21 October 2022


CLECAT has published a position paper in response to the CountEmissions EU initiative, in conjunction with its response to the public consultation on this initiative. CountEmissions EU aims to establish a common European framework for calculating GHG emissions of transport operations in the freight and passenger transport sector.

CLECAT has been supporting the objectives as outlined in the EC’s roadmap, in particular the establishment of a level playing field for GHG emissions accounting in the transport and logistics sectors to facilitate behaviour change. CLECAT also supports the development of a single EU framework for monitoring and calculating GHG emissions data of transport operations/services in freight and passenger sectors, provided that it is based on the ISO 14083 standard as the global reference methodology.

CLECAT considers that the reporting of logistics emissions accounting should remain for the coming years a voluntary initiative to allow the industry to get to grips with the international/ISO standard which will need further guidance for implementation by the sector. The EU should therefore take a step-by-step approach in mandating the reporting of GHG emissions: large companies which are already using their proper tools to calculate emissions could be obliged to report their emissions in the first place. SMEs should receive support to support for user friendly tools for measuring and reducing emissions, using climate commitments and actions as a value proposition to customers.

Ultimately, to achieve accurate reporting of GHG emissions, the ambition should be to move from default to real primary data. The reliability of the data, especially real data, is particularly important when it comes to issues relating to modal shift and transport decisions based on GHG emissions performance as this could be used in possible EU or national support schemes. For this reason, the data used for GHG calculation should be as close as possible to real data, and encompass a well-to-wheel approach, so as to better reflect GHG emissions across the supply chain.

It is expected that the Commission will publish the proposal in Q2 2023, together with other transport-related proposals (revised Weight & Dimensions Directive and revised Combined Transport Directive).