Measuring Pollution for CSRD, ESRS E2

Measuring Pollution for CSRD, ESRS E2

When it comes to CSRD, the biggest hurdle most companies face is gathering data.

Measuring Pollution for ESRS E2 is no different. Accurate data acquisition is crucial to be able to report on your organisation’s pollution levels, and monitor them going forward. But the complexities of value chains and demand on internal teams, makes this is no easy task. This is compounded by the lack of standardised frameworks.

The opportunity for companies to benefit from the insights provided by this data is sizable. Aside from being required for compliance with CSRD, understanding and reducing your non-GHG emissions lowers operational risk for your business and reduces risk of litigation & reputational damage, while also improving outcomes for soils, water, biodiversity.

So how do you go about measuring pollution?

The first step in measuring your Pollution is prioritisation

Not all sites are equal, and they should not be reported on as such. Locating and prioritising the environmental impact of assets across a business or supply chain is the first step to take. This is no easy task. Often it’s labour intensive and if you're starting with no data, it can be tricky to do. Plus because many supply chains are international, it is essential for prioritisation analyses to consider emissions from both EU and global industrial sites.

It is possible, however, to measure and monitor company pollution levels accurately, without needing labour intensive research. Existing Pollutant Release and Transfer Registers (PRTR) hold ample data that enables companies to prioritise their sites, streamlining the process. Yet, PRTRs don’t always follow the same format or measurements, meaning you need to standardise them first. This makes them tricky to use.

At natcap we have developed metrics, using PRTR data, to help you quickly understand industrial emissions and highlight priority sites in your business or supply chain.

To do this, we’ve integrated PRTR data resources from around the world into a single standardised format. As part of the database, pollutant names, pollutant risk status and units of emissions were standardised to ensure emissions from any location are reported inline with ESRS E2 guidance. With standardised data for over 130,000 sites we can rapidly report emissions across national and international supply chains and identify sites of high risk.

For high risk sites, we use the following criteria:

  • Site is emitting high volumes of pollutants. Through analysing the distribution of emissions between 2005 - 2020 natcap has created unique models able to rank individual site emissions.?
  • Site has reported emissions of pollutants on the EU REACH list of Substances of Very High Concern (SVHC) or banned by the Stockholm or Rotterdam Conventions.?
  • Site is not using direct measurement to report emissions.?
  • Site is emitting pollutants to land and water is areas of high or very high water stress.

Being able to quickly identify high risk sites, means you can focus your resource on gathering the data you need right now. Saving you time and money in the long run, whilst being able to incrementally add more sites to your dashboard over time.

Measure, then plan

Once you know the impact of emissions across your business value chain, you can start to implement action plans to improve this – another key part of the CSRD reporting requirements.

You may need to include what actions you’re taking to improve pollution, how much resource you’re putting into these actions, and explain your key steps and future plans to meet any goals you’ve set.

It’s a good time to start

With us well into the first year of CSRD reporting, it’s a good time to get started measuring your non-GHG pollution.

Aside from complying with EU legislation, knowledge of the environmental performance across your supply chain makes good business sense. It helps you see risk more clearly and shows opportunities to improve business performance, while highlighting where you can reduce your impact on nature and help mitigate the environmental risks affecting your business.?


At Natcap we help companies save money and time to measure, report, and act on nature.

Get in touch with Charles Shingles to find out how we can do this for you.

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