Pollution (E2)

Pollution of water

Our material impacts, risks and opportunities in connection with water pollution (E2 SBM-3)

As part of the materiality analysis, we identified impacts, risks and opportunities related to water pollution. Our disclosures focus on the following material impacts:

ESRS E2 SBM-3 – Our material impacts, risks and opportunities in connection with water pollution

Pollution of water

Identifier

 

E2-NI-01

Material impacts, risks and opportunities

 

Actual/potential negative impact

Time horizon

 

Medium-term

Value chain step

 

Own operations; downstream

Description

 

Manufacturing and/or handling of chemical and/or pharmaceutical substances can have a negative impact on water quality caused by the controlled release of these substances via wastewater or unintentionally by leakages, spills or other comparable events.

Our policies in connection with water pollution (E2-1)

ESRS E2-1 – Water EHS Policy

EHS Policy

Connection to material impacts, risks and/or opportunities

 

Identifier E2-NI-01

Material sustainability matter

 

Water pollution

Key contents

 

The basis of our operational environmental management is the Group-wide EHS policy (Environment, Health and Safety). The policy formulates our responsibility to minimize the negative environmental impact associated with our business activities and to protect the health and safety of our employees, customers, and contractors. It specifies our commitment to work in such a way that we reduce or eliminate risks to the environment, human health and safety. The policy is continually monitored and part of our EHS management system. We are certified according to ISO 14001. The compliance with the requirements of ISO 14001 is reviewed annually as part of external surveillance and/or recertification audits. We have established processes and procedures in order to comply with regulations. We provide mandatory EHS training courses for our employees.

Scope of application

 

The policy applies Group-wide to our own operations and to the upstream and downstream value chain.

Accountability

 

Chair of the Executive Board and CEO

Third-party standards/initiatives

 

The policy is based on the principles of the UN Global Compact and the Responsible Care® Global Charter. It is aligned with the ISO 14001 and 45001 standards.

Consideration of stakeholder interests

 

When setting the policy, we considered the interests of our employees and customers.

Availability

 

The policy is available internally on the intranet and publicly on our website.
ESRS E2-1 – Sustainable Water Management- Wastewater

Sustainable Water Management – Wastewater

Connection to material impacts, risks and/or opportunities

 

Identifier E2-NI-01

Material sustainability matter

 

Water pollution

Key contents

 

The policy concerns water quality and aims to minimize the negative impact of our facilities on the environment. This policy defines the responsibilities and sets global guidelines for the risk-based approach for managing wastewater from our operations. Monitoring is secured via our EHS audit system, see policy “Corporate EHS Audit Process”. Our operating sites establish programs to ensure compliance with local requirements and to prevent, detect and avoid unintended release of water-hazardous substances or monitor the routine discharge of all relevant water-hazardous substances. The sampling and analytical program shall be elaborated based on local regulatory requirements or local circumstances.

Scope of application

 

The policy applies Group-wide to our production sites and our research and development (R&D) facilities. Our internal stakeholders are the site manager/director or qualified, responsible employees to whom tasks are delegated, as well as EHS-managers and their staff and the employees at the sites. Our external stakeholder are all users of the receiving water as well as operators of downstream water treatment plants.

Accountability

 

Site managers/directors or qualified employees responsible for wastewater topics.

Third-party standards/initiatives

 

The policy considers the UN Sustainable Development Goal 6: "Clean Water and Sanitation" as well as the Common Antibiotics Manufacturing Framework of the AMR Industry Alliance. We are also a member of the AMR industry alliance.

Consideration of stakeholder interests

 

When setting the policy, we considered the interests of internal stakeholders.

Availability

 

The policy is available internally on the intranet.
ESRS E2-1 – Spillage Control of Hazardous Substances

Spillage Control of Hazardous Substances

Connection to material impacts, risks and/or opportunities

 

Identifier E2-NI-01

Material sustainability matter

 

Water pollution

Key contents

 

The policy sets a global framework for the storage, transfer, and handling of hazardous substances. It gives guidance on how facilities and technical equipment shall be designed, built, operated, and maintained in such a way that potentially polluting substances do not enter the environment. Monitoring is secured via our EHS audit system – see “Corporate EHS Audit Process” policy.

Scope of application

 

The policy applies to all legal entities of the Group that unload, store, transfer and handle hazardous substances.

Accountability

 

Site manager/director

Third-party standards/initiatives

 

None

Consideration of stakeholder interests

 

When setting the policy, we considered the interests of internal stakeholders.

Availability

 

The policy is available internally on the intranet.
ESRS E2-1 – Corporate EHS Audit Process

Corporate EHS Audit Process

Connection to material impacts, risks and/or opportunities

 

Identifier E2-NI-01

Material sustainability matter

 

Water pollution

Key contents

 

The policy describes how to identify and assess environmental, health and safety risks at our sites and to define suitable corrective actions. The policy also serves the purpose of checking compliance with EHS and regulatory requirements as well as monitoring the appropriate implementation of the EHS management system and its focus on continuous improvement. Regarding water pollution, we want to counter the negative effects that can arise on water quality if in the production and/or handling of chemical and/or pharmaceutical substances these substances are intentionally released in a controlled manner via wastewater or unintentionally disposed of improperly through leaks, spills or other similar incidents. Following the policy’s requirements, we define an audit plan for the production, R&D and warehouse sites at intervals of three to five years. Previous audit results also determine the frequency of audits per site. We pay particular attention to the quantity and properties of the substances handled as well as the environmental aspects and effects. An audit report including identified gaps and mitigating actions is addressed to the site manager, who is primarily responsible for closing the gaps within an agreed time frame.

Scope of application

 

The policy applies to the Corporate Environment Health and Safety (SQ-E) function and all sites (incl. subsidiaries and affiliates controlled by the Group).

Accountability

 

Head of Corporate EHS

Third-party standards/initiatives

 

None

Consideration of stakeholder interests

 

When setting the policy, we considered the interests of internal stakeholders.

Availability

 

The policy is available internally on the intranet.

The policies related to pollution of water are regularly monitored and updated. 

The EHS Policy (Environment, Health and Safety), and the policies Sustainable Water Management - Wastewater and Spillage Control of Hazardous Substances are geared toward mitigating impacts of our facilities on the environment and health related to pollution of water including prevention and control. The Corporate EHS Audit Process policy controls the implementation of the described policies. 

As part of our EHS Policy we define objectives, programs and performance indicators related to the environment, health and safety at both Group and site level. In this way, we aim to continuously monitor and reduce injuries and accidents, energy and resource consumption and reduce waste generation. Our aim is to go beyond compliance with our EHS regulations by constantly reviewing their potential for improvement to further reduce our impacts. To prepare for emergencies, we take actions to minimize risk and prevent damage. This should enable us to prevent negative impacts on the environment, human health and safety and ensure the continuity of our business operations.

In accordance with our Spillage Control of Hazardous Substances policy, the good condition and integrity of storage facilities, tanks, containment facilities and the necessary equipment must be maintained and checked regularly.

As part of sustainable water management which includes incidents and emergency preparedness, our sites must have retention basins with an appropriate volume for used extinguishing water and/or for wastewater that cannot be treated in routine operations. In the event of a fire, a retention basin is designed to control and limit the impact on the environment by isolating potentially contaminated extinguishing water. 

Our actions and resources related to water pollution (E2-2)

As part of our activities initiated in the 2020 financial, we implemented the following actions for our own production in our Healthcare, Life Science and Electronics business sectors. The actions aim to reduce water pollution resulting from routine production: by 2030, every water-polluting substance will be emitted at levels below its predicted no-effect concentration (PNEC, water reference value):

  • We identified the wastewater relevance for each substance handled in production in the Healthcare and Life Science business sectors.
  • In Healthcare, we completed risk assessments based on calculations for wastewater-relevant substances and continue to monitor the level of active pharmaceutical ingredients in our wastewater. For substances with concentrations above the water reference level we conduct laboratory and pilot tests to identify suitable mitigation measures, e.g., modernization measures in our wastewater treatment facilities.

For 2025, we are planning the following actions for the Life Science and Healthcare business sectors:

  • We will continue to refine our risk assessments and our determination of water reference levels (PNEC).
  • For our Healthcare business sector, we will assess analytical monitoring data to verify the outcome of risk assessments and the effectiveness of mitigation actions.

These assessments enable us to decide on necessary steps to reduce potentially harmful residues in our wastewater to levels below the established no-effect threshold, i.e. by adapting our wastewater treatment facilities. 

Our water management efforts focus on our manufacturing sites as production generally poses a higher risk to aquatic ecosystems. A total of 41 sites with wastewater from production are affected in our Life Science business sector, located in China, Germany, France, UK, India, Ireland, Israel, Switzerland and the USA. For Healthcare, this affects 14 sites with wastewater from production globally, which are located in Brazil, China, Germany, France, Indonesia, Italy, Mexico, Switzerland and Spain. For our Electronics business sector, this affects 27 sites with wastewater from production located in China, Germany, France, India, Japan, South Korea, Taiwan and the USA. Our time horizon to close the actions is set for 2030. No remediation actions have been taken. 

At the end of 2024, 41 sites of our business sector Life Science, 14 of Healthcare and 27 of Electronics were involved in the activity. 12 sites of our Life Science, three of our Healthcare and one of our Electronics business sector have ascertained that the concentrations of all water-hazardous substances in their wastewater are below the no-effect threshold. 

In 2024, no significant capital expenditures (CapEx) or operating expenditures (OpEx) were allocated in relation to the actions of water pollution. For 2025, we also do not intend to allocate any significant OpEx or CapEx. 

Our actions with regard to our wastewater do not extend to the downstream value chain. 

Our targets related to water pollution (E2-3)

Wastewater from our production sites is treated and discharged into the receiving water bodies according to the respective license. By 2030, we aim to reduce potentially harmful residues in our wastewater to below the no-effect threshold. We initiated our activities in 2020 and have been measuring the progress every six months since then. To achieve this ambition, we have defined a series of project steps that we monitor centrally for each site in scope. These steps include the identification of relevant water-hazardous substances, assessment of the risk in the specific context, mitigation actions if necessary and monitoring to verify the efficiency of the mitigation actions. Beyond this ambition, we have not set any targets related to water pollution.

Our metrics related to water pollution (E2-4)

ESRS E2-4 – Our metrics related to water pollution

 

 

2024

Pollution of water – pollutants (in kg)

 

Estimated median

 

Estimated minimum

 

Estimated maximum

Total nitrogen

 

55,992

 

55,992

 

55,992

Total phosphorus

 

–

 

–

 

–

Arsenic and compounds (as As)

 

–

 

–

 

–

Cadmium and compounds (as Cd)

 

–

 

–

 

–

Chromium and compounds (as Cr)

 

–

 

–

 

–

Copper and compounds (as Cu)

 

–

 

–

 

–

Mercury and compounds (as Hg)

 

–

 

–

 

–

Nickel and compounds (as Ni)

 

59

 

59

 

59

Lead and compounds (as Pb)

 

–

 

–

 

–

Zinc and compounds (as Zn)

 

–

 

–

 

–

Alachlor

 

–

 

–

 

–

Aldrin

 

–

 

–

 

–

Atrazine

 

–

 

–

 

–

Chlordane

 

–

 

–

 

–

Chlordecone

 

–

 

–

 

–

Chlorfenvinphos

 

–

 

–

 

–

Chloro-alkanes, C10-C13

 

–

 

–

 

–

Chlorpyrifos

 

–

 

–

 

–

DDT

 

–

 

–

 

–

1,2-dichloroethane (EDC)

 

–

 

–

 

–

Dichloromethane (DCM)

 

–

 

–

 

–

Dieldrin

 

–

 

–

 

–

Diuron

 

–

 

–

 

–

Endosulphan

 

–

 

–

 

–

Endrin

 

–

 

–

 

–

Halogenated organic compounds (as AOX)

 

–

 

–

 

–

Heptachlor

 

–

 

–

 

–

Hexachlorobenzene (HCB)

 

–

 

–

 

–

Hexachlorobutadiene (HCBD)

 

–

 

–

 

–

1,2,3,4,5,6-hexachlorocyclohexane (HCH)

 

2

 

2

 

2

Lindane

 

–

 

–

 

–

Mirex

 

–

 

–

 

–

PCDD + PCDF (dioxins + furans) (as Teq)

 

–

 

–

 

–

Pentachlorobenzene

 

–

 

–

 

–

Pentachlorophenol (PCP)

 

–

 

–

 

–

Polychlorinated biphenyls (PCBs)

 

–

 

–

 

–

Simazine

 

–

 

–

 

–

Tetrachloroethylene (PER)

 

–

 

–

 

–

Tetrachloromethane (TCM)

 

–

 

–

 

–

Trichlorobenzenes (TCBs) (all isomers)

 

–

 

–

 

–

Trichloroethylene

 

–

 

–

 

–

Trichloromethane

 

–

 

–

 

–

Toxaphene

 

–

 

–

 

–

Vinyl chloride

 

–

 

–

 

–

Anthracene

 

–

 

–

 

–

Benzene

 

–

 

–

 

–

Brominated diphenylethers (PBDE)

 

–

 

–

 

–

Nonylphenol and Nonylphenol ethoxylates (NP/NPEs)

 

1

 

1

 

1

Ethyl benzene

 

–

 

–

 

–

Ethylene oxide

 

–

 

–

 

–

Isoproturon

 

–

 

–

 

–

Naphthalene

 

–

 

–

 

–

Organotin compounds (as total Sn)

 

–

 

–

 

–

Di-(2-ethyl hexyl) phthalate (DEHP)

 

–

 

–

 

–

Phenols (as total C)

 

–

 

–

 

–

Polycyclic aromatic hydrocarbons (PAHs)

 

–

 

–

 

–

Toluene

 

–

 

–

 

–

Tributyltin and compounds

 

–

 

–

 

–

Triphenyltin and compounds

 

–

 

–

 

–

Total organic carbon (TOC) (as total C or COD/3)

 

–

 

–

 

–

Trifluralin

 

–

 

–

 

–

Xylenes

 

–

 

–

 

–

Chlorides (as total Cl)

 

5,483,545

 

4,219,545

 

5,483,545

Asbestos

 

–

 

–

 

–

Cyanides (as total CN)

 

–

 

–

 

–

Fluorides (as total F)

 

–

 

–

 

–

Octylphenols and Octylphenol ethoxylates

 

–

 

–

 

–

Fluoranthene

 

–

 

–

 

–

Isodrin

 

–

 

–

 

–

Hexabromobiphenyl

 

–

 

–

 

–

Benzo(g,h,i)perylene

 

–

 

–

 

–

Each site determines the relevance of pollutants at the site level through measurement, calculation, or estimation. The specified parameters of the above list are determined locally through measurement, calculation, or estimation. Only values above the applicable threshold values are reported. When determining emissions through measurements, analytical methods required in licenses and permits take precedence. If no methods are specified, standardized and recognized analytical methods are applied for the analysis of a parameter in wastewater. These methods may depend on the legal framework. If no standardized method is available, laboratories use their own internally validated methods. Limitations include, for example, intrinsic limitations of the measurements as outlined in the respective validation documentation. In calculations, the applied method depends on the specific process in which a substance is handled. These calculations may be based, for example, on input/output analyses or reaction formulas. Similarly, in estimations, the applied method depends on the specific process in which a substance is handled. Estimations may be based, for example, on documentation and records such as the amounts used or mass balances. The values determined in this way are recorded in a central EHS data management system. Due to the multitude of sites and metrics, we refrain from detailed disclosure of all pollutants at site level. On a corporate level, the determination of the metric has not been validated by an external body. Many of our sites discharge their wastewater into municipal treatment plants, where substances are degraded before the water enters the environment. The degree of reduction depends on the technology used in the respective wastewater treatment plant and, in many cases, on the ambient temperature. We have established a reduction range for each pollutant based on scientific findings. This range is applied to the locally determined value and results in the values “Estimated minimum”, “Estimated median” and “Estimated maximum”.

The measurement of water pollution metric has not been validated separately by an external body. 

Pollution of soil

Our main impacts, risks and opportunities related to soil pollution (E2 SBM-3)

As part of the materiality analysis, we identified impacts, risks and opportunities related to soil pollution. Our disclosures focus on the following material risks:

ESRS E2 SBM-3 – Our main impacts, risks and opportunities related to soil pollution

Pollution of soil

Identifier

 

E2-R-01

Material impacts, risks and opportunities

 

Risk

Time horizon

 

Medium-term

Value chain step

 

Own operations

Description

 

Production processes that were decommissioned a long time ago caused subsurface contamination in the past. Since then, regulatory restrictions regarding the management of subsurface contaminations have increased and are increasing. These stricter regulations are likely to increase our costs. This applies to all three business sectors.

Our policies related to soil pollution (E2-1)

ESRS E2-1 – Soil EHS Policy

EHS Policy

Connection to material impacts, risks and/or opportunities

 

Identifier E2-R-01

Material sustainability matter

 

Pollution of soil

Key contents

 

The basis of our operational environmental management is the Group-wide EHS Policy (environment, health and safety). The policy formulates our responsibility to minimize the negative environmental impact associated with our business activities and to protect the health and safety of our employees, customers, and contractors. It specifies our commitment to work in such a way that we reduce or eliminate risks to the environment, human health and safety. The policy is continually monitored and part of our EHS management system. We are certified according to ISO 14001. The compliance with the requirements of ISO 14001 is reviewed annually as part of external surveillance and/or recertification audits. We have established processes and procedures in order to comply with regulations. We provide mandatory EHS training courses for our employees.

Scope of application

 

The policy applies Group-wide to our own operations and to the upstream and downstream value chain.

Accountability

 

Chair of the Executive Board and CEO

Third-party standards/initiatives

 

The policy is based on the principles of the UN Global Compact and the Responsible Care® Global Charter. It is aligned with the ISO 14001 and 45001 standards.

Consideration of stakeholder interests

 

When setting the policy, we considered the interests of our employees and customers.

Availability

 

The policy is available internally on the intranet and publicly on our website.
ESRS E2-1 – Management of Contamination at Sites

Management of Contamination at Sites

Connection to material impacts, risks and/or opportunities

 

Identifier E2-R-01

Material sustainability matter

 

Pollution of soil

Key contents

 

The policy clarifies how to assess and handle subsurface contaminations. The objective of this policy is to systematically identify, manage and report risks related to the subsurface (soil and groundwater). To this end, the subsidiaries report their processes to the Corporate Sustainability, Quality and Trade Compliance function (SQ) with regard to:

  • The level of knowledge on contamination: information on new contamination and significant updates (e.g., new requirements from regulators)
  • Procedures for the investigation, analysis, monitoring and evaluation of contamination
  • Decontamination/remediation work on soil, groundwater or the removal of hazardous substances
  • The site must ensure that all relevant original documents related to the contamination and remediation actions are available. SQ monitors all activities related to post-transaction liabilities, for example agreed remediation work and/or known contamination (EHS due diligence and post-transaction).

Scope of application

 

The policy applies to all locations worldwide.

Accountability

 

Site manager/director or qualified, responsible employees

Third-party standards/initiatives

 

None

Consideration of stakeholder interests

 

When setting the policy, we considered the interests of internal stakeholders.

Availability

 

The policy is available internally on the intranet.
ESRS E2-1 – Spillage Control of Hazardous Substances

Spillage control of Hazardous Substances

Connection to material impacts, risks and/or opportunities

 

Identifier E2-R-01

Material sustainability matter

 

Pollution of soil

Key contents

 

The policy sets a global framework for storage, transfer, and handling of hazardous substances. It gives guidance on how facilities and technical equipment shall be designed, built, operated, and maintained in such a way that potentially polluting substances do not enter the environment. Monitoring is secured via our EHS audit system – see “Corporate EHS Audit Process” policy.

Scope of application

 

The policy applies to all legal entities of the Group that unload, store, transfer and handle hazardous substances. All employees shall adhere to the specified rules.

Accountability

 

Site manager/director and qualified responsible employees

Third-party standards/initiatives

 

None

Consideration of stakeholder interests

 

When setting the policy, we considered the interests of internal stakeholders.

Availability

 

The policy is available internally on the intranet.

The policies related to pollution of soil are regularly monitored and updated. 

We use our EHS Policy to define objectives, programs and performance indicators related to the environment, health and safety at both Group and site level. In this context, we aim to prevent new contamination at all our sites by strictly adhering to existing regulations as well as reducing and monitoring accidents and incidents. For this purpose, we implemented the Spillage Control of Hazardous Substances policy as a globally harmonized approach. As outlined in our Management of Contamination at Sites policy, we mitigate negative effects associated with existing soil pollution from historic activities through remediation by securing the subsoil and/or remediating existing underground contamination. In doing so, we reduce risks for potentially affected parties in the vicinity of the sites with regard to existing contamination from historic activities.

When it comes to the exposure of people, groundwater and surface water to hazardous substances, we act according to the ALARP principle: as low as reasonably practicable.

Our actions and resources in connection with soil pollution (E2-2)

The sites in Darmstadt and Gernsheim (Germany) as well as Norwood (USA) are affected by underground contamination because of historic and discontinued production processes. They are now the focus of our ongoing actions. We are in regular contact with environmental protection authorities on current topics; the frequency of this contact is based on the latest findings and actions.

Darmstadt site

At the Darmstadt site, more than 100 years of industrial use, including damage during World War II, resulted in soil and groundwater contamination. For this reason, the groundwater at the Darmstadt site is continuously collected by 32 remediation and process water wells, thus preventing the spread of groundwater contamination. By treating the removed water, we eliminate the pollutants prior to discharge into the surface water. Compliance with limit values is monitored. We also prevent potentially harmful environmental impacts from soil contamination at the site by carrying out extensive surface sealing in relevant areas. As part of our local groundwater remediation actions, regular exchange takes place with the soil protection authority on current issues; the frequency of this exchange is based on the latest findings and actions. These measures will be continued until new requirements require adjustment.

Gernsheim site

The surface of the Gernsheim site was elevated by backfilling with soil, construction waste and hexachlorocyclohexane (HCH), which was a byproduct of lindane production in the past and an authorized constructions material at that time. Between 1954 and 1972, the backfilling was approved by the authorities. HCH residues are now classified as substances with hazardous properties.

To prevent contact of the groundwater with the HCH residues, we are lowering the groundwater level at the Gernsheim site by extracting water from ten remediation and process water wells. The water from the wells is purified using a special treatment plant. In addition, the groundwater is monitored at 64 measuring points using an officially coordinated quality monitoring system. We systematically evaluate the data and submit it to the responsible environmental authority in annual reports. We take the necessary measures in the event of indications of possible harmful effects on the environment. In order to prevent possible harmful environmental effects from soil contamination, we also carried out extensive surface sealing in the relevant areas at the Gernsheim site. In addition, we are in exchange with environmental protection authorities on topics including technical questions and/or the development (fine-tuning) of the current water management (e.g., if the groundwater level changes due to changes in precipitation levels). These measures will be continued until new requirements require adjustment.

Norwood site

Our EMD Millipore Corporation site in Norwood has been used for the industrial production, storage, and distribution of organic and inorganic chemicals since the late 1940s. The former site owners filled a ravine in the southern part of the site with soil, construction waste and chemical waste containers.

Our key actions include containing the waste in the ravine and capturing contaminated groundwater runoff from the site to prevent human and environmental exposure to contaminants of concern (COCs). In addition, we covered the area professionally to minimize or eliminate the release of COCs from the deposits. We also use in-situ chemical oxidation (ISCO) injections to break down any pollutants released into the environment. These measures will be continued until new requirements require adjustment.

Monitoring our actions

Our ambition is to mitigate and prevent harmful effects from existing soil and groundwater contamination at all our sites by remediating the contamination and following safety rules and regulations. This should always be done in accordance with local regulations and in close cooperation with the relevant authorities. The actions are intended to help systematically identify, manage, and report risks associated with soil and groundwater contamination. Monitoring programs verify the effectiveness of the respective actions at each site. These monitoring programs are required by local authorities and determined in the respective license. All actions are monitored by our local qualified experts, and the progress and results are communicated to the authority in annual reports.

Affected stakeholders include EHS employees, local employees, and project managers. In addition, we count shareholders among our stakeholders in this respect. We have not set a time horizon for our actions; they are ongoing measures.

Efforts to prevent and monitor emissions to air, water and soil entail significant expense on our part, as does proper waste disposal. Therefore, we set up provisions for groundwater and soil remediation to ensure that we can execute all the necessary actions. As of December 31, 2024, our provisions for environmental protection totaled € 158 million, 96,6% of which was attributable to Merck KGaA, Darmstadt, Germany. We do not expect any significant change in the next reporting period. For details see “Other provisions” in the Consolidated Financial Statement. 

In 2024, we allocated € 9 million of operating expenditures (OpEx) to soil pollution related measures, which are included in the respective income statement lines. No capital expenditure (CapEx) was allocated. For 2025, we intend to allocate € 10 million of OpEx and no CapEx. 

Our targets related to soil pollution (E2-3)

Our ambition is to systematically prevent, identify, manage and report risks associated with soil and groundwater. Beyond this, we have not set any targets related to soil pollution. Further information on our actions can be found under E2-2 “Our actions and resources in connection with soil pollution”. 

Substances of concern and substances of very high concern

Our material impacts, risks and opportunities related to substances of concern and substances of very high concern (E2 SBM-3)

As part of the materiality analysis, we identified impacts, risks and opportunities related to substances of concern (SoC) and substances of very high concern (SVHC). Our disclosures focus on the following material impacts and risks:

ESRS E2 SBM-3 – Substances of concern and substances of very high concern

Substances of concern and substances of very high concern

Identifier

 

E2-NI-02

Material impacts, risks and opportunities

 

Potential negative impact

Time horizon

 

Medium-term

Value chain step

 

Upstream

Description

 

Many of our chemical products have intrinsic hazardous properties. A potential material impact is located at our supplier level. We assume that we have potential for negative impacts in our upstream value chain. This applies to all three business sectors.
ESRS E2 SBM-3 – Substances of concern and substances of very high concern

Substances of concern and substances of very high concern

Identifier

 

E2-R-02

Material impacts, risks and opportunities

 

Risk

Time horizon

 

Long-term

Value chain step

 

Upstream; own operations

Description

 

Substances of concern and substances of very high concern are subject to stricter regulations, which can pose a risk to our business opportunities and increase costs. In particular, the EU Chemicals Strategy for Sustainability (CSS) describes regulatory actions to transition to a toxic-free environment, aiming to limit the use of substances of concern and substances of very high concern to essential uses. The substitution of potentially banned/restricted chemicals with safe and sustainable chemicals is necessary and costly. Additional costs can also arise in the case of increased requirements for occupational health and safety and the environmental protection.

Our policies related to substances of concern and substances of very high concern (E2-1)

ESRS E2-1 – M-SPOT - Sustainable Portfolio Transformation

M-SPOT – Sustainable Portfolio Transformation of the Group

Connection to material impacts, risks and/or opportunities

 

Identifier E2-NI-02; E2-R-02

Material sustainability matter

 

Substances of concern and substances of very high concern

Key contents

 

We perform a portfolio sustainability assessment or PSA (Sustainable Portfolio Transformation of the Group – M-SPOT) in accordance with the PSA framework of the World Business Council for Sustainable Development (WBCSD). This methodology is intended to assess the sustainability performance aspects of our products in relation to several dimensions including chemical risks and regulatory trends. These assessments consider SVHC and SoC criteria in a risk-based approach and also assess future regulatory trends to account for business risks arising from future bans and restrictions. According to our M-SPOT policy, an identified chemical risk that may result in customers being unable to handle the product safely, must be reduced as quickly as possible. Our products are only sold to industrial and professional users who are generally well trained and receive all the necessary information they need to handle our products safely, such as our safety data sheets (SDS) or further digital solutions. This is why we consider a risk-based approach, as also used in our PSA methodology, to be appropriate to manage potential impacts. In the event of a risk being identified in the assessment of chemical risk or regulatory trends, the product would receive a negative rating.

Scope of application

 

The policy applies to all three business sectors. As part of the PSA method, we compare our products with the most relevant competitor products on a global level (regionalization would be an exception) along the entire value chain and in various dimensions such as water consumption, emissions or packaging. The stakeholders are customers and, for example, also investors who have an interest in reducing risks associated with a non-sustainable portfolio. Internal stakeholders include our business sectors and the Corporate Sustainability, Quality and Trade Compliance unit (SQ).

Accountability

 

Management of the individual business sector and the Head of SQ.

Third-party standards/initiatives

 

Our policy considers the World Business Council for Sustainable Development and the Chemical Industry Methodology for Portfolio Sustainability Assessments (PSA) dated Oct 26, 2018.

Consideration of stakeholder interests

 

Internal stakeholders actively contributed to the development of the policy in meetings and review cycles.

Availability

 

The policy is available internally on the intranet.
ESRS E2-1 – Umbrella - Sustainability in R&D

Umbrella – Sustainability in R&D

Connection to material impacts, risks and/or opportunities

 

Identifier E2-NI-02; E2-R-02

Material sustainability matter

 

Substances of concern and substances of very high concern

Key contents

 

The policy is relevant for the development of new products and the steering of the R&D portfolio: Each Research and Development (R&D) project will regularly complete and update a sector-specific sustainability scorecard. The scorecards are based on the Design for Sustainability (DfS) framework implemented in the business sectors as DfS Life Science, DfS Healthcare and Sustainability in R&D Electronics (SURE). The scorecards ensure a holistic approach to designing products and processes that aim to take into account the well-being of people and the environment over the entire life cycle of a product. The questions in the scorecards are assigned to five sustainability criteria: substances of concern, emissions, water, waste and human progress. Controls to avoid critical substances and replace them with safer alternatives are part of the Umbrella implementations in the business sectors.

Scope of application

 

The policy applies to all active R&D projects that result in a new product and were started in the year 2023 or later. The aim is to achieve a completion rate of at least 95% of the number of projects in scope. The assessment is carried out along the entire value chain and takes into account the effects on upstream, own and downstream activities. The stakeholders are customers and also investors who have an interest in reducing risks associated with a non-sustainable portfolio. Internal stakeholders are our business sectors’ R&D departments and the SQ department.

Accountability

 

Management of the individual business sectors and Head of SQ

Third-party standards/initiatives

 

None

Consideration of stakeholder interests

 

Internal stakeholders actively contributed to the development of the policy in review cycles.

Availability

 

The policy is available internally on the intranet.
ESRS E2-1 – Occupational Health and Safety Protection Concepts for Handling Hazardous Substances

Occupational Health and Safety Protection Concepts for Handling Hazardous Substances

Connection to material impacts, risks and/or opportunities

 

Identifier E2-NI-02; E2-R-02

Material sustainability matter

 

Substances of concern and substances of very high concern

Key contents

 

The policy describes our Group-wide process for identifying personal and environmental protection actions when handling hazardous substances. It includes protection concepts that may involve technical, organizational, or personal actions to reduce exposure at the workplace, release into the environment and loss of product. Hazardous substances can only be handled using equipment that provides the degree of protection corresponding to the occupational exposure limit value and the physico-chemical properties of the substance. When selecting protection concepts, we apply the hierarchy of the following controls: Substitution, Technology, Organization and Personnel (S-T-O-P). In order to successfully protect employees and the working environment, we often have to combine several control actions. As part of the technical actions, we use equipment and ventilation to contain and/or control the release of hazardous substances into the working environment. With these actions, we aim to reduce the risk of employee exposure, release into the environment and/or physical hazards (such as dust explosion, ignition of flammable vapors). Monitoring is secured via our EHS audit system; see the "Corporate EHS Audit Process" policy.

Scope of application

 

The policy applies Group-wide to all business areas and Group functions and all new projects or plants and projects involving the refurbishment of existing plants or facilities. This also applies if the site used is not the property of our Group.

Accountability

 

Managing director or site manager/director

Third-party standards/initiatives

 

We are guided by the STOP principle, which is described, for example, in the German standard TRGS 500 of the Hazardous Substances Ordinance and represents a standard approach for the safety and health protection of employees. The evaluation of substitution options that we use is formulated, among other things, in the TRGS 600 standard and is also prescribed by section 6 (1) of the German Hazardous Substances Ordinance. On an EU level, Council Directive 98/24/EC of April 7, 1998, on the protection of the health and safety of workers from the risks related to chemical agents at work specifies in Art. 6 (2) that substitution has the highest priority of the various measures that can be taken to protect workers.

Consideration of stakeholder interests

 

When setting the policy, we considered the interests of internal stakeholders.

Availability

 

The policy is available internally on the intranet.
ESRS E2-1 – EHS Fire protection

EHS Fire protection

Connection to material impacts, risks and/or opportunities

 

Identifier E2-NI-02; E2-R-02

Material sustainability matter

 

Substances of concern and substances of very high concern

Key contents

 

The policy describes the minimum requirements for fire protection systems at our sites. It includes requirements for the retention of extinguishing water and technical actions that must be implemented to prevent the flow of fire extinguishing water from areas where hazardous substances are handled or stored, or the flow of flammable/combustible/ignitable liquids into adjacent areas. Appropriate means of retaining fire extinguishing water must be provided locally or centrally on the premises or in the building (whichever is applicable) in order to prevent damage to the environment. This also includes fire extinguishing water retention for foam-based fire protection systems.
The EHS staff provide support and guidance. Local legislation must be reviewed along with the policy. Whichever requirement is stricter must be followed. Audits are carried out under the responsibility of the managing directors and site managers/directors to monitor the implementation of the procedure.

Scope of application

 

The policy applies Group-wide at sites. We implement the requirements described in our regular office, laboratory, supply, production and storage rooms and also in general use areas.

Accountability

 

Managing director or site manager/director

Third-party standards/initiatives

 

None

Consideration of stakeholder interests

 

When setting the policy, we considered the interests of internal stakeholders.

Availability

 

The policy is available internally on the intranet.

The policies related to substances of concern and substances of very high concern are regularly monitored and updated. 

There are no specific policies that explicitly address the adverse effects of substances of concern and substances of very high concern. However, any EHS-related policy used to mitigate the impact of hazardous substances in our operations on human health and the environment inherently mitigates the negative impact of subgroups of hazardous substances, e.g., substances of concern and substances of very high concern. As part of our EHS Policy, we define objectives, programs and performance indicators related to the environment, health and safety at both Group and site level. In this way, we aim to continuously monitor and reduce injuries and accidents and the volume of waste. Our aim is to go beyond compliance with EHS regulations by constantly reviewing their potential for improvement. We take actions to minimize risk and prevent damage to minimize negative impacts on the environment, human health and safety and ensure the continuity of our business operations (see “Sustainable Water Management – Wastewater” and “Spillage Control of Hazardous Substances” in section “water pollution”).

The policy “Occupational Health and Safety Protection Concepts for Handling Hazardous Substances” describes carrying out a substance-related substitution test for alternative substances or processes to protect employees from hazardous substances. Substitution is the first component of the STOP principle of the EHS protection actions. In addition to substituting a hazardous substance with a less hazardous substance, substitution also includes reviewing process activities to identify whether equipment or activities can be replaced with a less dangerous piece of equipment or activities. Examples include: Substituting a hand-sieving process with a process that utilizes mechanical equipment; incorporating an online analytical test instead of taking a sample and subsequently testing it in a laboratory; or replacing a dispensing step with a direct, closed transfer. Each of our legal entities that handles hazardous substances must carry out and document a substitution check before applying technical, organizational or personal protective actions.

With the help of our M-SPOT and Umbrella programs, we identify products containing SoC/SVHC and aim to avoid their use in improved and new products. More information regarding our M-SPOT and Umbrella programs can be found under “Our actions and resources related to substances of concern and substances of very high concern”.

Our actions and resources related to substances of concern and substances of very high concern (E2-2)

Increasing transparency through product assessments

We are performing a portfolio sustainability assessment or PSA (Sustainable Portfolio Transformation of the Group – M-SPOT). This methodology is intended to contribute to the transparency of the sustainability of our products. We are currently establishing a corresponding baseline and are monitoring progress centrally in a defined governance set-up, including quality checks of product assessments. By the end of 2024, products accounting in total for more than 35% of the product-related sales were assessed.

For 2025, we plan to have products assessed that account for around 80% of the product-related sales of the Electronics and Healthcare business sectors. Due to the extensive product range in the Life Science business sector, we committed to achieving the 80% goal for Life Science by the end of 2029. Based on the results, we will begin defining measures in 2025. At the beginning of 2026, we will start implementing these measures and establish initial SMART goals for the portfolio transformation. Our business sectors are currently the main stakeholder. Our actions do not extend to upstream value chain engagements. 

Integrating sustainability in research and development

We have introduced Umbrella for the development of new products and the management of the R&D portfolio: For each R&D project, a sector-specific sustainability scorecard must be filled out and updated regularly. At the end of 2024, more than 95% of all relevant R&D projects throughout the company were covered by a sustainability scorecard defined by Umbrella.

For 2025-2027, we plan to set specific improvement objectives for the management of the R&D portfolio by focusing on projects with a positive economic and environmental outlook. We assume that we will implement this within the set timeframe. Our actions should contribute to a good data base for portfolio management while also helping us to gradually build up a more sustainable product and R&D portfolio. All business sectors have scorecards in place and have integrated them in their project-management process. This leads to a more sustainable portfolio of new products.  Our actions can be used worldwide for all business sectors. 

In 2024, no significant capital expenditures (CapEx) or operating expenditures (OpEx) were allocated in relation to the actions M-SPOT and Umbrella. For 2025, we also do not intend to allocate any significant OpEx or CapEx. 

Our targets related to substances of concern and substances of very high concern (E2-3)

At the current stage, there are no explicit corporate targets defined concerning SoC and SVHC. 

Our metrics related to substances of concern and substances of very high concern (E2-5)

Substances of concern

In the following table, we report on the amounts of substances of concern, volumes of substances of very high concern are not included in the information provided.

ESRS E2-5 – Substances of concern

in metric tons

 

 

 

2024

Nature of hazard class

 

Hazard class (Category)

 

Sum of substances generated or used during production or that are procured

 

Sum of substances that leave facilities as products, or as part of products or services

 

Leave facilities as products

 

Leave facilities as part of products

 

Leave facilities as services

Environmental hazards

 

Persistent, mobile and toxic or very persistent, very mobile properties

 

–

 

–

 

–

 

–

 

–

 

Persistent, bioaccumulative and toxic or very persistent, very bioaccumulative properties

 

–

 

–

 

–

 

–

 

–

 

Chronic hazard to the aquatic environment (categories 1 to 4)

 

8,016.1

 

6,273.4

 

2,194.4

 

4,079.0

 

–

 

Endocrine disruption for the environment

 

–

 

–

 

–

 

–

 

–

Health hazards

 

Carcinogenicity (categories 1 and 2)

 

8,916.0

 

7,538.2

 

1,633.7

 

5,904.6

 

–

 

Germ cell mutagenicity (categories 1 and 2)

 

1,244.7

 

960.5

 

444.1

 

516.4

 

–

 

Reproductive toxicity (categories 1 and 2)

 

6,920.1

 

6,089.4

 

1,242.8

 

4,846.6

 

–

 

Endocrine disruption for human health

 

–

 

–

 

–

 

–

 

–

 

Respiratory and skin sensitization (category 1)

 

1,406.1

 

1,263.6

 

831.3

 

432.2

 

–

 

Specific target organ toxicity, single exposure (categories 1 and 2)

 

11,003.4

 

7,938.7

 

7,325.2

 

613.5

 

–

 

Specific target organ toxicity, repeated exposure (categories 1 and 2)

 

7,321.6

 

6,353.5

 

1,305.6

 

5,047.9

 

–

Other hazards

 

Hazardous for the ozone layer

 

1.4

 

1.1

 

1.1

 

0.02

 

–

 

Negatively affects the re-use and recycling of materials in the product in which it is present, as defined in relevant Union product-specific ecodesign requirements

 

–

 

–

 

–

 

–

 

–

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Total volume per path1

 

33,415.2

 

26,732.3

 

12,439.2

 

14,293.1

 

–

1

Actual total volumes per path, avoiding duplications of volumes for substances with more than one hazard class.

Substances of very high concern

In the following table, we report on the amounts of substances of very high concern.

ESRS E2-5 – Substances of very high concern

in metric tons

 

 

 

2024

Nature of hazard class

 

Hazard class (Category)

 

Sum of substances that are generated or used during production or that are procured

 

Sum of substances that leave facilities as products, or as part of products or services

 

Leave facilities as products

 

Leave facilities as part of products

 

Leave facilities as services

Environmental hazard

 

Persistent, mobile and toxic or very persistent, very mobile properties

 

0.8

 

–

 

–

 

–

 

–

 

Persistent, bioaccumulative and toxic or very persistent, very bioaccumulative properties

 

1.8

 

1.0

 

0.2

 

0.7

 

–

 

Chronic hazard to the aquatic environment (categories 1 to 4)

 

114.2

 

81.5

 

36.7

 

44.8

 

–

 

Endocrine disruption for the environment

 

381.5

 

175.5

 

64.4

 

111.1

 

–

Health hazard

 

Carcinogenicity (categories 1 and 2)

 

184.0

 

121.8

 

55.2

 

66.6

 

–

 

Germ cell mutagenicity (categories 1 and 2)

 

55.0

 

32.2

 

28.7

 

3.5

 

–

 

Reproductive toxicity (categories 1 and 2)

 

7,939.4

 

5,904.7

 

2,521.5

 

3,383.2

 

–

 

Endocrine disruption for human health

 

6.7

 

4.4

 

3.9

 

0.6

 

–

 

Respiratory and skin sensitization (category 1)

 

100.8

 

78.5

 

32.6

 

45.9

 

–

 

Specific target organ toxicity, single exposure (categories 1 and 2)

 

1.1

 

1.3

 

1.3

 

0,01

 

–

 

Specific target organ toxicity, repeated exposure (categories 1 and 2)

 

58.2

 

42.2

 

37.3

 

4.9

 

–

Other hazard

 

Hazardous for the ozone layer

 

–

 

–

 

–

 

–

 

–

 

Negatively affects the re-use and recycling of materials in the product in which it is present, as defined in relevant Union product-specific ecodesign requirements

 

–

 

–

 

–

 

–

 

–

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Total volume per path1

 

8,492.6

 

6,194.9

 

2,623.8

 

3,571.1

 

–

1

Actual total volumes per path, avoiding duplications of volumes for substances with more than one hazard class.

We use the following metrics to calculate the volumes of substances of concern (SoC) and substances of very high concern (SVHC) (in metric tons).

Substances qualifying as SoC/SVHC: The handled substances that qualify as SoC/SVHC were identified on the basis of the list of a leading-edge commercial chemical regulatory compliance content provider for enterprise resource planning (ERP) systems, which was updated in July 2024. Additional handled substances assigned to group entries with harmonized classifications have been identified and added to the list. Amendments to the harmonized classification or newly identified substances of very high concern in the second half of the year will be taken into account for the 2025 reporting year.

Materials handled consisting of or containing SoC/SVHC: All materials that are handled in our own operations (generated/procured which includes used materials) and contain or consist of identified SoC/SVHC according to the ERP system are listed along with their composition. Materials containing substances for which the harmonized classification is not valid (e.g., due to particle size limits) are excluded from further analysis. We assume that the list of identifiers for 2024 is complete and correct and that relevant materials are up to date in the ERP system.

Volumes generated/procured (including used volumes) and volumes leaving facilities as products, part of products or services: Volumes of individual SoC/SVHC in all relevant materials identified that are generated or procured or leave facilities as products (substances), parts of products (mixtures or articles) or as services (substances, mixtures and articles specifically booked for services) are calculated based on the relevant composition information and per substance assigned to the respective hazard classes. Intercompany sales are excluded. Total volumes of SoC/SVHC generated or procured and total volumes per hazard class are calculated for reporting on SVHC and other SoC. Our assumptions are the same as those described under “Materials handled consisting of or containing SoC/SVHC”. Substances generated have been defined as manufactured in line with the EU REACH legislation and guidance. This includes isolated intermediates and excludes purification of substances. Substances used have either been generated or have been procured for further use. The information provided for SoC excludes SVHC substances as these are presented in a separate table.

The measurement of substances of concern and substances of very high concern metric has not been validated separately by an external body. 

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