Key facts: ESRS E2 covers pollution of air, water and soil under CSRD. It is subject to materiality — you disclose ESRS E2 only if pollution is material in your double materiality assessment. For manufacturers with environmental permits (IED/IPPC), chemical producers, and wet processors, E2 will almost always be material. Key datapoints include pollutant emissions to air (NOx, SOx, VOCs, PM), water discharges and soil contamination.
What Is ESRS E2?
ESRS E2 (Pollution) is one of five environmental topic standards under the Corporate Sustainability Reporting Directive (CSRD). It covers pollution of air, water and soil, as well as substances of concern (including substances of very high concern — SVHC) and microplastics. Unlike ESRS E1 (Climate), which applies to virtually every company, E2 is more sector-specific — its materiality varies significantly by industry.
ESRS E2 Materiality: Does It Apply to You?
Under CSRD's double materiality framework, you must report ESRS E2 only if pollution is material from either an impact materiality (your operations impact the environment through pollution) or financial materiality (pollution risks affect your financial position — e.g., regulatory penalties, remediation costs, permit revocations) perspective.
| Sector | E2 Likely Materiality | Primary Pollution Topic |
|---|---|---|
| Chemicals & pharmaceuticals | Almost always material | SVHC, VOC emissions, wastewater |
| Metal production (steel, aluminium) | Almost always material | NOx, SOx, dust, heavy metals |
| Cement & building materials | Almost always material | NOx, SOx, PM10/PM2.5 |
| Textile wet processing | Usually material | Wastewater effluent, chemicals |
| Food & beverage manufacturing | Assess — often material | Wastewater (COD, BOD), odour |
| Retail, financial services | Usually not material | Office-level — likely not material |
ESRS E2 Disclosure Requirements
ESRS E2 is structured around four disclosure requirements (E2-1 to E2-4) plus metrics and targets (E2-5, E2-6). Each has mandatory datapoints and application requirements.
E2-1: Policies Related to Pollution
Describe your policies for managing pollution prevention, reduction and remediation. This should reference applicable legal frameworks (IED permits, national environmental regulations), your management approach, and how you handle substances of concern. Reference to an ISO 14001 EMS strengthens this disclosure.
E2-2: Actions and Resources Related to Pollution
Disclose the actions you have taken or plan to take to prevent, reduce or remediate pollution — including investments in abatement technology, operational improvements, and clean production substitutions. Include financial resources allocated.
E2-3: Targets Related to Pollution
Where pollution is material, you must set and disclose measurable reduction targets for key pollutants. Targets should be time-bound, quantitative, and aligned with regulatory limits (IED Best Available Techniques — BAT conclusions) and, where relevant, nature-positive commitments.
E2-4: Pollution of Air, Water and Soil
The quantitative core of ESRS E2. Required pollutant emission disclosures for air:
- NOx (nitrogen oxides) — tonnes/year
- SOx (sulphur oxides) — tonnes/year
- Non-methane volatile organic compounds (NMVOCs) — tonnes/year
- Particulate matter (PM10 and/or PM2.5) — tonnes/year
- Carbon monoxide (CO) — tonnes/year (where material)
- Heavy metals: lead (Pb), cadmium (Cd), mercury (Hg) — kg/year
- Persistent organic pollutants (POPs) — g/year (where applicable)
For water: Discharge volumes, concentrations and loads of key parameters as specified in environmental permits — typically COD, BOD, total nitrogen, total phosphorus, suspended solids, and any site-specific parameters.
For soil: Incidents of soil contamination, areas under remediation, and the management approach for contaminated land.
E2-5: Substances of Concern and SVHC
Disclose substances of concern used or released, and specifically substances of very high concern (SVHC) as listed on the REACH Candidate List. This datapoint will be significant for chemical manufacturers, electronics producers, and any facility using SVHC in operational processes.
ESRS E2 and ESRS E1: What's the Difference?
📊 E1 vs E2 at a Glance
| Dimension | ESRS E1 (Climate) | ESRS E2 (Pollution) |
|---|---|---|
| What it covers | GHG emissions (CO₂, CH₄, N₂O, F-gases) | NOx, SOx, VOCs, PM, heavy metals, SVHC, wastewater |
| Unit | tCO₂e | Tonnes, kg, g per substance per year |
| Regulatory framework | EU ETS, GHG Protocol, SBTi | IED, IPPC, REACH, national permits |
| Typical applicability | Nearly all sectors | Manufacturing, chemicals, construction |
Preparing for ESRS E2: Practical Steps
- Complete your double materiality assessment (DMA): Determine whether pollution is material from impact or financial perspective. Document the assessment clearly — auditors will review it.
- Compile your environmental permit data: IED/IPPC permit conditions, monitoring reports, stack emission test results, wastewater discharge records — these are your primary data sources for E2-4 quantitative datapoints.
- Map substances of concern: Conduct a REACH SVHC screening for your operations and supply chain — identify which SVHCs are present and what quantities are used or released.
- Set pollution reduction targets: Align targets with your permit requirements and BAT conclusions for your sector. Quantify investment in abatement.
- Link to ISO 14001: If you hold ISO 14001 certification, your environmental aspects register, operational controls and monitoring & measurement data are directly relevant to ESRS E2 disclosures.
Frequently Asked Questions
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