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CLECAT has given its response to the CountEmissionsEU initiative which sets out the Commission’s intention to initiate a common framework to calculate and report transport-related greenhouse gas emissions.  CLECAT supports 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.

Whereas CLECAT has since long been of the view that logistics emissions accounting and footprinting should remain a voluntary initiative led by the industry, we now consider that the time may be right for legislative measures – such as the development of a single EU framework for monitoring and calculating GHG emissions data of transport operations/services in freight and passenger sectors based on a global reference methodology. This should be subject to a number of conditions:

• The transport and logistic sector is an integral part in terms of facilitating international trade. That’s why as a reference methodology, the global standard for the calculation of emissions of transport and logistics supply chains including all modes of transport should be adopted. CLECAT has supported the development of the ISO standard (ISO 14083:2022) for quantification and reporting of GHG emissions of transport operations based on the GLEC Framework and in combination with a review of the existing European standard EN 16258 on calculation and declaration of energy consumption and GHG emissions of transport services.
• Facilitation of the uptake of GHG emissions accounting in business practices. Implementation should be easy at the first stage of introduction and can be improved over time, subject to the development of methods chosen. This would include technical support measures which would facilitate the use of GHG emissions accounting by stakeholders. This should involve developing simplified solutions and tools, especially for micro companies and SMEs, and specific software products and calculators.
• Whereas the objective should be to move from default data (as per GLEC framework)  to actual results, the calculation based on default-data must be accepted in the first place. Ultimately the aim should be to achieve real-time and primary data to incentivise improvement at corridor level of different modes. 
• A full impact assessment should be made on the possible impacts associated with compliance costs and administrative burden related to the adaptation, implementation, operation and maintenance of GHG accounting systems.

As a final comment, CLECAT appreciates that sustainability criteria will increasingly become a condition for forwarders to be able to become the suppliers of any customer in the future. We underline that the commercial decisions on how forwarders respond to these requirements remain with the commercial parties who can decide to focus on the minimum requirements or decide to taking a proactive approach and making green logistics part of their value proposition to customers, working together with shippers on joint emissions reduction goals.