Pollution to air, water and soil

(ESRS E2-4)

As part of its CSRD obligations, a multinational organization must report emissions of polluting substances to air, water and soil. These emissions are defined under European regulation (E-PRTR) and translated into reporting requirement ESRS E2-4 (2023 version). The scope also includes potential emissions of microplastics.

The company operates globally, with production sites in Europe, the United States, and Asia. Given this international footprint, understanding where emissions may occur — and whether reporting thresholds are exceeded — was a complex but essential task.

TOSCA supported the organisation throughout this process, implementing the regulatory requirements via a structured, practical approach, with attention to the location-specific circumstances.

The question
Which polluting substances could occur across the company’s production sites, and for which substances, if any, do reporting thresholds apply at one or more locations?

The approach
We started by designing a clear and pragmatic methodology. After an initial desk study, we applied a structured screening method to narrow down the long list of regulated substances to a focused shortlist relevant to the company’s activities.
To do this, we combined multiple sources:

• Insights from comparable industries and public annual reports
• Sector literature and regulatory guidance
• Internal environmental management system data
• Advanced analytical techniques have been applied to support the screening method

This allowed us to identify which site activities were most likely to contribute to emissions of specific substances. Substances that could not reasonably occur were filtered out. For the remaining substances, we assessed:

• The likelihood of occurrence within the organisation (on a 1–5 scale)
• The likelihood of exceeding reporting thresholds (also 1–5)

All assumptions were clearly documented, including generic assumptions (for example related to soil), which were later validated with local site representatives.

From insight to quantification
The next step was data collection and quantification at site level. For substances with a meaningful likelihood of occurrence, we conducted a targeted data request across relevant production locations, focusing both on the substances themselves and on the activities linked to potential emissions.

When primary data was not available, estimates were made to calculate the emissions per substance for the relevant locations based on carefully selected secondary information, in line with the methodologically approach. This ensured robust conclusions, even in the absence of perfect data. Based on this analysis, we determined which substances required reporting under ESRS E2-4, and which did not.

Key challenges overcome
Beyond answering the reporting question, the project delivered several broader insights:

• Overview of which activities are present at the locations and what emissions may be associated with them.
• Demonstrating why certain substances do not occur and substantiating it requires significant effort and careful documentation.
• A successful multi-site approach depends heavily on tailoring communication and data requests to different roles, capacities and local contexts — from project kick-off to data collection and feedback sessions. The chosen approach proved effective.
• Microplastics were not commonly reported in the sector for the 2023 reporting year. However, awareness is rapidly increasing, particularly around emissions from wear and tear of tires. This topic is gaining much more attention in 2024 disclosures.
• For substances below reporting thresholds, a clear message was communicated to sites: continue monitoring activities and substances, and proactively work towards reducing emissions over time.

Does this sound familiar?
Are you dealing with a CSRD topic or VSME item that requires insight across multiple locations? And could you use support in shaping the approach, organizing the process or executing the analysis?

Get in touch with Ulrike de Jong | | +31651072464 | ulrike@toscatribe.nl  — we’re happy to help translate complexity into clarity.