Pollution

In 2024, dsm-firmenich reported for the first time on Substances of Concern and Substances of very High Concern, as defined in Commission Delegated Regulation (EU) 2023/2772 of July 31, 2023.

dsm-firmenich has substances that qualify as a Substance of Concern while they are essential or beneficial for human or animal life. Our focus therefore is on safe production and use, as always. The topic is managed through our policy, requirements, and actions.

Impact, risk, and opportunity management

The 2024 results were discussed with the Business Units and a peer study was performed. The outcome of this process was that additional transparency was needed on our approach and position on Substances of Concern and Substances of very High Concern.

For Substances of very High Concern, EU regulations set the direction. Besides this, customers drive the phase-out as they require products, especially in the EU, without specific hazard classes of Substance of very High Concern or Substances of Concern. The replacement of these substances in our existing products is not an easy or straightforward process. It takes time to find the right substitute that still meets all the product specifications, and to follow up on all the implications a change of substance may have on the product and its application. The substitute found for one application may not be the right candidate for another. Substitution can be a complex process of trial and error.

Furthermore, given the broad set of qualifying criteria for Substances of Concern, replacement may be difficult, as a substitute may still qualify as a Substance of Concern, albeit classified under another hazard criteria.

Actions and resources

In 2025, the preparation for the migration of product data in one of our main product data platforms started. This migration is considered critical for the preparation of the ANH carve-out and an important step in our journey toward an integrated and sustainable product data platform. The project is running according to plan, and go-live is expected in early 2026.

Our Product Stewardship team supports the business globally and is heavily involved in this project. In 2025, it went through a major transition due to, among other things, the preparation for the carve-out of our ANH business. Business support continued, including the classification and labelling of substances and products according to the Globally Harmonized System for Classification and Labeling (GHS), and Dangerous Goods (DG) requirements. The classification enables us to generate required documentation such as the Safety Datasheets, product labels, and transportation documents.

Customers were served with tailored information upon request, besides having access to safety data sheets for all our products.

We strive to limit new Substances of Concern or Substances of very High Concern via our innovations by applying a stage-keeping approach, our 5D process.

Metrics and targets

For our existing portfolio, we aim to develop substance-specific targets in 2026, considering the dynamics in the listings used for qualifications as Substance of Concern or Substance of very High Concern, our product portfolio, and our belief in a risk-based approach as mentioned in our SHE policy.

Our focus will be on Substances of very High Concern, substances that are intended to be ultimately banned in EU, and we will aim to voluntarily reduce them across the globe.

We actively monitor and manage the impact of Substances of Concern that are currently used in our portfolio. In 2025, we continued to develop our reporting approach, including fully documenting our reporting methodology.

We only report on products. Given the type of business we are, the quantity of Substances of Concern and Substances of very High Concern in raw materials and intermediates is assumed to be consistent with the volume in our finished products.

In 2025, 127 kilotonnes of Substances of Concern, including Substances of very High Concern, were present in our finished products. The differences between 2024 and 2025 are due to a variety of factors including:

• The inclusion of new sales data

• Sales dynamics

• Listed substances present in our portfolio