[CSRD] E3-3: Targets related to water
CSRD Simplified: Disclosure Requirement E3-3: Targets related to water
1. Introduction
If policies (E3-1) set the rules and actions (E3-2) describe the work, then targets define the destination. ESRS E3-3 asks undertakings to disclose the specific, measurable goals they have set regarding water consumption, withdrawals, discharges, and the protection of marine resources.
This disclosure provides the benchmark for accountability. Because water is often a localized resource, vague global ambitions are no longer sufficient. E3-3 requires you to translate high-level water stewardship commitments into trackable, location-specific numbers.
I will briefly explain the requirements for disclosing water-related targets.
More elaborate articles are, or will become available, which can be found on: Sustainability Simplified.
2. What are water targets?
Water targets are measurable, time-bound objectives designed to manage an undertaking’s material water impacts or risks.
According to the cross-cutting standards, targets regarding material impacts must be outcome-oriented. This means they must focus on the actual environmental result (e.g., cubic meters of water saved) rather than just an internal process (e.g., conduct three water audits).
Typical examples include:
Withdrawal: Reduce absolute freshwater withdrawal by 40% by 2030 against a 2022 baseline.
Discharge/Quality: Achieve 100% zero-liquid discharge at all manufacturing sites by 2028.
Efficiency: Increase the proportion of recycled/reused water in operations to 60% by 2026.
Marine: Ensure 100% of procured seafood is certified by the Marine Stewardship Council (MSC) by 2025.
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 E3-3 at a glance
E3-3 requires that “the undertaking shall disclose its water-related targets in accordance with the provisions of ESRS 2 GDR-T“.
However, the Application Requirements for E3-3 (AR 3) explicitly adds that undertakings shall, where relevant, express water-related targets with reference to specific geographic areas, such as areas with water stress. A global target to reduce water use by 10% means very little if all the savings happen in rainy regions while operations in drought-stricken areas continue business as usual.
If the undertaking has not set any measurable outcome-oriented targets for a material water topic, it shall disclose this fact and explain how it tracks progress instead.
4. How E3-3 links to the rest of ESRS E3
Targets provide the necessary context to evaluate your raw data:
E3-1 (Policy): Establishes the commitment to reduce freshwater reliance in vulnerable regions.
E3-2 (Action): Details the €2M investment in a closed-loop cooling system at a specific Spanish facility.
E3-3 (Target): Sets the goal. For example, reduce freshwater withdrawal at the Spanish facility by 50% by 2028.
E3-4 (Metric): Provides the actual cubic meters withdrawn this year. Without the target in E3-3, the metric in E3-4 is just an isolated number; the target tells users whether that number represents success or failure.
5. Bottom line
E3-3 demands precision and localized context. To report effectively:
Ditch the global average: Move away from aggregate global water intensity targets. Investors and stakeholders want to see targets specifically mapped to the river basins where water stress is highest.
Define the baseline clearly: A water reduction target is impossible to verify if you do not explicitly state your starting point (baseline year and volume).
Look to context-based targets: The gold standard for E3-3 is setting targets grounded in local ecological thresholds. A 10% reduction might be ambitious in one basin, but entirely inadequate to prevent water depletion in another. Ground your targets in the reality of the local watershed.