ESRS E2 — Pollution, and the Substances Question That Narrowed
ESRS E2 is the European Union’s pollution disclosure standard: emissions to air, water and soil, and the substances an undertaking handles. It sits alongside E1 on climate, E4 on biodiversity and E5 on circular economy, gated by the same double materiality test.
The simplification adopted on 3 July 2026 did something to E2 that is more interesting than a datapoint count. It split the substances question by sector. The broad substances-of-concern universe is now scoped primarily to chemical-sector companies; substances of very high concern continue to apply to everyone. For most reporters that is a genuine reduction in scope, and it is the single most useful thing to know about E2 today.
1. The six disclosure requirements
| DR | What it asks for |
|---|---|
| E2‑1 | Policies related to pollution — what the undertaking has in place to manage its pollution impacts, risks and opportunities. |
| E2‑2 | Actions and resources — what is actually being done, and what has been committed to doing it. |
| E2‑3 | Targets — the measurable outcomes being aimed at, and their baselines. |
| E2‑4 | Pollution of air, water and soil — the quantified emissions themselves, including microplastics. |
| E2‑5 | Substances of concern and substances of very high concern — the metric that narrowed. See §3. |
The shape will be familiar from the other environmental standards: policies, actions and targets describe the management response, and the substantive metrics sit in the middle. Under ESRS (2023) a sixth requirement, E2-6, asked for anticipated financial effects; ESRS (2026) removed it from E2 — along with its counterparts in E3, E4 and E5 — and consolidated those disclosures into ESRS 2. Cross-cutting IRO-1 still sits upstream, describing how pollution impacts, risks and opportunities were identified in the first place.
| ESRS 2023 (2023/2772) | Simplified ESRS (2026/1563) |
|---|---|
| E2-1 Policies related to pollution | E2-1 Policies related to pollution |
| E2-2 Actions and resources related to pollution | E2-2 Actions and resources related to pollution |
| E2-3 Targets related to pollution | E2-3 Targets related to pollution |
| E2-4 Pollution of air, water and soil | E2-4 Pollution of air, water and soil |
| E2-5 Substances of concern and substances of very high concern | E2-5 Substances of concern and substances of very high concern |
| E2-6 Anticipated financial effects from pollution-related impacts, risks and opportunities | Removed |
The simplified standards (Delegated Regulation (EU) 2026/1563 (simplified ESRS)) have been in force since 10 November 2026 and apply to financial years starting on or after 1 January 2027; for FY2026 a reporter may use either set (Art 2). Titles as printed in the Official Journal. Read by GreenCalculus from the Official Journal texts (EUR-Lex / Publications Office Cellar) on 27 October 2026.
Provider directory
Need help reporting this to a regulator?
See who does this work. Every listing names the standards it works to, and paid placements are labelled. Including ESG PRO and Verdis Group.
Browse 4 regulatory reporting providers →Do this work? A listing is US$390 a year. Get listed →
2. Which version applies
The same boundary as every ESRS standard, and worth restating because it catches people. ESRS (2026) was adopted on 3 July 2026 and applies to financial years beginning on or after 1 January 2027. ESRS (2023), adopted by Delegated Regulation (EU) 2023/2772, governs everything before that.
FY2026 is not a single default, though. For a financial year beginning in 2026 an undertaking has three options, and it must say which one it took.
- Stay on ESRS (2023), as amended by the Quick Fix Delegated Act. The substances-of-concern metric is unnarrowed and E2-6 still applies.
- Early-adopt ESRS (2026) in full. Everything on this page applies a year ahead of the mandate.
- Stay on ESRS (2023) but take the named reliefs from ESRS (2026). They cover the materiality method, acquisitions and disposals, non-material activities, value-chain scope, joint operations, Taxonomy presentation and an optional executive summary — not the substances narrowing.
Whichever route is taken, the undertaking has to disclose it explicitly. And note what the third option does not include: those reliefs are procedural, so an undertaking on ESRS (2023) plus reliefs still reports the unnarrowed substances-of-concern metric. The narrowing described on this page arrives only with ESRS (2026) itself.
3. The substances split — the change that matters
E2-5 covers two different things that are routinely spoken of as one, and the simplification treated them very differently.
The practical consequence is that the SVHC question is now the one that reaches the widest set of undertakings, and it is a supply-chain question rather than an emissions one: it depends on what is in the articles you place on the market, which is information your suppliers hold.
4. E2-4 — pollution of air, water and soil
E2-4 is the quantitative heart of the standard. It asks for the pollutants an undertaking emits, by medium, where those emissions are material.
5. Microplastics stayed
Amid a simplification that removed a great deal, microplastics disclosure remained — sitting inside E2-4. The standard splits it in two, and the two halves ask for very different things: primary microplastics are reported as amounts, while secondary microplastics may be reported qualitatively.
EFRAG’s guidance points to the REACH restriction on synthetic polymer microparticles as the alignment reference — that is, the definitional boundary already drawn in EU chemicals law rather than a new one invented for reporting. If you have already scoped a product against that restriction, you have most of what E2 wants.
6. What the work actually looks like
Assuming pollution is material, this is the honest sequence. It is closer to a chemicals-compliance exercise than a carbon-accounting one, which is why it often lands on a different team than E1 does.
- Settle materiality first. E2 is gated by the double materiality assessment described under IRO-1. If pollution is not material, E2 does not apply — but the assessment that reached that conclusion is itself disclosable.
- Establish whether you are in scope for the broad SoC metric. Chemical sector or not. This single determination decides how large §3’s workload is for you.
- Run the SVHC question regardless. Above 0.1% by weight in articles. This is a supplier-data exercise and it is the long pole for most non-chemical undertakings.
- Inventory emissions by medium. Air, water and soil separately, and without folding greenhouse gases in. Existing permit and E-PRTR reporting is usually the best starting corpus.
- Answer the microplastics limbs. Intentionally produced first, because it is knowable; released-in-use second, because it is not.
- Write the policies, actions and targets last. E2-1 to E2-3 describe a response. Written before the metrics exist, they describe a response to nothing.
7. Where E2 sits against the rest of EU chemicals and pollution law
E2 does not create pollution obligations. It creates disclosure obligations about a position that other law already defines. That is why the data usually exists somewhere before the reporting project starts.
| Regime | What it does | Relationship to E2 |
|---|---|---|
| REACH | Registration, evaluation, authorisation and restriction of chemicals; defines SVHC and the candidate list. | Supplies E2-5’s substance definitions, and the microplastics restriction EFRAG points to. |
| CLP | Classification, labelling and packaging — hazard classes. | Underpins what counts as a substance of concern in the first place. |
| Industrial Emissions Directive | Permits and best available techniques for large installations. | A primary source of the air, water and soil numbers E2-4 asks for. |
| E-PRTR | The European Pollutant Release and Transfer Register — public facility-level release data. | Often the fastest route to a defensible E2-4 baseline for regulated sites. |
If your sites hold IED permits and report to E-PRTR, the E2-4 inventory is largely an exercise in reconciliation rather than measurement — matching an existing regulatory dataset to the reporting boundary of the undertaking. The gap is usually unpermitted sites and non-EU operations, which no register covers.
8. What E2 does not do
- It does not set limits. E2 is disclosure. Nothing in it makes a permitted emission unlawful, and nothing in it makes an unpermitted one lawful.
- It does not cover greenhouse gases. Those are E1.
- It does not cover water as a resource. Withdrawal, consumption and water stress are E3.
- It does not apply automatically. Double materiality gates it, and a well-documented negative conclusion is a legitimate outcome.
- It does not exempt non-chemical companies from substances disclosure. The SoC narrowing is not an SVHC exemption. See §3.
Frequently asked questions
No. Under ESRS (2026) the broad substances-of-concern metric is scoped primarily to chemical-sector companies, which is a real reduction for everyone else. But substances of very high concern continue to apply to all undertakings for which pollution is material. One metric narrowed by sector; the other did not narrow at all.
ESRS (2026) is mandatory for financial years beginning on or after 1 January 2027, so a calendar-year undertaking first applies it to FY2027, published in 2028. FY2026 is a choice rather than a default: stay on ESRS (2023) as amended by the Quick Fix, early-adopt ESRS (2026) in full, or stay on ESRS (2023) and take the named reliefs. The reliefs are procedural and do not include the substances narrowing, and whichever route is taken must be disclosed.
No. Greenhouse gases are disclosed under ESRS E1. E2-4 covers pollutants that cause local and regional harm — acidifying gases, ozone precursors, particulates, heavy metals and similar. Reporting CO2e under E2-4 duplicates E1 and leaves the actual air-pollutant disclosure empty.
E2 covers what is put into water — discharges and emissions. E3 covers water as a resource — withdrawal, consumption and operations in water-stressed areas. A single site can easily have material disclosures under both, and they draw on different measurements.
Yes, and the simplification did not remove it — it sits inside E2-4. The requirement has two halves that ask for different things. Primary microplastics, those manufactured or used in products, are reported as amounts, with those directly released into the environment shown separately. Secondary microplastics, arising from product breakdown or unintentional release over a product’s life, may be reported qualitatively. REACH’s restriction on synthetic polymer microparticles is the alignment reference for what counts.
0.1% by weight is the concentration threshold that triggers duties for substances of very high concern present in articles under REACH, and it is the reference point E2-5 inherits. Establishing it is a supplier-data exercise, which is why it is the long pole for most non-chemical undertakings.
Yes. E2 is gated by the double materiality assessment, and a negative conclusion is a legitimate outcome. But the assessment itself is disclosable: the reasoning that led to omitting E2 has to be visible, and it is exactly the kind of judgement an assurance provider will test.
For regulated sites, from existing permit reporting under the Industrial Emissions Directive and from the European Pollutant Release and Transfer Register. That makes the first pass a reconciliation exercise rather than a measurement one. The gap is unpermitted sites and non-EU operations, which no European register covers.
Related references
