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Substances of very high concern used during production or the provision of services or released into the environment, broken down by main hazard classes

Revised ESRS 2026

ESRS Standard

19. Users of substances, whether on their own or in mixtures, shall disclose:

  • (a) the total weight of SVHC that they used during production and during the delivery of services; and

  • (b) the total weight of SVHC that they directly released into the environment.

Application Requirements

AR 4. The requirements in paragraph 18 apply only to undertakings operating in the chemical sector, namely manufacturing chemical substances (e.g. NACE Rev.2.1 C20 and, if applicable, C21), formulating chemical mixtures (e.g. NACE Rev.2.1 C20.3, C20.4, C20.5) or operating in the wholesale of chemical substances (e.g. NACE Rev.2.1 G46.85). These requirements do not apply to undertakings whose main activity is the manufacture of non-chemical products. The requirements in paragraph 19 apply only to undertakings that are outside the scope of paragraph 18.

AR 5. Undertakings reporting under paragraphs 18 or 19 shall present SVHC grouped by

hazard class (as per CLP Regulation 1272/2008/EC). This implies that a single substance needs to be counted under all applicable hazard classes. However, in the total amounts of procured, manufactured, sold and released substances, double counting shall be avoided.

AR 6. The substances shall be presented in tonnes or kilogrammes, or other mass unit relevant to the quantity and types of pollutants being released.

AR 7. The information provided under this DR may refer to information the undertaking is already required to report under other legislation (e.g. Directive 2010/75/EU, Regulation (EC) No 166/2006, their subsequent amendments, etc.).

Definitions (ESRS)

Substances of concern are substances that

  • i. meet the criteria laid down in Article 57 of Regulation (EC) No 1907/2006 and are identified in accordance with Article 59(1) of that Regulation,

  • ii. are classified in Part 3 of Annex VI to Regulation (EC) No 1272/2008 in one of the following hazard classes or hazard categories:

    • carcinogenicity categories 1 and 2;

    • germ cell mutagenicity categories 1 and 2;

    • reproductive toxicity categories 1 and 2;

    • endocrine disruption for human health categories 1 and 2;

    • endocrine disruption for the environment categories 1 and 2;

    • persistent, mobile and toxic or very persistent, very mobile properties;

    • persistent, bioaccumulative and toxic or very persistent, very bioaccumulative properties;

    • respiratory sensitisation category 1;

    • skin sensitisation category 1;

    • hazard to the aquatic environment – categories chronic 1 to 4;

    • hazardous to the ozone layer;

    • specific target organ toxicity – repeated exposure categories 1 and 2;

    • specific target organ toxicity – single exposure categories 1 and 2; or

  • iii. have negative effects on the reuse and recycling of materials in the product in which they are present, within the meaning of the relevant product-specific Union ecodesign requirements.

Implementation in practice

  1. First, it is necessary to list all substances that are generated, used or procured during production, and/or that leave the undertaking's facilities in the form of emissions, products or as part of products or services
    ​e.g. substances contained in ingredients, semi-finished products or end products

  2. Next, check whether a substance has relevant negative properties.

    This applies, for example, if one of the hazard classes or hazard categories mentioned above is met. It also applies if a substance meets at least one of the H and P statements under the CLP Regulation.

    1. For purchased products, this information must be given in product data sheets and through warning notices on packaging (e.g. pictograms).

    2. Another source of information can be the harmonised list of substances of concern of the European Chemicals Agency ("ECHA"). It can be downloaded from the website as an Excel file. The column "Classification" - "Hazard Statement Code(s)" shows which hazard classes are affected.

    In addition, check product-specific ecodesign requirements for negative effects on reuse and recycling that arise from the use of the substance.

  3. If relevant negative properties exist, check whether ECHA lists the substance as a substance of very high concern in the "Candidate List of substances of very high concern for Authorisation".

In practice, AI tools can be used to support this. From a list of purchased or used products or substances, they can quickly assess whether these must be classed as substances of concern or substances of very high concern under the ESRS. A qualified person must then review the results.

Sources

The following legal texts and documents are particularly relevant for this datapoint:

REACH Regulation (Regulation (EC) No 1907/2006)

The REACH Regulation is an EU chemicals regulation that has been in force since 2007. REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals (Registration, Evaluation, Authorisation and Restriction of Chemicals).

CLP Regulation (Regulation (EC) No 1272/2008)

The CLP Regulation is another EU chemicals regulation that has been in force since 2009. CLP stands for Classification, Labelling and Packaging of substances and mixtures (Classification, Labelling and Packaging).

ECHA - European Chemicals Agency

The European Chemicals Agency (ECHA) works for the safe use of chemicals. It puts the chemicals legislation of the EU (e.g. the REACH and CLP Regulations) into practice.

Important reference works are

Article written by our experts

This article has been machine translated. In case of errors, please contact [email protected].

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