Substances of concern (CSRD ESRS E2)

This article has been translated with machine translation. 


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Reports > Customized > Substances of Concern (CSRD ESRS E2)

Please note that this is an add-on report. Please contact your account manager or [email protected] if you are interested in this report.


This article includes:


Why do I need to report Substances of concern?


The demand for reporting Substances of concern is derived from CSRD (Corporate Social Responsibility Directive) and its standard for reporting: ESRS (European sustainability reporting standards) in category E2: Pollution. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202302772

Two of the subtopics under E2: Pollution is SoC (Substances of concern) and SVCH (Substances of very high concern), and the regulation require you to disclose the quantity of these substances handled.


The regulation was set into force 1st of January 2024 for large companies and will gradually affect more businesses over the coming years.


What are Substances of concern?

Substances of concern is defined* on page 279 in the regulation (EU) 2023/2772:


En bild som visar text, skärmbild, Teckensnitt, nummer

Automatiskt genererad beskrivning 

In the report described in this article, there is an automation that looks for substances that meet criteria (i) or (ii). The remaining (iii) needs a more qualitative assessment from you.



How do I find Substances of concern in the chemicals we use?

We offer an advanced report where we list all substances that have either of the hazard classes/categories within the definition of SoC, and all substances that are listed in the REACH Candidate list.

In the report we display all necessary data: CAS/EC nr, classification, usage in kg (calculated from given product consumption x concentration in SDS), if it is SVHC etc.


The report is automatically sorted on Substance column. This is to make it easy to see the total usage of each individual substance, even when it is included in several different products on different departments. One challenge with this report, is that we calculate the substance in kg, based on the concentration level given in the products SDS section 3. Often, the stated concentration level is not exact, but rather given in a wide range, e.g. 20-50% or even 0-100% in some cases. We therefore have two columns showing both the minimum amount and the maximum possible amount of each substance. You will notice that you need to make some judgments of your own here, and for products you use in large quantities it may be valuable to contact your supplier to ask in what concentration approximately the substance occurs.



What is needed from me as an iChemistry user?

You need to do two things manually, for the report to work properly:


1. Add all chemical products you use in the iChemistry inventory and keep this updated over time. Hopefully, all your chemical products are already added to the iChemstry inventory so that step is probably done already.


2. Add annual consumption in kg for all products. This is needed for the quantity calculations to work. We recommend to delegate this work to the department responsibles, as this work can be quite comprehensive if you haven't added that information for any on your products before. You can limit your users to only being able to select the unit 'kg' in the inventory, if you want. Read how to do it here. 


Note that this report is helpful for identifying which substances you need to report, and gives a hint on how much of each substance you use, but you need to see it more as a basis for your reporting, rather than a finished report. CSRD ESRS E2 is more comprehensive and need qualitative assessment, and this dataset is an important part of it.


How does the report work in iChemistry?

The rule for which substances end up on the report is: 


  • Does the substance have a classification in section 3 of the SDS, according to definition* of Substance of concern?

AND/OR

  • Does the substance have a CAS/EC number on REACH Candidate list?


The most important columns are:

  • Substances - because this is what you need to report.
  • Substance consumption (high and low) - because this indicates how much of each substance is actually consumed, which you need to report.
  • Classification - because this is the reason why you need to report this substance.
  • Candidate list - because this is the reason why you need to report this substance.


Explanations of each column of the report


Product data columns:

  1. Prod. No. - The given product number, same as in iSafe. Can be either the i-number (unique iChemistry number) or the product number you added yourself to the product.
  2. Product name - The given product name, same as in iSafe. 
  3. Annual consumption of product - Estimated amount of the chemical product (i-number) that will be consumed during the current year in the selected department. Needs to be added manually for each product in the inventory module.
  4. Unit - Given unit of consumption for a product. We recommend using only the unit kg, for easiest possible handling when summarizing the substance usages. 


Substance data columns:

  1. Substance - Substance from section 3 of the SDS that either have a classification according to definition* of Substances of concern and/or are on the REACH Candidate list. Note that the report is sorted on this column, so that you see the same substances all together, to make it easier to summarize the total usage of that specific substance, even if it occurs in several products and departments.
  2. Concentration of substance - Collected from section 3 of the SDS, in the substance table. This is used for calculating the substance consumption. Please note that the concentration range is often not very precise in the SDS, and we therefore calculate minimum and maximum possible value for you in the columns Substance consumption.
  3. CAS No - CAS number collected from section 3 of the SDS, in the substance table.
  4. EC No - EC number collected from section 3 of the SDS, in the substance table.
  5. Hazard statements - Hazard statements for each substance, collected from section 3 of the SDS, in the substance table.
  6. Classification - Classification for each substance, collected from section 3 of the SDS, in the substance table. If classification is according to definition* of Substances of concern, the substance will end up on this report.
  7. Substance consumption (low) - Calculation of (lowest possible concentration of substance as given in SDS section 3)x(annual consumption of product/i-number)
  8. Substance consumption (high) - Calculation of (higest possible concentration of substance as given in SDS section 3)x(annual consumption of product/i-number)
  9. Unit - Unit for substance, always the same as the given unit on product level.
  10. Candidate list - If value is NO, the substance does not have a CAS/EC number on the REACH Candidate list, which means it is some classification from section three that causes the substance to appear on the report. If value is YES, the substance has a CAS/EC number that is on the REACH Candidate list.
  11. Location - In which department the product, which contains the substance of concern, is placed.

 


Substances of concern - "restriction list"

To assist you in identifying products that contain substances subject to reporting requirements, we have created a "restriction list" named "Substances of Concern (CSRD ESRS E2)." The sole purpose of this restriction list is to help you determine which products require a consumption value to be added, in order for the calculations to work in the SoC report. We recommend providing this value in kilograms (kg) for the products on this list.


It is perfectly normal that the number of rows in the report differs from the number of product on the "restriction list". This is because the report is based on substances, while the "restriction list" only list the products that include certain substances. The "restriction list" is simply a complement to the report and is not offered for purchase on its own.


While efforts have been made to ensure accuracy, this translation may not be entirely error-free. Please consider this when interpreting the information.

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