At a pivotal UNEP event in Sarajevo in February 2019, we presented insights from our internal report, “Initial Assessment of Industry Reporting Schemes Contribution to Chemicals-related MEAs (SAICM) and SDG Indicator 12.4.1”, aimed at advancing the alignment of business reporting with chemicals and waste-related Multilateral Environmental Agreements (MEAs). Our work preempted several key developments now partially formalized under the European Sustainability Reporting Standards (ESRS), particularly in the areas of chemicals, pollution, and waste.
During the Second Expert Group Meeting on Chemicals and Waste SDG Indicators, held from February 11-13, 2019, in Sarajevo, I had the privilege of sharing a comprehensive analysis of industry reporting mechanisms such as the Global Reporting Initiative (GRI), SASB, and Responsible Care. Our focus? Evaluating how these existing corporate frameworks could bridge the gap in reporting for SDG 12.4.1, which focuses on environmentally sound management of chemicals and wastes throughout their life cycle (see the 2019 post here).
Ahead of the Curve: Anticipating ESRS Developments
At the time, our analysis was pioneering, as it specifically looked beyond general sustainability disclosures to assess how industry reporting schemes could serve governmental bodies in tracking chemicals-related MEA commitments. Fast forward to today, the European Union has introduced the ESRS E2 under the 2023/2772 Commission Delegated Regulation, emphasizing reporting on pollution, substances of (very high) concern, and chemicals that pose significant risks to health and the environment. Back in 2019, we were already highlighting the importance of aligning voluntary corporate mechanisms with regulatory requirements to enhance transparency and accountability on these critical issues.
While the corporate world was predominantly focused on voluntary reporting and broader sustainability metrics, our presentation underscored the untapped potential for business to directly support international environmental goals through more targeted chemicals reporting, reusing already collected data. For example, we highlighted the Pollutant Release and Transfer Register (PRTR) as a key mechanism, which remains central today in informing MEAs, which again inform the SDGs (SDG indicator 12.4.1).
Integration of Business and Environmental Policy
Our report also delved into the critical intersection of business reporting and chemicals-related MEAs, such as the Basel, Rotterdam and Stockholm, as well as the Minamata, Montreal and Vienna Conventions and Protocols. We laid the groundwork for future policy integration by exploring how industry-led frameworks could systematically contribute to international tracking mechanisms, something that is now becoming increasingly mandatory with the EU’s CSRD (Corporate Sustainability Reporting Directive) and its focus on chemicals, pollution, and waste.
Back then, our key message was clear: voluntary reporting schemes like CDP, GRI, and SASB were important, but they needed to evolve. They had to become more robust and more aligned with regulatory frameworks if they were to truly contribute to governmental tracking and the achievement of global environmental objectives. Fast forward to today, and the ESRS’s detailed requirements on substances of (very high) concern and pollution impacts show how these ideas have become mainstream.
A Strategic Path Forward
Our participation in UNEP’s expert group meeting in 2019 was part of our broader commitment and efforts to not only participating in international dialogues but actively shaping them. By 2024, the introduction of the ESRS has validated the approach we advocated five years earlier. Reporting on chemicals and (e-)waste is no longer a niche concern but a central pillar of corporate sustainability and regulatory compliance.
Looking back, it’s clear that our work on business reporting for chemicals-related MEAs was ahead of its time, laying the foundations for today’s reporting frameworks that integrate environmental impact at a deeper level. We remain committed to pushing the boundaries of sustainability reporting, supporting business on their implementation, and the journey continues.