EFRAG Clarifies Chemical Reporting in Draft Revised ESRS E2

EFRAG has published drafts of the revised and simplified European Sustainability Reporting Standards (ESRS), specifically targeting the environmental standard E2 (Pollution). The update introduces critical clarifications regarding the disclosure requirements for Substances of Concern (SoC) and Substances of Very High Concern (SVHC).

Reporting scope
The revised draft distinguishes reporting obligations based on the company's role in the supply chain:

• Chemical Industry (Manufacturers, Formulators, Importers of Substances): Under amended Section 17, these entities must disclose the total weight of both SoCs and SVHCs that are procured, manufactured, placed on the market, or released into the environment.
• Non-Chemical Industry (Downstream Users, Article Manufacturers): Under amended Sections 18 and 19, the reporting obligation is significantly narrower. For market participants outside the chemical sector, the requirement focuses on the provision of information about SVHCs only.
  •  Users of substances must disclose the total weight of SVHCs used or released.
  • Article manufacturers/importers need only disclose the names of SVHCs present in concentrations above 0.1% w/w (aligned with REACH Article 33).

This distinction means downstream companies are not required to report on the broader category of "Substances of Concern," which includes other hazardous chemicals (e.g., carcinogens, mutagens, or substances affecting recycling) unless they are specifically classified as SVHCs.

Next steps
On December 2, 2025, EFRAG published its technical advice on these amended drafts. The European Commission will use this advice as the basis for a Delegated Act to officially amend the ESRS, with adoption expected by mid-2026.
Further details on the draft standards and technical advice are available on the EFRAG website and in the Technical Advice Cover Letter.