, for example for the environmental objective of pollution prevention and control. Undertakings should therefore align their E2 reporting with the rest of their sustainability statement and with existing environmental permits and monitoring obligations.
Legal Basis
ESRS E2 (Delegated Regulation (EU) 2023/2772); CSRD (Directive (EU) 2022/2464); Sections 289b et seq., 315b et seq. HGB
Practical Example
A mid-sized manufacturer of paints and coatings concludes in its double materiality assessment that emissions of volatile organic compounds (VOC) to air and the use of solvents qualifying as substances of concern are material. The sustainability officer then consolidates the emission data from the plant's environmental permits and the E-PRTR filing, complements it with the quantities of substances of concern required under E2-5, and documents the substitution strategy toward water-based systems as an E2-2 action with a measurable reduction target under E2-3 in the sustainability statement.