VOC and Emission Reporting for Chemical Manufacturers

Volatile Organic Compounds (VOCs) and process emissions are central environmental topics for chemical manufacturers. Whether producing solvents, coatings, or pharmaceutical intermediates, small and medium-sized enterprises (SMEs) must increasingly demonstrate that their air emissions are measured, managed, and reduced.

This guide explains how to track and report VOC and air emissions in line with the Corporate Sustainability Reporting Directive (CSRD) and the Voluntary Sustainability Reporting Standard for SMEs (VSME), using the Basic Module B4 – Pollution as the primary framework. For related guidance, see what pollutants SMEs need to measure and reporting solvent use and VOC emissions for manufacturers.

1. Why VOC and Emission Reporting Matters

Environmental and regulatory context

• VOCs contribute to air pollution and ground-level ozone, regulated under EU Directive 2010/75/EU (Industrial Emissions Directive).
• Many clients, particularly large manufacturers and pharma groups, require emission data from suppliers to meet their CSRD (EU 2022/2464) obligations.
• Transparent VOC and emission reporting helps SMEs demonstrate environmental compliance, reduce waste, and improve operational efficiency.

🧭 Relevant CSRD and VSME links:

• CSRD: ESRS E2 – Pollution
• VSME: Basic Module B4 – Pollution (Air, Water, Soil)

2. What Counts as a VOC or Air Emission

Under EU law, VOCs are organic compounds that evaporate easily and react with air to form smog. For SMEs, typical sources include:

⚗️ Note: VOCs can include ethanol, acetone, toluene, ethyl acetate, and other volatile organic solvents.

3. Step-by-Step: How to Report VOC and Air Emissions

Step 1 – Identify Emission Sources

Map all processes where gases, vapours, or fumes are released:

• Mixing, drying, or coating operations
• Solvent storage and transfer points
• Heating systems and combustion units
• Ventilation or scrubber exhausts

Use process flow diagrams to pinpoint emission points. Mark which are measured and which are estimated.

Step 2 – Measure or Estimate VOC Quantities

You can report emissions based on:

1. Direct measurement: Continuous emission monitoring (CEM), periodic testing, or gas analysis.
2. Mass balance method:

   VOC emitted = Solvent input - Solvent recovered - VOC in product

3. Emission factors: Use standard factors (e.g., from EMEP/EEA Air Pollutant Inventory Guidebook) when measurement isn’t feasible.

Example (mass balance):

• Solvent used: 12,000 kg
• Solvent recovered: 3,000 kg
• VOC in product: 500 kg → VOC emitted = 8,500 kg

Step 3 – Convert to Standard Units

Convert emissions into tonnes per year (t/y) or kilograms per product output (kg/t) for comparability. Also disclose CO₂, NOₓ, and SOₓ if fuel combustion or heating is used.

Step 4 – Describe Control Measures

Under VSME B4, companies should explain how emissions are controlled or reduced. Examples:

• Activated carbon filters or scrubbers on exhausts
• Closed-loop solvent recovery systems
• Low-VOC or water-based formulations
• Regular maintenance of tanks, gaskets, and seals

Example disclosure: “In 2024, ChemCore Ltd installed a condenser on its solvent recovery line, reducing VOC emissions by 26% and cutting solvent purchases by 1.4 tonnes.”

Step 5 – Report Accidents, Leaks, or Non-Compliance

Even minor incidents should be disclosed in your sustainability report:

• Number of spills or leaks involving VOCs or gases
• Corrective actions taken (e.g., containment, repairs)
• Any regulatory notifications or fines

Example: “No reportable VOC leaks occurred in 2024. One small vent seal failure was repaired within 24 hours.”

Step 6 – Summarise Results in Your VSME Report

Include your reduction initiatives and targets, even if qualitative.

“Target: Reduce VOC emissions by 10% in 2025 through solvent recovery expansion.”

4. Example: VSME-Aligned Emission Report

Company: ChemCore Ltd Sector: Solvent-based chemical manufacturing Employees: 48 Reporting Year: 2024 Module: Basic (B1–B11)

Narrative:

“ChemCore Ltd improved VOC management through condenser installation and better sealing. Emissions fell by 15% year-on-year. No environmental incidents occurred.”

5. Linking VOC Reporting to CSRD and ESRS

Under ESRS E2 (Pollution), CSRD-reporting companies must disclose:

• Air emissions of pollutants (including VOCs, NOₓ, SOₓ, PM)
• Pollution prevention measures and control systems
• Value chain impacts (suppliers’ emission data)

By reporting VOC data under VSME B4, SMEs provide structured, verifiable input to clients’ CSRD disclosures.

This helps small manufacturers show they are responsible suppliers, capable of contributing credible emissions data.

6. Quick Wins for Chemical SMEs

7. How to Present VOC Data in Your Report

Include a short “Air Emissions Statement” section:

“In 2024, ChemCore emitted 8.5 tonnes of VOCs, a 15% reduction from 2023. The company recovered 25% of solvents used and upgraded extraction systems. Total GHG emissions were 42 tonnes CO₂e, with no reportable incidents.”

Attach:

• VOC measurement reports
• Calibration and maintenance logs
• Certificates of air emission compliance
• Correspondence with authorities (if applicable)

Frequently Asked Questions

How do I estimate VOC emissions if I don’t have direct measurements?

You can estimate VOC emissions using a mass balance approach: track solvent purchases and usage, subtract recovered or recycled amounts, and account for any products containing solvents. For example, if you purchase 10 tonnes of solvent and recover 2.5 tonnes, estimate 7.5 tonnes as potential VOC emissions. Document your methodology and assumptions clearly in your disclosure. For more accuracy, consider installing monitoring equipment or working with an environmental consultant.

Do I need to report all VOCs or just specific types?

Under VSME B4, you should report total VOC emissions. However, if you’re subject to specific regulatory limits (e.g., for benzene, toluene, or formaldehyde), you may need to report those separately. Check your environmental permit or national regulations for specific requirements. For CSRD reporting, total VOC emissions are typically sufficient unless you’re a large company with detailed ESRS E2 requirements.

See the complete chemical distributor guide →

Can I reduce my VOC emissions by switching to water-based solvents?

Yes, switching to water-based or low-VOC solvents can significantly reduce your VOC emissions and improve your environmental performance. This also often reduces compliance costs and health risks for workers. When reporting, show the reduction in VOC emissions year-over-year and describe your substitution strategy. This demonstrates proactive pollution prevention, which is valued by CSRD-compliant customers.

How accurate do my VOC measurements need to be for CSRD?

For VSME reporting, reasonable accuracy is expected, not perfection. Use actual measurement data where available (from monitoring equipment or stack tests), or use mass balance estimates based on solvent purchases and usage. Document your methodology and any assumptions. The key is consistency year-over-year so you can track improvements and demonstrate progress. Large companies under full CSRD may need more precise measurements.

Key Terms

• CSRD – Corporate Sustainability Reporting Directive (EU 2022/2464).
• VSME – Voluntary Sustainability Reporting Standard for SMEs (EFRAG 2024).
• B4 (Pollution) – Disclosure covering air, water, and soil pollution.
• VOC – Volatile Organic Compounds; organic chemicals that vaporise easily.
• NOₓ / SOₓ – Nitrogen and sulphur oxides; combustion-related air pollutants.
• Mass Balance – Calculation method for estimating solvent losses.
• ESRS E2 – European Sustainability Reporting Standard on Pollution.
• Emission Factor – Conversion rate from process activity to pollutant quantity.