How Manufacturers Report Solvent Use and VOC Emissions under CSRD

Manufacturing businesses that use paints, coatings, adhesives, or cleaning agents often rely on organic solvents. These substances can release volatile organic compounds (VOCs) into the air — emissions that contribute to smog, ground-level ozone, and health risks.

Under the Corporate Sustainability Reporting Directive (CSRD) and the Voluntary Sustainability Reporting Standard for SMEs (VSME), solvent and VOC data form part of your environmental disclosure obligations. This guide explains how small and medium-sized manufacturers can measure, document, and report solvent use and VOC emissions in a CSRD-compliant way.

1. Why Solvent and VOC Reporting Matters

The CSRD and its supporting standards (the European Sustainability Reporting Standards – ESRS) require companies to disclose material environmental impacts, including pollution of air, water, and soil. For manufacturers, solvent emissions are often one of the main sources of Scope 1 (direct) emissions and local air pollution.

Under ESRS E2 – Pollution, companies must report:

• The main pollutants emitted, including VOCs, heavy metals, and particulates.
• Quantities released and related reduction efforts.
• Compliance with EU and national air quality legislation (such as Directive 2010/75/EU on Industrial Emissions).

Even if you are not legally required to hold an environmental permit, reporting solvent and VOC use demonstrates control over pollution sources and supports your climate and health risk disclosures.

2. Applicability for SMEs and Manufacturers

• Large undertakings within CSRD scope (over 250 employees, €40 m turnover or €20 m balance sheet) must report under ESRS.
• Non-listed SMEs can voluntarily report using the VSME Standard (EFRAG 2024).

In the VSME Basic Module, solvent and VOC data fall under:

• B4 – Pollution of air, water and soil: disclose pollutants emitted to air, including VOCs - see our guide on what pollutants SMEs need to measure.
• B3 – Energy and greenhouse gas emissions: if solvents contribute to energy-related processes.
• Optionally, under the Comprehensive Module (C3–C4), manufacturers may add VOC reduction targets and pollution prevention policies.

3. Step-by-Step: How to Measure Solvent Use and VOC Emissions

Step 1 – Identify Sources

List all products and processes involving solvents:

• Paints, varnishes, inks, coatings, adhesives, degreasers.
• Cleaning operations or spray booths.
• Printing or surface treatment lines.

Step 2 – Record Input Quantities

Use purchase invoices and inventory records to determine:

• Total quantity of solvent-based products used (in kg or litres).
• VOC content per product (from Safety Data Sheets, usually Section 9).

Step 3 – Estimate VOC Emissions

You can use one of two methods:

a. Mass balance method

VOC emitted = Solvent input – VOC in recovered waste – VOC retained in product.

This is suitable for SMEs and aligns with Annex VII of the Industrial Emissions Directive.

b. Emission factor method Use default factors published by the European Environment Agency (EEA) for typical processes, e.g.:

• Surface coating: 0.8 kg VOC/kg solvent used
• Cleaning/degreasing: 0.9 kg VOC/kg solvent used

Step 4 – Convert to Tonnes of VOC Emitted

Aggregate annual emissions in kg or tonnes per year, grouped by process type.

Step 5 – Link to Turnover

For transparency and comparability, calculate your VOC intensity:

VOC intensity = Total VOC emitted / Turnover (€)

This mirrors the GHG intensity indicator under VSME B3.

Step 6 – Record Control Measures

Document:

• Use of low-VOC or water-based products.
• Ventilation systems, solvent recovery units, or filters.
• Employee training on handling and disposal.

4. Example Disclosure Table (VSME Basic Module – B4)

Manufacturers can include a note such as:

“VOC emissions are estimated using the solvent mass balance method based on product purchase records and waste disposal documentation.”

5. Reporting in Your CSRD or VSME Sustainability Report

a. Under CSRD/ESRS E2 (for large companies)

Include solvent and VOC data within the Pollution section:

• Quantitative emissions by pollutant.
• Narrative on control measures, targets, and policy alignment.
• Any breaches of emission limits or fines.

b. Under VSME B4 (for voluntary SME reporters)

State:

• Main pollutants emitted and their quantities.
• Reference to any Environmental Management System (EMS) or national emission reports.
• Web link or annex if already reported elsewhere (e.g., permit returns).

6. Connecting Solvent and VOC Data to Other CSRD Areas

By linking solvent control with energy efficiency and waste reduction, manufacturers demonstrate integrated environmental management — a core principle of the CSRD.

7. Practical Tips for SME Manufacturers

1. Start simple: use purchase and waste data already available from invoices and suppliers.
2. Keep documentation: maintain Safety Data Sheets and permit records.
3. Automate where possible: spreadsheet templates or ERP export tools help track solvent use.
4. Engage suppliers: ask them for VOC content data to improve accuracy.
5. Disclose trends: even estimates are useful if methods are clear and consistent year-on-year.

8. Example VSME Disclosure Narrative

“The company operates two coating lines using solvent-based paints. Total solvent consumption for FY 2024 was 15 tonnes, of which 11.8 tonnes were emitted as VOCs (78 %).

Control actions include substitution of high-VOC thinners with water-based alternatives and installation of activated carbon filters in 2023, leading to an estimated 12 % reduction in VOC emissions.

No breaches of emission permit limits occurred during the reporting period.”

9. Preparing for Audit or Assurance

Under CSRD, sustainability data must be verifiable. Keep:

• Material Safety Data Sheets (MSDS) showing solvent composition.
• Annual solvent inventory and mass balance spreadsheets.
• Maintenance logs for filters and recovery systems.
• Evidence of employee training on solvent handling.

These form the audit trail for assurance providers.

Key Terms

• CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464), requiring large companies and listed SMEs to report sustainability impacts.
• VSME – Voluntary Sustainability Reporting Standard for SMEs (EFRAG 2024), a simplified CSRD-aligned standard for non-listed SMEs.
• ESRS – European Sustainability Reporting Standards, detailed disclosure requirements under CSRD.
• VOC – Volatile Organic Compound, an organic chemical that evaporates easily and contributes to air pollution.
• Scope 1 and 2 emissions – Direct and energy-related greenhouse gas emissions.
• Basic Module / Comprehensive Module – Two levels of VSME disclosure depth.
• SME – Small and Medium-sized Enterprise.
• Turnover – Total net sales of a company in a financial year.