Pollution has become an important business issue. Companies are expected to demonstrate how they prevent, control, and reduce their chemical and physical footprint across their value chain.

This article isn’t only for companies in scope of the CSRD. It’s for any organization that wants to report credibly on its environmental impact: EU or non-EU, listed or private, big or small. I use European Sustainability Reporting Standard (ESRS) E2 as a clear and practical blueprint for pollution disclosure. If CSRD doesn’t apply to you (yet), you can still use this guide to structure your reporting and align with international expectations like the Zero Pollution ambition.

ESRS E2 addresses how companies disclose their pollution-related impacts, risks, and opportunities, along with the strategies and metrics used to manage them. It is designed to align business reporting with among others the EU Action Plan ‘Towards a Zero Pollution for Air, Water and Soil’ and the Chemicals Strategy for Sustainability.

In this article, you will learn:

✅ What pollution is
✅ The main objectives of ESRS E2
✅ How ESRS E2 connects with other standards like Climate (E1) and Biodiversity (E4)
✅ The key components of ESRS E2 (E2-1 to E2-5), from policy to microplastics
✅ Acronyms and terms used in ESRS E2

By the end, you’ll gain a clear, structured understanding of reporting about pollution and ESRS E2.

2. Short introduction to pollution

First of all, it is important to know what pollution actually is in a reporting context. In short: Pollution is the direct or indirect introduction of pollutants into the air, water, or soil that can be harmful to human health or the environment.

In today’s world, the scale of pollution is becoming increasingly critical. It is no longer just a local issue but a global systemic threat that degrades ecosystems and reduces biodiversity. According to the 2025 Lancet Countdown on health and climate change, air pollution mortality has reached staggering levels. In 2022, deaths attributable to total ambient PM2.5 air pollution (fine inhalable particles with diameters generally 2.5 micrometers or smaller) increased from 7.5 million deaths in 2010 to 8.5 million globally.

The threat of chemical pollution, often referred to as “novel entities,” has reached a tipping point. Scientists have confirmed that we have crossed the planetary boundary for chemical pollution, meaning the pace at which humanity is producing and releasing new substances into the environment exceeds the Earth’s ability to safely process them. This crisis is exacerbated by the rise of microplastics, which are now found in almost every biological system, contributing to systemic inflammation and cardiovascular risks.

To halt the progression of pollution, the European Union has established the Zero Pollution Action Plan, which aims to reduce pollution to levels that are no longer considered harmful to health or natural ecosystems by 2050.

Because pollution poses such a direct and measurable risk to both global health and business resilience, it is included as the second environmental standard (ESRS E2) in the CSRD.

Here follows a brief timeline of two frameworks by the European Union:

• December 2019: The European Union published the European Green Deal. This massive framework introduced the overarching “Zero Pollution Ambition for a toxic-free environment.”

• October 2020: The EU published the Chemicals Strategy for Sustainability. The European Commission officially designated this strategy as the first step and a core pillar for delivering on the 2019 Green Deal’s zero-pollution commitment. It tackled the “toxic-free” part of the overarching goal first.

• May 2021 (the broader plan): The EU published the Zero Pollution Action Plan. This document formally laid out the targets for the remaining aspects of the 2019 ambition—specifically detailing the operational targets for air, water, and soil pollution.

Read the Zero Pollution Action Plan here:
Zero pollution targets - Environment - European Commission

Read more about the Chemicals Strategy for Sustainability here:
Chemicals Strategy

3. Understanding the objective of ESRS E2

The objective of ESRS E2 is for companies to disclose information on pollution whenever it represents a material impact, risk, or opportunity. This ensures stakeholders understand how a company manages its chemical footprint and its transition toward a toxic-free environment.

The standard defines five key sub-topics:

• Pollution of air: Emissions of pollutants like SOx, NOx, and particulate matter (excluding GHGs). To understand the difference between air pollution and greenhouse gas emissions check out this article:
  

• Pollution of water: Emissions to both freshwater and seawater.
  

• Pollution of soil: Direct emissions to land and groundwater.
  

• Substances of (very high) concern (SoC & SVHC): Including the manufacturing, use, and distribution of hazardous chemicals.
  

• Microplastics: Both primary (manufactured) and secondary (resulting from product wear and tear).
  

To get a better understanding of the interactions between air, water, and soil pollution:

Interaction with other topics (ESRS Standards)

ESRS E2 interacts with several other standards:

• ESRS E1 Climate Change: E1 covers the seven main greenhouse gases (like CO₂ and methane), while E2 covers all other harmful air emissions.

• ESRS E3 Water: E3 focuses on the volume of water used, while E2 focuses on the pollutants contained within that water.

• ESRS E4 Biodiversity: While E4 looks at how pollution drives ecosystem change, E2 focuses on the actual emissions causing that change.

• ESRS E5 Resource Use: E5 looks at circularity and waste, but the pollutants generated during resource extraction or waste transformation are handled by E2.

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4. The different components of ESRS E2

While ESRS E1 is structured around three pillars: Strategy (long-term plans, risk analysis, and resilience), Implementation (policies, actions, and resources), and Targets & Metrics (quantifiable goals, emissions data, and financial implications). ESRS E2 is structured into only two pillars: implementation (how you handle pollution) and targets & metrics (the actual numbers).

Read more below to explore each element in detail. I’ve also linked to my other articles below, where you can dive deeper into each specific topic, from ESRS E2-1 through ESRS E2-5, for a more comprehensive understanding.

E2-1, E1-2: Policies, actions, and resources

E2-1 (Policies): companies must disclose their policies for preventing and reducing pollution. The rules in ESRS 2 GDR-P frame these policies.

Read more about ESRS E2-1 here:

E2-2 (Actions and resources): requires reporting on the key actions taken (such as installing new filtration systems) and the financial resources (CapEx/OpEx) allocated to them.

Read more about ESRS E2-2 here:

E2-3: Targets related to pollution

E2-3 focuses on the disclosure of specific, measurable goals for reducing pollutants.

Read more about ESRS E2-3 here:

E2-4: Pollution of air, water, and soil

E2-4: this is the data-heavy section. Companies must report:

• Material emissions: Amounts of pollutants released into air, water, and soil from own operations.

• Microplastics: Weight of primary microplastics manufactured/used, and qualitative or quantitative info on secondary microplastics (like tire wear).

Read more about ESRS E2-4 here:

E2-5: Substances of concern and SVHC

This requirement is particularly strict for the chemical sector.

• Manufacturers/importers: Must disclose the total weight of SoC and SVHC procured, manufactured, placed on the market, or released.

• Other users: Must disclose the weight of SVHC used in production and released.

• Article manufacturers: Must name specific SVHCs present in products at concentrations above 0.1%.

Read more about ESRS E2-5 here:

Share CSRD Simplified

4. Acronyms and terms

Relevant Sources

November 2025 ESRS E2

The 2025 report of the Lancet Countdown on health and climate change: climate change action offers a lifeline - The Lancet

Planetary boundaries - Stockholm Resilience Centre

Microplastics and Nanoplastics in Atheromas and Cardiovascular Events - PubMed

Zero pollution targets - Environment - European Commission

Zero pollution targets - Environment - European Commission

Chemicals Strategy

We finish the Pollution standard with perhaps the most technical but chemically critical disclosure: Substances of Concern (SoC) and Substances of Very High Concern (SVHC).

While E2-4 focuses on bulk emissions, E2-5 zooms in on the toxicity of the materials you handle. It connects your reporting directly to major EU chemical regulations, such as REACH and CLP.

This disclosure asks a fundamental question: Is your business model dependent on hazardous chemicals?

I will briefly explain the requirements for disclosing information on these dangerous substances.

More elaborate articles are, or will become available, which can be found on: Sustainability Simplified.

2. What are SoCs and SVHCs?

These are not just pollutants in the general sense; they are chemicals flagged for their potential to cause serious harm to health or the environment.

• Substances of Very High Concern (SVHC): A specific legal list under the EU REACH regulation. These are carcinogens, mutagens, reproductive toxins (CMRs), or substances that persist and bioaccumulate in the environment.

• Substances of Concern (SoC): A broader category defined in the ESRS (aligned with the EU Chemicals Strategy). It includes SVHCs but also substances that hamper recycling (circular economy) or cause chronic health effects.

Read more about SVHC here:

The ESRSes define SoC and SVHC as follows:

Substances of Concern (SoC)

“A substance that:

(a) Meets the criteria laid down in Article 57 of Regulation (EC) No 1907/2006 and is identified in accordance with Article 59(1) of that Regulation;

(b) Is classified in Part 3 of Annex VI to Regulation (EC) No 1272/2008 in one of the following hazard classes or hazard categories:

• (i) carcinogenicity categories 1 and 2;

• (ii) germ cell mutagenicity categories 1 and 2;

• (iii) reproductive toxicity categories 1 and 2;

• (iv) endocrine disruption for human health categories 1 and 2;

• (v) endocrine disruption for the environment categories 1 and 2;

• (vi) persistent, mobile and toxic or very persistent, very mobile properties;

• (vii) persistent, bioaccumulative and toxic or very persistent, very bioaccumulative properties;

• (viii) respiratory sensitisation category 1;

• (ix) skin sensitisation category 1;

• (x) hazard to the aquatic environment – categories chronic 1 to 4;

• (xi) hazardous to the ozone layer;

• (xii) specific target organ toxicity – repeated exposure categories 1 and 2;

• (xiii) specific target organ toxicity – single exposure categories 1 and 2.”

Substances of Very High Concern (SVHCs)

“Substances that meet the criteria laid down in Article 57 of Regulation (EC) No 1907/2006 (REACH) and were identified in accordance with Article 59(1) of that Regulation.”

3. ESRS E2-5 at a glance

E2-5 is unique because your disclosure obligations depend entirely on what you do (your role in the value chain).

The standard breaks requirements down into categories:

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4. How E2-5 links to the rest of ESRS E2

E2-5 provides the hazard context to your pollution management:

• E2-1 (Policy): Establishes the governance and strategic commitment to eliminate or minimize the use of hazardous substances.

• E2-2 (Action): Details the concrete steps taken to substitute these substances, such as R&D into safer alternatives or changing procurement standards.

• E2-3 (Target): Sets the specific, measurable goals for reducing the volume of substances of concern in products and operations over time.

• E2-5 (Metric): Quantifies the risk. By reporting the actual weight of SVHCs used or produced, this metric reveals the “toxicity footprint” of your business. A static or increasing number here immediately challenges the credibility of your phase-out targets (E2-3) and the effectiveness of your substitution efforts (E2-2).

5. Bottom line

E2-5 is the bridge between sustainability reporting and chemical compliance.

• Check your REACH data: If you are a European manufacturer, you likely already track SVHCs for legal compliance. E2-5 asks you to aggregate and publish this data.

• Know your role: Determine immediately if you fall under Category A (Chemical Manufacturer) or Category B (User), as the reporting burden for manufacturers (tracking all SoCs) is significantly higher than for users (tracking only SVHCs).

• Transparency is inevitable: The EU’s goal is a “Toxic-Free Environment.” Hiding hazardous chemical use is becoming impossible; the strategy now is to show how you are managing and reducing it.

Relevant Standards

ESRS E2

November 2025 ESRS E2

We have covered the rules (E2-1), the work (E2-2), and the goals (E2-3). Now we arrive at the evidence. ESRS E2-4 asks undertakings to disclose the data on what they are releasing into the environment.

This disclosure is the proof of performance. It provides the numbers that allow stakeholders to assess your environmental footprint and verify if your actions are working.

I will briefly explain the requirements for disclosing metrics on pollution of air, water, and soil.

More elaborate articles are, or will become available, which can be found on: Sustainability Simplified.

2. What are pollution metrics?

Pollution metrics are quantitative measurements of the specific pollutants your company releases into the environment.

The scope covers three main areas:

1. Air emissions: Pollutants released into the atmosphere (e.g., Nitrogen Oxides (NOx), Sulfur Oxides (SOx), Volatile Organic Compounds (VOCs)). Note: GHGs like CO2 are covered in E1, not here.

2. Water emissions: Pollutants discharged into freshwater or seawater (e.g., Nitrates, Phosphates, Heavy Metals).

3. Soil emissions: Pollutants released directly to soil (e.g., pesticides, industrial leaks).

Plus microplastics: E2-4 also specifically targets microplastics, which are tiny plastic particles that accumulate in the environment. Companies must report on both the microplastics they intentionally use (primary) and those generated as a byproduct of wear and tear (secondary).

The ESRSes define metrics as follows:

“Qualitative and quantitative indicators that the undertaking uses to measure and report on the effectiveness of the delivery of its sustainability-related policies and against its targets over time. Metrics also support the measurement of the undertaking’s results in respect of affected people, the environment and the undertaking.”

3. ESRS E2-4 at a glance

E2-4 requires that “the undertaking shall disclose the amounts of material emissions of pollutants to air, water and soil from its own operations”.

To comply, the disclosure must include:

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The European Pollutant Release and Transfer Register (E-PRTR), originally established by Regulation (EC) No 166/2006, historically served as the publicly accessible database tracking key environmental data from industrial facilities across Europe. While it was amended in 2019 to streamline reporting, this framework has now been superseded. In 2024, the EU adopted the Industrial Emissions Portal Regulation (IEPR)—Regulation (EU) 2024/1244, which officially repeals and replaces the E-PRTR.

Under this updated framework, the existing register is being upgraded into a more comprehensive Industrial Emissions Portal. The regulation ensures that industrial operators continue to report their pollutant releases (to air, water, and land), off-site transfers, and resource usage annually. National authorities compile and submit this data to the European Commission, which makes it available to the public, supporting transparency and public participation in environmental decision-making.

The disclosed data must include emissions from all facilities under the company’s financial and operational control, provided they exceed the specific threshold values now detailed in Annex II of the IEPR (Regulation (EU) 2024/1244).

You can find the Annex here: Regulation - EU - 2024/1244 - EN - EUR-Lex

4. How E2-4 links to the rest of ESRS E2

E2-4 is the scorecard for your entire pollution strategy:

• E2-1 (Policy): Defines your commitment to compliance and pollution reduction.

• E2-2 (Action): Describes the technology (e.g., filters) installed to reduce emissions.

• E2-3 (Target): Sets the goal (e.g., “keep NOx below 50 tonnes”).

• E2-4 (Metric): Checks your progress. If you report 60 tonnes of NOx in E2-4, it immediately signals that you missed your E2-3 target, prompting questions about the effectiveness of your E2-2 actions.

5. Bottom line

E2-4 is often where companies face the biggest data challenges. To report effectively:

• Check the list: Review Annex II of the IEPR (European Industrial Emissions Portal). If you emit it, you likely need to measure and report it.

• Don’t forget water transfers: Sending dirty water to a municipal treatment plant doesn’t make the pollution disappear from your report, it just moves it to the “transfers” category.

• Microplastics are new: Many companies have data on chemicals but lack data on microplastics. Start mapping where plastic particles might be shedding from your products now.

• Absolute values matter: While intensity metrics (e.g., pollution per unit of revenue) are helpful for internal tracking, E2-4 demands absolute mass (tonnes/kg).

Relevant Sources

Regulation - EU - 2024/1244 - EN - EUR-Lex

ESRS E2

November 2025 ESRS E2

When we manage pollution in a corporate setting, we often treat it in silos. We view air emissions, wastewater discharge, and solid waste as separate compliance boxes to tick. However, nature does not recognize these boundaries. The Earth acts as a giant, interconnected system.

For sustainability professionals, understanding this movement is important. Solving a problem in one medium—for example, scrubbing toxins from a factory smokestack—can inadvertently create a new problem in another if the resulting toxic ash leaches into the soil. To avoid these regretful solutions, we must look at the environment as a whole.

In this article, you will learn:

✅ How air, water, and soil interact as connected reservoirs

✅ How air pollution travels in the sky to contaminate land and water

✅ How soil acts as a reservoir that can release pollutants

✅ How water bodies can release toxins back into the air or trap them in the soil

By the end of this article, you will understand pollution transport and why a holistic approach is necessary to prevent pollution shifting in your environmental strategy.

2. Pollution moves from bucket to bucket

When we think about pollution, we often picture them in separate boxes: a dark cloud of smoke in the sky (air pollution), a plastic bottle floating in a river (water pollution), or a landfill leaking into the ground (soil pollution).

In reality, nature doesn’t have boxes. Our planet acts as a giant, interconnected system. Pollution rarely stays where it starts. Instead, it constantly moves between the air we breathe, the water we drink, and the soil that grows our food.

This traveling of pollutants is known as cross-media transfer. It describes how a chemical or particle moves from one environmental compartment to another.

The three buckets: Imagine the environment as three interconnected buckets representing air, water, and soil.

• If you pour pollution into the air bucket (like exhaust from a car), it doesn’t just vanish.

• Gravity pulls some of it down into the soil bucket.

• Rain washes the rest into the water bucket.

If we only focus on cleaning up one bucket, for example, using a filter to scrub toxins out of factory smoke, we often end up with a pile of toxic ash. If that ash is buried improperly, it leaks into the soil and water. Solving a problem in one medium can inadvertently create a new one in another.

Learn more about soil, water, and air pollution here:

3. How air pollution becomes soil & water pollution

The atmosphere often acts as a rapid transport highway, carrying pollutants far from their source before depositing them onto land and water.

Atmospheric deposition

This is the primary mechanism by which airborne pollutants settle onto surfaces. It occurs in two forms:

• Wet deposition: Pollutants are scavenged by rain, snow, or fog. This is the dominant pathway for heavy metals like lead (Pb) and zinc (Zn) in humid regions.

• Dry deposition: Gases and particles settle directly onto surfaces due to gravity. In arid regions, this is the main source of soil contamination.

Acid rain

Emissions of sulfur dioxide (SO₂) and nitrogen oxides (NOx) from burning fossil fuels transform in the atmosphere into acids. These deposit onto lakes and soils, lowering pH levels (acidification), which can kill aquatic life and leach toxic metals like aluminum from the soil.

Mercury cycling

Mercury emitted into the air can travel globally. It eventually deposits into oceans and lakes, where it converts into methylmercury, a potent neurotoxin, and accumulates in the food web.

4. How soil pollution becomes water & air pollution

Soil acts as both a reservoir and a source of pollution, releasing stored contaminants into groundwater or back into the air.

From the soil to water

• Leaching to groundwater: Water moving through the soil (percolation) dissolves pollutants and carries them into underground aquifers. For example, nitrates from agricultural fertilizers and heavy metals like cadmium (Cd) can leach from soil into groundwater.

• Runoff to surface water: Heavy rains wash soil particles laden with pesticides and fertilizers into nearby rivers and lakes. This pollution causes eutrophication (nutrient overload) in water bodies.

From the soil to the air

Read more

Water is the foundation of life and a critical resource for nearly every industry. Yet, the chemical properties that make water essential, specifically its ability to dissolve almost anything, also make it uniquely vulnerable to pollution.

For sustainability professionals, water risk is often viewed through the lens of scarcity (quantity). However, water quality is equally important. Understanding how industrial activities transform water chemistry, often in subtle and invisible ways, is essential to comprehend the full extent of their environmental impact.

In this article, you will learn:

✅ Why water’s chemical structure makes it the Universal Solvent

✅ The difference between visible waste and invisible threats

✅ How specific business activities drive water pollution

By the end of this article, you will understand water pollution and how corporate activities directly alter the quality of this important resource.

1. Water, the perfect solvent

At first glance, water seems simple. We know its chemical formula, H₂O, which means it is made of just two hydrogen atoms and one oxygen atom. However, despite its simple structure, water behaves in complex ways that are essential for life but also risky for the environment.

Why water is sticky

Scientists call water the Universal Solvent because it is better at dissolving other substances than almost any other liquid. But why?

It all comes down to electricity. You can think of a single water molecule as a tiny magnet.

• The Oxygen side has a slight negative electrical charge.

• The Hydrogen side has a slight positive electrical charge.

Because opposites attract, the positive side of one water molecule grabs onto the negative side of another, or onto other substances entirely. This is called polarity. It is this “stickiness” that allows water to break down salts, sugars, and minerals effectively.

The delivery system

This magnetic ability makes water an incredible means of transportation.

• The good news: In nature and our bodies, water grips onto essential nutrients and carries them where they need to go. It transports dissolved vitamins through your blood to your cells and pulls sap from the roots of a tree all the way to the highest leaves.

• The bad news: This same strength is also water’s greatest vulnerability. Because it dissolves things so easily, it cannot distinguish between good nutrients and bad chemicals.

As water flows over the ground (like rainwater running off a street or farm), it easily dissolves and picks up toxic substances like pesticides, motor oil, and industrial waste. Instead of just washing over them, it absorbs them, becoming a delivery system for poisons. It then carries these pollutants into our rivers, lakes, and oceans.

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2. Understanding water pollution

Water pollution occurs when harmful substances—chemicals, microorganisms, or physical waste—contaminate a body of water to the point where it becomes unsafe for its intended use, such as drinking, swimming, or supporting aquatic life.

Pollution isn’t always visible like a plastic bottle floating in a river. Some of the most dangerous forms of pollution are invisible changes to the water’s chemistry:

• Oxygen depletion: Fish and other aquatic creatures need oxygen dissolved in the water to breathe. When too much organic waste (like sewage) enters the water, bacteria multiply rapidly to eat it. These bacteria use up all the available oxygen, creating “dead zones” where nothing else can survive.

• Thermal pollution: Pollution isn’t always a substance; sometimes it is energy. If the temperature of a river changes drastically (usually getting hotter), it can kill sensitive species. Warm water cannot hold as much oxygen as cold water, so heating a river effectively suffocates the fish.

• Eutrophication: This is a process caused by an excess of nutrients, specifically nitrogen and phosphorus (often from fertilizers). These nutrients act like super-food for algae, causing massive algal blooms on the surface. When these blooms die and rot, they choke the water of oxygen.

  

3. Business as the driver of water pollution

Industries are a major source of water degradation. While regulations exist, companies pollute water through several specific mechanisms, often categorized as point sources (a direct pipe) or non-point sources (runoff from a large area).

Here are the primary ways companies introduce pollution:

Industrial discharge

Many industries, such as textile manufacturing and pharmaceuticals, use water to wash chemicals during production. This wastewater is often loaded with dyes, heavy metals (like lead and mercury), and toxic solvents. If not properly treated before being released, these chemicals enter the food chain. Through a process called bioaccumulation, small animals eat these toxins, and larger predators eat the small animals, concentrating the poison until it reaches dangerous levels in the fish humans eat.

Thermal pollution

Power plants and steel mills use massive amounts of water to cool down their machinery. They draw cool water from a nearby lake, run it through their hot pipes, and dump it back into the lake at a much higher temperature. This sudden "thermal shock" kills fish eggs and larvae and depletes the water's oxygen levels.

Mining and acid mine drainage

Mining companies dig deep into the earth, exposing rocks that have been buried for millions of years. When certain minerals (like sulfides) are exposed to air and water for the first time, they react to create sulfuric acid. This acid flows into nearby streams, turning them bright orange or red and dissolving heavy metals from the surrounding rock, creating a highly toxic flow known as Acid Mine Drainage.

Agricultural runoff

While often viewed as farming rather than industry, large-scale corporate agriculture is a massive polluter. Rain washes excess fertilizers and pesticides off the fields and into waterways. This is the leading cause of eutrophication and algal blooms mentioned earlier, turning clear lakes into green swamps.

Sources

Regional Cooperation for Water Quality Improvement in Southwestern Pennsylvania

Comprehensive review of industrial wastewater treatment techniques

Water Pollution, Its Treatment, and Its Adverse Impact on Humans

HEAVY METAL LEACHING FROM LANDFILLS: A REVIEW OF GROUNDWATER CONTAMINATION AND LONG TERM ENVIRONMENTAL IMPACTS

THERMAL POLLUTION AND ITS IMPACTS ON HUMAN HEALTH: A REVIEW

A Comprehensive Review on Mine Tailings as a Raw Material in the Alkali Activation Process

A Current Review of Water Pollutants in American Continent: Trends and Perspectives in Detection, Health Risks, and Treatment Technologies - PMC

Global Distribution, Ecotoxicity, and Treatment Technologies of Emerging Contaminants in Aquatic Environments: A Recent Five-Year Review

Water Contamination and Its Effects on Human Health: A Review | Journal of Geography, Environment and Earth Science International

Water | H2O | CID 962 - PubChem

If policies (E2-1) set the rules and actions (E2-2) describe the work, then targets define the destination. ESRS E2-3 asks undertakings to disclose the specific, measurable goals they have set to reduce or eliminate pollution.

This disclosure allows investors and stakeholders to judge whether a company’s ambition matches the urgency of its material impacts. It transforms vague promises such as “we will be cleaner” into trackable commitments such as “we will reduce NOx emissions by 40% by 2030”.

I will briefly explain the requirements for disclosing pollution-related targets.

More elaborate articles are, or will become available, which can be found on: Sustainability Simplified.

2. What are pollution targets?

Pollution targets are measurable, time-bound objectives that the undertaking aims to achieve in relation to its material pollution impacts.

According to ESRS 2 (AR 47), targets regarding material impacts should be outcome-oriented. This means they should focus on the actual result for the environment or people (e.g., reduce tonnes of pollutants released), rather than just a procedural output (e.g., train 50 employees).

Typical examples include:

• Air: Reduce absolute SOx and NOx emissions by 50% by 2030 against a 2020 baseline.

• Water: Achieve zero discharge of untreated wastewater by 2027.

• Plastics: Eliminate 100% of microplastics from product formulations by 2028.

• Soil: Remediate all contaminated sites to regulatory standards by 2035.

The ESRSes define targets as follows:

“Measurable, outcome-oriented and time-bound goals that the undertaking aims to achieve in relation to material impacts, risks or opportunities. They may be set voluntarily by the undertaking or derive from legal requirements on the undertaking.”

3. ESRS E2-3 at a glance

E2-3 specifically requires that “the undertaking shall disclose its pollution-related targets in accordance with the provisions of ESRS 2 GDR-T“.

To comply with ESRS 2 GDR-T, the disclosure must include the following elements for each target:

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4. How E2-3 links to the rest of ESRS E2

The target gives context to the metric. A metric is just a number, but with a target, it becomes a performance indicator.

• E2-1 (Policy): “We commit to reducing air pollution.”

• E2-2 (Action): “We are installing scrubbers.”

• E2-3 (Target): “To achieve a 50% reduction by 2030.”

• E2-4 (Metric): “This year, we emitted 1,200 tonnes, which is a 5% reduction.”

5. Bottom line

To report E2-3 effectively:

• Be SMART: Ensure targets are Specific, Measurable, Achievable, Relevant, and Time-bound.

• Define the baseline: A target of reducing emissions is meaningless without knowing the starting point (the baseline year and value).

• Don’t hide: If you don’t have a target for a material pollution topic, you must admit it and explain how you are monitoring progress otherwise.

• Look to science: Whenever possible, ground your pollution targets in scientific evidence (e.g., planetary boundaries or local ecological limits).

Relevant Standards

ESRS E2

November 2025 ESRS E2

If policies (E2-1) are the rules of the road, then actions are the actual driving. ESRS E2-2 asks undertakings to move beyond high-level commitments and disclose the concrete steps they are taking to tackle pollution.

This disclosure is important for credibility. It proves that a company is investing real effort and capital into managing its environmental impact. It connects the policies defined in E2-1 to the measurable results reported in E2-3 (Targets) and E2-4 (Metrics).

I will briefly explain the requirements for disclosing pollution-related actions and the resources allocated to them.

More elaborate articles are, or will become available, which can be found on: Sustainability Simplified.

2. What are pollution actions?

Pollution actions are the specific initiatives, projects, or changes in business practices implemented to manage material pollution impacts, risks, and opportunities.

According to ESRS 2 (AR 38), environmental actions should ideally be classified according to the mitigation hierarchy:

1. Avoidance: Preventing the pollution from happening (e.g., phasing out a Substance of Very High Concern).

2. Minimization: Reducing the amount or intensity of pollution (e.g., installing air scrubbers or wastewater treatment plants).

3. Restoration: Remediating damage already done (e.g., cleaning up a contaminated soil site).

4. Compensation: Offsetting residual impacts (though this is less common for pollution than for biodiversity).

Typical examples include:

• Technology upgrades: Retrofitting factories with best available techniques (BAT) to reduce air emissions.

• Process changes: Reformulating products to eliminate microplastics or hazardous chemicals.

• Value chain engagement: Working with suppliers to reduce their water pollutant discharges.

• Remediation: Projects to decontaminate soil after an accidental spill.

The ESRS defines actions as follows:

“Actions refer to:

i. actions and action plans (including transition plans) that are undertaken to ensure that the undertaking delivers against targets set and through which the undertaking seeks to address material impacts, risks and opportunities; and
ii. decisions to support these with financial, human or technological resources.

Actions can be individual actions, taken only by the undertaking, or collective actions, this is, collaborative efforts by a group of stakeholders - such as undertakings, governments, civil society, or communities - to address shared challenges or achieve common goals, particularly when those goals cannot be effectively achieved by any single actor working alone.”

3. ESRS E2-2 at a glance

E2-2 requires that “the undertaking shall disclose its key pollution-related actions and resources allocated to the implementation of those actions in accordance with the provisions of ESRS 2 GDR-A“.

To comply with ESRS 2 GDR-A, the disclosure must include:

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4. How E2-2 links to the rest of ESRS E2

The Action disclosure is the bridge between policy and performance:

• E2-1 (Policy): You commit to “Zero Pollution.”

• E2-2 (Action): You invest €2M in a new water filtration system (CapEx) and €100k/year in maintenance (OpEx) to achieve this.

• E2-3 (Target): You aim to reduce water pollutants by 50% by 2030.

• E2-4 (Metric): You report the actual tonnes of pollutants discharged this year to verify if the action is working.

The disclosure of actions and resources provides the evidence that the company is mobilizing to meet its goals.

5. Bottom line

E2-2 is where you demonstrate execution. To report effectively:

• Be specific: Avoid vague statements like “we are working on it.” State what you are building, changing, or fixing.

• Show the money: Investors review the resources section to ensure your budget aligns with your ambitions. If you have a massive target but zero budget allocated, it raises red flags.

• Use the hierarchy: Frame your actions around avoidance and minimization first, as these are more effective than remediation.

• Link to value chain: Don’t forget actions taken to address pollution upstream (suppliers) or downstream (product use).

Relevant Standards

ESRS E2

November 2025 ESRS E2

Air emissions are often reduced to a single metric: carbon emissions. While climate change is important, it is only one aspect of air pollution. The atmosphere is a delicate chemical solution, and when businesses introduce foreign agents—whether through combustion, chemical solvents, or logistics—they disrupt a balance that has existed for millions of years.

To manage environmental impact effectively, we must look beyond carbon and understand the broader spectrum of atmospheric degradation.

In this article, you will learn:

✅ Why the air is important and how it impacts us

✅ The difference between the greenhouse gas emissions and air pollution

✅ Pollution traveling thousands of kilometers

✅ How specific industrial activities alter the air

By the end of this article, you will have a better understanding of air pollution.

1. Air, a dynamic mixture

Before understanding pollution, we must first appreciate the delicate baseline from which we are deviating. The Earth’s atmosphere is not merely the space between us and the stars; it is a complex, dynamic, and thin protective envelope that makes life possible. Think of the atmosphere as Earth’s life-support system. It acts like a shield (blocking harmful solar rays), a blanket (keeping us warm), and a water delivery system (moving rain around the world).

The perfect mixture

For millions of years, the atmosphere has maintained a relatively stable chemical composition. This specific mix of gases is what biological life has evolved to breathe and thrive in. If you were to take a dry sample of the air we breathe, it would consist of a distinct mixture:

• Nitrogen (~78%): The most abundant gas and essential for building proteins in plants and animals via nitrogen fixation in the soil.

• Oxygen (~21%): The fuel for respiration in most living organisms and a key component in the chemical reactions that drive our ecosystems.

• Argon (~0.9%): A noble gas that is chemically inert.

• Trace gases (~0.1%): This tiny fraction includes naturally occurring Carbon Dioxide, Neon, Helium, Methane, and water vapor.

The power of the 0.1%

It is important to recognize that although trace gases make up less than 0.1% of the atmosphere, they exert a massive influence on the planet’s climate and weather patterns. A slight alteration in this fractional percentage can trigger global shifts in temperature.

Ecosystem services of the atmosphere

Beyond simply providing air to breathe, the atmosphere performs critical services that maintain the planet’s habitability:

1. Thermal regulation: through the natural greenhouse effect, trace gases trap just enough solar heat to keep Earth’s average temperature at a habitable level (roughly 15°C/59°F). Without this, Earth would be a frozen rock.

2. Radiation shielding: High in the stratosphere, the Ozone layer acts as natural sunscreen, absorbing the majority of the sun’s harmful ultraviolet (UV) radiation before it reaches the surface.

3. Meteorological distribution: The movement of air masses redistributes heat and moisture from the equator toward the poles, creating the weather cycles and precipitation patterns required for agriculture and fresh water.

A delicate balance

In its pristine state, the atmosphere exists in dynamic equilibrium. This means that while gases are constantly being exchanged—oxygen produced by photosynthesis, carbon dioxide released by respiration—the overall ratios remain steady. The system is resilient, but it has limits.

When we view the atmosphere not as an infinite dump, but as a finite, delicately balanced chemical solution, the severity of introducing foreign agents becomes clear.

2. Understanding air pollution

Air pollution occurs when the atmosphere’s delicate chemical balance is disrupted by the introduction of harmful solids, liquids, or gases in concentrations that exceed natural capacities.

In the corporate sustainability conversation, we often lump emissions into one category. However, it is vital to distinguish between Greenhouse Gases (GHGs) and air pollutants. While often described as “two sides of the same coin,” they behave differently:

• Greenhouse Gases (CO2, Methane, etc.): These are a global stock problem. They accumulate in the atmosphere over centuries and primarily affect the climate by trapping heat.

• Air pollutants (PM2.5, NOx, Ozone, etc.): These are a local and regional flow problem. They remain in the air for a short time (days to weeks) but cause immediate damage to human health and ecosystems.

The major air pollutants

To understand the risk, we must look beyond just carbon. The primary pollutants include:

• Particulate Matter (PM2.5 and PM10): Tiny solid or liquid particles suspended in the air. PM2.5 is particularly dangerous because it is small enough to penetrate deep into the lungs and enter the bloodstream, causing systemic inflammation.

• Black Carbon (Soot): A component of PM formed by incomplete combustion. It is a short-lived climate pollutant that hits twice: it warms the atmosphere by absorbing sunlight and, when deposited on snow or ice, it darkens the surface and accelerates melting.

• Ground-level Ozone (O3): Unlike other pollutants, this is not emitted directly. It is a secondary pollutant formed when sunlight reacts with chemical ingredients (NOx and VOCs) in the air. It is the main component of smog and is highly toxic to human lungs and crops.

• Nitrogen Oxides (NOx) and Sulfur Dioxide (SO2): Reactive gases formed primarily from burning fossil fuels. They are major lung irritants and the primary drivers of acid rain.

• Volatile Organic Compounds (VOCs): Chemicals that vaporize easily (found in paints, solvents, and fuels). While some are directly toxic, their main danger is acting as a precursor for ground-level ozone.

• Ammonia (NH3): Often overlooked in industrial reports, this gas primarily comes from agriculture (fertilizers and livestock). It reacts with NOx and SO2 in the air to form dangerous secondary particulate matter.

The transboundary issue
We tend to think of pollution as a localized urban issue—smog over a city. However, phenomena like Atmospheric Brown Clouds (ABCs) prove otherwise. These are vast, 3-kilometer-thick layers of pollution consisting of aerosols, soot, and chemical particles that can span entire ocean basins. They prove that air pollution is not just a city problem; it is a transcontinental crisis that alters weather patterns and agriculture thousands of kilometers from the source.

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3. Business as the driver of air pollution

Incomplete combustion (energy & heat)

The most significant source of industrial air pollution is the burning of fossil fuels (coal, oil, natural gas) and biomass.

• The mechanism: When fuel is burned to generate electricity, power boilers, or run heavy machinery, it rarely burns “cleanly.”

• The output: This releases Carbon Dioxide (CO2), but also Nitrogen Oxides (NOx), Sulfur Dioxide (SO2), and Black Carbon.

• Key sectors: Energy generation, heavy manufacturing, and heating.

Industrial processes & fugitive emissions

Many industries release pollutants from the chemical reactions inherent to their production processes. And not just from burning fuel for power.

• Iron and steel: This industry is a major source of dust and heavy metals. The sintering and coking processes release vast amounts of PM, SO2, and NOx.

• Chemicals and solvents: Industries using solvents (paints, coatings, cleaning agents) release VOCs through evaporation. These are known as fugitive emissions because they often leak from valves, pumps, or open vats rather than a smokestack.

• Construction & mining: These sectors are responsible for significant coarse particulate matter (dust) generated by breaking rocks, moving soil, and demolition.

Supply chain & logistics (the hidden pollution)

For many companies, the bulk of their air pollution footprint lies outside their own fence line, within their supply chain.

• Transportation: The global movement of goods relies heavily on diesel engines (trucks, ships, trains). Diesel exhaust is a primary source of NOx and Particulate Matter.

• The “Pollution Haven” effect: There is a phenomenon known as the “Pollution Haven Hypothesis,” where multinational corporations may relocate dirty production stages to developing countries with laxer environmental regulations. This effectively offshores the air pollution, allowing the company to appear cleaner at home while contributing to global atmospheric degradation (such as the Asian Brown Cloud).

The Asian Brown Cloud is a massive, three-kilometer-thick layer of air pollution that hangs over South Asia and the Indian Ocean, primarily during the dry winter months. It is caused by a mixture of soot, dust, and chemicals from burning fossil fuels in factories and vehicles, as well as the burning of wood and crop waste in rural areas. Because there is no rain to wash the air clean between November and April, this toxic haze builds up and traps heat while blocking sunlight, which disrupts weather patterns, accelerates the melting of Himalayan glaciers, and poses serious respiratory health risks to millions of people.

Sources

The Atmosphere: Getting a Handle on Carbon Dioxide - NASA Science

Basics of air pollution

Frontiers | Environmental and Health Impacts of Air Pollution: A Review

Editorial: Atmospheric chemistry and air pollution - PMC

Global supply chain relocation reshaped PM2.5 pollution and human health risks

The Asian brown cloud

Air Quality and Climate Change Research | US EPA

Industrial pollution control based on artificial intelligence: A synergistic model using social network analysis and machine learning | Journal of Innovation & Knowledge

OCCUPATIONAL EXPOSURES DURING IRON AND STEEL FOUNDING - Chemical Agents and Related Occupations - NCBI

The Direct Effects of Air Pollutant Exposure from Industrial Complexes on Chronic Respiratory Diseases in Local Residents: A Population-Based Cohort Study - PMC

Unbundling the Pollution Haven Hypothesis

While targets and metrics measure the output of a company’s environmental impact, policies provide the governance framework that dictates how those results are achieved. ESRS E2-1 asks undertakings to describe the official rules, principles, and commitments they have established to prevent and control pollution.

This disclosure serves as the foundation of the Pollution standard. It connects your high-level sustainability governance (ESRS 2) to the tangible actions (E2-2) and targets (E2-3) aimed at reducing your environmental footprint.

I will briefly explain the requirements for companies to disclose their policies in relation to pollution of air, water, and soil.

More elaborate articles are, or will become available, which can be found on: Sustainability Simplified.

2. What is a pollution policy?

A pollution policy is a framework that outlines how an undertaking manages its emissions and releases into the environment. It addresses the prevention, control, and reduction of emissions to air, water (including freshwater and seawater), and soil.

Context-specific considerations are particularly important here, as pollution impacts are often tied to specific geographies or sites.

Typical examples include:

• Zero Pollution commitments: Strategies aligned with the EU Action Plan ‘Towards a Zero Pollution for Air, Water and Soil’.

• Chemical Management: Rules regarding Substances of Concern (SoC) and Substances of Very High Concern (SVHC), including restrictions on production or use.

• Microplastics: Commitments to reduce the use of primary microplastics or the release of secondary microplastics.

• Site-specific controls: Policies governing emissions at specific production sites or areas with water stress.

The ESRS 2 General Disclosures (GDR-P) provides the framing for this requirement. It states that the objective is to enable an understanding of the policies in place to manage the prevention, mitigation, and remediation of material negative impacts.

The ESRS defines a policy as follows:

“A set or framework of general objectives and management principles that the undertaking uses for decision-making. A policy implements the undertaking’s strategy or management decisions related to a material sustainability topic. Each policy is under the responsibility of defined person(s), specifies its perimeter of application, and includes one or more objectives (linked when applicable to measurable targets). A policy is validated and reviewed following the undertakings’ applicable governance rules. A policy is implemented through actions or action plans.”

3. ESRS E2-1 at a glance

E2-1 specifically requires that “the undertaking shall disclose its pollution-related policies in accordance with the provisions of ESRS 2 GDR-P”.

To comply with ESRS 2 GDR-P, the disclosure must include:

If a company has not adopted policies regarding pollution despite it being a material topic, it must explicitly disclose this fact.

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4. How E2-1 links to the rest of ESRS E2

• E2-1 (policies) sets the rules and strategic direction for pollution prevention and control.

• E2-2 (actions and resources) describes the key actions taken to implement those policies and the financial resources allocated to them.

• E2-3 (targets) defines the measurable goals the company aims to achieve.

• E2-4 & E2-5 (metrics) provide the data on actual emissions (air, water, soil) and substances of concern to track performance against the policy.

For example, a policy to eliminate microplastics (E2-1) would be implemented through specific manufacturing changes (E2-2), tracked against a reduction target (E2-3), and reported via the mass of microplastics released (E2-4).

5. Bottom line

E2-1 is your opportunity to demonstrate that your organization’s approach to pollution is systematic rather than reactive. To comply and communicate effectively:

• Define the scope clearly: Specify if policies apply to specific sites, the whole group, or the value chain, especially regarding transfers of pollutants to external treatment plants.

• Address the full spectrum: Ensure policies cover air, water, soil, and specific concerns like microplastics and hazardous substances.

• Link to regulations: Where relevant, show how your policies align with frameworks like the Chemical Strategy for Sustainability or the Industrial Emissions Directive.

A robust pollution policy is the starting point for credible reporting on how an undertaking contributes to a toxic-free environment.

Relevant Standards

ESRS E2

November 2025 ESRS E2

Soil is often treated as an inert platform for building factories or planting crops. In reality, it is the living skin of our planet, a complex, non-renewable resource that takes centuries to form but only moments to destroy.

Soil pollution presents a unique challenge: unlike a plume of smoke or an oil spill, it is often invisible. Contaminants can hide for decades, silently traveling through the ground to poison aquifers or accumulating in the food chain until they reach toxic levels on our plates.

To manage environmental liabilities, companies must understand not just what they emit, but how those emissions interact with the land beneath their feet.

In this article, you will learn:

✅ Why soil is often called the living skin of the Earth

✅ How pollutants behave underground

✅ How toxins climb the food chain through bioaccumulation and biomagnification

✅ How specific industries create a toxic soil

By the end of this article, you will understand the mechanics of soil pollution and why protecting this finite asset is important.

1. Soil, the living skin

Soil is often called the living skin of the Earth. It is a dynamic mix of mineral particles, organic matter, water, and air.

• Mineral particles (~45%): These come from the weathering of rocks over thousands of years. They are categorized by size: sand (large and gritty), silt (medium and floury), and clay (microscopic and sticky).

• Organic matter (~5%): This is the “engine” of the soil. It includes living organisms like bacteria and fungi, plant roots, and humus (decomposed plant and animal remains). It holds nutrients and helps the soil soak up water like a sponge.

• Pore space (~50%): The gaps between soil particles are filled with air and water, which are essential for roots to breathe and for nutrients to move.

Soil formation and layers

Soil forms very slowly through the interaction of climate, living organisms, and topography acting on rocks over time. This creates distinct layers called horizons. The top layer (topsoil) is the most fertile and is where most biological activity happens. Because it takes hundreds of years to form just one inch of topsoil, soil is considered a non-renewable resource.

2. Understanding soil pollution

Soil pollution occurs when human-made chemicals or other alterations reach concentrations that harm the health of plants, animals, or humans. Unlike air or water pollution, soil pollution is often “invisible” and can remain hidden for decades.

How pollutants behave in soil

Once a pollutant enters the soil, it doesn’t just sit there; it interacts with the soil particles:

• Sorption: This is when a pollutant “sticks” to the surface of clay or organic matter. If a pollutant is strongly “sorbed,” it stays in place; if not, it can move easily.

• Leaching: Rainwater can wash soluble pollutants down through the soil and into the groundwater, which eventually reaches our drinking water.

Soil pollution occurs when the concentration of harmful chemicals or substances in the soil is high enough to damage soil functions or pose a risk to the health of humans, animals, and plants.

Types of pollution

• Point-source pollution: Contamination originating from a single, identifiable source, such as a specific industrial spill, an illegal dumping site, or a leaking underground storage tank.

• Diffuse pollution: Contamination spread over large areas that cannot be traced to a single source. This often occurs through atmospheric deposition (pollutants falling with rain) or the widespread use of agricultural chemicals.

Common soil contaminants

Industrial and human activities introduce various pollutants into the soil:

• Heavy metals: Elements like lead, mercury, arsenic, and cadmium, which are toxic and persist in the environment for centuries.

• Organic pollutants: Including pesticides, mineral oils, and persistent organic pollutants (POPs).

• Nutrient imbalance: Excessive nitrogen and phosphorus from fertilizers can leach into water or disrupt soil biology.

Impact of soil pollution: The food chain

Soil is a natural filter, but when overloaded with pollution, it sends toxins directly into our food and water.

• Food & Water: Plants absorb heavy metals through their roots, and chemicals leak into our drinking water.

• Ecosystems: Pollution kills the beneficial microbes that keep land fertile.

Toxins climb the food chain via two processes:

1. Bioaccumulation: Plants act as biological pumps. They often cannot distinguish between nutrients and toxins. A plant might absorb toxic Arsenic instead of Phosphorus. When an animal (or human) eats that plant, the toxin is absorbed faster than the body can excrete it, accumulating in organs like the liver.

2. Biomagnification: As predators eat herbivores, the concentration of the toxin increases at each step up the food chain. A human eating livestock raised on contaminated feed ingests a concentrated dose of the pollutant.

The result: By the time we eat crops or livestock from polluted land, we are consuming a concentrated dose of the original soil toxins.

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3. Business as the driver of soil pollution

Mining and raw material extraction

Mining is one of the most visible ways industry alters the earth. It doesn’t just move dirt, it also changes the soil’s chemistry.

• Toxic legacies: Mining unearths heavy metals like lead, mercury, and arsenic. Unlike organic waste, these “forever chemicals” do not break down and can stay in the soil for centuries, long after the mine has closed.

• Waste mountains: After valuable minerals are removed, the leftover “tailings” (powdered rock) are often stored in large piles or ponds. These fine particles easily blow away in the wind or wash away in the rain, spreading toxins to nearby farms and forests.

• Fuel extraction: Drilling for oil and gas can lead to accidental spills. Additionally, “brines”—salty, toxic water found deep underground—are often brought to the surface during drilling, poisoning the soil if they leak.

Manufacturing and industrial factories

Factories create the products we use daily, but their production lines often generate hazardous by-products.

• Chemical leaks: Industries like textile dyeing, leather tanning, and chemical manufacturing use powerful solvents and dyes. If these aren’t stored in perfectly sealed containers, they seep into the ground through cracks in factory floors or storage area leaks.

• Falling pollutants: Pollution isn’t just a ground-level issue. Factories release smoke and soot into the sky. When it rains, these airborne chemicals turn into “acid rain” or simply settle as dust, coating the soil in a layer of industrial pollutants.

• The tech burden: As we produce more electronics, the “e-waste” industry has grown. When old phones or computers are recycled improperly—such as by burning them to get to the copper inside—toxic dioxins and metals are baked directly into the earth.

Waste disposal and trash Management

The way we get rid of what we don’t want is a major source of “hidden” soil pollution.

• Landfill hazards: Even “legal” landfills can be a problem. As trash decomposes, it creates a toxic “garbage juice” called leachate. If the landfill’s bottom liner fails, this liquid sinks into the soil, carrying battery acid, pharmaceuticals, and household cleaners with it.

• Historical burying: In the past, many companies used an “out of sight, out of mind” approach, simply burying barrels of industrial waste. Today, these aging barrels are rusting and leaking, creating “brownfields”—plots of land too contaminated to be used safely.

• Sewage sludge: Sometimes, treated waste from cities (sewage sludge) is used as fertilizer. While it contains nutrients, it can also contain concentrated pathogens and microplastics if the treatment process isn’t rigorous enough.

Construction and transportation

Building the world’s infrastructure requires movement and materials that can degrade the land.

• Road runoff: Busy roads are constant sources of pollution. Every time a car brakes or a tire wears down, tiny bits of metal and rubber fall onto the asphalt. Rain washes these metals and oily compounds (PAHs) into the soil along the roadside.

• Soil sealing: This is a unique type of “pollution” where we cover living soil with concrete or asphalt. This “seals” the soil, killing the beneficial microbes underneath.

• Leaded history: Even though leaded gasoline was banned decades ago in many places, the lead particles emitted from exhaust pipes during that era still sit in the topsoil of many urban yards today.

The agrochemical industry

Large-scale farming depends on an industrial supply chain that can inadvertently harm the soil it aims to help.

• Fertilizer impurities: Creating massive amounts of fertilizer involves processing rocks and minerals. This process can leave behind trace amounts of radioactive elements or heavy metals like cadmium, which are then spread across millions of acres of farmland.

• Pesticide production: The factories that manufacture bug and weed killers generate their own concentrated waste. If a manufacturing plant has a spill, it creates a “point-source” of pollution—a small area with an extremely high, dangerous concentration of chemicals.

Sources

Enviroweb Home

Soil chronosequences, soil development, and soil evolution: A critical review - Research Explorer The University of Manchester

Soil Processes

Major contaminants of emerging concern in soils: a perspective on potential health risks - PMC

Soil architecture and physical properties

Heavy Metals Removal from Electroplating Wastewater by Waste Fiber-Based Poly(amidoxime) Ligand

Polycyclic Aromatic Hydrocarbons: Sources, Toxicity, and Remediation Approaches - PMC

Don't let nitrogen acidify your soil

UN says up to 40% of world’s land now degraded | Environment | The Guardian

Frontiers | Phytoremediation: A Promising Approach for Revegetation of Heavy Metal-Polluted Land

Chemicals are important to how modern society functions, from the food we eat to the technologies we rely on. But not all chemicals are safe. Some, like PFAS (per- and polyfluoroalkyl substances), persist in the environment, accumulate in our bodies, and are linked to serious health risks. PFAS have been widely used for decades. But they are extremely persistent. That’s why they’re now known as “forever chemicals.” In recent years, PFAS have become a major global concern.

This article will help you understand:

✅ What PFAS are
✅ How PFAS affect human health and the environment
✅ Where they’re found and how we’re exposed
✅ Why regulating PFAS is so difficult
✅ How PFAS relate to substances of very high concern (SVHCs) under the EU’s CSRD framework

By the end, you’ll have a clear understanding of why PFAS are one of the most urgent chemical threats of our time.

2. What are PFAS?

Per- and polyfluoroalkyl substances (PFAS) are a group of more than 4,700 synthetic chemicals used in everything from waterproof clothing and non-stick cookware to firefighting foam and industrial processes. They are designed to resist heat, oil, grease, and water—qualities that make them commercially valuable but environmentally persistent.

The problem? PFAS don’t break down easily in nature. That’s why they’re known as “forever chemicals.” Once released into the environment, they accumulate in soil, water, wildlife, and human bodies.

Where you’ll find them:

• Food packaging and takeout containers

• Waterproof textiles and outdoor gear

• Cleaning products and stain repellents

• Industrial applications and electronics

• Drinking water near manufacturing sites

Their ubiquity makes PFAS incredibly hard to avoid.

3. Health effects: A slow-moving crisis

Research shows that exposure to PFAS can affect many parts of the body, even at low levels. Here's what has been found:

• Cholesterol: PFAS are consistently linked to higher cholesterol levels in people.

• Thyroid: These chemicals can disrupt thyroid hormones, especially in women and children.

• Immune system: PFAS may weaken the immune response, including lowering how well vaccines work in kids.

• Liver and kidneys: PFAS can build up in the liver and kidneys, leading to damage and increasing the risk of disease.

• Cancer: Studies link PFAS to higher risks of testicular and kidney cancer.

These effects are supported by both animal research and human studies, and the evidence is growing stronger.

4. How PFAS reach us: from factories to food

PFAS are used in many everyday products, including building materials, electronics, and firefighting foams, because of their durability. But, this durability comes at a cost: PFAS are released throughout the life cycle of these products and persist in the environment.

Example

Major pollution has been documented near production sites in Belgium and the Netherlands, where PFAS have contaminated soil and water. Industrial wastewater, especially from smaller factories, can spread PFAS to farmland via sewage sludge, as seen in Germany. Firefighting foams are another key source, most notably in Ronneby, Sweden, where drinking water contamination led to PFAS levels in residents’ blood over 100 times above normal.

Source: Cross-cutting story 3: PFAS — European Environment Agency

5. Environmental impact: A legacy that lasts

Once released PFAS contaminate groundwater, rivers, and even remote regions through atmospheric transport. Many PFAS are water-soluble and mobile, allowing them to spread far from their source. They build up in aquatic organisms and move up the food chain, leading to significant exposure in predators such as birds, seals, and humans. Even modern waste treatment and incineration processes often fail to completely destroy them, contributing to their global distribution. Their resistance to environmental breakdown, combined with toxicity and bioaccumulation, makes PFAS a long-term hazard to ecosystems and biodiversity​.

6. Why monitoring and regulating PFAS is so difficult

Even as PFAS gain attention, many still go undetected and unregulated. Here’s why tracking and managing them remains difficult:

• Hard to detect
  PFAS often exist in water at extremely low levels (parts per trillion), requiring specialized equipment and strict lab protocols. New sensing methods are promising but not yet reliable for broad use.

• Limited data on newer PFAS
  While legacy PFAS like PFOA are well studied, many newer ones lack toxicity and environmental data, making it hard to assess their risks or prioritize action.

• Patchy regulation
  Most PFAS rules are set at the national level, mainly in high-income countries. Many others lack the tools and infrastructure to monitor them.

• Treatment remains costly
  Removing PFAS is expensive, and current methods often fail to balance effectiveness, affordability, and sustainability, especially in low-resource regions.

Until these issues are addressed, PFAS will continue to quietly accumulate in people and the environment.

7. How PFAS are being regulated in the EU and globally

Efforts to regulate PFAS are growing, especially in the EU and through international treaties:

• Global bans
  PFOS and PFOA—two of the most harmful PFAS—are banned under the global Stockholm Convention. PFHxS was recently added, and more PFAS are under review.

• EU restrictions
  The EU bans several PFAS under its POPs and REACH regulations. More restrictions are coming, including a planned ban on PFHxA in 2026. Five EU countries have proposed a broader PFAS restriction covering many uses.

• Firefighting foams
  Special rules are being developed to restrict PFAS in firefighting foams, a major source of environmental contamination.

• High-concern substances
  Several PFAS, including GenX, PFOA, and PFHxS, are officially listed as Substances of Very High Concern (SVHC), which triggers extra reporting and safety obligations.

• Limits in water and food
  The EU sets a 0.5 µg/L limit for PFAS in drinking water. EFSA also set strict limits on PFAS in food, with fish, meat, and eggs being common sources.

• Group approach
  Because regulating each PFAS individually is too slow, the EU supports a group-based approach to manage them more efficiently.

In short, PFAS regulation is accelerating, with the EU aiming to phase out all non-essential uses. The Corporate Sustainability Reporting Directive (CSRD) requires businesses to report about their Substances of (Very High) Concern, thus including PFAS, read more about these substances here:

8. What’s next?

The science is clear about PFAS, the health risks are real, and the pollution is widespread. The next step is taking action against using PFAS. For businesses, moving away from PFAS now means staying ahead of regulatory bans and reducing liability. Meanwhile, it means protecting society, the environment and your brand’s reputation.

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Sources

A Review of the Pathways of Human Exposure to Poly- and Perfluoroalkyl Substances (PFASs) and Present Understanding of Health Effects - PMC

Cross-cutting story 3: PFAS — European Environment Agency

Sources, occurrence and toxic effects of emerging per- and polyfluoroalkyl substances (PFAS) - ScienceDirect

New study reveals diet link to PFAS ‘forever chemicals’ in human body | Pfas | The Guardian

Per- and Polyfluoroalkyl Substances (PFAS) | American Association for the Advancement of Science (AAAS)

PFAS Exposure Pathways for Humans and Wildlife: A Synthesis of Current Knowledge and Key Gaps in Understanding - PMC

Comprehensive analysis of PFAS presence from environment to plate | npj Science of Food

(PDF) Per- and Polyfluoroalkyl Substance Toxicity and Human Health Review: Current State of Knowledge and Strategies for Informing Future Research

Environmental impacts, exposure pathways, and health effects of PFOA and PFOS - ScienceDirect

PFAS Environmental Pollution and Antioxidant Responses: An Overview of the Impact on Human Field - PMC

Per- and polyfluoroalkyl substances (PFAS) - ECHA

Relevant DR under the CSRD:

ESRS E2: Disclosure Requirement E2-5 – Substances of concern and substances of very high concern

Chemicals are essential to modern industries, but some pose significant risks to human health and the environment. To regulate these risks, the European Union established the REACH Regulation (Registration, Evaluation, Authorisation, and Restriction of Chemicals), which sets strict guidelines on how hazardous substances are managed.

This article explains the criteria used to classify a substance as an SVHC, provides insight into the regulatory framework that governs SVHCs, including how substances are assessed, and details some of the obligations that companies face when handling SVHCs.

2. What are Substances of Very High Concern (SVHCs)?

A Substance of Very High Concern (SVHC) is a chemical that poses serious risks to human health or the environment. Under the EU REACH Regulation, certain substances are classified as SVHCs if they meet strict hazard criteria.

How is a substance classified as an SVHC?

A chemical may be identified as an SVHC if it falls into one or more of these categories:

• Carcinogenic, mutagenic, or toxic for reproduction (CMR)

  • These substances can cause cancer, alter DNA, or harm reproductive health.

  • The classification follows the CLP Regulation, which standardizes hazard labeling in the EU.

• Persistent, Bioaccumulative, and Toxic (PBT) or very Persistent and very Bioaccumulative (vPvB)

  • Persistent: The substance does not break down easily in the environment.

  • Bioaccumulative: It builds up in living organisms over time.

  • Toxic: It can cause long-term harm to humans or wildlife.

  • These classifications follow Annex XIII of REACH.

• Substances of Equivalent Concern

  • Some substances may not fit neatly into the above categories but still pose serious risks.

  • A common example is endocrine disruptors, which interfere with hormones and can cause developmental or reproductive harm.

There are over 1000 substances that may meet SVHC criteria. However, under REACH compliance, only those officially placed on the Candidate List by the European Commission and ECHA (European Chemicals Agency) are considered SVHCs in a legal sense. More about the candidate list below.

What happens if a substance is classified as an SVHC?

Once a chemical is listed as an SVHC:

• It is added to the Candidate List for potential future regulation.

• Companies must provide safety data sheets and inform customers if the substance is in their products.

• Some SVHCs may require authorization for use, meaning companies must justify why they still need to use them and prove there are no safer alternatives.

This system makes sure that hazardous substances are gradually replaced with safer alternatives where possible.

3. Regulatory framework and its origins

The regulatory foundation for identifying SVHCs lies primarily with REACH. Adopted by the European Union in 2007, REACH requires companies to register the chemicals they produce or import, assess their risks, and communicate this information throughout the supply chain. The European Chemicals Agency (ECHA) plays a central role in evaluating substances and maintaining a list of SVHCs. This list is updated regularly as new scientific evidence emerges.

Key components of REACH:

1. Registration: Companies must register any chemical substances they produce or import in quantities exceeding one tonne per year with the European Chemicals Agency (ECHA). This process provides detailed information about the substance's properties, uses, and safety measures. ​The amount of information required depends on the tonnage of the substance placed on the market per year.

2. Evaluation: ECHA, in collaboration with EU member states, assesses the information submitted during registration to ensure compliance and to further investigate substances of concern. This evaluation helps identify potential risks associated with specific chemicals. ​

3. Authorisation: Certain hazardous substances, known as Substances of Very High Concern (SVHCs), are subject to authorisation. The goal is to control their risks and promote their gradual replacement with safer alternatives when feasible. Companies must apply for permission to continue using these substances, demonstrating that risks are adequately managed or that no suitable substitutes exist.

4. Restriction: REACH can impose restrictions on the manufacture, marketing, or use of specific substances if they pose unacceptable risks. Restrictions can apply to particular uses or ban a substance entirely.

Regulations like REACH ensure that hazardous chemicals are monitored and controlled, thereby protecting human health and the environment. Other related regulations, such as Directive 2010/75/EU on industrial emissions, complement these efforts by addressing how pollutants, including hazardous substances, are managed and reported.

4. Understanding REACH lists

The European Chemicals Agency is the central body responsible for implementing REACH. The agency also maintains publicly accessible databases containing information on registered substances, including their hazards and safe usage guidelines. These databases, or lists, categorize substances based on their assessment and regulatory status. Such a list looks like this:

When clicking on a substance you will find more information, such as the restriction:

Candidate List

This list includes substances identified as SVHCs due to properties such as carcinogenicity, mutagenicity, reproductive toxicity, persistence, bioaccumulation, or equivalent concern (e.g., endocrine disruptors).

Legal obligations apply when a substance is included in the Candidate List under REACH:

• If an article contains an SVHC above 0.1% (w/w), suppliers must inform customers and consumers about safe usage.

• Consumers have the right to ask if a product contains Substances of Very High Concern (SVHCs).

• Importers and producers must notify ECHA within six months of a substance being added to the Candidate List (e.g., by 21 January 2025).

• Suppliers of substances or mixtures containing SVHCs must update their safety data sheets (SDS).

• Waste Framework Directive requires companies to notify ECHA if SVHCs exceed 0.1% (w/w) in their articles, and this is published in the SCIP database.

• EU Ecolabel Regulation prohibits awarding the ecolabel to products containing SVHCs.

See the list here: Candidate List of substances of very high concern for Authorisation - ECHA

Authorisation List (Annex XIV)

Substances from the Candidate List may be added to the Authorisation List, meaning they cannot be used or placed on the market after a specified sunset date unless a company obtains authorisation. This prioritization is based on factors like hazardous properties, widespread use, and high production volumes. Before finalizing its decision, ECHA launches a three-month consultation where stakeholders can provide input. The aim is to ensure that SVHCs are progressively replaced by safer alternatives.

Companies can apply for authorisation to continue using substances on the Authorisation List. ECHA provides guidance, submission deadlines, and evaluations of applications, including safer alternatives and dose-response data.

See the list here: Authorisation List - ECHA

Restriction List (Annex XVII)

This list specifies substances subject to restrictions, detailing the conditions under which they can or cannot be manufactured, used, or sold. Restrictions can also impose technical measures or labeling requirements. Restrictions are implemented to mitigate identified risks to health and the environment.

Exemptions include:

• On-site isolated intermediates

• Substances used in scientific research and development

• Substances posing risks only in cosmetics

See the list here: Substances restricted under REACH - ECHA

5. Is this relevant to your business?

Determining the relevance of substances of concern or SVHCs to your organization involves a few steps:

1. Assess your industry and products: Industries such as textiles, packaging, cosmetics, paints, and automotive are more likely to handle these hazardous substances. If your products or materials include chemicals known for CMR, endocrine disruption, or PBT properties, they may be relevant.

2. Review supply chain information: Look at safety data sheets, supplier disclosures, and regulatory labels. If your suppliers list chemicals that appear on the ECHA SVHC list, it’s a strong indicator that these substances are material to your business.

3. Stay informed on regulatory changes: Regulations evolve. Regularly checking updates from ECHA and other regulatory bodies ensures you remain compliant and proactive in managing chemical risks.

If you belong to one of the following categories:

Manufacturers and importers: Must identify and manage risks associated with the substances they produce or import, ensuring compliance with registration requirements and providing necessary safety information.

Downstream users: Companies using chemicals in their processes need to be aware of their obligations under REACH, including adhering to usage restrictions and substituting hazardous substances with safer alternatives when possible.​

Suppliers: Obligated to communicate information about hazardous substances down the supply chain, ensuring that customers are informed about safe handling and any restrictions.

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Sources

REACH Regulation - European Commission

Understanding REACH - ECHA

Authorisation process - ECHA

Candidate List of substances of very high concern for Authorisation - ECHA

Substances restricted under REACH - ECHA

Understanding REACH: EU Chemical Regulation Explained

Relevant DR under the CSRD:

ESRS E2: Disclosure Requirement E2-5 – Substances of concern and substances of very high concern

Microplastics are small plastic particles, smaller than 5 millimeters, that have quietly become one of the most pervasive pollutants in our environment. Whether deliberately added to products like cosmetics or unintentionally created through the breakdown of larger plastics, they are now everywhere: in the air we breathe, the water we drink, and even within our bodies. These tiny particles are creating big challenges, not just for ecosystems but for human health and the economy as well.

Let’s dive deeper into the world of microplastics to understand their origins, impacts, and what we can do to reduce their spread. We'll also explore how businesses are being held accountable through the Corporate Sustainability Reporting Directive (CSRD).

2. Substances Everywhere, Persistent Forever

Microplastics originate from two main sources: primary microplastics and secondary microplastics:

Microplastics are alarmingly persistent. Unlike organic materials, which decompose naturally, microplastics degrade very slowly, releasing increasingly smaller particles over decades or even centuries. Studies have shown that the majority of these particles accumulate in soils, roadside verges, and marine environments. However, they don’t remain there—they can travel through wind, water currents, and even food chains to reach new areas.

A systemic issue, microplastics are found in every stage of the plastic life cycle: production, use, disposal, and post-disposal. They represent a hidden consequence of the convenience plastics offer. For instance, packaging and tyre wear alone are responsible for a significant portion of microplastic pollution in the Netherlands.

3. Impacts on Health and the Environment

Microplastics are not just an environmental issue—they are a potential health crisis in the making. Research has found traces of microplastics in human lungs, blood, and even the placenta. Although the long-term health effects are not yet fully understood, research findings raise serious questions about the bioaccumulation of plastics in the human body and their potential to cause inflammation or interfere with biological processes. The potential impacts are shown in the figure below.

From an ethical perspective, the mere presence of synthetic particles in the natural world and human bodies is unacceptable. The precautionary principle, embraced by the Dutch government and aligned with EU strategies, demands immediate action to minimize exposure to microplastics and prevent unknown future problems.

Environmental impacts are equally dire. Microplastics disrupt ecosystems by affecting soil fertility, contaminating water sources, and entering the food chain. Marine animals, for example, often mistake microplastics for food, leading to ingestion that can block digestive systems and reduce survival rates. The environmental persistence of these particles also means that their effects are cumulative and will worsen over time without intervention.

4. Solutions to Microplastic Pollution

Addressing microplastics requires a multi-pronged strategy tailored to different industries.

1. Upstream measures

• Product redesign: Redesigning products to minimize plastic usage and improve durability reduces the generation of secondary microplastics.

• Use of bioplastics: Encouraging biodegradable and compostable materials, such as seaweed-based polymers in packaging and textiles, can lower microplastic release.

• Bans and restrictions: Implementing bans on single-use plastics and microbeads in products is a proven method, as seen in cosmetics​.

2. Downstream measures

• Improved waste management: Enhancing recycling infrastructure and implementing proper waste disposal methods can significantly reduce microplastic leakage.

• Wastewater treatment upgrades: Advanced filtration technologies, including nanofiltration and magnetic separation, can capture microplastics from industrial and domestic wastewater.

• Leaching prevention: Training staff and adopting best practices for handling and disposing of materials can prevent unintended microplastic releases.

3. Cross-industry collaboration

• Research and innovation: Investing in research to develop alternative materials, such as biodegradable coatings and eco-friendly textiles, is vital.

• Industry partnerships: Collaborations between companies, academia, and governments can accelerate innovation and policy implementation.

4. Regulatory and policy measures

• Setting Limits: Establishing maximum allowable microplastic emissions for different sources, such as textiles and tires, ensures accountability.

• Consumer awareness: Labels indicating the presence of microplastics in products can help consumers make informed choices.

Here is an overview from TNO with possible measures and their effectiveness:

5. Microplastics under ESRS E2

As the microplastics crisis intensifies, businesses are increasingly expected to take action. Under the CSRD, companies must comprehensively disclose their environmental impacts, including microplastic pollution. ESRS E2, the standard on pollution, specifically requires reporting on microplastics generated during operations or embedded in products, as well as efforts to mitigate their impact through policies, innovation, and supply chain measures.

Whether microplastics are material to your business depends on their significance to your operations, stakeholders, and environmental impact. For the following industries microplastics are often a material issue, as it can affect reputation, compliance costs, stakeholder expectations, and long-term financial performance:

1. Textiles: Synthetic fibers such as polyester, nylon, and acrylic shed microplastics during production, use, and washing.

2. Packaging: The packaging industry generates secondary microplastics as materials degrade over time. Flexible and rigid plastic packaging, especially from polyethylene, is a major source​.

3. Cosmetics: Microplastics, especially microbeads, have been common in personal care products. Despite increasing bans, thousands of metric tons of microplastics still enter aquatic ecosystems annually.

4. Paints: Often overlooked, the paint industry contributes significant amounts of microplastics through wear, tear, and disposal. Paints cause a considerable amount of microplastic leakage into waterways.

5. Automotive: Tyre wear particles are a primary source of microplastics, as abrasion during driving releases millions of particles onto roads, which are then carried into waterways.

The figure below can help you evaluate your company’s impact on microplastics.

6. Conclusion

Microplastics represent one of the most pressing environmental challenges of our time. While their effects on health and ecosystems are still being studied, the need for action is clear. Governments, industries, and individuals must work together to minimize the formation and spread of microplastics, leveraging innovative solutions and stringent regulations.

For businesses, the integration of microplastic disclosures into sustainability reporting under CSRD and ESRS E2 offers an opportunity to lead by example. Transparency, accountability, and proactive measures can help mitigate microplastic pollution.

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Sources

https://www.europarl.europa.eu/topics/en/article/20181116STO19217/microplastics-sources-effects-and-solutions

https://www.rivm.nl/en/news/main-sources-of-microplastics-in-environment-are-tyre-erosion-plastic-waste-and-industrial

https://www.tno.nl/en/newsroom/2022/11/sources-microplastics-the-netherlands/

https://publications.tno.nl/publication/34640142/ytwrjH/TNO-2022-microplastics-eng.pdf

https://www.researchgate.net/publication/364349390_Potential_human_health_risk_assessment_of_microplastic_exposure_current_scenario_and_future_perspectives

https://www.eufic.org/en/food-safety/article/microplastics-in-food-and-water-are-they-harmful-to-human-health

https://pswordpress-production.s3.amazonaws.com/2023/05/Microplastics-in-Industry-PreScouter-2023.pdf