[CSRD] E2-1: Policies related to pollution
CSRD Simplified: Disclosure Requirement E2-1 – Policies related to pollution
1. Introduction
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.
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.