B4 – Pollution of air, water and soil

🗂️ VSME Basic Module – Environment metrics, page 9

If the undertaking is already required by law or other national regulations to report to competent authorities its emissions of pollutants, or if it voluntarily reports on them according to an Environmental Management System, it shall disclose the pollutants it emits to air, water and soil in its own operations, with the respective amount for each pollutant. If this information is already publicly available, the undertaking may alternatively refer to the document where it is reported, for example, by providing the relevant URL link or embedding a hyperlink.

🗂️ VSME Basic Module Guidance – Environmental Metrics, page 23-28

Guidance on which undertakings need to report on pollution and what pollutants undertakings need to report on.

Paragraph 32 establishes that the undertaking shall disclose the pollutants it emits to air, water and soil in its own operations if such information is already required to be reported by law to competent authorities or under an Environmental Management System. This means that the undertaking will first assess whether it already reports such information, either as a legal requirement or voluntarily. If it already reports information on pollutants emissions (or is legally required to do so), the undertaking will then provide further information on such emissions according to the requirements in paragraph 32. However, if the undertaking does not yet report such information (and is not legally required to do so), it is simply required to state this to be the case.
In general, this requirement is expected to apply to undertakings that are operators of an industrial installation or intensive livestock farm covered by the Industrial and Livestock Rearing Emissions Directive (IED 2.0), amending the Industrial Emissions Directive (IED). The IED 2.0 applies to some 75,000 installations in Europe, covering activities such as burning fuel in boilers with rated power of more than 50 MW, founding in metal foundries, processing of non-ferrous metals, production of lime, manufacturing of ceramic products by firing, production of plant protection products or biocides, rearing of any mix of pigs or poultry representing 380 livestock units or more, tanning of hides, slaughterhouses, etc. In these cases, the installation must already report to the competent authority the pollutants released to air, water and soil, and the data is publicly available at the Industrial Emissions Portal Regulation (IEPR), replacing the European Pollutant Release and Transfer Register (E-PRTR). Companies that operate in more than one facility do not have to report on their consolidated company-wide emissions under the EPRTR, as they report only at facility level. This Standard requires the reporting of the total amount of pollutants of all the facilities. Similarly, companies owning but not operating in a facility do not have to report to the E-PRTR but are expected to reflect their facility-owned emissions in their sustainability report.
Likewise, if an undertaking has been identified as having to monitor and report on the pollutants listed in the E-PRTR under an Environmental Management System such as, for example, an EcoManagement and Audit Scheme (EMAS) or ISO 14001 certification. These are in principle relevant aspects for the undertaking to include in its sustainability report.
If an undertaking has only one facility or operates in only one facility, and if its pollution data is already publicly available, the undertaking may refer to the document where such information is provided instead of reporting it once again. Likewise, if the undertaking publishes an organisationwide report such as, for example, an EMAS report that incorporates pollution data, it can include it in the sustainability report by reference.
To report information on pollutants in the sustainability report, the undertaking should indicate the type of pollutant material being reported alongside the amount emitted to air, water and soil in a suitable mass unit (e.g. t or kg).
Below can be found an example of how undertakings may present information on their emissions to air, water and soil divided by pollutant type.

Pollutant	Emissions (kg)	Medium of release (air, water, soil)
e.g. Cadmium and compounds	10	Water
Type of pollutant 2
Type of pollutant 3

As for the types of pollutants that need to be considered when reporting under paragraph 32, the undertaking may refer to the following main pollutants that are currently covered under EU law. Nevertheless, each undertaking shall consider the specific pollutants covered by the legislation in their respective jurisdictions.
Examples of key pollutants to air (Dir. 2024/299; Reg. 2024/1244; EC, 2024; EEA, 2022) are: sulphur oxides (Sox/SO2 – e.g. from energy generation and heating in manufacturing), nitrogen oxides (NOx/NO2 – e.g. from transport), non-methane volatile organic compounds (NMVOC – e.g. from agricultural activities), carbon monoxide (CO – e.g. from fossil fuel combustion), ammonia (NH3 – e.g. manure application and storage), particulate matter (PM10 – e.g. from combustion in manufacturing, transport, agricultural activities), heavy metals (Cd, Hg, Pb, As, Cr, Cu, Ni, Zn), POPs (total PAHs, HCB, PCBs, dioxins/furans), ozone-depleting substances or ‘ODS’ (chlorofluorocarbons ‘CFCs’, hydrochlorofluorocarbons ‘HCFCs’, halons), black carbon (BC – e.g. from energy consumption), etc.
According to the Guide for Business on air pollutants emissions adopted by the Alliance for Clean Air, the major sources of emissions of air pollutants in the private sector (that are also highly impactful for the entire value chain) include:

(a) electricity generation from fossil fuel or biomass combustion (which may be done externally, distributed through a national grid, then consumed along the value chain activities);

(b) direct stationary fossil fuel or biomass combustion within an undertaking’s activities or industrial processes, or the operation of stationary machinery or other activities that require fuel combustion;

(c) transport (freight, road, rail, shipping and aviation, offroad vehicles such as those used in agriculture or construction);

(d) industrial processes (all other emissions that do not stem from fuel combustion and that occur during industrial processes);

(e) agriculture (livestock and manure management, crop production such as crop residue burning, manure and fertiliser application);

(f) waste disposal (e.g. landfilling, incineration or open burning, or composting).

The Guide represents an example of a simple methodology for developing a company’s air pollutant emission inventory and calculating the emissions of respective air pollutants. This methodology is divided into the following steps; excluding the mapping of the value chain as under the VSME Standard the information required by this Disclosure Requirement is to be reported at the level of the reporting company: (1) identifying emission sources within the value chain, (2) identifying methodologies for quantifying emissions, (3) collecting activity data, (4) identifying emissions factors, and (5) quantifying emissions. The guide provides a mapping of sources of pollution to methodologies for calculating information on emissions stemming from the main air pollutants (table below).

Sources of pollution	Methodology for quantifying emissions (Section in the guidance)
Electricity	Section 4,1
Fuel combustion	Section 4,2
Transport	Section 4,3
Industrial processes	Section 4,4
Agriculture	Section 4,5
Waste	Section 4,6

Below is an example of a calculation method for air pollutant emissions using the method for manufacturing taken from the Guide above. In the example considered, Mp is the quantity of material M used in (or produced by) a company’s value chain produced using process p (tonnes, litres); EFk,p is the emission factor for pollutant k for process p (g unit production-1); Emk,p are emissions of the specific pollutant k for process p (g).

Emk,p = Mp * EFk,p

121. For instance, a medium-sized chocolate manufacturer producing 1.750 tonnes of chocolate in 2022 would apply the default emission factor of 2 to calculate its emissions of NMVOCs, which would result in the following calculation:

*1.750 tonnes of chocolate ** 2 (emission factor of NMVOCs) = 3.500 tonnes of emissions of NMVOCs.

Transport may be another significant source of air pollution within own operations and at value chain level. In this case, to estimate the emission of a particular pollutant from road transport, for example, the entity will need to use the following formula, where FCv,f is the fuel consumption of vehicle type v using fuel f (kg); EFk,v,f is the emission factor for pollutant k for vehicle type v and fuel f (g vehicle-km-1); Emk,v,f represents the emissions of the specific pollutant k for vehicle type v and fuel f (g).

Emk,v,f = FCv,f * EFk,v,f

For example, a light commercial vehicle (LCV) running on diesel that travelled a total of 2.800 km in 2022 produced the following amount of PM10 emissions (PM10 emission factor of 1,52 g/kg):

2.800 km * 1,52 = 4.256 grammes of emissions of PM10.

124. Fuel combustion is an additional critical source of air emissions. In this case an example of a formula may be the following, where FCn is the fuel n consumed within the source category (Gj); EFk is the emission factor for this pollutant k (g/Gj); and Emk are emissions of the specific pollutant k (g).

*Emk = FCn ** EFk;

For example, a company consuming 3.000.000 grammes of fuel in 2020 will have an EF of 0,67 for SO2, resulting in:

3.000.000 * 0,67 = 2.010.000 grammes of emissions of SO2. from fuel combustion in 2020.

126. Examples of key pollutants to water (Reg. 2024/1244; Dir. 2000/60/EC; Dir. 2006/118/EC; Dir. 91/676/EEC; Dir. 2010/75/EU; and amendment Dir. 2024/1785; EEA, 2024) are: nitrogen (N), phosphorus (P), heavy metals (Cd, Hg, Pb as well as As, Cr, Cu, Ni, Zn), POPs and pesticides, BTEX (benzene, toluene, ethylbenzene, xylenes) and other Volatile Organic Compounds (VOCs), substances unfavourably influencing the oxygen balance (measured using parameters such as BOD, COD, etc.), total organic carbon (TOC), etc.

127. Pesticides and nutrients (e.g. N and P) may be released through agricultural activities (EEA, 2023; UNEP, 2023) (e.g. manure or inorganic fertiliser application). Heavy metal concentrations may stem from mining and wastewater discharges. TOC is a generic indicator of water contamination with organic matter which indicates the presence of living material, for example in wastewater, but also surface and groundwater (usual concentration levels of less than 10 mgl^-1 and 2 mgl^-1 , respectively). COD widely indicates the presence of industrial effluents or sewage, with values that are typically lower than 20 mgl^-1 in unpolluted waters and industrial wastewaters reaching values of up to 60.000 mgl^-1 . BOD is normally used to determine pollution by organic matter in surface waters as well as for the efficiency of sewage treatment, and it usually features values around 2 mgl^-1 in unpolluted waters and 10 mgl^-1 and more in polluted waters. The release of VOCs can be the result of spills to water.

128. As for the methodology used to measure emissions to water, the EEA recommends a simple estimation technique similar to the one used for the aforementioned air pollutants. In the formula below, ARa is the activity rate for activity a (to be chosen based on the specific activity or process; e.g. see Mp in the air emissions calculation above); EFp,a is the emission factor for pollutant p for activity a; and Emissionsp,a are emissions of the specific pollutant p for activity a.

*Emissionsp,a = ARa ** EFp,a

Examples of key pollutants emitted to soil (Reg. 2024/1244; Dir. 86/278/EEC) are: N, P, heavy metals (e.g. land application of sewage sludge), BTEX and other VOCs, POPs and pesticides.
Overall, the private sector sources of soil pollution are mainly the products or by-products of industrial processes (e.g. production of chemicals, energy, textiles manufacturing), accidental spills of petrol-derived products, livestock and agricultural activities (e.g. irrigation with untreated wastewater, poultry rearing), production and treatment of wastewater, production and processing of metals and minerals, and transportation (FAO, 2021).
Several national manuals have been developed to support companies in the calculation of their emissions to air, water and soil, For example, in Australia and South Africa entities are presented with a few estimation options to choose from, depending on their possibilities: direct measurement (e.g. sampling, continuous monitoring system), mass balance, engineering calculations, emission factors (same formula as above for air and water emissions), etc. The general approach to calculating such emissions is to: 1) identify the emission sources within the facility (combustion, manufacturing, solvent evaporation, storage, fugitive); 2) make a stock of the information available; 3) identify in the list of estimation methods the most suitable one for the specific process under evaluation, the information available, and the measuring tools that can be acquired to get the data that is needed; 4) gather the data required for each method; and 5) calculate emissions. The manuals provide several formulas and examples for each emissions’ calculation method.
A list of emission factors for air pollutants can be found at the dedicated webpage of the EEA. Although emission factors are more commonly used for air pollution, certain ones for surface water discharge and land disposal for specific processes were made available by the WHO. Additional emission factors for POPs may be consulted here.
It is to be noted that the requirements under paragraph 32 are only applicable to SMEs operating in specific sectors. Undertakings that are involved in the provision of services (e.g. operating in coworking or shared facilities or remotely), for instance, are typically not included in the scope of this disclosure. By contrast undertakings carrying out production activities (e.g. chemicals) generally have impacts in terms of pollution and are, therefore, expected to report under this disclosure. The table below (adapted from the EMAS User Guide) provides examples of sectoral impacts, including for office services, for which pollution-related aspects may not be significant.

Activity	Environmental aspect	Environmental impact
Transport	- consumed machine oils, fuel consumption - vehicle emissions - tyre abrasion (fine dust)	- soil, water, air pollution - greenhouse effect, noise
Construction	- primary raw material (resource) consumption - air emissions, noise, vibrations, etc. From construction machinery - land consumption	- raw material availability - noise, soil, water, air pollution - destruction of ground cover - biodiversity loss
Office services	- consumption of materials, (e.g. paper, toner) - electricity consumption (leads to indirect CO2 emissions)	- generation of mixed municipal waste - greenhouse effect
Chemical industry	- primary raw material (resource) consumption - wastewater - emissions of volatile organic compounds - emissions of ozone-depleting substances	- raw material availability - water pollution - photochemical ozone - destruction of the ozone layer