What Pollutants Do SMEs Actually Have to Measure for CSRD?
One of the most confusing parts of the Corporate Sustainability Reporting Directive (CSRD) is the question of pollution. Many small and growing businesses (SMEs) ask: Do we have to start measuring chemicals, dust, or wastewater discharges — and if so, which ones?
The short answer: most SMEs do not need to measure pollutants at all. But for those in certain sectors, there are specific categories to know about. Learn if your business needs to report pollution.
Pollution in CSRD and ESRS
Within the European Sustainability Reporting Standards (ESRS), pollution is covered by ESRS E2: Pollution. Large companies must disclose emissions to air, water, and soil, as well as hazardous substances and microplastics.
For SMEs, the simplified Voluntary Sustainability Reporting Standard for SMEs (VSME) takes a lighter approach. Under Disclosure B4: Pollution of air, water and soil, an SME only reports pollutants if:
- It is already legally required to report them (for example, under a permit or the Industrial Emissions Directive (IED)), or
- It voluntarily tracks them through an Environmental Management System (e.g. ISO 14001, EMAS).
If neither applies, the SME can simply state that pollution reporting is “not applicable”.
CSRD vs VSME: Pollution Reporting
| Framework | Pollution Requirement | Applies to |
|---|---|---|
| CSRD / ESRS E2 | Detailed disclosure of emissions to air, water, soil; hazardous substances; microplastics. | Large companies and some listed firms. |
| VSME / B4 | Report pollutants only if already legally required or monitored under a system (e.g. ISO 14001). Otherwise state “not applicable.” | SMEs (voluntary framework, often requested by banks or clients). |
Which Pollutants Matter for SMEs?
If your SME operates in a sector with pollution obligations (manufacturing, farming, waste, energy), these are the types of pollutants that usually matter. Industry-specific guides: manufacturing, farms, and printers.
1. Air Pollutants
- Sulphur oxides (SO₂) — from fuel combustion.
- Nitrogen oxides (NOx) — from vehicles and boilers.
- Particulate matter (PM10, PM2.5) — dust and smoke from combustion.
- Volatile organic compounds (VOCs) — from paints, solvents, or food production.
- Ammonia (NH₃) — from livestock.
- Heavy metals — e.g. cadmium, lead, mercury.
2. Water Pollutants
- Nutrients: Nitrogen and phosphorus (from fertilisers or wastewater).
- Heavy metals (e.g. lead, copper, zinc).
- Organic matter indicators like BOD, COD, TOC (showing oxygen depletion).
- Pesticides or hydrocarbons (e.g. oil, solvents).
3. Soil Pollutants
- Fertilisers and pesticides.
- Heavy metals from waste or sludge.
- Petroleum hydrocarbons from spills.
What This Means in Practice
- Office-based SMEs (IT, retail, consulting): No pollutants to measure. Simply state “not applicable.”
- Light manufacturing SMEs (bakeries, printers, workshops): You may have to measure limited pollutants if permits require it (e.g. VOCs from solvents).
- Industrial SMEs (chemicals, textiles, livestock, waste, energy): Likely already measuring pollutants. For CSRD, reuse that same data.
Sample Disclosure Texts
If pollution reporting is not relevant:
“The company does not emit pollutants to air, water, or soil beyond normal office operations. Disclosure B4 (VSME) and ESRS E2 (Pollution) are not applicable.”
If pollutants are already measured under a permit:
“The company is required under national law to monitor pollutant emissions. In 2024, reported emissions included Nitrogen Oxides (NOx) of 1.2 tonnes and Particulate Matter (PM10) of 0.6 tonnes. This information is reported annually to the competent authority and is reproduced here for CSRD purposes.”
Frequently Asked Questions
Which pollutants do I need to measure for CSRD?
Most SMEs don’t need to measure any pollutants at all. Under VSME, you only report pollutants if you’re already legally required to do so (e.g., under an environmental permit or the Industrial Emissions Directive) or if you voluntarily track them through an environmental management system like ISO 14001. If neither applies, you can simply state that pollution reporting is “not applicable.” For those who do need to report, common pollutants include nitrogen oxides (NOx), sulphur oxides (SO₂), particulate matter, volatile organic compounds (VOCs), and heavy metals.
Check if your business needs pollution reporting →
Do office-based businesses need to track pollutants?
No, office-based businesses (IT, consulting, retail, professional services) do not need to track pollutants for CSRD or VSME reporting. Your environmental reporting focuses on energy consumption, greenhouse gas emissions (Scope 1 and 2), waste, and water use instead. Pollution in the CSRD sense refers to toxic discharges, heavy metals, and industrial fumes — which are not relevant to typical office operations.
What if I already track pollutants under ISO 14001?
If you already track pollutants under ISO 14001 or another environmental management system, you can reuse that same data for your CSRD or VSME report. You don’t need to measure anything additional or create separate tracking systems. Simply reference your existing ISO 14001 reporting in your pollution disclosure and include the relevant pollutant data you’re already collecting.
How accurate do my pollution measurements need to be?
If you’re already required to report pollutants under a permit or national law, use the same data and accuracy standards you’re already meeting for regulatory compliance. For VSME reporting, you’re essentially repurposing existing data rather than creating new measurement requirements. The key is transparency: clearly state your data sources and any limitations in your disclosure.
Bottom Line
- CSRD pollution reporting requirements are broad for large companies (ESRS E2).
- SMEs under VSME only report pollutants if already required or voluntarily monitored.
- For most service SMEs, pollution reporting is not applicable. For others, it simply means reusing data already collected for permits.
Key Terms
- Corporate Sustainability Reporting Directive (CSRD) — EU law requiring large companies — and eventually some medium-sized ones — to report on environmental and social impacts. SMEs may be asked for CSRD-style data by clients.
- European Sustainability Reporting Standards (ESRS) — Detailed rules under CSRD. ESRS E2 covers pollution.
- Voluntary Sustainability Reporting Standard for SMEs (VSME) — A simplified voluntary framework. Pollution reporting is limited to cases where it’s already applicable.
- Disclosure B4: Pollution — VSME requirement to disclose pollutants, only if legally required or voluntarily tracked.
- Industrial Emissions Directive (IED) — EU law regulating pollutant emissions from industrial and intensive livestock activities.