🧾 Declarable substances under CSRD and ESPR

The concept of declarable substances under CSRD and ESPR is becoming central for manufacturers, importers, and brands operating in or with the European Union.

On the one hand, the Corporate Sustainability Reporting Directive (CSRD), implemented through the European Sustainability Reporting Standards (ESRS), requires undertakings to disclose detailed information on pollution, substances of concern, and substances of very high concern.

On the other hand, the forthcoming Ecodesign for Sustainable Products Regulation (ESPR) will impose product‑level obligations, including information on substances of concern through the digital product passport.

Aligning these two frameworks is now a strategic compliance priority.

EU framework: CSRD, ESRS and ESPR in context

The CSRD expands the scope and depth of sustainability reporting in the European Union.

It replaces the Non‑Financial Reporting Directive and gradually applies to:

• Large public‑interest entities and other large undertakings
• Listed small and medium enterprises (with transitional options)
• Certain non‑EU groups with significant EU turnover

To ensure consistent reporting, the European Commission adopted the ESRS, including ESRS E2 – Pollution, which specifies how organisations must disclose pollution‑related impacts, risks, opportunities, metrics, and targets.

In parallel, the ESPR will set horizontal ecodesign requirements for almost all product groups placed on the EU market.

A core element is the management and disclosure of substances of concern in products, often via the digital product passport.

Together, CSRD/ESRS and ESPR create a combined regime where:

• CSRD/ESRS focuses on corporate‑level transparency,
• ESPR focuses on product‑level sustainability and information.

📜 What are “declarable substances” under CSRD and ESPR?

Under CSRD and ESRS E2 – Pollution

ESRS E2 requires undertakings to report on:

• Pollution of air, water and soil, excluding greenhouse gases covered by ESRS E1
• Substances of concern, such as chemicals classified for serious health or environmental hazards or affecting reuse and recycling
• Substances of very high concern, typically those listed under EU chemicals legislation (for example, on candidate lists for authorisation)
• Microplastics, both generated and used in processes or contained in products

For CSRD purposes, these are “declarable” when they are material impacts, risks or opportunities under the double materiality assessment, and when ESRS E2 requires quantitative or qualitative disclosure (for example, amounts generated, used, or leaving facilities in products or emissions).

Under ESPR – Product requirements

ESPR will require manufacturers and other economic operators to manage and disclose information on substances of concern in products, particularly those that:

• Hinder reuse, repair, recycling or safe waste management
• Pose significant health or environmental hazards
• Trigger specific information obligations in the digital product passport

In practice, ESPR will create product‑level declarable substance lists, closely connected to REACH, CLP and other chemicals legislation.

These data will need to be available along the value chain and accessible to authorities and sometimes to users.

⚙️ CSRD and ESRS E2: how pollution and substances must be reported

Under ESRS E2, undertakings subject to the CSRD must:

• Identify pollution‑related impacts, risks and opportunities (IROs) across own operations and relevant parts of the value chain.
• Assess their materiality using double materiality (impact on people and environment, and financial effects on the undertaking).
• Disclose information where pollution‑related IROs are material.

Key disclosure areas include:

• Pollutants and microplastics
• Quantities of specified pollutants released to air, water and soil from own operations.
• Amounts of microplastics generated, used, and leaving facilities as emissions or in products and services.

• Substances of concern and substances of very high concern
• Total amounts generated, used or procured.
• How much leaves facilities as emissions, as products, or as part of products or services.
• Breakdowns by hazard class, sector or geography where relevant.

• Policies, actions, metrics and targets
• Policies to prevent, control, or remediate pollution.
• Key actions and allocated resources (operating expenditure and capital expenditure).
• Metrics to track pollution performance and progress.
• Targets to reduce specific pollutants or phase‑out substances of concern.

• Anticipated financial effects
• Qualitative and, where feasible, quantitative disclosure of the expected financial effects of pollution‑related risks and opportunities over the short, medium and long term.

This information must comply with general ESRS principles on quality (relevance, faithful representation, comparability, verifiability, understandability) and reflect the organisation’s due diligence and value‑chain assessment.

🧾 Declarable substances under CSRD and ESPR: convergence points

A growing number of substances will be “declarable” under both CSRD/ESRS and ESPR.

Key convergence elements include:

• Same chemical universe
• Many substances of concern and substances of very high concern under ESRS E2 correspond to chemicals regulated under REACH, CLP and other EU rules that ESPR will reference.

• Shared data needs
• CSRD requires corporate and value‑chain quantities (for example, total volumes generated, used, emitted).
• ESPR requires product‑level composition and presence of substances of concern to feed the digital product passport and to support design decisions.

• Value‑chain transparency
• ESRS recognises that not all value‑chain data may be directly available initially and allows the use of sector averages or proxies under defined conditions.
• ESPR, by contrast, will push for granular, product‑level declarations over time, making value‑chain data capture more precise and more systematic.

For compliance teams, this means that one coherent substance information architecture should serve:

• CSRD/ESRS reporting (corporate transparency), and
• ESPR ecodesign and product passport obligations (product compliance).

✅ Practical implications for manufacturers and supply chains

For manufacturers, importers and brand owners, the rise of declarable substances under CSRD and ESPR translates into several practical requirements:

• Inventory of substances
• Establish a robust inventory of substances of concern and substances of very high concern across own operations and key suppliers.
• Map where these substances enter, are transformed, emitted, and where they remain in products.

• Materiality and risk analysis
• Perform a double materiality assessment to determine which pollution‑related topics are reportable under CSRD.
• Identify products and applications likely to trigger ESPR substance obligations, including products for which recyclability or circularity is critical.

• Data collection strategy
• Define when to rely on direct supplier data, when to use industry databases or standardised tools, and when proxies are acceptable under ESRS transitional provisions.
• Anticipate that ESPR will gradually reduce the tolerance for proxies and estimations at product level.

• Alignment with financial reporting
• Under ESRS, significant pollution‑related provisions, remediation costs or investments must be aligned and reconcilable with the financial statements.
• ESPR‑driven design changes and phase‑out programmes will often have clear cost and investment implications.

🤝 Strategic benefits of aligning CSRD and ESPR substance reporting

Beyond regulatory risk mitigation, a structured approach to declarable substances under CSRD and ESPR offers several advantages:

• More resilient and future‑proof product portfolios
• Better anticipation of regulatory bans, restrictions and market expectations
• Stronger credibility with investors, customers and authorities
• More efficient preparation for audits and assurance of sustainability information

Compliance platforms such as ComplyMarket can support undertakings in this transition by helping to map regulatory obligations, structure ESRS datapoints, and centralise substance and product data so that the same high‑quality datasets can be reused for CSRD disclosures and for ESPR‑related product documentation and digital product passports.

By building one coherent framework for identifying, managing and disclosing substances of concern, supported by tools like ComplyMarket, undertakings can meet the combined demands of CSRD, ESRS E2 and ESPR, while supporting safer, more circular and more sustainable products in the European market.