ESRS E2 to E5: pollution, water, biodiversity and resources

What do ESRS E2 to E5 cover?

They complete the environmental pillar of the ESRS alongside ESRS E1 on climate change. A company reports under each standard only if its double materiality assessment finds the topic material, and then reports its policies, actions, targets and metrics for the material matters, applying the general disclosure requirements in ESRS 2. See ESRS E1 and double materiality.

What does each standard require?

• ESRS E2 Pollution: emissions of pollutants to air, water and soil; primary microplastics produced or used and released; and substances of concern and of very high concern produced, used or sold.
• ESRS E3 Water: water withdrawal, consumption and discharge, with figures for areas at water risk, including areas of high water stress.
• ESRS E4 Biodiversity and ecosystems: impacts and dependencies on nature, sites in or near biodiversity-sensitive areas, metrics for material sub-topics such as land-use change, and a biodiversity transition plan if the company has one and has published it.
• ESRS E5 Resource use and circular economy: resource inflows, including key materials and the share recycled or renewable; outflows, including the durability, repairability and recycled content of products; and waste by type and treatment.

What changed in the revised ESRS E2 to E5?

For E2, pollutant emissions are no longer tied to the EU's E-PRTR register or limited to own operations, microplastics requirements are clarified, and substances of concern reporting is limited to chemical manufacturers and importers, with a reference to REACH thresholds. E3 now focuses on water, with water withdrawal moved from optional to required, and marine matters are split between the environmental standards according to their nature. E4's disclosures on biodiversity-sensitive sites are consolidated in one requirement and its metrics simplified to those for material sub-topics. E5 introduces key materials, with a reference to the Critical Raw Materials Act, streamlines waste indicators and adds the share of waste whose final destination is unknown. See the revised ESRS.

ESRS E2 to E5 in practice: a packaging manufacturer

A manufacturer of plastic and paper packaging with eight plants finds all four topics material.

For E3, it withdrew 1.8 million cubic metres of water, 0.7 million of it, 39%, at two plants in areas of high water stress, and consumed 0.4 million. For E5, 12,000 of its 50,000 tonnes of resin were recycled, 24%; of 6,000 tonnes of waste, 4,500 were recycled, 600 incinerated and 900 landfilled. For E4, it reports one plant next to a protected area and the actions agreed with the site's conservation authority. For E2, it reports emissions of nitrogen oxides and volatile organic compounds from printing lines. It uses the phase-in to omit some E4 information in its first year. See impact materiality and water and waste metrics.

Which phase-ins apply?

Under the revised ESRS, wave one companies may omit E4 information for financial year 2026, and other companies for their first two years. Quantitative information on substances of concern may be omitted until financial year 2029 by wave one companies and for the first three years by others, and information on substances of very high concern for article users until 2027 by wave one companies and for the first year by others. Companies using a phase-in still give minimal transparency about the topic. See CSRD wave 1 relief.

How do E2 to E5 connect with other frameworks?

They mirror four of the EU Taxonomy's environmental objectives: pollution prevention, water, biodiversity and the circular economy. GRI covers the same ground through GRI 101 Biodiversity, GRI 303 Water and GRI 306 Waste, among others. For investors, the ISSB plans an IFRS Practice Statement on nature-related disclosures, building on the TNFD's work. See nature and biodiversity at the ISSB and EU Taxonomy reporting.

This guide is general information. It is not tax or legal advice for your situation.