Pollution (E2)

Managing pollution involves reducing the release of harmful substances into the environment and carefully handling materials, especially those classified as substances of concern (SoC) or substances of very high concern (SVHC). Through a range of dedicated efforts, we aim to protect natural resources, ensure regulatory compliance and support long-term environmental responsibility. To reflect the various dimensions of pollution, our Sustainability Statement addresses this topic via three focused material areas: pollution of water, pollution of soil, and SoC and SVHC.

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

Pollution of water

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

As part of our EHS Policy, we define objectives, programs and performance indicators related to the environment, health and safety at both the Group and site level. In this way, we aim to continuously monitor and reduce injuries and accidents, energy and resource consumption, and waste generation. To further decrease our impacts, we aim for our EHS regulations to exceed compliance by constantly reviewing their potential for improvement. We also prepare for emergencies by taking a range of actions that seek to minimize risks and prevent damage. These efforts help us prevent negative impacts on the environment as well as human health and safety while ensuring continuity in our business operations. The policy is geared toward mitigating impacts of our facilities on the environment and health related to the pollution of water including prevention and control.

To support sustainable water management, which includes incident and emergency preparedness, our affected sites must have retention basins with an appropriate volume for used extinguishing water and/or wastewater that cannot be treated in routine operations. In the event of a fire, these retention basins are designed to control and limit environmental impacts by isolating potentially contaminated extinguishing water.

In accordance with our Spillage Control of Hazardous Substances Policy, our sites must regularly check and maintain the condition and integrity of storage facilities, tanks, containment facilities, and their associated equipment.

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

To protect the environment, we are committed to ensuring that every water-polluting substance is emitted at a level below its predicted no-effect concentrations (PNEC) by 2030. The PNEC is defined as the concentration of a given substance below which no adverse effects to species in water can be expected. It is a substance property, which is scientifically derived. Based on this data, we reduce the water related impact on the environment below a no effect limit. To achieve this, we are implementing various actions and initiatives within our production processes. The process starts with the identification of water hazardous substances and their risk assessment in the specific production context. These risk assessments are crucial, as they trigger subsequent actions if any substance exceeds its PNEC, such as upgrading our wastewater treatment facilities.

In 2025, we progressed a number of key actions aimed at reducing the pollution of water. For example, our Life Science and Electronics business sectors advanced the assessments of relevant wastewater substances. In Life Science we made progress in preparing our risk assessments and improved the determination of PNEC for water-hazardous substances. These assessments intend to help us identify ways to reduce the levels of potentially harmful residues in our wastewater to below the no-effect threshold. In Healthcare, we assessed the wastewater relevance of each substance handled in production and completed risk assessments for wastewater-relevant substances. Going forward, we will continue monitoring the relevant active pharmaceutical ingredients in our wastewater. For substances that exceeded the PNEC water reference value, we conducted laboratory and pilot tests to identify appropriate mitigation measures, such as modernizing our wastewater treatment methods where necessary. Through these actions, we have identified a range of appropriate treatment technologies and are developing implementation plans for relevant sites by 2030.

Our water management efforts focus on our manufacturing sites, as wastewater from production generally poses a higher risk of contamination to aquatic ecosystems. At the end of 2025, 83 (2024: 82) sites in Brazil, China, France, Germany, India, Indonesia, Ireland, Israel, Italy, Japan, Korea, Mexico, Spain, Switzerland, Taiwan, United Kingdom and the United States were involved in water management activities. Of these, 29 (2024: 16) determined that the concentrations of all water-hazardous substances in their wastewater were below the no-effect threshold. We aim to close all set actions by 2030. We took no remediation actions in 2025, as none were necessary.

Our actions regarding wastewater do not extend to the downstream value chain.

Our targets related to water pollution (E2-3)

In our Life Science, Healthcare and Electronics business sectors, wastewater from our production sites is treated as necessary and discharged into municipal treatment systems or water bodies, according to the respective license. We have not set any targets related to the pollution of water but monitor our ambition. By 2030, we aim to reduce potentially harmful residues in our wastewater to below the no-effect threshold. To achieve this ambition, we have defined a series of project steps for each site within its scope, which we oversee centrally. Our steps include identifying relevant water-hazardous substances, assessing the risks in their specific context, performing mitigation actions if necessary, and monitoring their effectiveness. We initiated activities in 2020 and have been recording our progress every six months.

Our metrics related to water pollution (E2-4)

Our water pollution metrics describe emissions from our sites that surpass the threshold levels outlined in Annex II of Regulation (EC) No 166/2006 (E-PRTR Regulation) in 2024 and/or 2025 and originate from facilities operated by us.

The emissions of the three parameters total nitrogen, nickel and compounds, as well as nonylphenol and nonylphenol ethoxylates (NP/NPEs) fell below the reporting threshold in fiscal 2025 compared to the previous year. In fiscal 2024, emissions were reported for these parameters, which originated from the wastewater of a neighboring municipality, whose wastewater we co-treat at the wastewater treatment plant of one of our sites. In fiscal 2025, we only reported emissions from our own sources. The parameter nonylphenol and nonylphenol ethoxylates (NP/NPEs) fell below the reporting threshold due to production-related reasons.

Each site determines the relevance of pollutants at the site level through measurement, calculation or estimation. The specified parameters of key metrics related to the pollution of water 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. 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 the pollution of water metric has not been validated separately by an external body.

Pollution of soil

Our policies related to soil pollution (E2-1)

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, avoiding accidents and incidents as much as possible and monitoring in case they occur. 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 the existing pollution of soil 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 the focus of our ongoing actions. For an additional site in Hohenbrunn, Germany, we are evaluating the remediation of soil contamination caused by fire-fighting foams. 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 demand 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 construction 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 further development (fine-tuning) of the current water management (for example, if the groundwater level changes due to changes in precipitation levels). These measures will be continued until new requirements demand adjustment.

Norwood site

Our site in Norwood, USA, 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 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 injections to break down any pollutants released into the environment. These measures will be continued until new requirements demand 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; these 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, 2025, our provisions for environmental protection totaled € 133 million (2024: € 158 million), 98.4% (2024: 96.6%) of which was attributable to Merck KGaA, Darmstadt, Germany. We do not expect any significant change in the next reporting period. More information can be found under Other provisions in the Consolidated Financial Statement.

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 the soil pollution. More information on our actions can be found under E2-2 “Our actions and resources related to the pollution of soil”.

Substances of concern and substances of very high concern

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

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 potential negative impact of subgroups of hazardous substances, for example, 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 “Pollution of water”).

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 plants handling 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 policies related to hazard communication describe the procedures for generating Safety Data Sheets (SDS). Providing this safety information enables users to correctly handle our materials, which reduces exposure and the risk of incidents. By having relevant chemical safety information on hand, users can also take appropriate measures in the case of an emergency, limiting impacts on people and the environment. While SDS are not legally required for non-hazardous materials, we consider the communication of material properties and safety-relevant information to be important for all materials. Therefore, our policies do not discriminate between those classified as hazardous materials and those deemed not hazardous. The users can be our internal employees or external customers of our products.

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

Increasing transparency through product assessments

We are in the process of performing a portfolio sustainability assessment (Sustainable Portfolio Transformation of the Group, M-SPOT) since 2023. Through this method, we aim to increase transparency around the sustainability of our products, including the use of SoC and SVHC. We are currently establishing a corresponding baseline and monitoring our progress centrally in a defined governance setup, including quality checks of product assessments. By the end of 2025, products accounting for over 55% (2024: > 35%) of our total product-related sales had been assessed, covering over 80% of product-related sales in our Healthcare and Electronics business sectors. Due to the extensive product range in our Life Science business sector, we have committed to achieving the 80% of product-related sales assessment goal by the end of 2029. In 2026, we will start to develop initial SMART goals for the portfolio transformation. Our business sectors are currently the main stakeholder.

Integrating sustainability in research and development

We have introduced the Umbrella program for the development of new products and the management of our R&D portfolio in 2023. All active R&D projects that lead to a physical product are in scope as soon as they leave early ideation and until product launch. For each R&D project in scope, a sector-specific sustainability scorecard, which also covers the use of SoC and SVHC, must be filled out and regularly updated. At the end of 2025, over 95% (2024: > 95%) of all relevant R&D projects throughout our company were covered by an Umbrella-defined sustainability scorecard. At least 25% show an improved sustainability profile when compared to the next best alternative product or an industry standard. A project has an improved sustainability profile when compared to a benchmark it scores an improvement in at least one sustainability category without deterioration in another category.

For 2026 – 2027, we plan to successively adapt the objectives for managing our R&D portfolio by focusing further on projects that have both a positive economic and environmental outlook. Our actions will contribute to a robust data baseline for portfolio management while helping us incrementally develop ha more sustainable product and R&D portfolio. All business sectors have scorecards in place and have integrated them into their project management process, contributing to a more sustainable portfolio of new products.

Providing safety information through hazard communication

We continuously provide all internal and external users of our Life Science and Electronics materials with safety-relevant information via country- and language-specific SDS. Worldwide, over 10,000,000 individual SDS were created in 2025. Around half of these were for non-hazardous materials, despite there being no legal obligation to provide them. More information on our hazard communication of new product introduction processes can be found under “Our policies related to substances of concern and substances of very high concern (E2-1)”.

Across all three business sectors, our global network of regulatory experts continuously monitors changes to legal requirements and scientific developments to stay abreast of emerging trends and best practices.We continuously evaluate the intrinsic properties of our existing and new products to create relevant and compliant product safety information. We maintain and update the SDS electronically, as part of the broader automation and standardization of most of our hazard communication processes. For third-party products, we demand robust product safety documentation from our suppliers and integrate it into our own processes.

Our Life Science customers and all interested stakeholders can access product safety information in their respective language and according to country-specific regulations through a dedicated mobile app, My M Safety. Customers can retrieve this information by scanning a barcode on the product label or entering identifiers such as material numbers, names or CAS numbers.

Through our ScIDeEx™ web tool, anyone can check whether using a particular chemical is safe within the boundaries specified in the EU REACH exposure scenarios. ScIDeEx™ is based on a full implementation of the ECETOC TRA 3 model for human exposure assessments in industrial and professional settings.

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

At the current stage, there are no explicit group targets defined concerning SoC/SVHC, since we assess the sustainability of our products holistically.

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

Substances of concern

Substances of very high concern

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 2025. Additionally 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 2026 reporting year.

Materials handled consisting of or containing SoC/SVHC: 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. Intentionally added substances are included regardless of their concentration. Materials containing substances for which the harmonized classification is not valid (for example, due to particle size limits) are excluded from further analysis. We assume that the list of identifiers for 2025 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, parts 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.