ESRS E2 – Pollution
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Pollution
Material impacts, Risks, and Opportunities
In our double materiality assessment, we have identified business activities with negative impacts related to pollution. Beiersdorf has identified negative impacts on air and water pollution arising from its upstream sourcing activities, especially in energy-intensive industries like the chemical industry. In the downstream value chain, the Consumer Business Segment has identified negative impacts on water resources, as products may release substances of very high concern to the environment when used by consumers. Moreover, the Consumer Business Segment may have a negative impact on the environment when discharging microplastics (synthetic polymer microparticles (SPM)) into wastewater systems as a result of consumer use. We have not identified material risks or opportunities related to environmental pollution.
A detailed overview of all identified impacts, risks and opportunities and the methodology used for the double materiality assessment can be found in chapter “ESRS 2 – General Disclosures.”
Policies Related to Pollution
Beiersdorf has implemented several policies to systematically reduce the risk of environmental pollution while promoting sustainable practices throughout the supply chain. These policies address and have the purpose to mitigate the impacts, risks, and opportunities identified in our double materiality assessment, aiming to establish clear environmental standards and expectations.
Consumer
Consumer
Code of Conduct for Business Partners
The “Code of Conduct for Business Partners” (CoC) defines the requirements that must be met by our global business partners regarding environmental protection.
The CoC specifies that business partners should monitor, track, and document their emissions to air, water, and soil from their facilities, as well as the wastewater generated by their operations. Compliance with all applicable laws and local regulations concerning environmental impacts and protection is mandatory. We expect business partners to continuously aim to reduce any kind of negative environmental impact of products and services and to source in a responsible and sustainable manner. Moreover, it must be avoided causing water and air pollution that impacts natural food sources, denies local access to clean drinking water or sanitary facilities, or harms human health. The policy further states that emergency measures covering soil or water contamination must be prepared. Operators and, if available, company emergency response teams must be regularly trained about hazards and countermeasures. The policy does not specifically refer to the prevention of incidents and emergency situations, as well as the minimization and use of substances of (very) high concern.
The material impacts, risks, and opportunities addressed by the policy include upstream negative impacts on air and water pollution. Further details on the CoC are given in chapter “ESRS S2 – Workers in the Value Chain.”
Beiersdorf Environmental Policy
The “Environmental Policy” outlines general environmental objectives of Beiersdorf such as reducing emissions and substituting or minimizing the use of substances of concern. The policy is also designed to address the critical issues of pollution and the environmental safety of products and processes. It does not specifically refer to avoiding incidents and emergency situations. The policy addresses the material impacts, risks, and opportunities associated with air and water pollution, as well as microplastics and substances of very high concern. Please see chapter “ESRS E1 – Climate Change” for further details.
tesa
tesa
tesa Code of Conduct for Suppliers
The tesa “Code of Conduct for Suppliers” (CoCS) serves as the foundation for supplier relationships in sourcing goods and services. It aims to guide the actions of tesa and its suppliers and aims to reach a positive impact on people, society, and the environment. Suppliers are required to have an effective environmental policy and comply with all existing environmental protection laws and regulations. They are encouraged to adopt a precautionary approach to environmental issues, promote greater environmental responsibility, advance environmentally friendly technologies, and implement sustainable life-cycle practices.
One of the key aspects of this policy is the management of chemicals and hazardous materials. Suppliers must identify any chemicals and materials that pose a hazard if released into the environment. Additionally, suppliers are required to regularly monitor air emissions, implement emission controls, and adhere to a greenhouse gas reduction plan that complies with or surpasses regulatory standards. Air emissions covered by this policy include, but are not limited to, volatile organic chemicals, aerosols, corrosives, particulates, ozone-depleting chemicals, and combustion by-products. The CoCS however, does not specifically refer to avoiding incidents and emergency situations.
The policy addresses upstream negative impacts on air and water pollution, with the scope focusing on tesa suppliers. Accountability for policy implementation rests with the Executive Board, which holds the highest level of responsibility.
Progress towards the policy objectives is monitored through internal tracking of signatures to the CoCS, with ongoing coverage checks. The policy is made available to all stakeholders through the tesa official website and is sent to business partners before the contract is signed.
Further details on the CoCS are given in chapter “ESRS S2 – Workers in the Value Chain.”
Policies in Relation to Substances of Very High Concern
The following section describes the policies addressing the material negative impacts associated with substances of very high concern. These have exclusively been identified for the Consumer Business Segment. Accordingly, it has different policies in place that manage the procurement and handling of substances of very high concern.
Consumer
Consumer
Standard Operating Procedure (SOP) Selection Criteria for Raw Materials
The SOP (identified as CBE.20003005.000.01) outlines the requirements for raw materials used in the manufacture of cosmetic and Over-the-Counter (OTC) products. It encompasses aspects related to product safety, regulatory compliance, quality, microbiology, and Beiersdorf specific restrictions.
A key part of this SOP is that raw materials must not contain substances prohibited by the EU Cosmetics Regulation or EU chemicals legislation (REACH). Additionally, unless exempted, raw materials must not contain substances listed in the “Candidate List of substances of very high concern for Authorization.”
The policy addresses material negative impacts related to substances of very high concern. It covers raw materials intended for Beiersdorf cosmetic and OTC products, including those from third-party suppliers but excluding fragrance compounds and packaging materials as well as La Prairie and Chantecaille products, which are covered separately. Furthermore, the safety-related requirements stipulated in our global safety policy apply globally across all regions. The functions “Global Product Stewardship” and “Product Safety” as part of the Research and Development (R&D) department are responsible for defining the raw material requirements summarized in this policy. Progress towards the policy objectives is monitored through internal standard processes before final release and utilization of new materials in marketed products.
The SOP is accessible to internal stakeholders and is stored in the central document management system, part of the Global Quality Management System (QMS).
Fragrance Restriction List
The “Fragrance Restriction List” aims to ensure consumer safety and product quality by specifying the quantities of certain fragrance ingredients allowed in various cosmetic product categories. This list is based on internal assessments and expert judgments and includes requirements that exceed legal standards, including bans on certain substances and groups of substances. Notably, submissions must not contain substances listed in the “Candidate List of substances of very high concern for Authorization” (SVHC), as published by the European Chemicals Agency (ECHA) at the time of the “Fragrance Briefing.”
The policy addresses material negative impacts related to substances of very high concern and applies globally to all Beiersdorf AG fragrances and aromas used in our products. This includes Beiersdorf affiliates and contract manufacturers. All fragrances and aromas must meet the requirements outlined in the corresponding “Fragrance Briefing” and the “Fragrance Restriction List.”
The policy’s accountability lies with the internal Expert Team “Fragrances,” led by the Manager for “Ingredient Compliance” from “Regulatory” department. There is a contractual agreement between fragrance houses and Beiersdorf ensuring the binding nature of the “Fragrance Restriction List.” Progress towards policy objectives is monitored by working with a fixed and small set of Fragrance Houses. Before being allowed to submit new fragrances, Fragrance Houses must undergo an intensive qualification process to ensure they can fulfil all requirements, with particular attention to systems and tools that safeguard compliance with global regulations and the “Fragrance Restriction List.” Regular on-site visits and exchanges with the fragrance houses are conducted to reaffirm their compliance capabilities.
New fragrance creations submitted by the fragrance houses are approved only after an evaluation process. Documentation created by the supplier ensures that fragrances comply with the “Fragrance Restriction List” and any special requirements addressed during the briefing process. This involves obtaining a “Fragrance Compliance File”: with this Beiersdorf-specific questionnaire, we request all relevant information to validate global regulatory compliance and adherence to the “Fragrance Restriction List,” with written and signed confirmation.
Before a new version of the list is published and becomes valid, fragrance houses are invited to comment on a draft version. This open dialog helps avoid technical barriers to new creations. Once the commenting period concludes, the final version is sent to the regulatory contacts within the fragrance houses, along with a deadline for implementing the new restrictions into their IT systems. After implementation, Fragrance Houses must send a confirmation of compliance.
Actions Related to Pollution
In order to avoid and reduce the identified material negative impacts related to environmental pollution, the Consumer Business Segment is implementing concrete actions explained below.
Consumer
Consumer
Phase-out of cyclomethicone
Description: The action overview for 2030 focuses on the phase-out of cyclomethicone, a significant source of SVHCs (D5/D6) in the Consumer product portfolio. This substance, classified in the EU as very persistent, which means it is only slowly biodegradable, and very bioaccumulative, was targeted for phase-out by the R&D leadership team in April 2019.
Scope: The action plan covers the entire Consumer Business Segment on a global scale.
Time horizon: The completion timeline for this key action for NIVEA and Eucerin products marketed in Europe extends to 2025 and globally to 2030.
Expected outcome: We strive for a significant reduction in the usage of SVHCs, thereby contributing to policy objectives and targets aimed at minimizing environmental hazards.
Progress: A downward trend in the annual volume is notable: Compared to 2019, the annual volume of cyclomethicone has decreased by 64%.
Environmental Performance Assessment Process
Description: An “Environmental Performance Assessment Process,” which includes ecotoxicological criteria and classifications, was approved by the R&D leadership team in February 2019, and has been in use ever since. The guidelines for both new and existing cosmetic ingredients have been implemented, ensuring that no new persistent ingredients enter the raw material portfolio. This process provides clear guidance for Environmental Assessment based on hazard data, with criteria that include persistency, bioaccumulation, and aquatoxicity.
Scope: The process covers the Consumer Business Segment and pertains to our own operations on a global scale.
Time horizon: This is an ongoing action; a specific completion timeline has not been set.
Expected outcome: The primary expected outcome is to reduce the usage of persistent ingredients in the product portfolio. This action contributes to the objectives of the Beiersdorf policy “SOP Selection Criteria for Raw Materials.”
Progress: The “Environmental Performance Assessment Process” has been actively used since its approval in 2019, ensuring the continual evaluation and exclusion of persistent ingredients from the company’s raw material portfolio.
Beiersdorf has currently not implemented significant action plans in relation to the topics air and water pollution in the upstream value chain and regarding microplastics. Actions concerning downstream microplastic pollution typically involve addressing cosmetic ingredients that may enter the environment through wastewater effluents. Since our company has already largely discontinued the use of microplastics as defined by the “United Nations Environment Programme” (UNEP), we consider this impact to be sufficiently mitigated. There are no additional actions to be reported for 2024.
While we recognize the importance of minimizing upstream pollution, such as emissions or contaminants introduced during the production and sourcing stages, these impacts largely fall outside our direct operational control. Our ability to influence these areas is limited to ensuring compliance with our Supplier Code of Conduct, which already encompasses stringent environmental and social criteria. Compliance with the supplier code of conduct is monitored and addressed under chapter “ESRS S2 –Workers in the Value Chain.”
Targets Related to Pollution
Consumer
Consumer
100% of cosmetics free from synthetic polymer microparticles by 2032
A restriction on Synthetic Polymer Microparticles (SPM) has been in place in the EU since October 2023. The transition times are four years for rinse-off products, and six years for leave-on products. Our commitments exceed regulatory requirements, as they consider SPM on a raw material level and have implemented a global pledge, not just limited to the EU region. Many SPMs lose their particulate nature when incorporated into cosmetic formulations, thus falling outside the restriction’s scope.
To address our material negative impacts related to pollution associated with microplastics, we defined a target in the reporting year which is as follows: 100% of cosmetics free from synthetic polymer microparticles.
This target is aligned with the objectives set out in the “Environmental Policy” and is planned to be achieved by 2032 (baseline year: 2024).
The target scope is global, covering various activities and the entire value chain. It involves all affected stakeholder groups and mandates that methodologies and significant assumptions used to define targets, including selected scenarios and data sources, align with national, EU, or international policy goals. The target is absolute, with a complete phase-out planned. As previously stated, the efforts of Beiersdorf surpass EU regulations, eliminating “United Nations Environment Programme (UNEP) Microplastics” in the EU for NIVEA by 2021 and for Eucerin by 2023.
Regarding target performance, no progress has been recorded yet, since 2024 has been the baseline year. Monitoring and review processes are in place, with raw materials evaluated against the SPM restriction definition from October 2023, tracking progress meticulously.
Stakeholders have not been involved in target setting. For environmental targets, this initiative is science-based, highlighting the objective difference between UNEP-Microplastics and SPM. While all UNEP-Microplastics are SPMs, not all SPMs are UNEP-Microplastics. This target is more ambitious as it includes persistent polymers that, although soluble in cosmetic formulations, persist in the environment. Hence, this target surpasses standard requirements significantly.
Use of 100% biodegradable polymers in European product formulations by the end of 2025
We intend to use only biodegradable polymers in our European product formulations by the end of 2025 (absolute). With this target, we address the negative impacts regarding microplastics and on water resources in the downstream value chain, thereby minimizing the risk of future regulatory restrictions. The target therefore contributes to achieving the ambitions formulated in the “Environmental Policy.”
Polymers are molecules that consist of many recurring subunits. They are commonly used in cosmetics and provide various product properties, such as increased water resistance in sunscreen products. Many polymers containing organic carbon are biodegradable – that is, they can be fully broken down into water and carbon dioxide by microorganisms such as bacteria or fungi. However, this is not the case with other polymers, which leave chemical substances in the environment. We are gradually phasing out the use of such non-biodegradable polymers in order to reduce potential environmental impacts.
To this end, we evaluate all raw materials in terms of their biodegradability. The evaluation is based on Annex XIII of the European REACH Regulation and the corresponding “Guidance on Information Requirements” (Chapter R.11). The criteria for the persistence of substances contained in these documents define the timescale for a molecule to be considered biodegradable. On this basis, we identify polymers that are not sufficiently biodegradable and that should be eliminated from our European product formulations by the end of 2025.
To achieve this goal, we are not only replacing ingredients but also developing completely new polymer technologies. We report separately on the raw material group of silicones, which comprises dimethicone and cyclomethicone, among others. While silicones do degrade in nature over time, they are not biodegradable by definition due to their chemical composition – as they do not contain any organic carbon in the polymer chain. We therefore consider them separately from other polymers and are working to reduce their use as well.
In comparison with 2018, we already used 69% fewer non-biodegradable polymers in our European product formulations in the reporting year. The base value in 2018 was 978 kt.
Stakeholders were not involved in setting the targets.
Beiersdorf has currently not set any targets in relation to the topics air and water pollution in the upstream value chain. Beiersdorf actively tracks the Code of Conduct (CoC) coverage of its suppliers to ensure compliance with the environmental requirements outlined in the CoC. Beiersdorf has also set a specific target to enhance and monitor this coverage, thereby addressing upstream pollution. More information is given in chapter “ESRS S2 – Workers in the Value Chain.”
The assessment of raw materials used at Beiersdorf covers both human and environmental toxicity as well as an assessment in context of applicable regulations. As the main criteria for the identification of SVHC are in conflict with the requirements of the cosmetic product regulation or with Beiersdorf’s internal policies on human and environmental safety, no further targets are set for SVHC in the downstream value chain.