ESRS E2: Substances of (Very High) Concern
ESRS E2: Substances of concern and substances of very high concern
1. Introduction
In our increasingly environmentally conscious world, businesses need to be transparent about the substances they handle, especially those that may pose risks to health and the environment. This article focuses on what the disclosure requirements for substances of concern and very high concern are.
How companies can effectively disclose this information will be covered in another article.
2. Substances of Concern and Substances of Very High Concern
Substances of concern are those that:
Meet criteria in Article 57 and are identified per Article 59(1) of Regulation (EC) No 1907/2006.
Are classified in Part 3 of Annex VI to Regulation (EC) No 1272/2008 in specific hazard classes/categories, including:
Carcinogenicity (categories 1 and 2)
Germ cell mutagenicity (categories 1 and 2)
Reproductive toxicity (categories 1 and 2)
Endocrine disruption (for human health and the environment)
Persistent, Mobile and Toxic (PMT) or Very Persistent, Very Mobile (vPvM)
Persistent, Bioaccumulative and Toxic (PBT) or Very Persistent, Very Bioaccumulative (vPvB)
Respiratory and skin sensitisation (category 1)
Chronic aquatic hazard (categories 1 to 4)
Hazardous to the ozone layer
Specific target organ toxicity (single and repeated exposure, categories 1 and 2)
Negatively affect the re-use and recycling of materials in products, as defined by relevant EU ecodesign requirements.
Substances of Very High Concern (SVHCs) meet the criteria in Article 57 of Regulation (EC) No 1907/2006 (REACH) and are identified per Article 59(1) of that Regulation
Companies must provide comprehensive information about the substances of concern and very high concern they deal with, including:
Production and use: Details on how these substances are produced, used, distributed, commercialized, and imported or exported.
Quantities and emissions: The total amounts generated or used in production, procured, and those that leave the facilities as emissions or in products.
Hazard classes: Breakdown of substances into main hazard classes to clarify their potential risks.
This disclosure helps to:
Assess health and environmental impact: Understand how the company's activities affect health and the environment through the use of these substances.
Identify risks and opportunities: Recognize material risks and opportunities, including potential regulatory changes that could impact the company's operations.
Information about substances of concern and very high concern must be reported separately.
Companies must disclose detailed information about the production, use, and emissions of substances of concern and substances of very high concern. This includes reporting total amounts and categorizing them by hazard class, with separate reporting for substances of very high concern.
3. Conclusion
By disclosing detailed information on substances of concern and very high concern, companies can better demonstrate their commitment to environmental and public health. This transparency not only helps in managing risks and adhering to regulations but also builds trust with stakeholders and contributes to a safer and more sustainable future.
In an upcoming article, we will explore how companies can report on these disclosures. Subscribe to stay updated.
Relevant Standards
ESRS E2
Disclosure Requirement E2-5 – Substances of concern and substances of very high concern
32. The undertaking shall disclose information on the production, use, distribution, commercialisation and import/export of substances of concern and substances of very high concern, on their own, in mixtures or in articles.
33. The objective of this Disclosure Requirement is to enable an understanding of the impact of the undertaking on health and the environment through substances of concern and through substances of very high concern on their own. It is also to enable an understanding of the undertaking’s material risks and opportunities, including exposure to those substances and risks arising from changes in regulations.
34. The disclosure required by paragraph 32 shall include the total amounts of substances of concern that are generated or used during the production or that are procured, and the total amounts of substances of concern that leave its facilities as emissions, as products, or as part of products or services split into main hazard classes of substances of concern.
35. The undertaking shall present separately the information for substances of very high concern.
Relevant Sources
REGULATION (EC) No 1907/2006 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL