2.2. ESRS E2. Pollution
Current and potential incidents, risks and opportunities
Negative impacts
- Air, water and soil pollution.
- Generation of microplastics in the production processes of own operations.
- The accidental release of chemicals into the environment can negatively affect health and safety.
- Damage to the natural environment due to pollution related to products, materials, and substances used. Plastics.
Positive impact
- Investment in technologies for treatment and disposal that mitigate the risk of pollution.
Risks
- Imposition of fines and penalties, and implementation of corrective actions as a result of litigation arising from non-compliance with air, water and soil pollution regulations.
- Risk of environmental non-compliance related to pollution, such as exceeding permit limits, or incidents that may damage reputation and result in a loss of confidence by investors, customers and other stakeholders, leading to a higher cost of capital.
Opportunity
- Valorisation of emissions and polluting materials.
Policies and commitments
- Pollution control and reduction policy.
- Environmental policy.
- Occupational health and safety policy.
- ISO 14001 and 45001 certifications.
Actions and resources
- Investments totalling €11.5 million have been allocated to pollution prevention projects. These include the installation of a gas scrubber at the Cáseda plant in Spain and the investment in water treatment at Zacapu.
- Viscofan promotes certification under the ISO 14001 environmental management system for the Group's plants, which includes risk analysis and internal audits to ensure the measures implemented.
Sustainability goals
- Compliance with applicable pollution laws.
Bodies responsible for oversight
- Board of Directors. Appointments, Remuneration and Sustainability Committee, Audit Committee.
- Executive Sustainability Committee.
- Chief Executive Officer.
- Operations and Operational Sustainability Management.
- Local General Managers.
2.2.1. Incident, risk and opportunity management
Description of the processes for determining and evaluating the material IROs
ESRS 2 IRO-1
In the materiality assessment of the Viscofan Group described in section 1.1.4 of this Sustainability Report, pollution has been identified as a relevant aspect, particularly from emissions to the atmosphere and discharges into water.
Additionally, and in accordance with the general process for determining impacts, risks and opportunities, Viscofan identifies several specific IROs based on the analysis of the Group's operations, the upstream and downstream phases of the value chain, as well as the interactions maintained with different groups (mainly regulatory authorities, own staff and local communities), using mechanisms to integrate their perspectives in the assessment of impacts, risks and opportunities related to pollution.
The description of each IRO details the particular characteristics and elements used in its examination and analysis, such as the review of environmental permits or the findings of ISO 14001 audits.
Incidents, risks and opportunities of relative importance and their interaction with the strategy and business model
ESRS 2 SBM-3, ESRS E2-6 (introduced gradually)
The following details the main IROs, their classification by category and their description, as well as their interaction with Viscofan's business, strategy and financial planning in accordance with the SBM-3 disclosure requirement of ESRS 2.
Viscofan has specific response plans in place to anticipate, mitigate, or capitalize on potential future financial impacts related to material contamination impacts, risks, and opportunities. Based on these plans, no impairments of current assets have been identified, and no significant investments are planned to meet the commitments established in the new 2026-2030 Sustainability Action Plan.
Negative impacts
Air, water and soil pollution and generation of microplastics in the production processes of own operations
The manufacture of casings for meat products is an industrial process of a physical-chemical nature that transforms raw materials into a continuous tubular structure. The procedure begins with the preparation of the raw materials, which undergo denaturing treatments to give them the properties necessary for subsequent shaping. This transformation involves interaction with chemical substances.
The processed material is then extruded into a continuous tube known as a casing. This tube undergoes washing and neutralization stages to remove any traces of processing agents, ensuring food safety and compliance with food regulations.
The chemical substances used in these stages, while essential for achieving the product's functional properties, have an environmental impact. During the process, emissions into the air and discharges into the water can be generated, requiring treatment and control systems to minimize their effect on the environment.
Additionally, Viscofan's products include wraps, films, and plastic bags manufactured using microplastics, defined as those smaller than 5 millimetres. Without proper controls, these microplastics used in the manufacturing process could leach into waterways.
Both negative impacts are not constrained to a specific time horizon, beyond the need for proper asset maintenance, safety protocols and adoption of best available technologies. The more Viscofan works to minimize the environmental impact of its production process, the lower the probability of future occurrences.
Therefore, within its business model and in line with its Pollution Control and Reduction Policy, Viscofan has an environmental management system that integrates essential measures to guarantee compliance with environmental and industrial safety regulations at all its plants. In this regard, the facilities include:
- Ventilation and purification systems to capture and treat the generated vapours, especially sulphur compounds.
- Installation of water treatment and purification plants on the premises.
- Investment in advanced filtration and emissions scrubbing technologies, as well as water treatment and discharge systems, aims to improve air and water quality near production plants. Collaboration with specialized equipment suppliers is a fundamental pillar of this initiative, ensuring not only the acquisition of cutting-edge technologies but also fostering continuous innovation.
- Personal protective equipment, including respiratory, eye, skin, and safety footwear, is required. In particular, the use of masks or respirators with specific vapour filters is mandatory in areas where there is a risk of emissions.
- Segregated areas for safe reagent storage, reducing the risk of spills or exposure.
- Training and awareness measures.
- Environmental certification: Implement ISO 14001 or similar systems to ensure continuous improvement and traceability.
During 2025, Viscofan's plants complied with the environmental permits for their respective locations, and no significant deviations in pollutant levels were reported. Additionally, with regard to microplastics, there were no spills at Viscofan Group facilities that required notification to the relevant authorities, defined as those causing damage to the external environment. Furthermore, there are no other outstanding claims from previous fiscal years that could have a significant impact.
The accidental release of chemicals into the environment can negatively affect health and safety.
An accidental release of the aforementioned chemical materials, if the appropriate equipment and prevention measures are not used, could generate risks to both air and water quality, as well as to occupational health.
With this, Viscofan has elements and practices to prevent and detect incidents involving the accidental release of chemical substances, aimed at minimizing risks to the environment and health:
- Airtight equipment, which prevents leaks and guarantees the safety of the process.
- Detection and alert systems for toxic gases and vapours at critical points.
- Alarms and action protocols in case of any deviation
- Safe design of the production process and maintenance programs to detect wear before failures
- Comprehensive assessments of personal protective equipment and installation of additional physical barriers and measurement systems.
- Strengthening training in occupational safety.
During 2025, Viscofan's production plants did not experience any accidental releases of chemicals significantly exceeding permitted levels that required notification to the relevant authorities. Furthermore, no workplace accidents resulted from such incidents.
Damage to the natural environment and animal welfare due to pollution related to products, materials, and substances used. Plastics
The use of single-use plastic materials can have a significant negative impact on the natural environment. This is the case with some products sold by Viscofan, which are made from plastic polymers. The same applies to some of the packaging used by Viscofan.
These polymers are highly persistent in the environment, contributing to the accumulation of waste in landfills and ecosystems. Over time, these plastics can break down into microplastics that contaminate soils and bodies of water.
Although Viscofan's plastic packaging and other products represent a very small part of the industrial GDP in the countries where it operates, an increase in production without seeking reduction and recovery could have a negative impact on the environment.
Within its business model, and particularly with regard to plastic products, Viscofan operates according to the 3Rs (reduce, reuse, and recycle). Key strategies for reducing the use of single-use plastics include:
- Development and promotion of the eFAN casings, which contains up to 95% recycled or bio-based plastic material.
- The search for the reduction of raw material waste in the extrusion of plastic products through the standardization of processes.
- The development of products that have less thickness and therefore require less plastic.
- The search for biodegradable plastic packaging.
Positive impact
Investment in technologies for treatment and disposal that mitigate the risk of pollution
Investing in advanced technologies for treating air emissions and water discharges not only significantly reduces the risk of water pollution and the release of compounds into the environment, but also fosters collaboration with third parties specializing in sustainable solutions. Through strategic alliances with technology providers, innovative systems such as biological treatments, advanced oxidation processes, and gas filtration and neutralization equipment, among others, can be developed. Furthermore, these initiatives have the potential to generate technological developments applicable to other industrial sectors, extending their positive impact beyond Viscofan.
Risks
Imposition of fines and penalties, as well as the implementation of corrective actions, as a result of litigation arising from non-compliance with air, water and soil pollution regulations
Viscofan's casing manufacturing operations are subject to strict environmental, health, and safety requirements. These requirements include air, soil, and water pollution control, proper waste management, ongoing staff training, and the availability of personal protective equipment and safety systems. In addition, administrative obligations such as timely data monitoring and reporting apply. These requirements vary according to the applicable legislation in each location.
Based on this foundation, operations are periodically monitored by environmental authorities, ensuring regulatory compliance and continuous improvement in sustainability and safety.
As part of its usual practice of collaboration and ongoing monitoring with the authorities, deviations or administrative non-compliance may arise that, in the first instance, lead to the application of corrective measures and their preferential resolution through administrative channels. There is also the possibility of imposing fines and penalties arising from litigation for non-compliance in matters of pollution.
The effects of this risk could be varied, ranging from corrective investment to monetary penalties or a production shutdown. These impacts are difficult to quantify, as they depend on the type of incident, its severity, regulatory differences based on location, and associated costs.
During 2025, there were no significant fines, penalties, or litigation arising from non-compliance with pollution regulations. See Note 13.3 of the Viscofan Group's Consolidated Financial Statements regarding Contingent Liabilities. Similarly, there are no significant fines, penalties, or litigation stemming from prior financial years.
For this reason, Viscofan is committed to updating and complying with environmental regulations in the countries where it operates, and aims for continuous improvement in preventing and reducing pollutants, while minimizing risks of this nature and a possible impact on Viscofan's financial situation.
This is the basis of the Pollution Control and Reduction Policy and the management strategy and system
The environmental management system implemented and described below in the section “Environmental Management System Focused on Pollution Prevention” is detailed in the subsection on pollution-related actions and resources. Viscofan's actions to mitigate this risk and its main investments are outlined in the section on pollution-related actions and resources.
Damage to reputation and loss of trust from stakeholders such as investors and customers, leading to a higher cost of capital
In the current context, concern for environmental impact has become an aspect of special relevance for stakeholders, who show a special sensitivity towards matters related to pollution, both for its direct effects on health and for the long-term consequences on the environment.
This attention is intensified in industrial sectors where the use of chemical compounds and the generation of waste can pose risks if not properly managed.
In this regard, non-compliance with environmental regulations poses a significant risk to the company's stability and reputation. Exceeding the limits established in permits for emissions, discharges, or waste management, or experiencing incidents that affect the environment, can have consequences that go far beyond financial penalties or temporary production shutdowns.
These types of situations erode the trust of customers, shareholders, and other stakeholders, generating a negative perception of the company's commitment to sustainability. This loss of credibility can translate into reduced competitiveness, restricted access to certain markets, and an increased cost of capital, as the company is perceived as a higher-risk investment. In a context where sustainability criteria are increasingly crucial for customer and shareholder decisions, ensuring environmental compliance is not only a legal obligation but also a strategic condition for maintaining trust, stability, and long-term value.
In 2025, the Danville plant in Illinois, USA, was the subject of accusations by a digital media outlet alleging specific breaches of environmental regulations and the requirements established in the permits applicable to the plant's operations. These accusations were based on requirements from US environmental authorities regarding atmospheric emissions, waste management, and the reporting of water discharge parameters. All of these requirements have been satisfactorily resolved or are pending final administrative resolution, with no material impacts anticipated. Furthermore, to date, these accusations have not resulted in any firm sanctions, third-party claims, or material impacts on Viscofan's assets, although they did cause a decline in the share price on the day the accusations were published.
The measures adopted by the company have been aligned with its own reputational crisis management protocols, including, among other actions, specific communications to the National Securities Market Commission (CNMV), including in November 2025 one on the result of the internal investigation carried out to verify and ensure compliance with regulations in the operations of the affected plant, as well as the implementation of initiatives aimed at continuous improvement.
To this end, and complementing the environmental management system focused on pollution prevention (next section), Viscofan has engaged the advice of the US law firm Baker & McKenzie and other consultants who have conducted a comprehensive review of the environmental, health and safety policies and procedures at the Danville plant with the aim of further improving standards of excellence in all aspects of operations, as well as ensuring the
regulatory compliance, environmental protection and occupational safety in accordance with the most demanding industry standards.
In this regard, the section “Actions and resources related to pollution” presents the set of reinforced measures in environmental and occupational health matters, including those carried out at the Danville plant.
Opportunity
Valorisation of emissions and polluting materials
The recovery of emissions and polluting materials generated by the casing manufacturing process represents a strategic opportunity to reduce environmental impacts and generate added value. Currently, production involves the use of chemical compounds that generate gaseous emissions and liquid effluents with a high chemical load. Instead of treating them solely as pollutants and waste, the development and implementation of capture and transformation technologies to convert them into useful byproducts for both our production process and other sectors represents a significant opportunity for Viscofan.
Viscofan, in line with its environmental compliance goals and its ongoing efforts to utilize emissions and pollutants, collaborates with companies specializing in pollutant treatment, employing technologies tailored to the casing production process and the aforementioned emissions and effluents. This strategy yielded results in 2025 at the Cáseda plant in Spain through investment in an emissions scrubbing system and a sulphate crystallizer for wastewater treatment. These are detailed in the section on pollution-related actions and resources of this report.
Expected financial effects of material risks and opportunities related to pollution
ESRS E2-6. Information requirement introduced gradually
Viscofan does not report this information in the present sustainability report because it is a reporting requirement that was introduced gradually and is therefore exempt from reporting in the current year's sustainability report.
Environmental management system focused on pollution prevention
Viscofan has an environmental management system designed to prevent and manage pollution incidents and risks in its operations. Management is primarily carried out at the local level, adapting to the specific regulations of each country and ensuring legal compliance at all plants.
Each production facility has its own environmental management systems, most of which are certified under ISO 14001, enabling it to identify, control, and reduce the impacts of its industrial activity. These local systems are the foundation for ensuring responsible practices that comply with regulatory requirements.
In addition, at the corporate level, the systems are monitored by the Operational Sustainability team, which oversees compliance with internal standards and seeks to strengthen prevention.
Within the system, in addition to technology, the training of people is essential, including education.
continuous emergency protocols, good operating practices and awareness campaigns, which consolidate the environmental culture throughout the organisation.
Viscofan has a Sustainability Strategy and Action Plan to address impacts, risks, and opportunities of relative importance, with the aim of preventing a pollution event by promoting, where possible, a management system and investments in the best available technologies. This qualitative analysis is based on the premise of improving the current status. A quantitative resilience analysis has not been performed.
Prevention is conceived as a dynamic process that integrates the following components:
Risk assessment and analysis
Production plants conduct an assessment to identify and control potential sources of air, water, and soil pollution. This analysis covers all stages of the packaging manufacturing process, the handling of raw materials and chemicals, and the management of waste and effluents: solids, liquids, and gaseous emissions.
These points are prioritized based on their risk potential, considering factors such as toxicity and hazard of the compounds used and emissions, as well as compliance with applicable regulations.
Monitoring
To ensure early risk detection and minimize environmental impact, production plants in the most sensitive areas have periodic monitoring systems. These systems allow for the collection and analysis of critical data, facilitating an immediate response to any deviations and ensuring compliance with current regulations.
The monitoring covers essential parameters such as air quality and emissions at process points and chimneys, as well as water quality in areas with wastewater treatment plants and discharge points. Conditions are also monitored in areas designated for the storage of hazardous waste, reinforcing safety and reducing the risk of incidents.
The information obtained is used to identify patterns, anticipate possible deviations, and activate corrective measures in an agile manner.
Investments in equipment
Viscofan promotes investment in plants, seeking, as far as possible, the best available technologies to prevent pollution.
- Related to air: it is worth highlighting the installation of filtration systems to capture and eliminate Viscofan efficiently removes particles and compounds present in emissions from production processes. These systems aim to ensure that air quality at the facilities and in nearby communities remains within permissible levels. Viscofan also promotes the installation of gas scrubbing technologies that eliminate gaseous pollutants through absorption and chemical reaction processes, reducing emissions of substances into the environment.
- Water-related matters: Viscofan works to improve the quality of its discharges into freshwater bodies by ensuring the proper treatment of its wastewater and minimizing the environmental impact of its activities. To this end, Viscofan operates wastewater treatment plants in Cáseda (Spain), Zacapu (Mexico), Itu (Brazil), Pando (Uruguay), Suzhou (China), and Novi Sad (Serbia). In addition to its own plants, when wastewater is sent to municipal treatment systems, internal pretreatment is carried out to ensure that the water delivered to the public network meets the required standards. established by the competent water management authorities. These actions include monitoring critical parameters, as well as implementing control systems that allow for immediate action in the event of any deviation.
- Personal protective equipment and hazard signage: A critical aspect is ensuring the safety of staff and the correct identification of environmental hazards through the use of personal protective equipment appropriate to the level of risk. Additionally, mandatory use protocols are established for areas with emissions, chemical handling, or water treatment, and clear and standardized signage is required in all locations with environmental hazards: emissions, spills, and hazardous products.
Development of response and mitigation protocols
The plants have specific protocols in place to ensure a rapid and effective response to any pollution incident. These protocols define the necessary actions to contain and mitigate the impact.
They include emergency procedures that allow for the identification of the incident, the activation of the responsible teams, and the implementation of corrective measures in the shortest possible time. They also cover immediate communication with the relevant authorities and regulatory bodies, ensuring coordination and compliance with legal requirements. To ensure their effectiveness, the protocols are reviewed and updated periodically.
This system seeks to reduce risks and improve response capacity, integrating emergency management as an essential part of the organisation's environmental strategy.
Audits
Internal and external audits are conducted to evaluate the effectiveness of the implemented measures. Viscofan is working towards certifying all its plants under the ISO 14001 standard, which, among other environmental aspects, emphasizes minimizing and preventing pollution incidents.
Regulatory compliance and relationship with government agencies
A key element is compliance with local pollution standards, ensuring that each production plant operates in accordance with the regulations applicable in its location. This is not limited to the internal application of controls, but is reinforced by periodic monitoring carried out by the relevant authorities, who verify key parameters such as air emissions, discharges, and waste management.
At Viscofan, we maintain a constant and collaborative relationship with environmental authorities. Inspections, audits, and regulatory requirements are part of our daily operations and are a key tool for driving improvement. This dialogue helps us identify opportunities to reduce impacts, strengthen preventative protocols, and ensure that our operations comply with regulatory standards.
All our plants operate under environmental, health, and safety regulations, which include specific permits and monitoring and reporting obligations. Compliance is managed in coordination with the relevant authorities, prioritizing prevention and early correction. When any deviation is detected, corrective action plans are established, which are typically resolved through administrative channels.
Environmental management system certified under the ISO 14001 standard
Work is underway to achieve this environmental management certification at all production plants. By the end of 2025, 74% of production plants will have this certification, with short- and medium-term plans to certify the Danville plant in the USA and the Rayong plant in Thailand.
Details of the Group's plants with ISO 14001 certification as at December 31, 2025 have been reported in section ESRS E1 - Climate Change in point 2.1.4. Incident, risk and opportunity management.
Policies related to pollution
ESRS E2-1, ESRS 2 MDR-P
Pollution control and reduction policy
Fundamental content and principles
Within the framework of the general Sustainability Policy and in line with the Sustainable Development Goals (SDGs), Viscofan has a Pollution Control and Reduction Policy approved by the Board of Directors.
This policy provides the framework for establishing an environmental management system within the Viscofan Group, based on the principles of precaution, prevention, and continuous improvement regarding air, water, and soil pollution. It is based on the following fundamental principles:
- Recurring assessment of the incidents and risks of air, water and soil pollution, including the analysis of production processes, raw material handling and waste management.
- Implementation and continuous monitoring of identified high-risk areas to detect patterns and potential contamination incidents early.
- Promotion of investments in equipment with the best available technologies for pollution prevention.
- The development of rapid response protocols to mitigate any pollution incident that may occur, with emergency procedures, communication with the competent authorities and corrective measures to minimize the environmental and public health impact.
- Conducting internal and external audits to evaluate the effectiveness of the measures implemented under ISO standards.
- The implementation of a structure of professionals in the field of operational sustainability with expertise in pollution prevention.
- Minimization of substances of concern.
Furthermore, the development and implementation of the Policy's basic principles and commitments will be based on the management of risks and impacts, establishing objectives, programs, and plans that promote the continuous improvement of processes and practices within the Group's framework regarding pollution prevention, and particularly through:
- Monitoring compliance with and respect for applicable regulations, as well as other voluntarily adopted obligations, including the implementation of certified environmental management systems and the development of internal and external audits under ISO standards that, among other aspects, emphasize the minimization and prevention of pollution incidents and promote their implementation in suppliers.
- The establishment and periodic review of targets and plans for reducing air pollutants, undertaking the necessary investments for the implementation of advanced filtration and emissions washing technologies, in order to improve air quality in accordance with applicable regulations.
- The establishment and periodic review of targets for water resource consumption reduction plans and investment in the more advanced technologies that guarantee the purification of used water before its return to the waterways.
- Develop action plans to improve waste control and management, including circular economy projects for waste reduction.
- Develop training programs for professionals in the Group's companies that include skills in pollution prevention.
- To promote Research and Development and Innovation and to that end to establish collaborative relationships with specialized equipment suppliers as a way of ensuring the availability of advanced technologies in the field of pollution prevention.
- Develop response and mitigation protocols for all production centers that include emergency procedures, communication with local authorities, and corrective measures to minimize the environmental and public health impact.
This policy is available on the Viscofan website, in the Corporate Governance – Regulations and Policies section.
Additionally, information regarding the scope of the policy and the monitoring and supervision in accordance with ESRS 2 MDR-P has been reported in ESRS G1 Business Conduct, section Business conduct policies and corporate culture.
Occupational health and safety policy
Viscofan also has an Occupational Health and Safety Policy, detailed in section ESRS S1, Employees. Among other principles, the Policy is based on the idea that preventing accidents, injuries, and work-related health problems requires allocating resources that contribute to safety and health and emphasizing training in prevention techniques. It also emphasizes integrating occupational health and safety into all decisions, business processes, and work methods, ensuring that managers, supervisors, technicians, and other professionals continuously assume their responsibilities.
Actions and resources related to pollution
ESRS E2-2, ESRS 2 MDR-A
Completed in 2025
In 2025, Viscofan's investment in pollution mitigation totalled €11.5 million. According to the pollution reduction hierarchy established in section 19 of ESRS E2, these investments were primarily aimed at reducing and preventing pollution by improving air and water quality and minimizing the risk of accidental spills. They have been identified from the list of acquisitions of property, plant and equipment and intangible fixed assets of the Viscofan Group (see notes 5 and 6 of the consolidated financial statements).
Of particular note is the investment in the Cáseda plant in Spain for a sulphate crystallizer for wastewater treatment. This technological solution, through a controlled crystallization and separation process, allows for the recovery of suphate present in wastewater, preventing its discharge into the environment. This facility was commissioned in June 2025.
Furthermore, in November 2025, a gas scrubbing system was implemented in the production of cellulose casings. This is a water-based scrubbing system.
The oxygenated process, in addition to reducing polluting emissions, allows for the elimination of sodium sulfite residue. As part of the treatment, the developed technology allows for the production of sulphuric acid as a valuable byproduct, which can then be reused internally as raw material in the manufacturing process of cellulose casings.
Investments have also been made at the Zacapu plant in Mexico and in Danville in the USA to improve the treatment and extraction of carbon disulfide.
In parallel, Viscofan is working to promote investment in improving water purification and treatment capacity. In this regard, in 2025, an investment was made to improve the water treatment and sanitation system at the Zacapu plant in Mexico. Additionally, at the Danville plant, the first phase of an investment to improve water quality has been completed. This water is then sent for municipal treatment before being discharged into the sewer system.
Beyond the investments detailed, in our continuous improvement business model for the management system we are implementing measures in multiple areas:
- Atmospheric emissions. Upgrading of measuring equipment; improvement of maintenance, calibration and alarms of the purification system; strengthening of emergency procedures.
- Waste management. Improvement of the management of hazardous waste areas; improvement of labelling and documentation.
- Workplace safety. Comprehensive assessments of personal protective equipment and reinforcement of training in workplace safety and measurement systems; additional physical barriers.
- Compliance systems. Enhanced procedures for monitoring, reporting, and training of workers.
The actions and resources have been financed through the business's cash flow. Viscofan has sustainable financing that is not yet allocated to the aforementioned projects, although it contributes to Viscofan's sustainable performance as outlined in the Sustainability Action Plan. See note 15 of the consolidated financial statements.
Expected
The following actions are planned for 2026:
At the Cáseda plant in Spain, an investment of €1.3 million is budgeted for the installation of a stripping system to improve the treatment of wastewater from the production process. This technology is used to remove volatile or dissolved contaminants from liquid or gaseous streams through a physical mass transfer process.
Also, a budgeted investment of €1.0 million for biological water treatment at the Novi Sad plant in Serbia.
Continuous improvement initiatives in the area of pollution, together with the work to obtain the ISO 14001 environmental management certificate at the Danville and Rayong plants.
2.2.2. Parameters and goals
Pollution-related goals
ESRS E2-3, ESRS 2 MDR-T
Within the framework of the Sustainability Action Plan, Viscofan has not established specific pollution reduction targets at the Group level beyond compliance with the limits set by the competent authorities and obtaining ISO 14001 certification in all production plants.
Monitoring the effectiveness of the actions and the environmental management system, aimed at preventing pollution described in this ESRS with respect to the IROs of relative importance, is managed at the local level with indicators based on the limits of air and water emissions, and waste management that are included in the environmental permits issued for all operations by the competent authorities.
This strategy has allowed us to respond to the specific needs of each location and ensure compliance with local environmental regulations, which identify priority substances and provide guidance for reducing emissions, with which Viscofan works at the local level.
The Pollution Control and Reduction Policy, approved in December 2024, has established that for the development and implementation of its basic principles and commitments, objectives and plans for the reduction of air pollutants will be established.
Based on this, and following the reporting regulations of this sustainability report, the relevant emission levels have been consolidated, resulting in a broader and more detailed view of our environmental impact across all our operations.
Air, water and soil pollution, and substances
ESRS E2-4, ESRS E2-5
Pollutants
The pollutants in consolidated quantities from installations that exceed the thresholds detailed in Annex II of Regulation (EC) No 166/2006 of the European Parliament and of the Council (European Pollutant Release and Transfer Register, 'European PRTR Regulation') emitted into the atmosphere and water, with the exception of GHG emissions, which have been reported in accordance with ESRS E1. Climate Change, are Ammonia (NH3), Nitrogen Oxides (NOx/NO2), Total Organic Carbon (TOC) (as total C or COD/3), Chlorides (as total Cl) and Nickel.
In 2025, no emissions to the soil were recorded that exceeded the reporting thresholds of the PRTR Regulation.
Air emissions
| Absolute emissions to air. In tons | 2025 | 2024 |
| Ammonia (NH3) | 368 | 267 |
| Nitrogen oxides (NOx/NO2) | 371 | 361 |
From the reported table:
Ammonia (NH3) is a byproduct of the packaging production process. The increase compared to the previous year is due to the higher level of production activity and the use of a higher emission factor based on concentration measurements taken by the R&D department.
Nitrogen oxides (NOx/NO2) emitted into the atmosphere from the combustion of natural gas in boilers for steam production. Evolution in line with boiler availability during the period.
Water emissions
Depending on the configuration of each plant, there are two ways of managing water discharges that cause the level of pollutant load to differ when it leaves Viscofan's facilities, although in both cases the objective is to ensure that wastewater is managed safely and in accordance with current legislation.
On the one hand, Viscofan has production plants with their own treatment and purification systems, where wastewater undergoes internal processes that reduce the pollutant load before being discharged into freshwater bodies. In other facilities, the water is diverted directly to municipal treatment plants that carry out the treatment.
| Absolute emissions to water. In tons | ||
| Treated in our own purification plants | 2025 | 2024 |
| Total organic carbon (TOC) (as total C or COD/3) | 90 | 96 |
| Sent to municipal treatment plant. In tons | 2025 | 2024 |
| Total organic carbon (TOC) (as total C or COD/3) | 492 | 404 |
| Chlorides (as total Cl) | 3,258 | 3,644 |
| Nickel | 0.02 | n.a. |
From the reported table:
Total organic carbon (TOC) (as total C or COD/3), consisting mainly of cellulose or collagen fibers, which on their own and in irrelevant quantities are not harmful to the environment, although in high quantities in the river they can reduce the level of oxygen in the water and could affect aquatic ecosystems.
Chlorides (as total Cl) originate primarily from the preparation of the raw material prior to denaturation, where saline solutions are used for conditioning. Some of these compounds dissolve in the liquid streams generated during the process. Additionally, chlorides are used in the cleaning of facilities and equipment to ensure cleanliness and prevent residue buildup. The reported chlorides are directed to a municipal treatment plant for further processing.
Calculation of emissions and sensitivity analysis of estimates
For the quantification of contaminants, Viscofan has not used a direct measurement method due to the complexity and variability of industrial processes, which makes it difficult to perform accurate direct measurements at all times in a continuous process such as that of the casings.
It is important to note that, because they rely on estimates, there is an inherent degree of uncertainty in the calculations. This can arise from multiple sources, such as variability in operating conditions, the accuracy of the models used, and the accuracy of historical data.
In the case of ammonia (NH3), the estimate was based on consumption data for this raw material and concentration measurements taken by the R&D department at specific sites. A variability of +/-5 percentage points in the emission factor could represent an increase or decrease of 21 tons in the amount of emissions.
The nitrogen oxides (NOx/NO2) emitted from the Cáseda plant's emission sources are estimated based on a periodic measurement taken annually for the State Register of Emissions and Polluting Sources and an official factor from the public entity in Navarre. A variation of +/- 5% in the factors used may result in an increase or decrease of 19 tons in the quantity.
Regarding discharges into the water, total organic carbon and chlorides are calculated using laboratory measurements applied to the average flow rate for the period. A variation of +/- 5% in the factors used can result in an increase or decrease of 29 tons in the amount of total organic carbon and 163 tons in chlorides.
Microplastics:
During 2025, the Viscofan Group used 7,932 tons of microplastics in the production process of its plastic casings, films, and bags, most of which leave the facilities as finished products (6,287 tons in 2024). The increase in the current fiscal year compared to the previous year is due to increased production of plastic products in response to recovering demand and the commissioning of special bag production capacity at the San Luis Potosí plant in Mexico.
This information has been obtained from consumption data originating from the SAP raw materials management computer system implemented in the Group's locations that have this type of production process.
Other substances
In accordance with Regulation (EC) No 1272/2008 of the European Parliament and of the Council, the Group has used substances of concern which, if improperly managed, could pose a chronic danger to organs or the aquatic environment through prolonged exposure in relevant quantities.
From the table reported below:
Sulphur compounds. CS2 and H2S: The production process for cellulose and fibrous casings uses, produces, and emits gaseous sulphur compounds. The washing process prevents these compounds from being incorporated into the final product, while emissions into the air are minimized through the installation of gas scrubbers. In this regard, the installation of an oxidation treatment technology in 2025 has reduced CS2 emissions at the Cáseda plant.
| 2025 | 2024 | |||
| Information on substances of concern. In tons. | Consumption | Emission | Consumption | Emission |
| Carbon disulfide (CS2) | 8,624 | 5,073 | 8,429 | 6,157 |
| Hydrogen sulfide (H2S) | 0 | 66 | 0 | 300 |
| Ammonia (NH3) | 1,238 | 368 | 936 | 267 |
| Sodium hypochlorite | 1,938 | n.a. | 2,918 | n.a. |
Sodium hypochlorite: This substance is used in water treatment and purification plants to oxidize organic matter before it is discharged into the water. In these plants, the substance is transformed into other compounds, such as chlorides, which are not considered to be of concern, and is not discharged directly into the water.
Viscofan uses ammonia (NH3) in the production process of casings, which is subsequently washed and released into the atmosphere in lower concentrations.