COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND THE COUNCIL on the accounting of greenhouse gas emissions of transport services

EN EN
EUROPEAN
COMMISSION
Strasbourg, 11.7.2023
SWD(2023) 441 final
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT REPORT
Accompanying the document
Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND THE
COUNCIL
on the accounting of greenhouse gas emissions of transport services
{COM(2023) 441 final} - {SEC(2023) 441 final} - {SWD(2023) 440 final} -
{SWD(2023) 442 final}
Offentligt
KOM (2023) 0441 - SWD-dokument
Europaudvalget 2023
Table of contents
INTRODUCTION: POLITICAL AND LEGAL CONTEXT ........................................................................1
Rationale......................................................................................................................1
Political context...........................................................................................................1
EU and international context.......................................................................................2
Synergies with other EU policy instruments...............................................................4
PROBLEM DEFINITION..............................................................................................................................7
What are the problems?...............................................................................................7
What are the problem drivers? ..................................................................................10
Interlinkages between the problem drivers ...............................................................15
Affected stakeholders................................................................................................16
How likely is the problem to persist? .......................................................................18
Foresight....................................................................................................................19
WHY SHOULD THE EU ACT?..................................................................................................................20
Legal basis.................................................................................................................20
Subsidiarity: Necessity of EU action.........................................................................20
Subsidiarity: Added value of EU action....................................................................20
OBJECTIVES: WHAT IS TO BE ACHIEVED?.........................................................................................21
General objectives .....................................................................................................21
Specific objectives.....................................................................................................21
WHAT ARE THE AVAILABLE POLICY OPTIONS?..............................................................................22
What is the baseline from which options are assessed? ............................................22
Description of the policy measures and policy options.............................................24
HOW DO THE OPTIONS COMPARE? .....................................................................................................44
Effectiveness .............................................................................................................44
Efficiency ..................................................................................................................46
Coherence..................................................................................................................48
Subsidiarity and proportionality................................................................................49
Comparison of the options ........................................................................................50
Sensitivity analysis....................................................................................................50
PREFERRED OPTION................................................................................................................................51
Identification of the preferred policy option .............................................................51
Application of the ‘one in, one out’ approach...........................................................52
HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? ...........................................53
ANNEX 1: PROCEDURAL INFORMATION............................................................................................56
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT)................................................61
ANNEX 3: WHO IS AFFECTED AND HOW? ..........................................................................................75
ANNEX 4: ANALYTICAL METHODS .....................................................................................................80
ANNEX 5: COMPETITIVENESS CHECK ............................................................................................. 134
ANNEX 6: DISCARDED POLICY MEASURES.................................................................................... 136
ANNEX 7: RETAINED POLICY MEASURES....................................................................................... 141
ANNEX 8: ANALYSIS OF METHODOLOGICAL CHOICES FOR COUNTEMISSIONS EU............ 150
ANNEX 9: EFFECTIVENESS OF THE DIFFERENT POLICY OPTIONS ........................................... 187
ANNEX 10: SME TEST ........................................................................................................................... 194
ANNEX 11: CASE STUDIES AND USE CASES ................................................................................... 200
Glossary
Term or acronym Meaning or definition
boe barrels of oil equivalent
CEN European Committee for Standardisation
CH4 Methane
CO2 Carbondioxide
CO2-eq. Carbondioxide equivalents
DCS Data Collection System
EASA European Union Aviation Safety Agency
EPA Environmental Protection Agency (US)
GCD Great Circle Distance
GHG Greenhouse Gas
GLEC Global Logistics Emissions Council
IATA International Air Transport Association
ICAO International Civil Aviation Association
IPCC Intergovernmental Panel on Climate Change
ISO International Organisation for Standardisation
kWh Kilowatt-hour
LCA Life cycle assessment
MJ Mega Joule
MRV Monitoring, Reporting and Verification
NABs National Accreditation Bodies
N2O Nitrous oxide
NOx Nitrogen oxides
PEFCR Product Environmental Footprint Category Rules
pkm Passenger kilometre
SFD Shortest feasible distance
SOx Sulphur oxides
tkm Tonne kilometre
toe Tons of oil equivalent
TTW Tank-to-Wheel
WTT Well-to-Tank
WTW Well-to-Wheel
1
1. INTRODUCTION: POLITICAL AND LEGAL CONTEXT
1.1. Rationale
This Impact Assessment accompanies a new legislative proposal on the accounting of
greenhouse gas (GHG) emissions of transport services1
, hereafter “CountEmissions EU”.
Emissions accounting is a measure used in various economic sectors – including transport – to
generate emissions data from specific activities of businesses and individuals. Transparent
information on emissions empowers customers2
for more efficient choices and influences
business decisions of entities organising and offering different type of transport services3
on the
market. These data may therefore be considered an underlying requirement for stimulating
sustainability, innovation and behavioural change towards low and zero emission transport.
Benefits and value added of emissions accounting are evidenced by the outcomes of existing
emissions monitoring and reporting schemes in the EU and beyond4
.
Unlocking the potential of emissions accounting requires however that the underlying
calculations are comparable and accurate, addressing the characteristics and granularity of a
transport service. Therefore, emissions should be quantified based on a scientifically sound,
detailed and harmonised methodological approach. Currently, no such harmonised approach
exists. Instead, various standards, methodologies and calculation tools entailing different
approaches and diverging input data5
are used throughout the market. This situation results in
the provision of fragmented and incomparable emissions data that creates confusion among
businesses and citizens and hampers informed transport choices and business decisions.
CountEmissions EU aims to provide a single set of rules for the quantification of GHG
emissions and the harmonisation of the underlying data formats, thus enabling to generate and
share reliable and comparable information on the environmental performance of a given service
for all transport modes, segments and countries, across the EU.
1.2. Political context
Transport6
accounted for 26% of all EU GHG emissions in 2020, with road transport alone
representing around 20% of the total7
. The initiative has therefore to be seen in the context of the
European Green Deal (EGD)8
, and the European Climate Law9
which set out the steps
towards climate-neutrality by 2050. The Sustainable and Smart Mobility Strategy (SSMS)10
,
published on 9 December 2020 lays the foundation on how the EU transport system can achieve
1
I.e. transporting freight or a passenger from an origin to a destination; a transport service can imply one or multiple
transport chain elements requiring both transport operation(s) and/or hub operation(s).
2
Transport service users, see more in Annex 3
3
Transport service organisers and hub operators; see more in Annex 3
4
In the freight sector for instance, the EU-based Lean and Green, the UK Logistics Emissions Reduction Scheme
(LERS), and the US SmartWay programme.
5
Especially default values; see more in section 2.2
6
Including international aviation and maritime.
7
Statistical pocketbook 2022 (europa.eu)
8
COM(2019) 640 final
9
Regulation (EU) 2021/1119
10
COM(2020) 789 final
2
this systemic change, including a 90% cut in transport GHG emissions by 2050, to be delivered
by a smart, competitive, safe, accessible and affordable transport system. Apart from targeted
actions to make individual transport modes more sustainable, the Strategy also refers to
incentives for choosing the most sustainable transport options, within and across the modes. The
incentives may be of both economic and non-economic nature, including the provision of better
information for users and increased transparency of the GHG performance of transport services.
This is why the Strategy announced plans11
to “establish a European framework for the
harmonised measurement of transport and logistics greenhouse gas emissions, based on global
standards, which could then be used to provide businesses and end-users with an estimate of the
carbon footprint of their choices, and increase the demand from end-users and consumers for
opting for more sustainable transport and mobility solutions, while avoiding greenwashing”12
.
CountEmissions EU therefore represents a relevant policy response. In this context, it forms part
of the ‘Greening Freight package’, a set of initiatives catering for more sustainable solutions
to improve the operational and system efficiency of the transport sector.
Through its emissions reduction potential, CountEmissions EU will contribute towards the
United Nations Sustainable Development Goal (SDG) 13 “Take urgent action to combat climate
change and its impacts”. In addition, it will indirectly support SDG 7 “Ensure access to
affordable, reliable, sustainable and modern energy for all” and SDG 12 “Ensure sustainable
consumption and production patterns”.
1.3. EU and international context
Several standards and methodologies13
(both referred also as ‘methods’) are currently available
for the EU transport stakeholders to account GHG emissions from various transport activities.
These have been developed by standardisation bodies, public authorities or private organisations.
At international level, the GHG Protocol Corporate Accounting and Reporting Standard14
of 2001, was a pioneering initiative establishing a global standardised framework to measure and
manage GHG emissions of private and public sector organisations. The GHG Protocol enables
to account for indirect emissions from value chain activities as it is complemented by the
Corporate Value Chain (Scope 3) Accounting and Reporting Standard and can therefore be used
also for the quantification of emissions from transport and logistics15
.
11
Action 33 of the Action Plan accompanying the SSMS
12
Greenwashing is the practice of companies to give a false impression of their environmental impacts or benefits.
13
There may be different meaning of a standard and a methodology. An emissions accounting standard can be
commonly defined as the technical calculation and/or allocation rules used as a norm, or model in comparative
evaluations. A methodology can be based on a standard, and in most cases it forms part of a broader policy or
incentive programme. Source: Ecorys and CE Delft (2023), Impact assessment support study
14
https://ghgprotocol.org/
15
The Corporate Value Chain (Scope 3) Accounting and Reporting Standard is a supplement to GHG Protocol
Corporate Accounting and Reporting Standard allowing all types of organisations to assess their entire value chain
emissions impact, and identify where to focus reduction activities. Whereas Scope 1 and 2 refer to direct and indirect
emissions from activities of an organisation, Scope 3 reflects emissions generated outside of the owned or controlled
sources of this organisation, including from transport activities. Importantly, Scope 3 emissions for one organisation
may represent Scope 1 for another one (such as a transport service provider). See more under Corporate-Value-
Chain-Accounting-Reporing-Standard_041613_2.pdf (ghgprotocol.org)
3
The first transport-service specific standard was introduced in 2012 by the European Committee
for Standardisation (CEN)16
. CEN EN 16258 sets out a common methodology for the calculation
and declaration of energy consumption and GHG emissions related to any transport service17
.
At national level, the French Transport Code18
requires that all entities offering transport
services on the market (freight and passenger, including all modes) calculate GHG emissions for
each service departing from and/or ending in France, based on a specific methodology19
. The
French Transport Code also provides that the information on emissions should be reported to
relevant parties20
, which is the only mandatory requirement of this type in the EU.
Specific methodologies for GHG emissions accounting exist also in the different segments of
the transport sector, especially in freight. In many cases, they form part of broader green transport
programs or other initiatives promoting efficient and low carbon transport activities. These
include for instance the industry-led Global Logistics Emissions Council (GLEC)
framework21
, the public-private US SmartWay program, and the Topsector Logistics22
collaboration program between the Dutch government and businesses.
Furthermore, there are numerous mode specific emission accounting methods and requirements,
which are either developed by the industries themselves, or launched by public authorities as
parts of specific legislative frameworks. In maritime, for instance, there exists the Clean Cargo
Working Group23
, a business-to-business initiative for containerised sea transport. Also, the
International Maritime Organisation (IMO)24
adopted a mandatory Fuel Oil Data Collection
System (DCS) for international shipping, requiring vessels to collect and report relevant data
into a common database25
. Concerning aviation, the Carbon Offsetting and Reduction Scheme
for International Aviation (CORSIA)26
developed by the International Civil Aviation
Organisation (ICAO)27
provides a method to calculate CO2
28
emissions at the flight level. ICAO
and the International Air Transport Association (IATA)29
have also established standards for the
16
https://www.cencenelec.eu/
17
Despite its important contribution towards harmonising emissions accounting processes, EN 16258 is still
considered not precise enough to deliver fully comparable and consistent emissions data for services performed
across various transport segments. It is also a purely European standard that creates limitations for stakeholders
operating globally. Until March 2023, when ISO 14083 was published, EN 16258 was the only transport specific
and multi-modal (i.e. covering road, rail, IWT, maritime transport and aviation) standard available. Source: Ecorys
and CE Delft (2023), Impact assessment support study
18
Article L. 1431-3
19
Established on the basis of CEN standard EN 16258
20
Such as a person purchasing tickets for the transport of passengers, or a transport service user for the shipment of
goods
21
https://www.smartfreightcentre.org/en/how-to-implement-items/what-is-glec-framework/58/
22
https://topsectorlogistiek.nl/
23
https://www.bsr.org/en/blog/clean-cargo-working-group-transparency-and-transformation-in-ocean-transpor
24
All EU Member States are IMO members
25
https://www.imo.org/en/ourwork/environment/pages/data-collection-system.aspx.
26
Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) (icao.int)
27
All EU Member States are ICAO members
28
For alternative fuels, the relative reduction should be based on CO2, CORSIA methodology calculates carbon
dioxide equivalent (CO2e) emissions: of CO2, CH4 and N2O
29
https://www.iata.org/
4
aviation sector that prescribe in more detail how emissions need to be reported per passenger and
per tonne of freight30
.
Given this fragmented methodological landscape, there have been various efforts by both the
European Commission and industry towards a harmonised methodological framework. Between
2011 and 2019, two consecutive EU-funded projects, the FP7 - Carbon Footprint of Freight
Transport (COFRET)31
and H2020 – Logistics Emissions Accounting & Reduction Network
(LEARN)32
, addressed the calculation, reporting and verification of GHG emissions from
transport services, with the aim to develop a global method. These efforts led to the development
of the GLEC framework (mentioned above) and initiated a coordinated action towards
establishing a comprehensive and tailor-made standard at the level of International Organization
for Standardization (ISO)33
. This new standard, referred to as ISO 1408334
was published in
March 2023 and adopted by CEN in April as EN ISO 14083:202335
. It builds inter alia on the
CEN EN 1625836
and GHG Protocol.
1.4. Synergies with other EU policy instruments
As a cross-modal, horizontal initiative, CountEmissions EU accounts for synergies and
complementarities with other regulatory EU actions regarding emissions reduction frameworks,
fuel and emissions standards, enhanced transparency for users and stronger consumer rights.
These relationships concern in principle the use of input data and emissions accounting methods,
as well as the requirements related to the unambiguous communication on GHG emissions of
transport services.
In this regard, there are important interlinkages with regulatory actions regarding the collection
of information on emissions and environmental reporting. Under the EU MRV framework37
maritime vessels above 5,000 GT sailing to and from EU ports have to monitor, verify and report
annually their CO2 emissions based on the fuel burned during the performance of their
activities38
. In aviation, the Emissions Trading System of the European Union (EU ETS)39
requires airlines to calculate CO2 emissions per flight in a comparable way as established by
CORSIA, and to submit an emissions report for each year. While EU MRV and EU ETS serve
different objectives and do not lead to accounting emissions of specific services40
, they may be
30
https://www.iata.org/en/programs/environment/
31
https://cordis.europa.eu/project/id/265879
32
https://learnproject.net/
33
https://www.iso.org/home.html
34
A transport specific method on the quantification and reporting of greenhouse gas emissions arising from transport
chain operations. https://www.iso.org/standard/78864.html
35
Greenhouse gases - Quantification and reporting of greenhouse gas emissions arising from transport chain
operations (ISO 14083:2023)
36
EN ISO 14083 superseded CEN EN 16258 based on specific arrangements between CEN and ISO. EN ISO
14083 is the version of the standard that is referred in respective policy measures and options in the remaining of
this document
37
Regulation (EU) 2015/757
38
The data monitored and reported for the EU MRV Regulation are intended to be used for other upcoming
initiatives, like the possible inclusion of maritime shipping in the EU ETS or FuelEU Maritime.
39
Directive 2003/87/EC
40
For instance the differences relate to the methodological boundaries applied and the allocation of emissions to
transport service level. Both terms in the context of emissions accounting are explained in Annex 8.
5
seen as complementary to CountEmissions EU, especially as regards the collection of the actual
energy consumption data. The consistency of the input data for quantifying GHG emissions is
also addressed in the context of the emerging EU initiatives on the uptake of renewable low
carbon fuels. To this effect, CountEmissions EU includes a thorough reflection of the Fit-for-55
package41
, with particular reference to the Commission’s proposals for the revised Renewable
Energy Directive (RED II)42
, and the new initiatives FuelEU Maritime43
and ReFuelEU
Aviation44
, the latter consisting inter alia of provisions for a dedicated environmental label
for flights45
. The revised RED II and FuelEU Maritime specifically, will offer sets of default
values46
for emissions generated during the lifecycle of fuels (“Well-to-Wheel” emissions)47
. All
these aspects would be of high relevance for the uniform implementation of CountEmissions EU
on the European market. This implementation will also take account of other legislative
frameworks, such as CO2 performance standards for new heavy-duty vehicles48
and light
duty vehicles49
, as well as a planned EU action on the access to in-vehicle generated data50
.
Possible synergies may be related for instance to the collection of actual fuel consumption data,
and to default values on the CO2 emissions per vehicle kilometre in road transport51
.
On the other hand, information on GHG emissions calculated and collected when applying
CountEmissions EU, may be used for the purpose of corporate reporting, such as in the context
of Corporate Sustainability Reporting Directive (CSRD)52
. The CSRD and CountEmissions
EU are consistent in their approach, both aiming at CO2 equivalent emissions of Scope 1 (direct
emissions), Scope 2 (indirect emissions from the generation of purchased or acquired electricity,
steam, heat, or cooling consumed by the undertaking), and Scope 3 (indirect emissions that occur
in the value chain of the reporting company)53
. While these frameworks differ in terms of the
subject and level of precision (the CSRD refers to the emissions at the level of an entire company
and CountEmissions EU covers emissions from door-to-door transport operations), information
generated by CountEmissions EU may contribute to sustainability reports of companies thus
facilitating the implementation of the CSRD. However, it should be noted that the vast majority
of entities targeted by CountEmissions EU (i.e. SMEs and micro-companies) would not be
affected by the CSRD requirements addressing rather large European companies, as well as
companies listed on regulated markets, except listed micro-enterprises.
41
https://ec.europa.eu/commission/presscorner/detail/en/IP_21_3541
42
COM(2021) 557 final
43
COM(2021) 562 final
44
COM(2021) 561 final
45
The development of an environmental label for aviation is based on Action 35 of the SSMS. The label may consist
of different elements, including a flight emissions assessment.
46
Derived by using pre-determined factors based on estimates.
47
This makes the difference with the approach applied in the EU MRV, IMO DCS, CORSIA and EU ETS, which
address solely activity based emissions (“Tank-To-Wheel”). The fuel/energy lifecycle covering both activity-based
emissions and those generated at the production and distribution of fuels is referred to as “Well-To-Wheel”.
48
Regulation (EU) 2019/1242
49
Regulation (EU) 2019/631
50
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13180-Access-to-vehicle-data-
functions-and-resources_en
51
It has to be noted however, that these initiatives address only activity-based emissions (“Tank-to-Wheel”) and do
not cover those generated upstream (“Well-to-Wheel”).
52
Directive 2014/95/EU
53
Addressed in the GHG Protocol
6
As regards the efficient information flow in logistics chains, Regulation (EU) 2020/1056 on
electronic freight transport information (eFTI)54
relates to the exchange of regulatory
information on transport of goods by road, rail, air and inland waterways in the electronic form.
It will allow operators to prove compliance to a wide range of both European and national
reporting formalities applicable to the transport of goods. By establishing a fully decentralised
but harmonised and trusted data sharing network, eFTI is expected to support sharing of GHG
emissions data between various entities and individual users, thus supporting the implementation
of this initiative.
CountEmissions EU also seeks complementarities with the Circular Economy Action Plan
(CEAP)55
and, under its umbrella, with specific initiatives aiming at the provision of adequate
information to consumers. In particular, it interlinks with the Product Environmental
Footprint (PEF)56
as regards methodological requirements for quantifying emissions. PEF was
originally developed in the context of Single Market for Green Products Initiative57
, and
provides a horizontal and cross sectoral method for the measurement of the environmental
performance of a good or service throughout its full life cycle (LCA). However, the general PEF
framework does not specifically address transport services and its implementation for
benchmarking purposes would still require the definition of specific Product Category Rules58
.
An analysis of PEF in the context of CountEmissions EU is presented in Annex 8.
Synergies were also identified with Directive 2005/29/EC concerning unfair business-to-
consumer commercial practices in the internal market that applies to misleading
environmental claims, and subsequently, the proposal for a Directive on empowering
consumers for the green transition (amending Directive 2005/29/EC) that sets out a number
of specific requirements on environmental claims and prohibits communicating generic
environmental claims which are not based on recognised environmental performance relevant to
the claim59
. These synergies concern in principle the need for better and reliable information on
sustainability aspects of services, including the protection of consumers against information that
is not true or presented in a confusing or misleading way, in order to give the inaccurate
impression that a service is more environmentally sound. CountEmissions EU would regulate
specific aspects of environmental claims through the provision of a harmonised, commonly
applicable framework, ensuring accurate and comparable emissions data to be made available to
consumers by any relevant entity accounting emissions of transport services.
The Commission’s proposal for Directive on substantiation and communication of explicit
environmental claims (Green Claims Directive)60
is conceived as lex specialis to Directive
54
Regulation (EU) 2020/1056 of the European Parliament and of the Council of 15 July 2020 on electronic freight
transport information; OJ L 249
55
COM(2020) 98 final
56
Commission Recommendation (EU) 2021/2279. Full life cycle emissions “From cradle to grave”, include the
emissions of vehicle production, maintenance and disposal, and infrastructure as far as relevant.
https://ec.europa.eu/environment/eussd/smgp/
57
EUR-Lex - 52013DC0196 - EN - EUR-Lex (europa.eu)
58
Currently, PEF Category Rules are not available for transport services. It should be noted that specific Category
Rules would need to be still elaborated for a broad range of products and services across all the economic sectors
of the EU.
59
COM/2022/143
60
COM/2023/166 final
7
2005/29/EC. Green Claims Directive addresses the lack of trust in the credibility of
environmental claims and the proliferation of misleading commercial practices related to the
environmental sustainability of products. This Regulation is complementary to the provisions
related to explicit environmental claims, specifically where assessing and communicating GHG
impacts of transport services.
Finally, interactions with the Car Labelling Directive61
and Tyre Labelling Regulation62
,
dealing with the provision of information to transport users regarding fuel economy, efficiency
and emissions, were also investigated. However, these initiatives focus rather on data related to
the type of a vehicle or tyre, and not on those associated with emissions of transport services,
thus being less relevant for CountEmissions EU.
2. PROBLEM DEFINITION
The underlying problems, problem drivers and implications that are relevant for CountEmissions
EU are presented in Figure 1: Problem treeError! Reference source not found..
Figure 1: Problem tree
1.1 What are the problems?
Problem 1 – Limited comparability of results from GHG emissions accounting of transport
services in transport and logistics
Accurate and reliable figures are seen as a prerequisite to effectively manage emissions and to
use emissions data for specific areas of application, such as setting and monitoring emissions
targets, or benchmarking the environmental performance of services from different transport
operators. However, as indicated above, currently no universally accepted framework for the
GHG emissions accounting in transport exists. To quantify emissions, transport stakeholders can
choose from a basket of different standards, methodologies, calculation tools and numerous
emissions default values databases and datasets.
61
Directive 1999/94/EC
62
Regulation (EU) 2020/740
8
This situation leads in many cases to a very high variance of results that compromise the
comparability of emission figures in the market63
. It also bears the risk of selecting an emissions
calculation method and default data based on what is more beneficial for an individual entity.
This results in the provision of misleading information on the performance of a transport service,
thus creating conditions for greenwashing and turning up in wrong incentives for a user. The
problem may be further aggravated by the reluctance of companies to disclose detailed GHG
emissions data quantified from their transport operations, as this driver may contribute to the
existence of an incomplete and inconsistent transport emissions data environment.
As a consequence, environmental claims related to transport services cannot, in particular in a
multimodal context, be compared in a fair and meaningful way by either businesses or
consumers. GHG emissions figures that are not accurate, do not allow to make informed choices
and may cause market distortions because of potential competitive advantages for those entities
that do not use a proper calculation method, or formulate untruthful or unsubstantiated claims.
The issue is generally recognised and has materialised in several attempts by industry or national
governments64
to produce a standard framework. However, none of these efforts has led to the
harmonisation of the GHG emissions accounting methods and uniform treatment of data at the
entire EU level.
The lack of reliable and comparable information on GHG emissions of transport services is seen
as a relevant problem also by the consulted stakeholders. It was in principle confirmed by the
results of the Open Public Consultation (OPC), with 136 out of 169, or 80% respondents
recognising the prevalence of this problem and considering it significant or very significant.
Similar views were recorded while analysing the feedback to the Call for Evidence, the targeted
stakeholders’ survey (‘targeted survey’) as well as during the discussions at the stakeholders’
workshop65
.
Problem 2 – Limited uptake of emissions accounting of transport services in usual business
practice
Despite growing interest of transport stakeholders in GHG transport performance data66
, the
overall uptake of GHG emissions accounting of transport services is still very limited. In most
cases, transport service users do not obtain accurate information on the performance of transport
services, and transport service organisers do not calculate their emissions. What is more, most
of transport service organisers that do so, make calculations rather at a company or vehicle level,
and are not able to generate data on the emissions of transport services67
, while only the latter
63
Auvinen, H. et al., 2014. Calculating emissions along supply chains - Towards the global methodological
harmonisation. Research in Transportation Business & Management. Binnenvaartemissielabel, 2022.
64
Such as Article L. 1431-3 of the French Transport Code or GLEC framework mentioned in section 1.3
65
Organised on 27 October 2022
66
Desk research and targeted interviews highlighted that the main motivations were to raise environmental
awareness and meet emissions reduction targets, as sales argument or as a decision-making support tool. Source:
Ecorys and CE Delft (2023), Impact assessment support study
67
In order to generate accurate data on the GHG performance of a transport service (especially in the multimodal
transport chain) it is necessary to account emissions of each individual transport chain element (leg). This level of
calculation requires specific data and is more complex and costly from the perspective of an individual organisation.
See more in Annex 8
9
type of information is relevant to support and influence decisions of users. In this context, it is
estimated that almost 600,000 entities in the EU transport ecosystem measure their emissions
(2020), but only about 22,000 of these do it at such disaggregated level that enables to produce
GHG emissions data of transport services. This represents only 1.2% of the overall population
of the entities performing transport operations on their own (amounting to approximately 1.8
million)68
.
It should be also acknowledged that the capability of companies to calculate and report GHG
emissions does not spread equally across the EU. According to a 2021 analysis undertaken for
road freight carriers, this capability is significantly higher in countries implementing specific
green freight programs, such as the Netherlands, France and Austria. France, applying Article L.
1431-3 of the French Transport Code69
, is a particularly good example showing that a targeted
legislation may lead to considerable results, despite lax enforcement70
.
There are several drivers behind this problem, including the perceived complexity and high costs
of GHG emissions accounting, the lack of trust regarding the emissions figures that are shared
on the market, and the reluctance of transport service organisers to reveal sensitive operational
data. This problem is particularly relevant for small and medium sized enterprises (SME)71
,
offering transport services on the EU market72
. Given that road freight transport represents the
largest population of SME carriers73
, this segment is particularly affected74
.
The problem of the limited uptake of emissions accounting in usual business practice was also
highlighted in the stakeholders’ consultation. In the OPC 45 out of 56 organisations (80%); 61
out of 70 individuals (87%); and 60 out of 65 online customers (92%) stated they are not given
enough information when planning/organising a journey, shipment or choosing the delivery of
their package. In addition, 26 out of 31 (84%) respondents to the targeted survey estimated
current levels of uptake as low or very low. Looking from the emissions accounting perspective,
the targeted survey showed that although 78% of the respondents (29 out of 37) already measure
in some form their emissions, only 35% of those who measure (9 out of 26) do it at transport
service level. However, this finding may not be fully representative for all entities concerned,
and, as outlined above, the actual number of companies calculating transport services emissions
appears to be significantly lower. Altogether, various consultation activities demonstrated that
emissions accounting in transport and logistics is still very limited in uptake, completeness,
68
Ecorys and CE Delft (2023), Impact assessment support study
69
See Annex 8 and Annex 11 for more detail
70
Tölke, M. and McKinnon, A. (2021), Decarbonizing the operations of small and medium-sized road carriers in
Europe. An analysis of their perspectives, motives, and challenges, Smart Freight Centre, Kühne Logistics
University.
71
Small and Medium Enterprises (SMEs) are companies with a staff headcount lower than 250 and turnover equal
or lower than EUR 50 million (either a balance sheet total equal or lower than EUR 43 million), according to EU
Recommendation 2003/361.
72
Tölke, M. and McKinnon, A. (2021), Op.cit.
73
Source: Eurostat (SBS_SC_1B_SE_R2)
74
A 2021 survey among 811 carriers from 32 European countries, showed that only around 10% of carriers with
fewer than 10 vehicles are able to calculate and report emissions at a customer level (compared to 25% carriers in
total), Tölke, M. and McKinnon, A. (2021), Op. cit. Another survey among 252 road carriers demonstrated that only
about 23% of respondents in total are able to calculate transport related emissions. Source: Transporeon (2022),
Decarbonizing Freight 2022. Where shippers and carriers stand on the road to net zero.
10
frequency and precision. Feedback to another question of the same targeted survey revealed that
most respondents (30 out of 31) would adopt a harmonised emissions measurement framework
if established at the EU level.
1.2 What are the problem drivers?
Problem Driver 1: No set of common methodological principles to apply GHG emissions
accounting
As already shown in section 1.3, there exists a highly fragmented environment of methods
available for accounting emissions of transport activities. Some of them function as self-standing
initiatives to be applied by any interested party, other form part of specific policies, reporting
schemes and green incentive programmes that oblige or promote measurement and calculation
of emissions among the respective stakeholders’ groups. Also, several methods feature in the
various calculation tools75
that are offered to market players to facilitate and simplify emissions
accounting. Table 1 provides an overview of methods identified as the most relevant for the
transport sector.
Table 1: Overview of the main methods for GHG emissions accounting in the transport sector
Standard/methodology Transport modes/segments
GHG protocol All modes Passengers & freight
EN 16258 All modes Passengers & freight
ISO 14083 All modes Passengers & freight
PEF All modes Passengers & freight
French transport code (Article L. 1431-3) All modes Passengers & freight
Parcel Delivery Environmental Footprint76
All modes Parcel
GLEC All modes Freight
SmartWay All modes Freight
Topsector All modes Freight
Clean Cargo Working Group Maritime Freight
EU MRV Maritime Freight
IMO DCS Maritime Freight
CORSIA Aviation Passengers & freight
ICAO/IATA RP1678 Aviation Freight
IATA Aviation Passengers
EU ETS aviation Aviation Passengers & freight
Source: Ecorys and CE Delft (2023), Impact assessment support study
These methods have been, or are being developed, by various bodies, including standardisation
organisations77
, public authorities78
and industry associations79
, based on specific principles,
objectives and perspectives, in many cases entailing very specific governance structures80
. Some
75
Such as BigMile, Carbon Care, Carbon Visibility/Transporeon, EcoPassenger, EcoTransit, Eurocontrol small
emitters tool, GHG Protocol Calculation tool for transport, GreenRouter, LogEC, NTM calc, Reff tool, Seaexplorer,
Sncf, TK'Blue, TRACKS.
76
https://single-market-economy.ec.europa.eu/sectors/postal-services_en
77
E.g. CEN EN 16258
78
E.g. French Transport Code
79
E.g. IATA RP1678
80
E.g. Topsector
11
of these cover only individual segments or modes of transport; others enable to quantify
emissions across the entire transport chain.
The methods differ in terms of principles and approaches. These differences concern a number
of design elements, including the scope (such as type of emissions covered81
, activity
boundaries82
, intended users83
, perspective84
), the method of emissions calculation (granularity
of output85
, metrics86
) or allocation of emissions to transport services87
, thus resulting eventually
in highly inconsistent and non-comparable GHG emissions data that is available on the market.
A detailed analysis of these specific methodological principles and approaches in relation to the
identified methods is provided in Annex 8.
The responses to the OPC acknowledged that the proliferation of standards and methodologies
poses a serious challenge for the comparability of emissions data. 90% of respondents (157 of
174 respondents) indicated the problem with fragmented emissions calculation methods in the
transport sector to be at least significant, and 69% (113 out of 163) stated that this situation
affects their private or professional activities. This problem driver was reported as important also
in the other consultation activities.
Problem Driver 2: No set of harmonised input data to apply emissions accounting
The lack of harmonised input data is another key driver contributing to the limited comparability
of results from GHG emissions accounting in transport and logistics (problem 1). Depending on
the method chosen88
, different types of input data are required or used to quantify emissions from
transport activities. The types of data required or used are presented in Box 1.
Box 1. Type of data
Primary data (actual data) recorded at source by continuous monitoring and measuring actual fuel/energy
consumption. This may also include transport performance data (e.g. origin, destination, number of persons /
volume of freight transported).
Secondary data include default values from literature or modelled data.
81
E.g. CO2 emissions, non-CO2 emissions originating from combustion of fuel, non-CO2 emissions originating from
refrigeration, global warming effect of emission of non-CO2 products at high altitudes, global warming effect of
black carbon emissions, etc.
82
Tank-to-Wheel, Well-to-Wheel, full lifecycle.
83
Transport service providers, transport users.
84
Ex post, ex ante.
85
Total GHG emissions of a transport operator, GHG emissions of a transport service user or organiser, transport
service level (passenger, freight type, mode), transport chain element/leg, single vehicle, individual trip, total GHG
emissions of a hub operator, GHG emissions per activity at hub.
86
E.g. emissions per tonne-km or passenger-km.
87
Company level, transport leg level, transport chain element, trip level - journey specific.
88
Some methods prescribe only activity based emissions (primary information and/or emission intensity factors),
e.g. MRV, CORSIA; other cover the energy lifecycle emissions (activity based emissions and energy emission
factors), e.g. ISO 14083, CEN 16258; and other reflect emissions generated during the full lifecycle of products,
such as PEF.
12
The following default values are most relevant in the context of CountEmissions EU: (1) GHG emission
intensity factors (default values for GHG emission intensity), used to derive estimates of GHG emissions related
to fuel combustion based on transport performance data. These factors are often expressed in grams of GHG
emissions per vehicle kilometre, grams of GHG emissions per tonne-kilometre or grams of GHG emissions per
passenger-kilometre; (2) GHG energy emission factors (GHG emission factors), used to derive estimates of
GHG emissions based on the amount of energy/fuel used. These factors are often expressed in grams of GHG
emissions per litre/kWh or grams of GHG emissions per MJ; and (3) other emission factors applied by methods
that incorporate emissions stemming from the production and scrapping of vehicles, or infrastructure use.
Modelled data are data established by use of a model that takes into account primary data and/or GHG emission-
relevant parameters of a transport operation or hub operation. The model may be provided for instance through
a commercial calculation tool offered on the market
The majority of methods listed in Table 1 and in Annex 8 prioritise the use of primary data
reflecting the actual fuel/energy consumed while performing operations. Nonetheless, this type
of information is not always available to businesses89
, and in this case default values need to be
applied. On the other hand, using default values, or even modelled data, bears the risk that the
calculation outcomes do not reflect all the relevant aspects of a transport service. To limit this
risk, default values should be based on trustful, scientifically proven and accurate datasets, and
the GHG emission-relevant parameters of modelled data should result in best possible
representation of actual GHG emissions of a transport service.
Currently available databases of default values are scattered across the entire transport sector,
and this concerns especially those covering the emission intensity factors90
. The emission
databases often have a national scope, reflecting emission intensity factors in gram per vehicle-
kilometre, passenger-kilometre or tonne-kilometre. There are important differences between
countries, for instance regarding the share of transport modes used (e.g. road, rail, aviation,
waterborne), the composition of the vehicle fleet, energy mix, etc. What is more, a number of
specific datasets are also embedded in specific calculation tools offered on the market as a
support for emissions accounting, thus further contributing to the proliferation of the default
values environment91
.
As a result, transport service organisers (and other entities calculating emissions from transport
services) face considerable challenges to access credible sources of input data for the
quantification of their GHG emissions, in particular for cross-border transport activities. As the
available datasets, especially in case of emission intensity factors, vary in terms of their
specification level (also because of different models used to calculate the values), this leads to
substantial divergences in the GHG emissions data, even when calculated using the same
method92
.
89
For example, Stevens et al., 2018, Towards an adequate methodology for GHG emissions accounting in logistics,
TU Delft, found that one of the main challenges of applying GHG emissions accounting for transport at Heineken
is obtaining accurate (primary) data.
90
For instance ADEME, DBEIS/DEFRA, GLEC, STREAM.
91
It should be noted that approaches used by these tools differ widely. Some of them focus on calculating emissions
based on default data, while other tools aim to support users in their GHG emissions accounting by automating
calculations based on primary data and allocating the emissions to specific transport services.
92
Based on the experimentation in the EU LEARN project.
13
This problem driver was signalled by several stakeholders during the targeted survey and
especially the workshop as a key barrier hampering the comparability of the GHG emissions data
in the transport chain. Also, 24 of the 31 (77%) respondents to the targeted survey considered it
relevant or highly relevant (addressing it together with the driver related to the proliferation of
methodological principles).
Problem Driver 3: Reluctance to reveal sensitive operational data
GHG emissions accounting may be perceived to imply sharing commercially sensitive data.
Primary data in particular, may reveal the amount of fuel or energy consumed that is related to
the assignments of specific customers, and therefore emissions can be reversely converted into
the cost of operation. Especially in the freight transport sector, this is seen as a factor negatively
affecting the negotiating power of transport operators vis-à-vis users, or creating competition
issues amongst operators themselves.
As a result, transport operators very often are reluctant to share actual emissions data, even
though the attempts to reverse-engineer costs are often complex and expensive. This situation
occurs in particular when the data of competitors show better performance, or if the operator
considers that competitors may use different (more beneficial from their viewpoint) methods to
compute the data, or eventually when a user is able to estimate the actual cost of the service. The
latter is mostly related to the issue of splitting incentives between transport operators and users,
stemming from contractual agreements and reflecting for instance the division of responsibility
for the fuel costs that has an impact on the final price of the service.
This reluctance is a driver behind the limited availability of the GHG emissions data, and overall
low uptake of emissions accounting on the market. If operators refuse to share data on their actual
emissions, transport users have to use modelling data or default values to complete their GHG
emissions calculations. Consequently, these calculations reflect less accurately the actual
emissions associated with the transport services, thus hindering the quality and comparability of
these data.
In the OPC, this problem driver was generally regarded as more important by stakeholders
operating in the freight and logistics segments, and especially by those working with complex
supply chains. In the targeted survey, 19 out of 31 (61%) respondents indicated that this problem
driver is either highly relevant or relevant. Although both large and small organisations are
reported to be unwilling to share operational data, operators and users interviewed in the targeted
consultation pointed out that particularly SMEs are hesitant in this respect, since they have less
market power and hence, they perceive disclosing information on their emissions as a higher
risk.
Problem Driver 4: Lack of trust concerning GHG emissions output data
The trust in the relevance of GHG emissions output data is strongly correlated with their
reliability and accuracy. This trust may be compromised if there is no confidence on how the
emissions figures are calculated and what type of input data are used. The lack of trust therefore
limits the demand for the emissions data from transport service users, and results in disincentives
for transport service organisers (especially operators) to make the calculations.
There are several reasons behind this situation. Some of them are associated with the
proliferation of GHG methods and the very fragmented landscape of default emissions values,
14
discussed above. Others are linked to the fact that transport service providers make unconscious
errors in their measurements and calculations of emissions, or intentionally underreport their
GHG emissions to improve their own competitive position on the market93
. For instance, the
latter may take the form of “values shopping”. If emissions accounted from primary data are
higher than those resulting from the use of specific default values, there is a strong incentive on
the part of the reporting organisation to use secondary data, at the expense of their accuracy and
reliability. These causes are closely related to the issue of unsubstantiated environmental claims
and greenwashing and are further exacerbated by the absence of a common data verification
system that would guarantee the uniform application of accounting processes and the reliability
of the GHG emission calculation across transport modes and segments. On the other hand
however, additional costs and burden associated with the verification activities may further
discourage certain stakeholders from accounting and sharing emissions data.
According to the stakeholders consulted, the lack of trust concerning GHG emissions output data
is a reason for less demand for such output data and hence lower uptake of GHG emissions
accounting. In particular, the lack of a credible and harmonised verification mechanism for the
output shared or published has been raised as an issue by many stakeholders during the
workshop. In the OPC, 145 out of 175 respondents acknowledged that the access to reliable and
accurate GHG emissions data is very important or important.
Problem Driver 5: Perceived complexity and high costs of GHG emissions accounting
The uptake of GHG emissions accounting, especially by transport operators, is also hampered
by the perceived complexity and high associated costs, especially related to the operation of
specific computation processes, and sharing of GHG emissions output data in the transport
networks.
The GHG emissions computation processes require the combination and matching of various
data sets, which may be stored in different systems and parts of an organisation94
. Particularly in
case of fragmented or incomplete data, the use of different sources, inside or outside of an
organisation, proves to be challenging. This situation is further aggravated by the proliferation
of methods and defaults values datasets, and by the limited availability of transport activity data
that is required for quantifying emissions related to actual operations95
. The perceived
complexity and costs associated with the computation processes concern in particular small
transport operators that very often are confused by the fragmented methodological environment,
do not have the capacity and resources to collect primary data, to allocate it to specific
operations/shipments/passengers and to perform the calculation of their emissions.
93
Dobers, K. et al. (2019), Challenges to standardizing emissions calculation of logistics hubs as basis for
decarbonizing transport chains on a global scale, Transportation Research Record 2673, no. 9 (2019): 502-513.
94
For instance, fuel use data, which are often stored by the financial administration of an operator (as it is what
transport operators buy), need to be matched with transport activity data, which are stored elsewhere (as it is related
to customer orders) or they may be even in the possession of a shipper who has a better view on these data. Source:
Dobers, K. et al. (2019), Challenges to standardizing emissions calculation of logistics hubs as basis for
decarbonizing transport chains on a global scale, Transportation Research Record 2673, no. 9 (2019): 502-513.
95
For instance, because the exact mass of a shipment is not recorded or available routing information is not detailed
enough (e.g. missing data on the actual route followed by the vehicle). Ehrler, V.C. et al. (2018), Standardisation of
transport chain emission calculation - status quo and what is needed next, Proceedings of 7th Transport Research
Arena TRA 2018
15
Subsequently, a large number of SMEs, and especially microenterprises are reported as not being
able to account their emissions, or not even having emission accounting capabilities96
. SMEs
also experience specific knowledge gaps97
, while for larger companies, data collection and data
quality/completeness are the most challenging issues. In addition, as already shown above, a
number of businesses that eventually decide to calculate emissions are unable to perform these
activities at the service (leg) level.
Furthermore, there are also significant costs perceived with processing and sharing of GHG
emissions output data between transport service organisers and transport service users. In freight
transport, for instance, a large shipper may work with a wide range of carriers undertaking
operations in specific parts of the supply chain, including cross-border. Collection of GHG
output data therefore means dealing with different subcontractors that quantify emissions in
different forms, based on different underlying methodologies, assumptions and default values98
.
Large carriers face a mirror problem, as they frequently need to report to an uncountable number
of customers, who may have their own requirements for reporting. In addition, in the passenger
transport segment, the collection of information on emissions output data from operators can be
hampered by the fact that in many cases contracts with public authorities, or other responsible
bodies, are long term and the requirements to provide information on emissions output data had
not always been reflected in the past negotiations.
20 out of 31, or 64% of the stakeholders that replied to the targeted survey, consider this problem
driver relevant or highly relevant. Respondents to the OPC also ranked this driver among the
most relevant ones when asked about reasons of not measuring emissions by transport service
providers. These findings were also broadly confirmed in the context of the targeted interviews
and workshop.
1.3 Interlinkages between the problem drivers
Different characteristics and hierarchy of the problem drivers
The identified problem drivers may be categorised as either of a more technical (PD1 and PD2)
or behavioural type (PD4 and PD5). This typology was reflected in the construction of the
problem tree, where PD1 and PD2 represent main drivers behind the technical Problem 1, and
PD4 and PD5 are linked to more behavioural Problem 2. PD3 is mainly associated with the
behavioural Problem 2, however it may have some implications (i.e. the use of imprecise default
values instead of primary data) on Problem 1 as well.
Based on the results of various stakeholders’ consultation activities (summarised in Annex 2)
PD1, PD2 and PD4 are considered as having the highest weight. These drivers were addressed
96
For instance, according to the survey of Smart Freight Centre and Kühne Logistics University, reported above,
around 60% of the operators with fewer than 10 vehicles claim to have no emission measurement capabilities at all.
Source: Tölke, M. and McKinnon, A. (2021), Op.cit.
97
For instance, test cases carried out in the LEARN (Choumert & Smit, 2019) show that a common mistake made
by small road carriers was in the computation of transport activity. All small road carriers that took part in the test
cases computed transport activity by multiplying the sum of kilometres driven by the sum of weight of all shipments
transported instead of summing up all shipments multiplied by the shipment-specific distances.
98
Sources: Connekt (2021), Carbon Added Accounting - Background and principles of the CCA framework;
Logistics Innovation (2021), Carbon accounting in freight transportation after the publication of EN 16258; Stevens,
H. et al. (2018), Towards an adequate methodology for GHG emissions accounting in logistics - A case study at
Heineken, TU DELFT
16
with key policy measures structured around the methodological framework, input data and
conformity (see Section 5.2 and Annex 7).
Synergies and trade-offs between the problem drivers
PD1 and PD2 featured very prominently in the debate with stakeholders. Because of the impact
that the choice of the common reference method will have on other choices, i.e. the input data
that needs to be used, PD1 and PD2 are inherently interlinked. For instance, a different set of
default values would be necessary for using well-to-wheel (WTW) and full life cycle assessment
(LCA) methodologies, respectively. Therefore, it is not possible to fully disentangle how to deal
with input data from the choice of a method. The two drivers are therefore “feeding” each other
while the quality of the output of the calculations will be substantially based on the quality of
the input data, and the solidity and acceptability of the method. However, the relationship
between PD1 and PD2 is rather nuanced and therefore these drivers were separated on clear
request of the stakeholders. This is because the use of different methodologies and different sets
of input data leads to higher variance of GHG emissions calculation results, but significant
inconsistencies may also be observed when using the same methodology and different type of
input data. PD1 and PD2 also show some trade-offs with PD4 and PD5, as presented below.
PD3 needs to be considered in conjunction with PD4 concerning the lack of trust, and PD5
related to the complexity and high costs of emissions calculation. Concerning its link with PD4,
there is important trade-off between the two – the less operational data is used in the emissions
calculation, the less reliable the results of the calculation would be available for the final data
recipients.
As far as PD4 is concerned, apart from the synergies with PD3, interlinkages with PD1 and PD2
may also be observed, especially where the lack of trust in GHG emissions data is driven by the
proliferation of GHG calculation methods and the very fragmented landscape of default
emissions values. In addition, trade-offs with PD5 may be identified, especially related to the
situation, where, from the one hand, a dedicated GHG data verification system would increase
trust in the emissions figures shared on the market, but additional costs and burden associated
with the verification activities may discourage transport organisers and operators from
accounting and sharing emissions data, from the other.
Eventually, PD5 demonstrates synergies with PD1 and PD2, since the complexity and high costs
of GHG emissions accounting may be associated with the proliferation of methods and default
values datasets. It is also related to the limited availability of transport activity data, required for
quantifying emissions from actual operations, which also establishes a relevant link to PD3.
1.4 Affected stakeholders
The problems and problem drivers discussed above affect various stakeholders operating in the
transport sector, and the magnitude of the impact on each stakeholders’ group depends on their
role in the transport chain. The main stakeholders’ groups identified in the context of the
initiative are:
 Transport service organisers (or transport service providers) that include transport
operators, transport intermediaries (e.g. travel agencies, freight forwarders) and operators
of freight and passengers hubs (e.g. terminals, logistics platforms, ports, airports);
17
 Transport service users that include passengers, customers, public authorities,
manufacturers/shippers, wholesalers, retailers, transport service intermediaries and data
intermediaries99
.
The way how the problems affect these specific groups of stakeholders and their motivation to
measure, report or base their decision on GHG emissions accounting, is presented in Table 2.
Table 2: Stakeholders affected by the identified problems
Problems Stakeholders’ groups affected
P1: limited comparability
of results from GHG
emissions accounting of
transport services in
transport and logistics
- Transport service organisers providing transport services (especially
operators), as the lack of a common methodology and harmonised data
(1) creates market distortions because of potential competitive advantages
for those entities that do not use a proper calculation method, (2) results
in uncertainty as regards the choice of a calculation method and datasets,
that may also in certain cases translate in higher complexity (and hence
costs) of calculating emissions data of their services.
- Transport service users, as this problem does not allow for a fair
comparison of GHG emission figures of different transport services, thus
preventing users from making informed transport decisions. For large
transport intermediaries (such as freight forwarders) and shippers that
aggregate transport emissions data from various sources, the limited
comparability of GHG emission figures from carriers heavily complicates
the calculation of emissions from their activities.
- Impacts related to the reluctance of sharing operational data differ widely
between transport users (that require more transparency about transport
services) and transport organisers (that are reluctant to share operational
data), thus being far less significant for the latter category.
P2: Limited uptake of
emissions accounting of
transport services in usual
business practice
- Transport service users, as accurate emission figures per transport service
are not available on a wide scale, preventing them from making informed
transport decisions. Similarly as above, for large transport intermediaries
(such as freight forwarders) and shippers that aggregate transport
emissions data from various sources, the lack of GHG emission figures
from carriers heavily complicates the calculation of emissions from their
activities.
- Transport service organisers (especially operators), as due to the lack of
data (1) they cannot effectively benchmark their services against other
similar ones, which may result in inadequate business decisions and
additional costs, (2) they may find themselves in disadvantage when
competing with enterprises being able to deliver accurate and reliable
information on emissions to the users.
- Similarly as in the case of Problem 1, transport operators may not be
interested in disclosing operational data, therefore this issue affects
99
A data intermediary may be perceived as a specific category of a user that collects information on a transport
services from transport organisers and operators and discloses it further on the market.
18
mostly transport service users that are recipients of information on GHG
emissions.
1.5 How likely is the problem to persist?
Problem 1: Limited comparability of results from GHG emissions accounting of transport
services in transport and logistics
Despite recent harmonisation efforts towards a common GHG emissions accounting approach
for transport services, the problem of limited comparability of GHG emissions output data is
likely to persist without EU level action. As regards the method used, the ISO standard 14083
may represent a step towards establishing a common set of rules and emissions calculation
principles. Full harmonisation between the various methods and calculation tools is however not
possible, particularly because of the voluntary nature of this standard. This phenomenon can be
evidenced through the experience with the existing CEN standard EN 16258, which eventually
has not led itself to the harmonisation of the emissions accounting processes at EU level100
.
As explained in section 2.2, the issue of harmonised input data is equally important to ensure the
comparability of the GHG emissions calculation outputs. According to the interviewed
stakeholders, some increase in the use of primary data is expected over time. The primary data
improves the accuracy of the calculations and therefore makes it possible to use the emissions
data for operational optimisation purposes. However, this progress is expected to happen mainly
within large companies, often having more resources and knowledge at their disposal. Smaller
transport companies usually lack such capabilities, and in addition, are highly reluctant to share
operational data. Therefore, their calculations are likely to continue to be mostly based on default
emission intensity factors, the quality of which may also improve, for instance with respect to
the development of specific metering and monitoring systems offered by third parties101
.
Nonetheless, in the absence of harmonised databases and datasets, differences in the quality of
these intensity emission factors are likely to persist in the future.
Concerning the energy emission factors, specific initiatives such as the Commission’s proposal
for the revision of the Renewable Energy Directive and the proposed FuelEU Maritime
Regulation, if adopted by co-legislators, may contribute to better reliability and accuracy of the
available emissions input data. However, since the energy emission factors represent only one
part of the calculation inputs, these are not likely to allow for a uniform approach for accounting
emissions from the entire energy lifecycle perspective.
100
EN 16258 provided general principles, definitions, system boundaries, calculation methods and allocation rules
to harmonise the quantification of energy consumption and GHG emissions of transport services. The standard was,
however, affected by some shortcomings preventing from the uniform implementation of GHG emissions
accounting on the market. In addition, other parallel methods stayed in use by transport sector stakeholders,
preventing from the comparability of various GHG emissions data. Finally, the stakeholders’ consultation showed
that market players usually prefer a global approach instead of a European one, especially to be able to capture also
emissions from the services performed beyond the EU network. See more details in Annex 8.
101
These systems for instance may include telematics, data analytics, modelling and Artificial Intelligence (AI) to
generate and transmit data to the back-office of fleet managers.
19
Finally, when speaking about the full lifecycle assessment approach, relevant emission factors
may be only developed in case a dedicated LCA method is launched and widely used in the
transport sector.
Problem 2: Limited uptake of emissions accounting of transport services in usual business
practice
Without an EU level action, the uptake of GHG emissions accounting in the transport sector is
likely to increase only at a limited extent. This process will be mostly driven by:
 the development and implementation of public policies that require data on GHG emissions
from transport and logistics activities, like the Corporate Sustainable Reporting Directive, or
the French Transport Code at the national level;
 growing environmental awareness, leading to higher demand and supply of sustainable
products and services;
 the need to support decision-making or improve investor and consumer relations;
 the development of specific implementation guidelines, calculation tools, secure data sharing
platforms, or sectorial standards (such as those existing in the chemical industry and emerging
in the postal delivery sector).
Therefore, the factors identified above will not ensure the common application of emission
accounting at the level of transport services and will not guarantee uniform procedures and
processes across segments and modes, thus compromising the trust in quality of emissions output
data generated by transport service providers. This situation will persist in the absence of a
common verification system that otherwise would provide for the increased reliability of various
GHG emissions outputs, and the correctness of the underlying quantification processes.
In addition, there will be no means to fully alleviate the problem driver related to the reluctance
of operators to share operational information on their emissions. As explained in section 2.2, this
issue affects in particular SMEs in business-to-business relations, and cannot be solved without
ensuring the trust and security when sharing emissions data.
As regards the perceived complexity and costs related to quantification of emissions, this driver
may be addressed to a certain extent by the emergence of specific calculation tools and
implementation guidelines. However, in the absence of a common methodological framework,
it is not expected to change significantly the situation on the market.
1.6 Foresight
The analysis incorporates throughout all its dimensions relevant foresight tools. It does so to
anticipate trends and issues that may affect the initiative and build a robust, future-proof evidence
base for its likely impact. The megatrend “climate change and environmental degradation”102
is
relevant for both the problem related to the comparability of GHG emissions data and that related
to the limited uptake of emissions accounting, especially as regards to the increasing need in the
future for a harmonised approach to quantify transport services emissions. According to the 2022
Strategic Foresight Report103
, the aspect of “enabling a greener transport sector with digital
102
https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en
103
COM(2022) 289 final.
20
technologies” is one of the areas where the twinning of the green and digital transitions is
expected to have a major effect. It is particularly relevant to the challenges linked to the
continuously growing population, increasing consumer awareness, evolving costs of sustainable
transport options and new supply chain business models affecting the transport and mobility
sector. Another megatrend that is relevant for the evolution of the problems is “continuing
urbanisation”. Together with the growing demand for better connections to and between urban
centres, this calls also for more sustainable modal choices. This has been duly taken into account
in the analysis presented in the following sections.
3. WHY SHOULD THE EU ACT?
1.7 Legal basis
The legal basis giving the EU the right to act are Article 91(1) and Article 100(2) of the Treaty
on the Functioning of the European Union (TFEU). In accordance with Article 4(2) of the Treaty,
shared competence between the EU and the Member States applies in the area of transport.
1.8 Subsidiarity: Necessity of EU action
Under the principle of subsidiarity, in areas which do not fall within its exclusive competence,
the Union shall act only if and in so far as the objectives of the proposed action cannot be
sufficiently achieved by the Member States. Since transport is not an exclusive Union
competence pursuant to Article 4(g) TFEU, the subsidiarity principle applies. By providing
harmonised rules for GHG emissions accounting at the transport service level, CountEmissions
EU is particularly relevant for operations in the cross-border transport sector between EU
Member States. This level of harmonisation, related to the methodological choices and input
data, cannot be effectively achieved across the EU by action of individual Member States104
.
1.9 Subsidiarity: Added value of EU action
Overall, the EU transport sector has a strong cross-border dimension, playing an important role
for the free flow of people and goods on the EU internal market. Efficient transport services are
key to meet the demand of transport users, support the growth of the EU economy and preserve
lifestyle of the citizens. At the same time, attention should be drawn to challenges related to
environmental impacts from transport, still growing mostly due to the increase of freight and
passenger traffic on the European network105
.
CountEmissions EU is therefore conceived as an enabler for the transport community to facilitate
green transition. The initiative will contribute to creating the level playing field for GHG
emissions accounting between all segments and modes of transport, and across the national
networks. By providing for better transparency on the performance of transport services, and
104
So far only France has established a dedicated harmonised methodological framework, including measures to
incentivise its uptake. No plans for other similar national initiatives have been identified. However, in case further
Member States follow, this is expected to lead to very diverse calculations and/or reporting requirements for
transport operators and users, with additional costs and administrative burden for industries operating across
borders. Actions at national level may also lower the general effectiveness of emissions accounting, as GHG
emissions output data from transport operations carried out in different countries would not be comparable, with a
significant risk of creating confusion for users, and providing different, or even negative incentives for operators.
105
Statistical pocketbook 2022 (europa.eu)
21
supporting the use of GHG emissions data to make specific transport choices, it will lead to
creating incentives for more sustainable solutions and innovation. Any national approaches
would be highly counterproductive for achieving these objectives, bearing significant risk of
conflicting requirements and inconsistent methodologies and data. These divergent national
approaches would add costs and create unnecessary burden to businesses operating between
different Member States.
4. OBJECTIVES: WHAT IS TO BE ACHIEVED?
1.10 General objectives
In view of the problems described in section 2, the general objective of CountEmissions EU is
to incentivise behavioural change among businesses and customers to reduce GHG
emissions from transport services through the uptake and use of comparable and reliable
GHG emissions data. To this end, the initiative will provide a harmonised regulatory framework
for GHG emissions accounting, and specific rules stimulating its use across the entire transport
chain.
In this context, and as already indicated above, CountEmissions EU will contribute towards SDG
13 (“Take urgent action to combat climate change and its impacts”), SDG 7 (“Ensure access to
affordable, reliable, sustainable and modern energy for all”) and SDG 12 (“Ensure sustainable
consumption and production patterns”).
1.11 Specific objectives
This initiative is designed to effectively address the existing barriers hindering the harmonisation
of the GHG emissions accounting and its uptake. The specific objectives (SOs) and their
interlinkages with the problem drivers are presented in Figure 2.
Figure 2: Interlinkages between the specific objectives and the problem drivers
SO1: Ensure the comparability of results from GHG emissions accounting of transport
services. This objective aims at the provision of a common reference methodology and a
harmonised set of input data for accounting emissions from transport services, as well as
addressing the issue of the sensitivity of emissions data.
22
SO2: Facilitate the uptake of GHG emissions accounting of transport services in business
practice. This objectives aims to provide a harmonised approach for implementing the common
reference methodology and supporting its use across all transport segments and modes. Together
with SO1 it addresses the issue of the sensitivity of emissions data.
5. WHAT ARE THE AVAILABLE POLICY OPTIONS?
1.12 What is the baseline from which options are assessed?
The EU Reference scenario 2020 (REF2020) is the starting point for the impact assessment of
this initiative106
. The REF2020 takes into account the impacts of the COVID-19 pandemic that
had a significant impact on the transport sector. More detailed information about the preparation
process, assumptions and results are included in the Reference scenario publication107
. Building
on REF2020, the baseline has been designed to include the initiatives of the ‘Fit for 55’ package
proposed by the Commission on 14 July 2021108
and the initiatives of the RePowerEU package
proposed by the Commission on 18 May 2022109
. In terms of GHG emissions accounting, the
Baseline scenario assumes no further EU level intervention beyond the current initiatives in place at
national level and enterprise level. More details on the baseline are provided in Annex 4.
The baseline also incorporates foresight megatrends110
and developments captured in the 2022
Strategic Foresight Report111
. Among others, it captures the trend of increasing demand for
transport as population and living standards grow as well as the links between the digital and
green transition.
In the Baseline scenario, EU transport activity is projected to grow post-2020, following the
recovery from the COVID pandemic. Road transport would maintain its dominant role within
the EU by 2050. Rail transport activity is projected to grow significantly faster than for road,
driven in particular by the completion of the TEN-T core network by 2030 and of the
comprehensive network by 2050, supported by the CEF, Cohesion Fund and ERDF funding, but
also by measures of the ‘Fit for 55’ package that increase to some extent the competitiveness of
rail relative to road and air transport. Passenger rail activity is projected to go up by 24% by 2030
relative to 2015 (67% for 2015-2050). High speed rail activity, in particular, would grow by 68%
by 2030 relative to 2015 (165% by 2050), missing however to deliver on the milestone of the
SSMS of doubling its traffic by 2030 and tripling it by 2050. Freight rail traffic would increase
by 42% by 2030 relative to 2015 (91% for 2015-2050) also not delivering on the milestone of
the SSMS of increasing the traffic by 50% by 2030 and doubling it by 2050112
. Well-to-wheel
106
EU Reference Scenario 2020 (europa.eu)
107
https://energy.ec.europa.eu/data-and-analysis/energy-modelling/eu-reference-scenario-2020_en
108
https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal/delivering-european-green-deal_en
109
https://ec.europa.eu/commission/presscorner/detail/en/IP_22_3131
110
https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore
111
COM(2022) 289 final.
112
It should be noted that the scenarios underpinning the impact assessment accompanying the 2030 Climate Target
Plan and the staff working document accompanying the Sustainable and Smart Mobility Strategy, as well as the
impact assessments accompanying the ‘Fit for 55’ initiatives and the staff working document accompanying the
REPowerEU package, took into account a broader range of policies (including this initiative as well as the initiatives
on rail capacity, weights and dimensions for heavy duty vehicles and combined transport) that were represented in
a stylised way ahead of the actual proposals, to show the delivery of at least 55% emissions reduction target by 2030
23
GHG emissions from transport including international aviation and maritime, are projected to be
26% lower by 2030 compared to 2015, and 89% lower by 2050. NOx emissions are projected to
go down by 56% between 2015 and 2030 (87% by 2050), mainly driven by the electrification of
the road transport and in particular of the light duty vehicles segment. The decline in particulate
matter (PM2.5) would be slightly lower by 2030 at 53% relative to 2015 (91% by 2050).
Regarding the uptake of GHG emissions accounting of transport services, due account was taken
of the results of the stakeholders’ consultation and the experience derived from other initiatives
aimed to harmonise the quantification and reporting of emissions in transport. As explained in
section 2.5, in the absence of a regulatory framework, and despite the publication of ISO standard
14083, this uptake is likely to increase only at a limited extent since market forces alone will not
be able to secure the uniform application of GHG accounting practices across the transport
sector, and to guarantee the reliability, accuracy and comparability of GHG emissions data of
different transport services shared by transport organisers. This assumption can be illustrated
with the example of CEN EN 16258 standard, which has not led to the uniform GHG emissions
accounting system for transport services.
The number of enterprises in the transport sector and other sectors performing transport on own
account is estimated at 1.8 million in 2020 and is projected to remain stable over time. The large
majority (99.7%) are micro, small and medium enterprises. The number of enterprises
performing GHG emissions accounting at service level (i.e. for individual services delivered by
an operator) is estimated at 21,660 in 2020, of which 21,342 SMEs. Their number is projected
to increase over time to 39,380 by 2030 (38,693 SMEs and 687 large companies) and 69,599 by
2050 (68,279 SMEs and 1,320 large companies), driven by initiatives at national level and
enterprise level. However, their share in the total number of enterprises in the transport sector
and other sectors performing transport on own account is projected to remain limited by 2050
(2.2% in 2030 and 3.9% in 2050, relative to 1.2% in 2020). The number of large companies
measuring GHG emissions at service level is projected to grow at higher pace relative to SMEs.
The total costs incurred by the enterprises that measure GHG emissions from transport at service
level are projected to increase from EUR 36.4 million in 2020 (EUR 34.1 million for SMEs and
EUR 2.2 million for large companies) to EUR 61.4 million in 2030 (EUR 56.9 million for SMEs
and EUR 4.6 million for large companies) and EUR 92.7 million in 2050 (EUR 85.1 million for
SMEs and EUR 7.6 million for large companies). The largest share of the costs is associated to
SMEs.
The baseline scenario reflects the projected higher energy prices driven by the Russian invasion
of Ukraine113
. Beyond this aspect, it was however not possible to quantify the impact of the
Russian invasion of Ukraine in the context of the baseline scenario, given large uncertainty with
respect to its impacts, in particular for the medium to long term. However, the Russian invasion
and to account for the interaction with the forthcoming initiatives. These initiatives (in particular the rail capacity
initiative) are contributing towards the achievement of the milestones set in the context of the Sustainable and Smart
Mobility Strategy. To define a meaningful baseline scenario for the initiatives part of the Greening transport
package, these initiatives were not considered in the baseline scenario. This is the reason why the milestones of the
Sustainable and Smart Mobility Strategy in terms of rail traffic growth are not assumed to be met in the baseline. If
considering the milestones of the Sustainable and Smart Mobility Strategy in terms of rail traffic growth to be
achieved in the baseline, the benefits of the policy options in terms of reduction in external costs of GHG emissions
and air pollution emissions, as well as the avoided use of fuel, would be somewhat lower.
113
SWD(2022) 230 final of 18 May 2022.
24
of Ukraine is not expected to have an impact on the number of companies performing GHG
emissions accounting at service level, relevant for this initiative.
1.13 Description of the policy measures and policy options
As a first step, a comprehensive list of possible policy measures was established after extensive
consultations with stakeholders (surveys, meetings, stakeholder workshop), independent
research in the context of the impact assessment support study and the Commission’s own
analysis. This list was subsequently screened based on the likely effectiveness, efficiency and
proportionality of the proposed measures in relation to the given objectives, as well as their legal,
political and technical feasibility.
Discarded policy measures
A number of possible policy measures considered during the impact assessment process were
discarded, either because the identified problem driver was not validated by the stakeholders, the
problem was not susceptible to a solution by means of EU intervention, or proposing an action
to address the issue at EU level would not yield additional value. The full list of discarded policy
measures and the reasons for discarding them is included in Annex 6.
Examples of policy measures discarded on the basis of stakeholders’ contribution and desk
research performed in the context of this impact assessment are:
 the development of a completely new reference methodology for accounting emissions – this
measure was evaluated as neither realistic nor proportionate, given the very low stakeholders’
support, and the time and resources to be invested in its development;
 the mandatory use of primary data as input for the GHG emissions calculations – it was found
that such data is not yet widely available for certain types of transport operators (especially
for SMEs and micro companies), and such requirement would thus impose disproportionate
burden and costs on them;
 the certification of sectorial implementation guidelines – it was considered too complex,
costly and bringing limited value added for achieving the objectives of the initiative,
compared to other measures that were eventually retained.
Retained policy measures and policy options
The retained policy measures (see details in Annex 7) have been structured around the following
areas of action:
 Methodological framework – to determine a common reference method ensuring that the
quantification of emissions for transport services is performed in a standardised way across
the entire transport sector. An additional assessment was performed to shortlist the
methodologies that are the most relevant for the policy options (see Annex 7);
 Input data and sources – to provide a harmonised approach for the input data, by
incentivising the use of primary information, increasing the reliability, accessibility and
adequacy of default values, and mitigating variations between national, regional and sectorial
datasets;
 Applicability – to determine the relevant type of policy instrument (ranging from mandatory
to voluntary) to effectively apply CountEmissions EU on the EU market;
25
 Harmonised emissions output data and transparency – to determine appropriate formats
and metrics for generating and sharing the GHG emissions data, as well as to provide for
common rules on the communication and transparency of the emissions accounting results;
 Sectorial implementation support – to provide for harmonised implementation of
CountEmissions EU in various transport segments;
 Conformity – to ensure a common, proportionate and reliable verification system for the
GHG emissions data generated from specific transport services, and for the underlying
calculation processes;
 Complementary measures – to cover aspects related to the development and use of technical
support measures.
The impact assessment considers six policy options, combining retained policy measures based
on the areas of action discussed above. Table 3 Table 3 presents the interlinkages between the
retained policy measures, policy options, the specific policy objectives and problem drivers.
Table 3: Overview of specific objectives, problem drivers, measures and policy options
Specific
objectiv
e
Problem
driver
Policy measure PO
1
PO
2
PO
3
PO
4
PO
5
PO
6
SO1
PD1
PM1: ISO 14083 is set as common reference
methodology at EU level
√ √ √
PM2: Product Environmental Footprint Category
Rules for GHG emissions in transport, including
rules for transport services, is set as common
reference methodology at EU level
√
PM3: A common reference methodology is set at
EU level, based on ISO 14083 but with additional
elements and increased accuracy
√ √
PD2
PD3
PM4: The use of primary data is recognised and
centralised databases for default values for GHG
emission intensity and GHG energy emission
factors are established at EU level (by European
Environment Agency). Modelled data is used in
conformity with the reference methodology.
√ √ √
PM5: The use of primary data is incentivised and
centralised databases for default values for GHG
emission intensity and GHG energy emission
factors are established at EU level. Quality
assurance of external databases operated by third
parties is provided at EU level (by European
Environment Agency). Modelled data is used in
conformity with the reference methodology.
√ √ √
SO1,
SO2
PD1
PD3
PD4
PM6: Minimum requirements for harmonised GHG
output data metrics are provided at EU level,
together with common rules on communication and
transparency
√ √ √ √ √ √
PD3
PD4
PD5
PM7: Horizontal guidelines for the harmonised
implementation of CountEmissions EU in various
sectors and segments of the transport market are
provided at EU level
√ √ √ √ √ √
SO2 PD4
PM8: Mandatory process and data verification for
all entities falling under the scope of
CountEmissions EU is established at EU level
√
PM9: Mandatory process and data verification for
entities above a certain size falling under the scope
of CountEmissions EU is established at EU level
√ √ √ √
26
Specific
objectiv
e
Problem
driver
Policy measure PO
1
PO
2
PO
3
PO
4
PO
5
PO
6
PM10: Voluntary process and data verification for
all entities are established at EU level
√
PD5
PM11: Emissions calculation tools are provided at
EU level (by the European Commission)
√ √
PM12: Emissions calculation tools are provided by
the market but they are certified at EU level
√ √ √ √
PM13: Mandatory application of CountEmissions
EU in the transport sector
√ √
PM14: Binding opt-in application of
CountEmissions EU in the transport sector
√ √ √
PM15: Voluntary opt-in application of
CountEmissions EU in the transport sector with a
label
√
Policy option 1
Policy option 1 (PO1) envisages the highest level of centralisation and harmonisation for
accounting GHG emissions from transport services and boosting its uptake on the market.
To address Specific Objective 1 (Ensure comparability of results from GHG emissions
accounting of transport services), PO1 includes a comprehensive reference methodology based
on ISO 14083 but with certain additional specifications and elements increasing accuracy and
comparability of the results114
(PM3), and also measures related to the input and output emissions
data. As regards the input data, PO1 recommends the use of primary data and recognises entities
that apply this type of information in their emissions accounting processes (PM4). In case this
type of information is not available for an economic operator, PO1 allows the use of default
values derived from a common database of the emission intensity factors established at the
central EU level (by the European Environment Agency). This database is complemented by a
separate database of the energy emission factors enabling to calculate GHG emissions in the
energy lifecycle (Well-to-Wheel) perspective. Insofar the emissions output data is concerned,
PO1 will mandate their formats and metrics, to ensure the alignment in the measurement units115
,
and it will establish common rules on the communication and transparency for any
environmental claims related to GHG emissions of transport services based on CountEmissions
EU (PM6) - a measure that is included in all policy options.
As regards Specific Objective 2 (Facilitate the uptake of the GHG emissions accounting of
transport services for businesses and customers), PO1 will mandate the verification of the
adherence to CountEmissions EU, for GHG emissions data generated by transport service
providers, and the accounting processes applied for the quantification of emissions (PM8), to
address the lack of trust in GHG emissions outputs. Furthermore, a dedicated GHG emissions
calculation tool will be provided at the central EU level (by the European Commission), to
facilitate the use of the common methodology on the market (PM11). To ensure high uptake and
harmonisation of GHG emissions accounting, PO1 will require the mandatory application by all
entities organising and providing transport services, with CountEmissions EU as the only
114
For details see Annex 8.
115
For instance, to determine how the data shall be presented and communicated to any party in the transport chain.
27
applicable framework. After a transition period ending in 2035, all companies involved in the
organisation and provision of transport services should account GHG emissions (PM13).
Finally, PO1 includes the provision of horizontal guidelines for the implementation of the
common accounting framework across various segments and sectors of the transport market
(PM7) that addresses both Specific Objectives 1 and 2 - a measure that is included in all policy
options.
Policy option 2
Policy option 2 (PO2) proposes an equally high level of centralisation as PO1, but with a
methodology based on a global standard, less stringent conformity requirements and voluntary
application by the transport service providers.
With respect to Specific Objective 1 (Ensure comparability of results from GHG emissions
accounting of transport services), PO2 includes ISO standard 14083 as a common reference
methodology for quantifying GHG emissions from transport services (PM1). Regarding issues
related to the harmonisation of input and output data, PO2 follows the same approach as in PO1
(including respectively PM4 and PM6).
For Specific Objective 2 (Facilitate the uptake of the GHG emissions accounting of transport
services for businesses and customers), PO2, contrary to PO1, proposes a voluntary verification
of the adherence to CountEmissions EU in terms of the emissions data and underlying calculation
processes (PM10). Concerning GHG emissions calculation tools, similarly to PO1 they will be
provided centrally at EU level by the European Commission (PM11). PO2 will leave the
application of CountEmissions EU as a voluntary choice. The use of other frameworks is also
possible, but the transport service providers choosing to adhere to the common framework are
offered a CountEmissions EU label (PM15).
As in PO1, PO2 also includes the provision of horizontal guidelines for the implementation of
the common accounting framework across various segments and sectors of the transport market
(PM7) that addresses both Specific Objectives 1 and 2.
Policy option 3
Policy option 3 (PO3), includes measures with a lower level of centralisation and reduced
requirements for harmonisation and applicability, but it is based on a comprehensive accounting
methodology.
With regard to Specific Objective 1 (Ensure comparability of results from GHG emissions
accounting of transport services) PO3 includes the same comprehensive methodology as
proposed under PO1 (PM3), but with a less centralised approach for the treatment of emissions
input data (PM5). Specifically, PM5 recommends the use of primary data and recognises those
entities that apply it while quantifying emissions; it also proposes common EU databases for
emission intensity factors and energy emissions factors. However, unlike PM4, this measure
allows the use of additional national, regional or sectorial datasets, subject to a specific quality
assurance process. This set of measures is complemented by PM6 that harmonises the GHG
output data formats and metrics at EU level - also included in PO1 and PO2.
28
Regarding Specific Objective 2 (Facilitate the uptake of the GHG emissions accounting of
transport services for businesses and customers), PO3 will mandate the verification of the
adherence to CountEmissions EU, for both emissions data and underlying calculation processes,
to entities above a certain size, i.e. large organisations (PM9). Unlike PO1 and PO2, PO3 will
allow the use of external calculation tools developed both by industry and public authorities116
,
under the condition that these are certified as conforming to CountEmissions EU (PM12).
Eventually, PO3 envisages the application of CountEmissions EU as “binding opt-in”, imposing
the requirement to use the common framework whenever entities providing and/or organising
transport services choose or are mandated by other means117
to share, publish, report or make
claims on GHG emissions related to the performed transport services (PM14).
As in PO1 and PO2, PO3 also includes the provision of horizontal guidelines for the
implementation of the common accounting framework across various segments and sectors of
the transport market (PM7) that addresses both Specific Objectives 1 and 2.
Policy option 4
Policy option 4 (PO4), proposes a similar approach as envisaged under PO3, however with a
methodology based exclusively on a global standard, offering the opportunity for the global
outreach. Therefore, with respect to Specific Objective 1 (Ensure comparability of results from
GHG emissions accounting of transport services), PO4 includes a direct reference to ISO
standard 14083 as a common methodology for accounting emissions (PM1), instead of PM3
included in PO3. All other measures are the same as in PO3, including those addressing Specific
Objective 2 (Facilitate the uptake of the GHG emissions accounting of transport services for
businesses and customers).
Policy option 5
Policy option 5 (PO5), similarly to PO3 and PO4, envisages a balanced level of centralisation
and harmonisation. The only differences concern Specific Objective 1 (Ensure comparability of
results from GHG emissions accounting of transport services), where PO1 includes the Product
Environmental Footprint Category Rules for GHG emissions in transport, as the common
reference methodology (PM2), and establishes centralised databases of default values (PM4).
All other policy measures, including those addressing Specific Objective 2 (Facilitate the uptake
of the GHG emissions accounting of transport services for businesses and customers) replicate
the approach taken in PO3 and PO4 (i.e. PM6, PM7, PM9, PM12 and PM14).
Policy option 6
Policy option 6 (PO6), is based on a similar set of policy measures as PO4, with one exception
related to the applicability in the context of Specific Objective 2 (Facilitate the uptake of the
GHG emissions accounting of transport services for businesses and customers). Consequently,
116
Developed and offered for the use by wider public by enterprises, industrial associations, public authorities and
other relevant bodies
117
For instance, by other EU or national legislation or through contractual relations.
29
instead of the binding opt-in approach envisaged under PM14, PO6 includes PM13, requiring
the mandatory use of CountEmissions EU framework in the transport sector.
6. WHAT ARE THE IMPACTS OF THE POLICY OPTIONS?
This sectionsummarises themain expected economic, social and environmental impacts of eachpolicy
option118
(PO). The proposed measures are assumed to be implemented from 2025 onwards, so the
assessment has been undertaken for the 2025-2050 period and refers to EU27. Costs and benefits are
expressed as present value over the 2025-2050 period, using a 3% discount rate.
Further details on the methodological approach are provided in Annex 4.
1.14 Economic impacts
This section provides the economic impacts of the policy options on national public authorities, the
European Environment Agency (EEA), the European Commission, and businesses and business
associations involved in the accounting of GHG emissions from transport services. It also
provides an assessment of impacts on SMEs, on consumers, on the functioning of the internal market
and competition, and on competitiveness. The assessment of economic impacts draws on multiple data
sources, including the targeted stakeholders’ consultation (interviews and survey) and OPC, and
findings from desk research in the context of the impact assessment support study.
6.1.1 Impacts on national public authorities
Adjustment costs for national public authorities. All six policy options entail adjustments costs for
national statistical offices dealing with transport emissions statistics, driven by the minimum
requirements for harmonised GHG output data formats and metrics at EU level (PM6). The workload
needed for adapting to the harmonised GHG output data format is estimated at 120 hours per statistical
office. The average cost per hour is estimated at EUR 40.9119
in 2022 prices for ISCO 2 category
(Professionals) and is assumed to remain constant over time in real prices. Thus, the total one-off
adjustment costs at EU level in 2025 are estimated at EUR 132,504 relative to the baseline (in 2022
prices) for all policy options.
Administrative costs for national public authorities. All six policy options entail administrative
costs for accreditation of verifiers by National Accreditation Bodies (NABs), in view of performing
data verification. The accreditation of verifiers by NABs is part of:
 PM8 (mandatory process and data verification for all entities falling under the scope of
CountEmissions EU at EU level) included in PO1,
 PM9 (mandatory process and data verification for entities above a certain size falling under
the scope of CountEmissions EU at EU level) included in PO3, PO4, PO5 and PO6, and
 PM10 (voluntary process and data verification for all entities at EU level) included in PO2.
118
The analysis in this section is based on the Ecorys and CE Delft (2023), Impact assessment support study, and
on the analysis of stakeholders' feedback.
119
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour
30
The workload per NAB for the accreditation of verifiers is estimated at 120 hours in 2025 and is the
same for all options. Thus, the total one-off administrative costs at EU level in 2025 are estimated at
EUR 132,504 relative to the baseline (in 2022 prices) for all policy options.
6.1.2 Impacts on the European Environment Agency (EEA)
Adjustment costs for EEA. All policy options establish centralised databases for default input values
(i.e. emissions intensity factors and energy/fuel emissions factors) at EU level (PM4 in PO1, PO2 and
PO5, andPM5 in PO3, PO4 andPO6). The centralisedEU databases will be developed andmaintained
by the European Environment Agency (EEA). In addition, PM5 (included in PO3, PO4 and PO6)
allows for the use of data from databases operated by third parties, following quality assurance check
by EEA.
For developing the databases (PM4 in PO1, PO2 and PO5), 1 full time equivalent (FTE) is estimated
to be needed by EEA in 2025, 2026 and 2027, in addition to EUR 200,000 for infrastructure costs120
.
The one-off adjustment costs associated to the development of the databases are thus estimated at EUR
693,149. In addition,oneFTE andoperational costs formaintenance wouldberequired formaintaining
and updating the databases from 2026 onwards. The recurrent adjustment costs for EEA in PO1, PO2
and PO5 are estimated at EUR 186,000 per year from 2026 onwards relative to the baseline. Expressed
as present value over 2025-2050, the total adjustment costs for PO1, PO2 and PO5 are estimated at
EUR 3.5 million of which EUR 0.7 million one-off costs (in 2022 prices).
As explained above, PM5 (included in PO3, PO4 and PO6) covers the costs for developing the
databases plus the quality assurance check by EEA. For the quality assurance check of external
databases, the workload is estimated at 15 hours per database. The quality check is assumed to be
performed for the first time in 2026 for 24 databases and would take place every two years. Thus, the
recurrent adjustment costs for the quality assurance check are estimated at EUR 35,791 per year
(occurring every two years from 2026 onwards). These are identified as operational costs for EEA.121
The total adjustment costs for developing the databases plus the quality assurance check by EEA in
PO3, PO4 and PO6 are estimated at EUR 693,149 one-off costs in 2025-2027 and EUR 221,791
recurrent costs in 2030 and 2050 relative to the baseline. Expressed as present value over 2025-2050,
the total adjustment costs in PO3, PO4 and PO6 are estimated at EUR 3.9 million relative to the
baseline of which EUR 0.7 million one-off costs (in 2022 prices).
6.1.3 Impacts on the European Commission
Adjustment costs for the European Commission. The definition of Category Rules (PEFCRs) for
transport of the Product Environmental Footprint methodology (PM2) in PO5 will be done via a
research project. The budget to be dedicated to develop the PEFCRs for transport is estimated at EUR
1.5 million per PEFCR. Based on previous work done in the context of ESPR122
and aviation label,
forcoveringall transport services, at least 4PEFCRs areneeded(road,maritime and inlandwaterways,
aviation, rail). However, the work on aviation has already started and part of these costs (50%) are
included in the baseline. Thus, the one-off adjustment costs for the European Commission in 2025
for PO5 are estimated at EUR 5.25 million relative to the baseline (in 2022 prices).
120
Source: EEA
121
Source: EEA
122
COM(2022) 142 final
31
The development of the additional requirements for the methodology based on ISO 14083 but with
additional elements and increased accuracy (PM3) in PO1 and PO3 will be also done via a research
project. The budget to be dedicated to this work is estimated at EUR 2.4 million for 2025 (one-off
costs) relative to the baseline (in 2022 prices).
Furthermore, PO1 and PO2 will lead to additional costs for the European Commission linked to the
development of calculation tools following the common reference methodology (PM11). Based on the
cost of THETIS-MRV123
and experience with existing THETIS-EU modules, such IT-developments
are estimated at EUR 300,000 (one-off costs in 2025).
Thus, the total one-off adjustment costs for the European Commission in 2025 are estimated at EUR
2.7 million in PO1, EUR 0.3 million in PO2, EUR 2.4 million in PO3 and EUR 5.25 million in PO5.
6.1.4 Impact on businesses and business associations involved in transport
services
Adjustment costs for businesses and business associations. All policyoptions result in recurrent and
one-off adjustment costs for businesses and business associations. While under PO2, PO3, PO4 and
PO5 the application of CountEmissions EU in the transport sector is voluntary or quasi voluntary (i.e.
voluntary opt-in with a label in PO2 and binding opt-in in PO3, PO4 and PO5), PO1 and PO6 foresee
the mandatoryapplication. Thus, the total (one-off and recurrent) adjustment costs in PO1 and PO6 are
significantly higher than in all other policy options. For PO1, they are estimated at EUR 0.5 billion in
2025, EUR 3.9 billion in 2030 and EUR 6.4 billion in 2050 relative to the baseline, and for PO6 at
EUR 0.3 billion in 2025, EUR 2 billion in 2030 and EUR 3.2 billion in 2050, relative to the baseline.
At the same time, PO2 results in the lowest total adjustment costs amongthe options, estimated at EUR
54.8 million in 2025, EUR 101.3 million in 2030 and EUR 4.7 million in 2050 relative to the baseline,
due to the voluntary opt-in foreseen by this option. Table 4 to Table 13 provide the recurrent and one-
off adjustment costs by policy option and by policy measure for 2025, 2030 and 2050 relative to the
baseline.
The highest share of the costs in all policy options is related to the setting of a common reference
methodology at EU level (ISO 14083 in PO2, PO4 and PO6, ISO 14083 with additional elements and
increased accuracy in PO1 and PO3 and PEFCR in PO5). Other important cost categories, discussed
below, relate to the verification activities and the emissions calculation tools. More detailed
explanations on the costs and the assumptions used to derive them, by policy measure and policy
option, are provided in Annex 4.
The setting of the new ISO 14083 methodology as the common reference methodology (PM1) in
PO2, PO4 and PO6 is expected to lead to additional labour costs relative to the baseline for the
new businesses performing GHG emissions accounting at service level, but also for the
businesses that are already quantifying GHG emissions in the baseline and would need to adjust
their processes in line with the new ISO 14083 requirements. The costs of PM1 in PO2, PO4 and
PO6 are different because of the voluntary opt-in application with a label of CountEmissions EU
in PO2 (in conjunction with PM15), the binding opt-in application in PO4 (in conjunction with
PM14) and the mandatory application in PO6 (in conjunction with PM13). For PO2, the one-off
adjustment costs for businesses are estimated at EUR 31.8 million in 2025, EUR 56.4 million in
123
https://mrv.emsa.europa.eu/
32
2030 and EUR 2.9 million in 2050 relative to the baseline, while the recurrent annual costs at
EUR 15.9 million in 2025, EUR 31.3 million in 2030 and EUR 1.3 million in 2050 (see Table 4
and Table ). Expressed as present value over 2025-2050, the total adjustment costs due to PM1 in PO2
are estimated at EUR 0.9 billion relative to the baseline, of which EUR 0.6 billion one-off adjustment
costs. For PO4, the one-off adjustment costs for businesses are estimated at EUR 44.8 million in
2025, EUR 73.9 million in 2030 and EUR 16 million by 2050 relative to the baseline, while the
recurrent annual costs at EUR 23.6 million in 2025, EUR 41.6 million in 2030 and EUR 9 million
in 2050 (see Table 5 and Table 13). Expressed as present value over 2025-2050, the total adjustment
costs due to PM1 in PO4 are estimated at EUR 1.4 billion relative to the baseline, of which EUR 0.9
billionone-offadjustment costs. For PO6, the one-off adjustment costs for businesses are estimated
at EUR 0.2 billion in 2025, EUR 1.7 billion in 2030 and EUR 2.7 billion by 2050 relative to the
baseline, while the recurrent annual costs at EUR 107.3 million in 2025, EUR 835.5 million in
2030 and EUR 1.4 billion in 2050 (see Table 5 and Table 13). Expressed as present value over
2025-2050, the total adjustment costs due to PM1 in PO6 are estimated at EUR 60.5 billion relative to
the baseline, of which EUR 40.3 billion one-off adjustment costs. According to stakeholders’
feedback, meetings with experts and desk research, the alignment with a global standard
provided by ISO 14083 would allow for better comparability and usability by the businesses
across the world.
The setting of the Product Environmental Footprint (PEF) as common reference methodology
(PM2) in PO5 is expected to lead to additional labour costs for those businesses that are already
quantifying GHG emissions in the baseline, as they will need to adjust their processes in line
with the PEF requirements once the PEFCRs for transport have been developed, but also for the
new businesses performing GHG emissions accounting. The one-off adjustment costs for
businesses are estimated at EUR 63.1 million in 2025, EUR 94.6 million in 2030 and EUR 14.6
million by 2050 relative to the baseline, while the recurrent annual costs at EUR 29.9 million in
2025, EUR 50 million in 2030 and EUR 6.9 million in 2050 (see Table 5 and Table 13).
Expressed as present value over 2025-2050, the total adjustment costs due to PM2 in PO5 are
estimated at EUR 1.6 billion relative to the baseline, of which EUR 1.1 billion one-off adjustment
costs (in 2022 prices). According to stakeholders’ feedback, this measure may not ensure
alignment at the global level, which may lead to difficulties for the aviation and the maritime
transport sectors that are global in nature. Due to the fact that Category Rules are still to be
developed, the costs reported are dependent on the future developments of the methodology.
The setting of the new ISO 14083 with additional elements and increased accuracy as common
reference methodology (PM3) in PO1 and PO3, is expected to lead to additional labour costs
relative to the baseline for the new businesses performing GHG emissions accounting, but also
for the businesses that are already quantifying GHG emissions in the baseline and would need
to adjust their processes in line with the new ISO 14083 requirements, once the additional
elements have been developed. The costs of PM3 in PO1 and PO3 are different because of the
mandatory application of CountEmissions EU in PO1 (in conjunction with PM13) and the
binding opt-in application in PO3 (in conjunction with PM14). For PO1, the one-off adjustment
costs for businesses are estimated at EUR 0.3 billion in 2025, EUR 2.3 billion in 2030 and EUR
3.7 billion in 2050 relative to the baseline, while the recurrent annual costs at EUR 0.1 billion in
2025, EUR 1 billion in 2030 and EUR 1.6 billion in 2050 (see Table 4 and Table ). Expressed as
present value over 2025-2050, the total adjustment costs due to PM3 in PO1 are estimated at EUR 80.3
billion relative to the baseline, of which EUR 56 billion one-off adjustment costs (in 2022 prices). For
PO3, the one-off adjustment costs for businesses are estimated at EUR 43.6 million in 2025,
EUR 76.3 million in 2030 and EUR 12 million in 2050 relative to the baseline, while the
33
recurrent annual costs at EUR 18.1 million in 2025, EUR 33.8 million in 2030 and EUR 4.9
million in 2050 (see Table 4 and Table ). Expressed as present value over 2025-2050, the total
adjustment costs due to PM3 in PO3 are estimated at EUR 1.2 billion relative to the baseline, of which
EUR 0.8 billion one-off adjustment costs. According to stakeholders’ feedback, meetings with experts
and desk research, the stricter requirements and additional elements relative to the global ISO 14083
standardarenotlikelytobefollowedat globallevel,whichmayleadto somechallenges fortheaviation
and maritime transport sectors that are global in nature. The costs estimates above are also dependent
on the additional elements that would still need to be developed.
All six policy options will require the provision of horizontal guidelines for the harmonised
implementation of CountEmissions EU in various sectors and segments of the transport market (PM7).
The workload required by businesses sector associations to adapt sector processes in line with the
guidelines set in the implementing act of CountEmissions EU is estimated at 90 hours per sector
association. The average cost per hour is estimated at EUR 40.9124
in 2022 prices for ISCO 2 category
(Professionals). The number of sectors that will need to adapt processes is estimated to be 17, which
represents an upper bound estimate (including all relevant NACE categories125
). Thus, the one-off
adjustment costs for business sector associations in 2025 are estimated at EUR 62,571 relative to the
baseline (in 2022 prices).
All policy options foresee process and data verification for businesses (PM8, PM9 and PM10). The
scope however varies between policy options: mandatory for all businesses (PM8) in PO1; mandatory
for businesses above a certain size, excluding SMEs (PM9) in PO3, PO4, PO5 and PO6; and voluntary
for all businesses (PM10) in PO2. The annual verification is performed by bodies that are accredited
by NABs, following specific EU rules. A secondary act will define the accreditation rules and the
verification rules for verification bodies. In PO1, the additional number of companies that would
undergo verification activities (in conjunction with the mandatory application of CountEmissions EU,
due to PM13) is estimated at 134,873 in 2025, 949,093 in 2030 and 1,758,729 in 2050, leading to
recurrent adjustment costs of EUR 41.5 million in 2025, EUR 296.2 million in 2030 and EUR
481.9 million in 2050 relative to the baseline. Expressed as present value over 2025-2050, the total
adjustment costs for PM8 in PO1 are estimated at EUR 7.2 billion relative to the baseline.
For PM9, the costs are different between policy options (between PO3, PO4, PO5 and PO6) because
of the different unit cost per company for verification activities, linked to the method for GHG
accounting applied (ISO 14083 with additional elements and increased accuracy in PO3, ISO 14083
in PO4 and PO6, and PEFCR in PO5). In PO3, PO4 and PO6, businesses that already perform
verification activities in the baseline are expected to be faced with costs savings due to the fact that unit
costs per company126
for verification activities are expected to be lower relative to the baseline. On the
other hand, the additional number of companies that perform verification activities (in conjunction
with the binding opt-in application of CountEmissions EU, due to PM14 and the mandatory
application due to PM13) leads to an overall increase in the recurrent adjustment costs in 2025 and
124
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour
125
NACE is a four-digit classification providing the framework for collecting and presenting a large range of
statistical data according to economic activity in the fields of economic statistics (e.g. production, employment and
national accounts) and in other statistical domains developed within the European statistical system (ESS).
126
The provision of a single standardised set of rules will lead to time savings to support verification activities. The
verification is conducted on annual basis on random samplings of quantifications. The verifiers will be provided
with specific standardised rules to perform verifications. Source: Ecorys and CE Delft (2023), Impact assessment
support study.
34
2030 relative to the baseline (for PO3 estimated at EUR 0.3 million in 2025 and EUR 1.1 million in
2030; for PO4 estimated at EUR 0.1 million in 2025 and EUR 0.9 million in 2030; for PO6 estimated
at EUR 5 million in 2025 and EUR 47.6 million in 2030). In 2050, both PO3 and PO4 result in net
costs savings relative to the baseline (EUR 1.3 million costs savings in PO3 and EUR 1.8 million in
PO4) due to the lower unit cost of verification activities relative to the baseline, while PO6 results in
additional adjustment costs for verification activities of EUR 77.4 million in 2050 due to the increased
uptake. Expressed as present value over 2025-2050, PM9 results in total adjustment costs estimated at
EUR 1 million in PO3, adjustment costs savings of EUR 3.6 million in PO4 and additional adjustment
costs of EUR 1.2 billion relative to the baseline in PO6. In PO5, the recurrent adjustment costs are
estimated at EUR 7.4 million in 2025, EUR 11.6 million in 2030 and EUR 8.9 million in 2050 relative
to the baseline. Expressed as present value over 2025-2050, PM9 results in adjustment costs estimated
at EUR 180.3 million in PO5 relative to the baseline. For PM10 (included in PO2)127
, the recurrent
adjustment costs are estimated at EUR 3million in 2025, EUR 5.2million in 2030 andEUR 2.1million
in2050relativetothebaseline.Expressedas present valueover2025-2050,PM10results in adjustment
costs of EUR 68.1 million in PO2 relative to the baseline.
Finally, all policy options foresee the use of calculation tools by businesses. PM11 (included in PO1
and PO2) will provide businesses with calculation tools developed at EU level (by the European
Commission), while PM12 (included in PO3, PO4, PO5 and PO6) foresees that calculation tools are
developed by the market but certified according to EU rules that will be defined by a secondary act.
The use of these calculation tools will require labour costs for incorporating them into the
business practice, and time dedicated to use them. The recurrent adjustment costs relative to the
baseline are driven by the unit costs for using the tools, which are dependent on the methodology
applied, and the additional number of companies using the tools relative to the baseline. The
highest recurrent adjustment costs related to the use of calculation tools are expected in PO1
(EUR 41.2 million in 2025, EUR 312.1 million in 2030 and EUR 505.3 million in 2050), and
PO6 (EUR 32.5 million in 2025, EUR 257.7 million in 2030 and EUR 417.3 million in 2050)
due to the mandatory application (in conjunction with PM13). The lowest recurrent adjustment costs
are expected in PO2 (see Table 4) due to the voluntary opt-in application but also the lower unit costs
for using the tools relative to the baseline. Expressed as present value over 2025-2025, the use of
calculation tools is estimated to lead to recurrent adjustment costs of EUR 7.6 billion in PO1, EUR
74.5 million in PO2, EUR 167.6 million in PO3, EUR 138.6 million in PO4 (see Table 5) and EUR
470 million in PO5.
Table 4: Recurrent costs for business in the PO1, PO2 and PO3 relative to the baseline scenario (EU27), in million
EUR (2022 prices) in 2025, 2030 and 2050
Difference to the Baseline
PO1 PO2 PO3
2025 2030 2050 2025 2030 2050 2025 2030 2050
Adjustment costs 212.9 1,611.3 2,611.7 22.9 44.9 1.8 25.8 48.7 8.2
PM1 - ISO 14083 set as common
reference methodology
15.9 31.3 1.3
PM2 - PEFCR set as common
reference methodology
127
The assumption behind the uptake of verification activities in PO2 is that 100% of the businesses that voluntarily
opt-in to CountEmissions EU will perform verification. Verification in PO2 is the condition under which the
CountEmissions EU label is awarded. Therefore, it is reasonable to assume that all businesses that invested in the
quantification will decide to receive the label assessing their conformity to CountEmissions EU.
35
Difference to the Baseline
PO1 PO2 PO3
2025 2030 2050 2025 2030 2050 2025 2030 2050
PM3 - ISO 14083 with additional
elements and increased accuracy set
as common reference methodology
130.2 1,003.0 1,624.5 18.1 33.8 4.9
PM8 - Mandatory process and data
verification for all entities
41.5 296.2 481.9
PM9 - Mandatory process and data
verification for entities above certain
size
0.3 1.1 -1.3
PM10 - Voluntary process and data
verification for all entities
3.0 5.2 2.1
PM11 - Emissions calculation tools
are provided at EU level
41.2 312.1 505.3 4.0 8.4 -1.6
PM12 - Emissions calculation tools
are provided by the market but they
are certified at EU level
7.5 13.7 4.5
Administrative costs 0.00 0.00 0.00 0.00 0.00 0.00 0.02 0.03 0.03
PM5 - Quality assurance of external
databases operated by third parties is
provided at the EU level
0.00 0.02 0.02
PM12 - Emissions calculation tools
are provided by the market but they
are certified at EU level
0.02 0.02 0.02
Total net costs 212.9 1,611.3 2,611.7 22.9 44.9 1.8 25.9 48.7 8.2
Source : Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs savings,
where relevant.
Table 5: Recurrent costs for business in the PO4, PO5 and PO6 relative to the baseline scenario (EU27), in million
EUR (2022 prices) in 2025, 2030 and 2050
Difference to the Baseline
PO4 PO5 PO6
2025 2030 2050 2025 2030 2050 2025 2030 2050
Adjustment costs 30.4 54.8 8.6 56.6 93.2 37.3 144.9 1,140.9 1,848.2
PM1 - ISO 14083 set as common
reference methodology
23.6 41.6 9.0 107.3 835.5 1,353.5
PM2 - PEFCR set as common
reference methodology
29.9 50.0 6.9
PM3 - ISO 14083 with additional
elements and increased accuracy set
as common reference methodology
PM8 - Mandatory process and data
verification for all entities
PM9 - Mandatory process and data
verification for entities above certain
size
0.1 0.9 -1.8 7.4 11.6 8.9 5.0 47.6 77.4
PM10 - Voluntary process and data
verification for all entities
PM11 - Emissions calculation tools
are provided at EU level
36
Difference to the Baseline
PO4 PO5 PO6
2025 2030 2050 2025 2030 2050 2025 2030 2050
PM12 - Emissions calculation tools
are provided by the market but they
are certified at EU level
6.7 12.3 1.4 19.3 31.6 21.5 32.5 257.7 417.3
Administrative costs 0.02 0.03 0.03 0.02 0.02 0.02 0.02 0.03 0.03
PM5 - Quality assurance of external
databases operated by third parties is
provided at the EU level
0.00 0.02 0.02 0.00 0.02 0.02
PM12 - Emissions calculation tools
are provided by the market but they
are certified at EU level
0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02
Total net costs 30.4 54.8 8.7 56.6 93.3 37.4 144.9 1,140.9 1,848.2
Source : Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs savings,
where relevant.
Table 6: One-off costs for business in PO1, PO2 and PO3 relative to the baseline scenario (EU27), in million EUR
(2022 prices)
One-off costs Difference to the Baseline
PO1 PO2 PO3
2025 2030 2050 2025 2030 2050 2025 2030 2050
Adjustment costs
PM1 - ISO 14083 set as
common reference methodology
31.8 56.4 2.9
PM2 - PEFCR set as common
reference methodology
PM3 - ISO 14083 with
additional elements and
increased accuracy set as
common reference methodology
295.0 2,308.0 3,747.8 43.6 76.3 12.0
PM7 - Guidelines for
harmonised implementation
0.06 0.06 0.06
Total costs 295.1 2,308.0 3,747.8 31.8 56.4 2.9 43.7 76.3 12.0
Source : Ecorys and CE Delft (2023), Impact assessment support study
Table 7: One-off costs for business in PO4, PO5 and PO6 relative to the baseline scenario (EU27), in million EUR
(2022 prices)
One-off costs Difference to the Baseline
PO4 PO5 PO6
2025 2030 2050 2025 2030 2050
Adjustment costs
PM1 - ISO 14083 set as common reference
methodology
44.8 73.9 16.0 210.5 1,660.2 2,698.2
PM2 - PEFCR set as common reference
methodology
63.1 94.6 14.6
PM3 - ISO 14083 with additional elements
and increased accuracy set as common
reference methodology
PM7 - Guidelines for harmonised
implementation
0.06 0.06 0.06
Total costs 44.8 73.9 16.0 63.2 94.6 14.6 210.5 1,660.2 2,698.2
Source : Ecorys and CE Delft (2023), Impact assessment support study
37
Total (one-off and recurrent) adjustment costs for businesses, expressed as present value over 2025-
2050, are estimated to be the highest in PO1 (EUR 95 billion), followed by PO6 (EUR 67.9 billion)
and at large distance by PO5 (EUR 2.3 billion), PO4 (EUR 1.5 billion), PO3 (EUR 1.4 billion) and
PO2 (EUR 1.1 billion). As already explained, while under PO2, PO3, PO4 and PO5 the application of
CountEmissions EU in the transport sector is voluntary or quasi voluntary (i.e. voluntary opt-in with a
label in PO2 and binding opt-in in PO3, PO4 and PO5), PO1 and PO6 foresee the mandatory
application and thus lead to significantly higher costs. At the same time, PO2 results in the lowest total
adjustment costs among the options, due to the voluntary opt-in foreseen by this option. The highest
share of the adjustment costs for each policy option relates to the setting of a common reference
methodology at EU level (91% of the total costs in PO4 and 89% in PO6 for ISO 14083, 88% in PO3
for ISO 14083 with additional elements and increased accuracy, 87% in PO2 for ISO 14083, 84% in
PO1 for ISO 14083 with additional elements and increased accuracy and 72% in PO5 for PEFCR).
The second category of costs in terms of share of the total costs relates to the use of the calculation
tools (21% of the total costs in PO5, 12% in PO3, 9% in PO4 and PO6, 8% in PO1 and 7% in PO2).
The verification activities account for less than 8% of the costs in all options.
Administrative costs for businesses. PM12 (included in PO3, PO4, PO5 and PO6) foresees that the
development of calculation tools following a common reference methodology is left to the market but
certified at EU level. A maximum of 34 tools are expected to be certified in addition to the baseline.
The cost per tool for submitting for certification, per year, is estimated at EUR 531.65, assuming 13
hours of work per certification at an average cost per hour estimated at EUR 40.9128
in 2022 prices for
ISCO 2 category (Professionals). Thus, the recurrent administrative costs for businesses are estimated
at EUR 18,076 from 2025 onwards relative tothebaseline. Expressed as present value over2025-2050,
the total administrative costs are estimated at EUR 332,840 relative to the baseline.
In addition, in PO3, PO4 and PO6 the possibility of using data from sectorial specific datasets (PM5)
recognised through the quality check performed by EEA will create additional administrative costs for
the datasets developers willing to use this alternative. The recurrent administrative costs for datasets
developers are estimated at EUR 16,686 in 2026 relative to baseline, and every two years up to 2050.
Expressed as present value over 2025-2050, the total administrative costs are estimated at EUR
177,452. For the purpose of reporting on the application of the ‘one in, one out’ approach129
, the annual
average number of hours per database for datasets developers to submit the databases has been
estimated at 12 hours each year (instead of every two years). The cost per hour is estimated at EUR
40.9 and a number of 17 databases is assumed to be submitted. The cost per database for preparing the
submissionis thus estimatedat EUR490.76perdatabase. Forthepurposeof‘onein,oneout’ approach,
the recurrent administrative costs for datasets developers are estimated at EUR 8,343 per year.
Expressed as present value over 2025-2050, total administrative costs for calculation tool developers
are estimated at EUR 0.5 million in PO3, PO4 and PO6, and EUR 0.3 million in PO5.
Energy costs savings. All policy options are expected to incentivise behavioural change, leading to
higher use ofmore sustainabletransport options andoptimised trips. This is expectedto result in energy
savings for transport service providers. The energy savings and the reduction in the energy costs for
transport service providers for 2025, 2030 and 2050 relative to the baseline are provided in Table 8. In
128
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour
129
https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and-
how_en
38
cumulative terms over 2025-2050, the energy savings are estimated to be the highest in PO1 and PO6
(8.9 Mtoe130
), followed by PO4 (1.9 Mtoe), PO2 (1.2 Mtoe) and PO3 and PO5 (around 0.5 Mtoe).
Total energy costs savings for the transport service providers, expressed as present value over 2025-
2050 relative to the baseline, are estimated at EUR 10 billion in PO1 and PO6, EUR 2.3 billion in PO4,
EUR 1.5 billion in PO2, EUR 0.7 billion in PO3 and EUR 0.6 billion in PO5131
. It should however be
noted that there is large uncertainty related to these estimates, that depend on behavioural change (for
more details, see Annex 4).
Table 8: Energy savings and the reduction in energy costs for transport service providers in the policy options
relative to the baseline scenario (EU27)
2025 2030 2050
Energy savings for transport service providers (ktoe)
PO1 32.6 259.4 385.7
PO2 46.8 93.9 3.5
PO3 23.6 56.0 1.2
PO4 70.6 123.8 24.0
PO5 21.3 51.5 1.1
PO6 32.6 259.4 385.7
Reduction in the energy costs for transport service providers (in million EUR)
PO1 52.0 391.4 776.3
PO2 74.6 141.7 7.0
PO3 37.6 84.5 2.4
PO4 112.6 186.9 48.4
PO5 34.0 77.8 2.2
PO6 52.0 391.4 776.3
Source: Ecorys and CE Delft (2023), Impact assessment support study; Note: ktoe stands for kilo tonnes of oil
equivalent.
Net costs/costs savings for businesses. PO1, PO3 and PO5 are expected to lead to net costs for
businesses, estimated at EUR 85.1 billion in PO1, 57.9 billion in PO6, EUR 0.7 billion in PO3 and
EUR 1.7 billion in PO5, expressed as present value over 2025-2050 relative to the baseline. On the
other hand, PO2 and PO4 are projected to lead to net costs savings of EUR 0.4 billion and EUR 0.8
billion, respectively, relative to the baseline. The beneficiaries of the net savings are enterprises in the
transport ecosystem, namely: (i) transport service organisers (TSO), (ii) transport service users (TSU)
or hub operators (HO), as detailed in Annex 4.
130
Million of tonnes of oil equivalent.
131
The energy use by policy option is derived based on the transport activity by transport mode corresponding to
each option and the projected energy intensity per transport mode from the baseline scenario. The energy intensity
is expressed in ton of oil equivalent (toe) per tonne-kilometre and takes into account all energy forms, including
green electricity and hydrogen. The energy savings are computed by taking the difference between the energy use
in the policy options and the baseline. Finally, projected average fuel costs in EUR per toe for each transport mode
from the baseline scenario is used to monetise the energy savings. The average fuel costs takes into account all the
energy forms used by transport mode, including green electricity and hydrogen. It needs to be clarified that the
baseline scenario of this initiative includes significant reductions in the energy intensity of all modes over time. This
is because it reflects the ‘Fit for 55’ and the REPowerEU packages. Yet, the rail transport shows significantly lower
energy intensity per tonne-kilometres than other modes, as also the case today.
39
6.1.5 Impacts on competitiveness
The impact on businesses involved in GHG emissions accounting of transport services is
presented in section 6.1.4. This section focuses on the possible impacts on the competitiveness
of a wider set of actors in the EU industry cluster, namely the transport sector, manufacturing
companies, retailers and fuel suppliers as actors in the European supply chain. These impacts are
driven by expected behavioural change, leading to higher use of more sustainable transport solutions
and optimised trips. All policy options are expected to lead to indirect benefits for the EU industry
cluster at large, resulting from energy costs savings due to increased efficiency of transport
operations, helping companies de-risk future carbon prices. Sustainability is becoming an
important issue also when influencing the decision of businesses when choosing with whom to
work with. The assessment of impacts of the policy options on competitiveness is based on
stakeholders’ consultation.
Table 9: Impacts on competitiveness
Stakeholder
group
PO1 PO2 PO3 PO4 PO5 PO6
Transport sector Positive Small
positive
Small
positive
Positive Small
positive
Positive
Manufacturing Small
positive
No change No change Positive No change Positive
Retail sector Small
positive
No change No change Small
positive
No change Small
positive
Fuel suppliers No change No change No change Positive Small
positive
Positive
A small positive to positive improvement in the competitive position of the transport sector is
expected in all policy options, while the impacts on other sectors largely depend on the uptake
of GHG emissions accounting at transport service level. In addition, the policy options may also
provide incentives for the uptake of zero-emission vehicles and of the renewable and low carbon
fuels, strengthening the EU leadership position in sustainable mobility. Positive impacts on
innovation (including process innovation) and faster technology uptake by transport service
providers and hub operators may also be expected. The wider demand for collecting and sharing
transport emissions data may also trigger further efforts by companies towards digital solutions.
PO4 is expected to provide overall positive impacts on the competitiveness of the EU market,
followed by PO6, PO1, PO5, PO2 and PO3.
6.1.6 Impacts on consumers
All policy options are expected to improve the comparability of GHG emissions data and allow
consumers make informed decisions on their trips. This is expected to incentivise behavioural
change, leading to higher use of more sustainable transport solutions. As a result, energy costs
savings for consumers, expressed as present value over 2025-2050 relative to the baseline, are
estimated to be the highest in PO1 and PO6 (EUR 405.3 million), followed by PO4 (EUR 108.1
million), PO2 (EUR 72.9 million), PO3 (EUR 34.6 million) and PO5 (EUR 30.6 million). It
should however be noted that there is large uncertainty related to these estimates, that depends on the
scale of behavioural change (for more details, see Annex 4).
40
6.1.7 Impacts on small and medium enterprises (SMEs)
SMEs play a very significant role in the supply chain of goods and passenger transport. Therefore, the
initiative is considered relevant for the SMEs and the SME test has been performed. More detailed
explanations on the SME test, including the four SME steps, are provided in Annex 10.
The share of SMEs in the sectors affected by the quantification of GHG emission for transport services
is estimated at 99.7%, as shown in Annex 4. Therefore, the consultation activities were designed to
identify the affected businesses and to further investigate the extent to which they would be affected.
PO2 and PO4 are estimated to result in net benefits for SMEs relative to the baseline. PO4 would lead
to the highest net benefits estimated at EUR 43.7 million in 2025, EUR 70 million in 2030 and EUR
28.1 million in 2050 relative to the baseline, while PO2 at net benefits of EUR 23.1 million in 2025,
EUR 46.7 million in 2030 and EUR 2.2 million in 2050. On the other hand, PO1, PO6, PO3 and PO5
are estimated to result in net costs (see Table 10 and Table 11). Annex 10 provides a detailed
presentation of the total costs and benefits for SMEs, including a breakdown of the costs between
adjustment and administrative costs132
and by policy measure (see Table 10Error! Reference source
not found. and in Annex 10). Expressed as present value over 2025-2050, the net benefits for PO2 and
PO4 are estimated at EUR 0.5 billion and EUR 0.9 billion, respectively, while the net costs in PO1 at
EUR 83.9 billion, in PO6 at EUR 66.6 billion, in PO5 at EUR 1.3 billion and in PO3 at EUR 0.4 billion
relative to the baseline. As explained in section 6.1.4, the benefits are related to energy savings driven
by behavioural change that leads to higher use of more sustainable transport options and optimised
trips.
Table 10: Total costs and benefits for SMEs in PO1, PO2 and PO3 relative to the baseline scenario (EU27), in
million EUR (2022 prices)
Difference to the Baseline
PO1 PO2 PO3
2025 2030 2050 2025 2030 2050 2025 2030 2050
Recurrent and one-off costs 490.8 3,866.2 6,288.2 50.9 93.9 4.7 57.9 103.8 11.9
Adjustment costs 490.8 3,866.2 6,288.2 50.9 93.9 4.7 57.8 103.8 11.9
Administrative costs 0.00 0.00 0.00 0.00 0.00 0.00 0.02 0.02 0.02
Benefits (energy costs savings) 51.7 390.7 775.1 74.0 140.6 6.9 37.2 83.6 2.4
Net costs/costs savings 439.1 3,475.5 5,513.1 -23.1 -46.7 -2.2 20.7 20.2 9.5
Source : Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs savings,
where relevant.
Table 11: Total costs and benefits for SMEs in PO4, PO5 and PO6 relative to the baseline scenario (EU27), in
million EUR (2022 prices)
Difference to the Baseline
PO4 PO5 PO6
2025 2030 2050 2025 2030 2050 2025 2030 2050
Recurrent and one-off costs 68.0 115.4 19.9 101.2 156.4 37.4 344.7 2,767.6 4,501.4
Adjustment costs 68.0 115.4 19.9 101.2 156.4 37.3 344.7 2,767.5 4,501.4
Administrative costs 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02
Benefits (energy costs savings) 111.7 185.4 48.0 33.6 77.0 2.2 51.7 390.7 775.1
Net costs/costs savings -43.7 -70.0 -28.1 67.6 79.5 35.1 293.0 2,376.9 3,726.3
132
In the assessment it has been assumed that the calculation tool developers are SME. Therefore, all the
administrative costs presented in section 6.1.4 are assumed to belong to SMEs.
41
Source : Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs savings,
where relevant.
6.1.8 Impact on the functioning of the internal market and competition
All policy options are expected to improve the comparability of GHG emissions data and have a
positive impact on the functioning of the internal market. The companies providing services or
working with subcontractors in different EU Member States will have a common methodology
for measuring GHG emissions. In addition, according to stakeholders’ feedback, the alignment
with a global standard provided by ISO 14083 (in PO2, PO4 and PO6) would allow for better
comparability and usability of GHG emissions data by the businesses across the world. On the
other hand, ISO 14083 with additional elements and increased accuracy (in PO1 and PO3) and the
Product Environmental Footprint Category Rules (in PO5) will not ensure alignment to a global
standard and may lead to challenges for the aviation and the maritime transport sectors, as well as
large logistics and express companies, that are global in nature. The measures related to the
verification of processes and data (PM8 included in PO1, PM9 included in PO3, PO4, PO5 and PO6,
and PM10 included in PO2), are expected to have a positive impact on the fair competition between
transport service providers. This is because the verification avoids distorting competition by “cherry
picking” between the default values and primary data, to show lower emissions at transport service
level.
6.1.9 Digital by default
All policy options are expected to have positive impacts on the application of the ‘digital-by-default’
principle, driven by the fact that the calculation and sharing of GHG emissions data in most cases will
be associated with using digital tools and systems, and the wider demand for data in general. The
demand may trigger further efforts by companies towards digital solutions, as reported in section 6.1.5
and Annex 5. Positive impacts on innovation (including process innovation) and faster technology
uptake by transport service organisers and hub operators may also be expected.
The real magnitude of the impacts on the “digital-by-default” is however not directly quantifiable due
to the current lack of a harmonised framework driving the progress in data access, data reuse and data
interoperability at the level of the entire transport sector. This harmonisation process will largely
depend on the successful implementation of the European Strategy for Data133
, including such
initiatives as the European Mobility Data Space134
, Electronic Freight Transport Information
Regulation135
, and activities of the Digital Transport and Logistics Forum136
.
These considerations were duly taken into account when addressing learning effects for the
stakeholders affected by various policy options (see Annex 4 for more detail).
133
https://digital-strategy.ec.europa.eu/en/policies/strategy-data
134
https://transport.ec.europa.eu/news/share-your-views-common-european-mobility-data-space-2022-11-14_en
135
https://eur-lex.europa.eu/EN/legal-content/summary/electronic-freight-transport-
information.html#:~:text=Electronic%20freight%20transport%20information%20(eFTI)%20is%20a%20set%20of
%20data,between%20operators%20and%20competent%20authorities.
136
https://transport.ec.europa.eu/transport-themes/digital-transport-and-logistics-forum-dtlf_en
42
1.15 Social impacts
This section assesses the impacts of the policy options on public health, road safety and fundamental
rights.
6.2.1 Impacts on public health
The availability of comparable data across transport services will facilitate customer choices towards
higher use of more sustainable transport option for both passenger and freight, resulting in reduced air
pollutant emissions and subsequent positive impacts on public health. The savings in the external costs
of air pollutants, expressed as present value over 2025-2050 relative to the baseline, are estimated to
be the highest in PO1 and PO6 (EUR 600.6 million), followed by PO4 (EUR 163.5 million), PO2
(EUR 110.8 million), PO3 (EUR 53.1 million) and PO5 (EUR 47 million)137
. The reason for the
significantly higher savings in the external costs of air pollutants in PO1 and PO6 is due to the
mandatory application of CountEmissions EU that will affect all businesses involved in transport
services in EU27.
6.2.2 Impacts on road safety
The reduction in the road transport activity in all policy options, induced by better data available to
customers to make more sustainable choices, is expected to result in a decrease in the number of
fatalities and injuries relative to the baseline. Cumulatively over 2025-2050, PO1 and PO6 are
estimated to lead to 510 lives saved and 2,732 serious injuries avoided, followed by PO4 (103 lives
saved and 558 serious injuries avoided), PO2 (68 lives saved and 353 serious injuries avoided), PO3
(28 lives saved and 151 serious injuries avoided) and PO5 (23 lives saved and 133 serious injuries
avoided). The reduction in the external costs of accidents is estimated to be the highest in PO1 and PO6
(EUR 2.8 billion), followed byPO4 (EUR 645.2 million), PO2 (EUR 424.4 million), PO3 (EUR 192.2
million) and PO5 (EUR 168.6 million), expressed as present value over 2025-2050 relative to the
baseline138
.
6.2.3 Impacts on fundamental rights
The policy options were assessed to determine if they have an impact on the fundamental rights and/or
equal treatment of EU citizens. The starting point for the assessment of the fundamental rights is the
Charter of Fundamental Rights of the European Union139
. All six POs were assessed having regard to
the relevant EU instrument and it was concluded that they maintain full respect for human and
fundamental rights, and none will have any negative impact thereon.
1.16 Environmental impacts
The analysis of environmental impacts covers well-to-wheel GHG emissions and air pollutant
137
The 2019 Handbook on the external costs of transport (Source: https://op.europa.eu/en/publication-detail/-
/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1) has been used to monetise the costs.
138
The 2019 Handbook on the external costs of transport (Source: https://op.europa.eu/en/publication-detail/-
/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1) has been used to monetise the costs. According to the
Handbook, the external cost of a fatality in 2022 prices is estimated at EUR 3.9 million and that of a serious
injury at EUR 0.6 million.
139
OJ C 326 of 26.10.2012 p.2
43
emissions.
It should be acknowledged that the empirical evidence on the relation between the GHG emissions
accounting, changes in transport activity and the related reduction in the GHG emissions and air
pollutant emissions is scarce. The relevant assumptions and projections used in estimating the impacts
of the policy options are therefore based on the literature review, case studies/use cases140
and the
feedback from the stakeholders’ consultation. In relation to this point, a sensitivity analysis was also
performed to show the range of impacts. The sensitivity analysis presented in section 7.6 and
detailed in Annex 4, section 5, assumes a lower share of passengers making sustainable choices
among the climate aware population(scenario A), and lower shares of activity shifted to more
sustainable transport modes and optimisation of trips.
6.3.1 Impacts on well-to-wheel GHG emissions
The reduction in the well-to-wheel GHG emissions is mainly driven by the behavioural effects
incentivising the higher use of more sustainable transport options and optimised trips. The highest
reduction in the well-to-wheel GHG emissions from the transport sector relative to the baseline is
projected for PO1 and PO6 (0.2% decrease in 2030 and 0.5% in 2050 or 904 thousand tonnes of
emissions saved in 2030 and 438 thousand tonnes saved in 2050) and PO4 (0.1% decrease in 2030 and
less than 0.1% decrease in 2050 or 432 thousand tonnes of GHG emissions saved in 2030 and 27
thousand tonnes saved in 2050). Cumulatively over 2025-2050, PO1 and PO6 result in 22.1 million of
tonnes ofGHGemissions saved relativetothebaseline,PO4in5.6millionoftonnes ofGHGemissions
saved, PO2 in 3.7 million of tonnes of GHG emissions saved, PO3 in 1.7 million of tonnes of GHG
emissions saved and PO5 in 1.5 million of tonnes of GHG emissions saved. The reduction in the
external costs related to GHG emissions is estimated to be the highest in PO1 and PO6 (EUR 2.9
billion), followed by PO4 (EUR 0.7 billion), PO2 (EUR 0.4 billion), PO3 (EUR 0.2 billion) and PO5
(EUR 0.17 billion), expressed as present value over 2025-2050 relative to the baseline (in 2022
prices)141
. Notwithstandingthis result, indirect environmental benefits that PO5 would unlock from the
assessment of emissions in the full lifecycle perspective should also be considered. They may bring
along some accelerated greening of mobility, but due to lack of relevant data, these effects could not
be quantified.
The improvements in the comparability of GHG emissions data is also expected to result in
increased transparency, credibility, positive effects on reputation and public image of transport service
providers and higher levels of trust in supply-chain partners.
6.3.2 Impacts on air pollutant emissions
Similarly to well-to-wheel GHG emissions, the reduction in air pollution emissions is mainly driven
by the higher use of more sustainable transport options and optimised trips. Cumulatively over 2025-
2050, NOx emissions are estimated to reduce by 53.2 thousand tonnes in PO1 and PO6 relative to the
baseline, 12.7 thousand tonnes in PO4, 8.4 thousand tonnes in PO2, 3.9 thousand tonnes in PO3 and
3.4 thousand tonnes in PO5. The reduction in the particulate matter emissions would also be highest in
PO1 (0.9 thousand tonnes), followed by PO4 (0.2 thousand tonnes saved) and PO2, PO3 and PO4 (0.1
140
See Annex 12
141
The 2019 Handbook on the external costs of transport (Source: https://op.europa.eu/en/publication-detail/-
/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1) has been used to monetise the costs.
44
thousand tonnes saved) relative to the baseline.
All policy options are consistent with the environmental objectives of the European Green Deal and
the European Climate Law142
. All policy options contribute towards Sustainable Development Goal
13 (‘Take urgent action to combat climate change and its impacts’). No significant harm is expected
on the environment in any of the policy options.
7. HOW DO THE OPTIONS COMPARE?
1.17 Effectiveness
The assessment of effectiveness looks at the extent to which the general and specific objectives
(SO) of the intervention are met. Table 12 provides the link between policy objectives and
assessment criteria.
Table 12: Link between objectives and assessment criteria
General objective Specific objective Assessment criteria
Incentivise behavioural
change among businesses
and customers to reduce
GHG emissions from
transport services through
the uptake and use of
comparable and reliable
GHG emissions data
SO1 – Ensure the
comparability of results
from GHG emissions
accounting of transport
services
Expected improvement in the comparability of GHG emissions
data shared in the transport chain (based on the relevant
methodology, generated with accurate input data, and
communicated from trusted sources in unambiguous and clear
manner)
SO2 - Facilitate the
uptake of GHG
emissions accounting of
transport services in
business practice
Expected increase in the use of the common methodological
framework by economic operators and other relevant entities
Expected decrease in the well-to-wheel GHG emissions of
transport services
Concerning SO1, all policy options will result in improved comparability of the GHG emission results,
although PO1, PO3, PO4, PO5 and PO6 are expected to be more effective than PO2.
PO1 and PO3 both rely on a comprehensive GHG emissions accounting methodology based on
ISO 14083, but with additional elements143
and increased accuracy (PM3). PO1 envisages the
strongest regulatory intervention, including inter alia the development of centralised databases
for default values (PM4) and emissions calculation tools at EU level, thus ensuring the
comparability of the output data (PM11). In turn, PO3 enables, under specific conditions, the
provision of emissions intensity factors databases (PM5) and emissions calculation tools (PM12)
by the market. While these measures are expected to significantly contribute to improving
comparability, they may be less effective than the databases and calculations tools established at
the EU level. For both POs, ISO 14083 with additional elements and increased accuracy will ensure
appropriate comparability and reliability of the GHG emissions outputs, but it will also require
time and resources to develop the additional elements and to eventually offer the methodology
for the use to stakeholders (it should be noted for instance, that at the moment there is no
commonly accepted business practice to estimate emissions related to the production and end
life of batteries in the context of transport services, and which is envisaged to form part of this
methodology). Furthermore, given the inclusion of additional elements, this methodological
142
Regulation(EU) 2021/1119
143
Such as emissions from the production of batteries; see details in Annex 8.
45
choice may lead to inconsistencies in terms of harmonised accounting of emissions for
international transport operations (mostly affecting maritime transport and aviation144
that are
global in nature). Given all the arguments above, PO1 is considered more effective than PO3.
PO4 includes the same policy measures as PO3, with the exception of the common reference
methodology. While the plain ISO standard 14083 (included in PO4) does not ensure the same
level of accuracy as the advanced methodology based on the ISO standard 14083 with additional
elements (included in PO3 and PO1), it has certain advantages over the latter one. First, it has
already been developed, based on a robust research process including public consultation.
Secondly, it also offers the opportunity to align emissions accounting for international transport.
Thus, PO4 is assessed to be equally effective as PO1, and more effective than PO3.
As far as SO1 is concerned, PO6 includes the same policy measures as envisaged under PO4,
including the methodological choice (ISO 14083). Therefore, with respect to SO1, PO6 is
considered to be equally effective as PO4.
The timescale and resources needed to develop the PEFCR (included in PO5), that addresses
emissions accounting in the most comprehensive way, based on the full lifecycle (from cradle to
grave), is expected to be even more substantial than for the methodology based on ISO standard
14083 with additional elements and increased accuracy. This is because the transport specific
PEFCRs do not exist yet. In addition, the use of this methodology will likely result in even larger
misalignment with emissions accounting approaches for transport services at the international
level. Otherwise, PO5 also foresees centralised databases for default values to be established at
the EU level (PM4). However, the accuracy, and thus reliability of the default values included
in the databases envisaged under PO5 may not be as high as those included in the other policy
options, given the significant degree of uncertainty related to the valuation of emission factors
in the LCA perspective. Therefore, PO5 is assessed to be less effective than PO3 in achieving
SO1.
PO2 includes the ISO standard 14083 (PM1) methodology and a centralised approach for the
input data (PM4) that, once combined, may offer a high level of comparability of GHG emission
figures on the market. However, PO2 envisages a voluntary application of the common
methodological framework that leaves its use to the discretional decision of the concerned
entities (PM15). The latter feature may eventually result in the co-existence of various
approaches for accounting emissions, and lesser methodological alignment on the market in the
short and medium term. Thus, PO2 is assessed to be the least effective in achieving SO1 among
the policy options.
Based on this analysis, PO1, PO4 and PO6 are equally effective in achieving SO1, followed by PO3,
PO5 and finally PO2.
Concerning SO2, the uptake of GHG emissions accounting in business practice, and the related
reduction of WTW emissions from transport, will be mostly determined by the choice related to
the application of the initiative on the market (PM13, PM14 and PM15). Especially for the policy
options envisaging the voluntary or quasi voluntary application (PM14 and PM15) the uptake
will also be driven by the choice of the methodology (PM1, PM2 and PM3), data and process
144
Including with respect to existing and future requirements at IMO and ICAO level.
46
verification system (PM8, PM9 and PM10), as well as other measures that will facilitate the
implementation of the initiative on the market, including through the use of calculation tools
(PM11, PM12).
PO1 and PO6 are assessed to be the most effective with respect to SO2 since they mandate the
application of CountEmissions EU (PM13) to all entities involved in transport service activities.
Both PO1 and PO6 are expected to result in 918,003 additional businesses performing GHG
emissions accounting in 2030 and 1,703,841 additional businesses in 2050, relative to the
baseline. In addition, they would result in 22.1 million tonnes of GHG emissions saved over the
2025-2050 period relative to the baseline.
PO3, PO4 and PO5 will mandate the use of the CountEmissions EU framework only for those
companies that decide or are required by other means145
to quantify and disclose GHG emissions
data from their transport services (PM14), and therefore these policy options are assessed to be
less effective than PO1 and PO6 in achieving SO2. The approach on the verification (only for
large enterprises) and the provision of certified calculation tools is the same for PO3, PO4 and
PO5, thus not affecting their ranking in terms of effectiveness. However, between these options,
the use of the common methodological framework by economic operators will vary, subject to
the complexity and costs related to its implementation. Therefore, PO4, offering a conducive
methodology provided by the ISO standard 14083 (PM1), is assessed to be more effective than
PO3 and PO5 that envisage additional methodological elements, associated with increased
complexity of emissions accounting for users. PO4 would result in 39,358 additional businesses
performing GHG emissions accounting in 2030 and 9,139 additional businesses in 2050, relative
to the baseline, and 5.6 million tonnes of GHG emissions saved over the 2025-2050 period
(relative to the baseline). PO3, implementing the ISO standard 14083 with additional elements and
increased accuracy is expected to result in 26,745 additional businesses performing GHG
emissions accounting in 2030 and 3,640 additional businesses in 2050, relative to the baseline.
It would also result in 1.7 million tonnes of GHG emissions saved over the 2025-2050 period
relative to the baseline. PO5 is assessed to be almost equally effective to PO3, with 25,102
additional businesses performing GHG emissions accounting in 2030 and 2,783 additional
businesses in 2050, relative to the baseline, and 1.5 million tonnes of GHG emissions saved over
the 2025-2050.
PO2 is expected to be more effective in achieving SO2 than PO3 and PO5 but less effective than
PO4, given the lax application of CountEmissions EU on the EU market (PM15) and the fully
voluntary verification system for processes and data (PM10). This assessment is based on the
fact that PO2 includes a more conducive and user friendly methodology (PM1), recognises the
use of CountEmissions EU through a label (PM15), and offers dedicated emissions calculation
tools to be managed at the central EU level (PM11). These features may especially attract interest
of SMEs that represent the majority of entities operating on this market. PO2 is expected to result
in 30,219 additional businesses performing GHG emissions accounting in 2030 and 1,388
additional businesses in 2050, relative to the baseline, and 3.7 million tonnes of GHG emissions
saved over the 2025-2050 period.
Therefore, with respect to SO2, PO1 and PO6 are assessed to be the most effective options, followed
145
For instance, based on a contractual relationship, or other legal requirements stemming from separate provisions.
47
by PO4, PO2, PO3 and PO5.
1.18 Efficiency
Efficiency concerns the ‘extent to which objectives can be achieved for a given cost (cost
effectiveness)’. The estimates of costs and benefits are summarised in Table 13.
Table 13: Summary of costs and benefits of policy options – present value for 2025-2050 compared to the baseline
(in million EUR), in 2022 prices
Difference to the Baseline
PO1 PO2 PO3 PO4 PO5 PO6
National public authorities
(including NABs)
Adjustment costs 0.1 0.1 0.1 0.1 0.1 0.1
Administrative costs 0.1 0.1 0.1 0.1 0.1 0.1
EEA
Adjustment costs 3.6 3.6 3.9 3.9 3.6 3.9
European Commission
Adjustment costs 2.7 0.3 2.4 0.0 5.3 0.0
Businesses
Adjustment costs 95,010.8 1,084.6 1,374.4 1,542 2,283.7 67,927.7
Administrative costs 0.0 0.0 0.5 0.5 0.3 0.5
Benefits
Avoided fuel used (operators and
passengers) 10,362.9 1,585.5 718.3 2,415.9 630.5 10,362.9
Reduction in external costs of
GHG emissions 2,878.9 445.4 200.0 674.1 174.9 2,878.9
Reduction in external costs of air
pollution emissions 600.6 110.8 53.1 163.5 47.0 600.6
Reduction in external costs of
accidents 2,760.5 424.4 192.2 645.2 168.6 2,760.5
Total costs 95,017 1,089 1,381 1,547 2,293 67,932
Total benefits 16,602.9 2,566.1 1,163.6 3,899 1,021.0 16,602.9
Net benefits -78,414.4 1,477.3 -217.9 2,352.1 -1,272.1 -51,329.4
Benefits to costs ratio 0.2 2.4 0.8 2.5 0.4 0.2
Source: Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect net costs.
The major cost element of the policy options consists of adjustment costs for businesses for
implementing the new emissions quantification methodologies. Other significant groups of costs,
includedinallPOs,areadjustment costs relatedto theuseofcalculationtools andverificationactivities.
Total costs. PO1 and PO6 set the mandatory application of CountEmissions EU to all business
performing transport on own account (around 1.8 million businesses) and are expected to result in the
highest total costs, estimated respectivelyat EUR 95 billion and EUR 67.9 billion, expressed as present
value over 2025-2050 relative to the baseline. The lower costs in PO6 compared to PO1 are mainly
due to the lower unit costs associated to PM3 (ISO 14083) and the use of calculation tools. PO3, PO4
and PO5, that envisage a binding opt-in application, show significantly lower costs estimated at
EUR 1.4 billion, EUR 1.5 billion and EUR 2.3 billion, respectively. The additional costs in PO5
compared to PO3 (EUR 912 million) and PO4 (EUR 747 million) are mainly associated to the
additional complexity for implementing the PEFCR and also the use of calculation tools and
verification activities. The additional costs in PO4 compared to PO3 (EUR 165 million) steam from
thehigher shareof companies expectedtoimplement GHG emissions accountingat service level. PO2,
48
envisaging voluntary application, shows the lowest total costs, estimated at EUR 1.1 billion relative to
the baseline, expressed as present value over 2025-2050.
The highest share of the total costs for each policy option relates to adjustment costs for businesses for
the setting of a common reference methodology at EU level (91% and 89% of the total costs in PO4
and PO6 respectively for ISO 14083, 88% in PO3 for ISO 14083 with additional elements and
increased accuracy, 87% in PO2 for ISO 14083, 84% in PO1 for ISO 14083 with additional elements
and increased accuracy and 72% in PO5 for PEFCR). The second category of costs in terms of share
of the total costs relates to adjustment costs for businesses for the use of the calculation tools (21% of
the total costs in PO5, 12% in PO3, 9% in PO4 and PO6, 8% in PO1 and 7% in PO2).
Total benefits. All policy options result in better transparency and improved harmonisation of GHG
emissions datafortransport services.Thisis expectedtolead tohigheruseofmoresustainabletransport
options and optimised trips, resulting in energy costs savings for transport operators and consumers,
andareductionintheexternal costsoftransport.PO1andPO6showthehighesttotal benefits estimated
at EUR 16.6 billion, due to the mandatory application of the CountEmissions EU146
. The other policy
options show significantly lower benefits estimated at EUR 3.9 billion in PO4, followed by PO2 (EUR
2.6 billion), PO3 (EUR 1.2 billion) and PO5 (EUR 1 billion). It should however be noted that there is
large uncertainty related to these estimates, that depend on behavioural change towards more
sustainable solutions, as explained in Annex 4.
Overall, PO2 and PO4 are expected to result in net benefits relative to the baseline. PO4 shows the
highest net benefits, estimated at EUR 2.4 billion expressed as present value over 2025-2050 (relative
to the baseline), followed by PO2 (EUR 1.5 billion). On the other hand, PO1, PO6, PO3 and PO5 are
expected to result in net costs (EUR 78.4 billion in PO1, EUR 51.3 billion in PO6, EUR 0.2 billion in
PO3 and EUR 1.3 billion in PO5). PO4 also shows the highest benefit to cost ratio (2.5), followed by
PO2 (2.4), PO3 (0.8), PO5 (0.4), PO6 and PO1 (0.2).
1.19 Coherence
Internal coherence assesses how various elements of the new legal act function together to achieve
the objectives. It should be noted that this does not only concern the legal act itself, but also its
accompanying secondary legislation and rules, as well as guidelines. Although all five policy options
address theidentifiedproblems,they do so in different ways. PO1 proposes the strongest regulatory
approach including the mandatory application of a comprehensive methodology, mandatory
verification rules, as well as EU centralised default data databases and calculation tools. This
approach ensures that all the entities involved in transport services activities account emissions,
and they do so based on the same methodology and data. PO2, to the contrary, envisages a fully
voluntary framework, both in terms of the applicability and verification, based on a conducive
methodology, but supported with centralised databases and calculation tools. In this respect, PO2
aims to achieve the objectives with minimum burden and costs for the market. In turn, PO3, PO4
and PO5 offer a semi voluntary approach (binding-in) and lighter verification process, but they
differ in terms of the use of centralised or decentralised databases, and the type of an accounting
methodology referred to. PO6 proposes the mandatory application of the framework, but
combined with a more conducive methodology, lighter verification process and some flexibility
146
Feedbacks from stakeholder consultation and literature review does not provide further evidence for a modal
shift in excess of 10% because of the harmonisation of GHG emissions methodology. Therefore, applying a
conservative approach, the modal shift has been capped at 10%.
49
related to the use of input data and calculation of emissions, as already envisaged under PO4.
Specific choices that are made for these options will determine the implementation modalities at
different effectiveness and costs. Finally, there are common measures (implementation
guidelines, harmonised rules for the output data) that aim to complement various policy
components within the respective options. In this context, all options ensure internal coherence.
External coherence concentrates on the compliance of the initiative with other EU instruments, and
also relevant international obligations. In this respect, all identified policy options were built in such
a way to ensure complementarity to several existing and emerging EU and international initiatives
dealing with emissions measurement and reporting and consumer protection, as presented in
sections 1.3 and 1.4. However, the coherence of respective policy options vary, especially with
respect to the choice of a reference GHG emissions accounting methodology, and the type of
input data framework. In this context PO2, PO4 and PO6 show a high level of external coherence,
being based on the existing (international) ISO standard 14083 and hence offering better
opportunity for a global methodological alignment. However, PO4 and PO6 allowing external
(international, national, sectorial) databases of default values (under certain conditions) are
slightly more coherent than PO2, offering a single, centralised EU default values dataset. The
coherence of PO1 and PO3 will be lower than PO4, PO2 and PO6, since both options are based
on the ISO standard 14083 with additional elements (such as LCA147
for batteries), that are not
yet taken up in the international emissions accounting approaches. PO3 will nevertheless feature
better than PO1, due to the decentralised system for default values, allowing the use of external
databases (under certain conditions). PO5 scores the lowest, given the most complex and specific
methodology provided through PEFCRs, that is not in use at the EU and international scale for
quantifying emissions of transport services (this is especially valid for aviation and maritime that
operate internationally). What is more, PO5 offers an EU centralised database of default values.
1.20 Subsidiarity and proportionality
None of the options goes beyond what is necessary to achieve the objectives or causes
subsidiarity concerns. All policy options provide solutions towards a harmonised methodological
approach, data access and treatment, as well as specific implementation aspects. These solutions
constitute significant added value compared to the situation where this harmonisation process is
left to the market or Member States alone.
In terms of proportionality, PO4 appears as the option providing the most balanced approach.
Specifically, it envisages the use of the already existing and widely recognised standard ISO
14083, it allows (under specific conditions) for the decentralised approaches for input data and
calculation tools, and sets rational requirements (excluding SMEs) for the verification. In
addition, by including the binding opt-in application of the harmonised framework, PO4 enables
a level playing field for emissions accounting across transport modes and segments, limiting the
requirements only to those entities that decide or are mandated to quantify and share GHG
emissions data. This aspect is important for stakeholders, in particular SMEs148
, which very often
lack capacity and knowledge to effectively start accounting emissions in the short term, and
therefore expect a more gradual implementation approach addressing their specific situation.
147
Feedback received from stakeholders and desk research showed that the LCA approach, while worth of gradually
pursuing in the long term, was not deemed fully feasible in the short term, especially in the context of the current
requirements and practice at international level.
148
See section 4.2.4 of Annex 2
50
PO2 ranks second mainly because of challenges associated with the achievement of the full
harmonisation of emissions accounting on the market. The other four policy options (PO1, PO3,
PO5 and PO6) are less proportionate, especially PO1 and PO6 with very burdensome and costly
approaches related to the mandatory application of the framework.
1.21 Comparison of the options
Table 14 provides a summary of the comparison of the options against the baseline scenario in
terms of effectiveness, efficiency, coherence, subsidiarity and proportionality. The following
ranking symbols have been used: from '+' (more effective/efficient/coherent/ proportionate than
the baseline) to '+++++' (much more effective/efficient/coherent/proportionate than the
baseline); from '-' (less effective/efficient/coherent/proportionate than the baseline) to '-----'
(much less effective/efficient/coherent/ proportionate than the baseline).149
Table 14: Comparison of options in terms of effectiveness, efficiency, coherence, subsidiarity and proportionality relative to the
baseline
Criteria PO1 PO2 PO3 PO4 PO5 PO6
Effectiveness +++++ + ++ +++ + +++++
Efficiency ----- ++++ -- +++++ --- -----
Coherence + +++ + +++++ + +++++
Subsidiarity and
proportionality -- ++ -/+ +++++ -/+ --
1.22 Sensitivity analysis
It should be noted that there is uncertainty regarding the estimates of the benefits identified in the
previous sections. CountEmissions EU is expected to contribute to the reduction of GHG emissions
from the transport and logistics sector in two ways: by providing more transparency with respect to the
emissions of different transport services and by its use by other decarbonisation initiatives. While the
first set of direct impacts can be estimated, those triggered by the development of new programs using
CountEmissions EU as their tool cannot be quantified but are probablymuch larger than direct savings.
The empirical evidence on the effects between the GHG emissions accounting, changes in transport
activity and the related reduction in the GHG emissions is scarce. For this reason, a sensitivity analysis
hasbeenperformed,assumingadecreaseby40%intheshareofpassengersmakingsustainablechoices
amongtheclimateawarepopulation(scenarioA),and adecreaseby30%inthesharesofactivityshifted
to more sustainable transport modes and optimisation of trips (scenario B). Methodological details on
the sensitivityanalysis are provided in Annex 4, section 5. Table 15 shows that even with lower shares
of passengers making sustainable choices because of increased transparency and data availability, the
benefits from GHG emissions and air pollutants emissions reduction, fuel saved and accident
reductions would realize, although the positive impacts would be limited. The same applies for the
scenario assuming reduction of the shares of activity shifted to more sustainable transport modes and
trips optimisation. Therefore, the ranking of the policy options would not change.
149
This is a qualitative assessment and for presentational purpose, thus we decided to limit the number of + to
provide a clear overview of the ranking of the options. For instance, the effectiveness of PO1 and PO6, due to their
mandatory applicability, is 23 fold the number of companies estimated in PO4 in 2030. This is clarified in section
6 and Annex 4.
51
Table 15: Results of the sensitivity analysis on the net benefits and benefit to costs ratio, expressed as present value over 2025-
2050 (in million EUR) relative to the baseline
Difference to the Baseline
PO1 PO2 PO3 PO4 PO5 PO6
Net Benefits (in million EUR)
Share of passengers and activity - central case -78,414.4 1,477.3 -217.9 2,352.1 -1,272.1 -51,329.4
Share of passengers (A) – 40% lower -81,735.0 964.1 -450.6 1,572.4 -1,476.3 -54,650.0
Shares of activity (B) – 30% lower -83,060.8 758.1 -544.1 1,259.7 -1,558.4 -55,975.7
Benefits to cost ratio
Share of passengers and activity - central case 0.2 2.4 0.8 2.5 0.4 0.2
Share of passengers (A) – 40% lower 0.1 1.9 0.7 2.0 0.4 0.2
Shares of activity (B) – 30% lower 0.1 1.7 0.6 1.8 0.3 0.2
8. PREFERRED OPTION
1.23 Identification of the preferred policy option
Even though all policy options are in line with the general objective and include measures that
address all specific objectives and problem drivers, they vary when assessed on different criteria.
First, there is a clear difference in their effectiveness. As explained in section 7.1 and shown in
Table 14, PO1 and PO6 are considered by far to be the most effective, followed by PO4, by
contributing substantially to the harmonisation of GHG emissions data from transport services
(SO1) and the uptake of GHG emissions accounting on the market (SO2). On the other hand,
PO1 and PO6 score lowest on efficiency, given the very high costs (and very low benefit to cost
ratio, 0.2) associated with the mandatory application and implementation of the harmonised
framework by all entities involved in transport service activities. PO4 is assessed to be the most
efficient, with the highest benefit to cost ratio (2.5).
In relation to internal coherence all policy options perform broadly the same. However, in
relation to the external coherence with other instruments and policies, as shown in section 7.3
and in Table 14, PO4 and PO6 perform better than PO2, relative to the baseline, and much better
than PO1, PO3 and PO5.
All policy options are in line with the principle of subsidiarity, addressing issues that cannot be
solved by interventions at national level. In terms of proportionality, PO4 is deemed to be the
most proportionate, as shown in section 7.4 and Table 14. PO2 ranks second mainly because of
challenges associated with the achievement of the full harmonisation of emissions accounting
on the market. The other four policy options (PO1, PO3, PO5 and PO6) are less proportionate,
especially PO1 and PO6 with very burdensome and costly approaches related to the mandatory
application of the framework.
In conclusion the analysis points at PO4 as the preferred policy option.
This option is supported by the stakeholders. As regards the methodological choice, one should
note a strong support across all the consultation activities for an approach that considers already
existing or emerging emissions accounting harmonisation efforts. In this respect, there was a
clear preference in favour of the Well-to-Wheel, GHG perspective, with the new ISO standard
52
14083 as a relevant reference methodology150
. When it comes to the input data, stakeholders
strongly favoured the use of primary data for accounting emissions in the transport sector.
However, they indicated that the use of primary data is not always possible in the business
practice, and therefore default values should also be allowed, provided they are of a suitable
quality. In terms of applicability, whereas most respondents advocated for certain mandatory
components, SMEs preferred rather optional approaches, or possible derogations from a
mandatory instrument. Similarly, regarding the verification of compliance of GHG emissions
data and processes, stakeholders were in favour of such a system to be established, but called for
specific exemptions in case it proves to be burdensome and costly. Finally, the majority of
respondents believed specific implementation guidelines for market players to be necessary,
however they were not fully clear on how these should be addressed in the context of
CountEmissions EU. It should be noted therefore, that the set of policy measures included in the
preferred policy option address these opinions in the most comprehensive way.
The transport services ecosystem and interactions between different types of stakeholders under
PO4 is illustrated in Figure 3 below.
Figure 3: Transport service ecosystem and actors involved in a harmonised emissions accounting framework
1.24 Application of the ‘one in, one out’ approach
PO4 will result in a limited increase in the administrative costs for businesses (business sector
associations and calculation tools developers), estimated at EUR 26,419 per year relative to the
baseline151
. These costs are composed of annual labour costs for the submission by the business
sector associations of the databases to be quality checked by EEA (PM5, EUR 8,343) and the
150
The LCA approach emerged as important in many stakeholders’ responses too, especially in the context of the
open public consultation.
151
As explained in Annex 4, estimations about costs and cost savings for business associations and calculation tools
developers are made on the basis of the assumption that 17 databases will be submitted to EEA for quality check,
and 34 tools will be certified every year by the verification bodies. The costs for preparing the submission of
databases and tools for submission is estimated at EUR 490.76 per database and EUR 531.65 per tool respectively.
53
certification of calculation tools by tools developer (PM12, EUR 18,076). Expressed as present
value over 2025-2050, relative to the baseline, the total administrative costs for businesses are
estimated at EUR 0.5 million.
In addition, total adjustment costs for businesses in PO4 are estimated at EUR 1.5 billion
expressed as present value over 2025-2050, relative to the baseline. These will however be over
compensated by energy costs savings for transport service providers, estimated at EUR 2.3 billion in
PO4. Thus, the net benefits for businesses are estimated at EUR 0.8 billion expressed as present
value over 2025-2050, relative to the baseline.
9. HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?
The Commission services will monitor the implementation and effectiveness of this initiative
through a number of actions and a set of core indicators that will measure progress towards
achieving the objectives. Five years after the implementation date of the legislation, the
Commission services should carry out an evaluation to verify to what extent the objectives of
the initiative have been reached.
As regards Specific Objective 1 (Ensure the comparability of results from GHG emissions
accounting of transport services) the main milestones to achieve this objective are the provision
of a common GHG emissions calculation methodology, the central database of energy emission
factors and the core database of emission intensity factors. The method will be established
already in the basic act, and the databases will be provided in the implementation phase.
Therefore, the main indicators that may be derived for the remaining aspects related to the
comparability of GHG emissions data, would refer to the use of accurate default values offered
by third party database developers and the level of correctness of the calculations undertaken by
concerned entities, namely:
 number of external default values databases having undergone the quality check,
 number of entities having undergone the verification of the calculated GHG emissions data
and related processes.
Monitoring of the achievement of Specific Objective 2 (Facilitate the uptake of GHG emissions
accounting of transport services in business practice) is expected to be more straightforward. It
may embrace in particular:
 number of companies accounting GHG emissions from transport services using
CountEmissions EU,
 number of certified technical calculation tools,
 number of conformity assessment bodies being accredited under CountEmissions EU.
However, it would not be possible to directly derive information feeding the indicator that refers
to the number of companies accounting GHG emissions of transport services using
CountEmissions EU. The majority of interactions related to disclosing GHG emissions data will
take place in a Business-to-Business or Business-to-Customer perspective, and this information
will not be available to public authorities. Since imposing such reporting requirements on the
businesses would create additional burden, the only solution to generate this type of information
would be a dedicated survey, for instance in the context of the future evaluation of the initiative.
54
In this context, the following information needs to be collected:
 A conformity assessment body concerned should maintain an up-to-date list of the calculation
tools that it has certified and for which it has withdrawn or suspended certification. It shall
make that list publicly available on its website and shall communicate the address of that
website to the Commission;
 A conformity assessment body concerned should draw up and maintain an up-to-date list of
the entities that have undergone the verification and notify this list to the Commission on
annual basis;
 A Member State should designate an authority maintaining an up-to-date list of the accredited
conformity assessment bodies. The designated national authority should notify this list to the
Commission on annual basis;
 Commission assisted by the European Environmental Agency (EEA) should monitor the
status of the quality assessment activities performed with respect to the external default values
databases.
 Upon request, horizontal analysis and technical assistance on specific implementation aspects
should be provided by the EEA.
EEA will be instrumental in assisting the evaluation and monitoring of the initiative in the part
related to the development and management of databases. The role of EEA is described in Table
16.
Table 16: Role of EEA
Role of EEA Stakeholders involved
 Development and maintenance of
core database of emission intensity
factors
 EEA (developments and management of the
database)
 Entities calculating GHG emissions, mainly TSO
and HU (as data users)
 Emissions calculation tools providers (as data
users)
 Establishment of a database of the
energy emission factors
 EEA (management of the database)
 Entities calculating GHG emissions, mainly TSO
and HU (as data users)
 Emissions calculation tools providers (as data
users)
 Quality check of third party
emission intensity factor databases
 EEA (performing quality check)
55
Role of EEA Stakeholders involved
 Entities – database developers (public, private)
submitting databases for the quality check (as data
users and providers)
56
ANNEX 1: PROCEDURAL INFORMATION
1. LEAD DG, DECIDE PLANNING/CWP REFERENCES
The lead DG is DG MOVE, Unit D1: Maritime Transport & Logistics.
DECIDE reference number: PLAN/2021/11499.
Item 2 in Annex I to Commission Work Programme 2022.
2. ORGANISATION AND TIMING
The impact assessment started in 2021, with the call for evidence published on 19 November
2021.
The impact assessment on CountEmissions EU was coordinated by an Inter-Service Steering
Group (ISSG). The Commission Services participating in the ISSG were: Secretariat-General,
Legal Service, DG Justice and Consumers, DG Climate Action, DG for Energy, DG
Environment, DG for Financial Stability and Capital Markets, DG Industry, Entrepreneurship
and SMEs, DG Research and Innovation. The Inter-Service Steering Group met 6 times: on 27
October 2021, 12 April 2022, 1 July 2022, 27 October 2022, 2 February 2023 and 23 February
2023. It was consulted throughout the different steps of the impact assessment process: notably
on all the stakeholder consultation material, the deliverables from the external contractor, and on
the draft Staff Working Document.
3. CONSULTATION OF THE RSB
The draft report was submitted to the RSB on 1 March 2023 and was discussed by the Board on
29 March 2023. RSB issued a positive opinion with reservations, that is attached to this report.
Recommendations from the Board have been addressed in this final version of the Impact
Assessment report as detailed in the table below.
Table 17: Modifications of the IA report in response to RSB recommendations
RSB recommendations Modifications to the IA report
Main considerations
(1) The report does not explain clearly how a
harmonised methodological framework is
coherent with existing reporting regimes and
methodologies and will enable the reduction
of GHG emissions of the transport sector.
Additional information on existing reporting
regimes has been included and discussed in
section 1.4 of the revised report. This
information addresses coherence and
complementarity of these regimes with the
proposed harmonised framework.
Further evidence supporting the assumptions
related to the reduction of GHG emissions
based on the literature review and
57
stakeholders’ consultations have been
addressed in section 6 and Annex 4.
(2) The report does not provide a complete
and realistic set of options.
A new policy option 6 (PO6), mandating the
use of a conducive metholdogy (ISO 14083)
but with a more decentralised approach, has
been added to the assessment. This option is
reflected in sections 6 and 7, and Annexes 4,
5, 9 and 10 of the revised report.
(3) The report does not sufficiently analyse
the intended versus unintended consequences
of the options, including as regards SMEs. It
is not sufficiently clear to what extent the
options will achieve behavioural changes
among transport service providers and users.
The revised version of the Annex 4 includes:
 new tables showing the relative (%)
impacts on SMEs and larger
companies, together with necessary
explanations;
 complementary information on
benefits and costs impacting both
SMEs and larger companies, broken
down per specific qualifier (fuel
saved, adjustment costs,
administrative costs, etc.);
 additional details on impacts
stemming from the behavioural
change to support the evidence
underpinning the calculations.
(4) The report does not well explain the
scoring methodology used when comparing
the options.
A new section 7.5 (Comparison of the
options) including clearer scoring
methodology, together with necessary
clarifications has been added to the revised
report.
Adjustment requirements
(1) The report should explain more clearly in
its problem definition and intervention logic
how a harmonised methodological framework
will enable the reduction of the GHG
emissions of the transport sector. The problem
drivers behind a limited uptake of GHG
emissions accounting in business practice are
of a different nature than the problem drivers
behind the limited comparability of GHG
emissions accounting results. The report
should make more use of evidence
underpinning the assumed changes in the
transport activity under each option. Given
that rules on emissions reporting exist also
Additional details clarifying interactions with
other relevant regulatory regimes have been
incorporated in section 1.4. New sections 2.3
(Interlinkages between the problem drivers)
and 2.4 (Affected stakeholders) have been
added to the revised report. Additional
references regarding the limited uptake of the
GHG emissions accounting of transport
services have been included in section 2.5.
Complementary clarification for the evidence
underpinning the assumed changes in the
transport activity has been included in
sections 6, 8.1, and Annex 4.
58
elsewhere in EU law and exist through other
methodologies in areas such as Emission
Trading System and corporate sustainability
reporting, the report should better assess the
coherence of the initiative (and later the
options) with existing instruments.
(2) The report should provide a complete and
realistic set of options. While it presents an
ambitious option which requires mandatory
emissions counting for all entities, this option
comes with additional requirements with less
flexibility and raises short-term feasibility and
coherence issues. To present a more credible
and ambitious option, the report should
consider presenting an option based on ISO
14083 while designing the other measures in
a more SME friendly manner.
A new policy option 6 (PO6) has been added
to the report. This option tests a fully
mandatory application of the common GHG
emissions accounting framework with a
similar set of policy measures with respect to
the preferred policy option (PO4). Based on
the assessment performed, the choice of the
preferred policy option has not changed.
(3) The report should analyse more deeply
what the intended as well as unintended
consequences would be of the options.
Although the preferred option is quasi-
voluntary, there seems to be a likelihood that
transport actors will impose emissions
accounting on their subcontractors, often
SMEs, to meet the sustainability expectations
of the transport demand side. Consequently, a
quasi-voluntary approach for enterprises
below a certain threshold might then become
a de facto standard. The report should
elaborate on the likelihood of this happening
and on what the main implications for the key
actors in terms of costs and benefits would be.
The report should also clarify whether the
adoption of the specific methodology and
related reporting would be expected to
influence other reporting regimes or become
obligatory under current or future initiatives,
and if so, what would be the consequences, in
particular on SMEs, including for areas such
as financing.
The consequences of various policy options
have been clarified in revised sections 1.4, 6,
and 8, and Annex 4. Additional implications
of quasi-voluntary policy options (binding
opt-in approaches) have been further
explained in Annex 4.
(4) The report should better explain how the
options will incentivise behavioural change,
made both on the supply and demand sides of
the transport market, towards their choice of
transport services. It should provide evidence
on the causality effect between the GHG
Clarifications have been added to Section 6
and Annex 4 (including sensitivity analysis).
The results of the sensitivity analysis on the
net benefits and the benefits to costs ratio, for
each policy option, have been added in
section 7.6. The impact on modal shift,
59
emissions accounting, changes in transport
activity and the related reduction in the GHG
emissions. If empirical evidence is limited or
unavailable, it should present use cases and
case studies used to support the assumptions
made in the modelling of changes to transport
activity due to this initiative. The report
should be clearer on how the different
transport modes will be affected by the
options. Given the high uncertainty related to
the estimates, the report should undertake a
sensitivity analysis on the key assumptions
driving the results.
underpinning the environmental impacts, has
been further explained in Annex 4. A new
annex (Annex 11) with illustrative case
studies and use cases has been added to the
report.
(5) The report should explain better the
scoring methodology used when comparing
the options. The scores attributed per criteria
for the options should be consistent with the
preceding analysis and adequately reflect the
differences in observed impacts. If, for
example, there are large differences in the
effectiveness or coherence of options, this
should be clearly explained and adequately
reflected in the scoring. The report should
clarify if factors outside the initiative’scope
have been factored in or out in the
effectiveness scoring, including
acknowledging limits to the analytical work
itself.
Section 7.5 has been added to the revised
report. This section further details the
effectiveness, efficiency, coherence,
subsidiarity and proportionality of the policy
options with a clearer scoring methodology
embedded. Respective corrections and
clarifications have also been included in
Annex 9.
(6) The report should ensure analytical
consistency throughout. Costs related to the
One In, One Out approach should be
presented in the aggregated format.
The analytical consistency has been checked
across the report and its annexes. Costs
related to the One In, One Out approach are
now presented in the aggregated format in
Annex 3.
4. EVIDENCE, SOURCES AND QUALITY
The impact assessment is based on several sources, using both quantitative and qualitative data.
These include:
 Stakeholder consultation activities (see Annex 2);
 External support study carried out by an independent consortium (led by Ecorys Nederland
B.V);
 Commission experience in standardisation activities and quantification of emissions in
transport.
60
61
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT)
This annex provides a summary of the outcomes of the stakeholders’ consultation activities
carried out for the CountEmissions EU initiative, including in the context of the technical support
study. It illustrates the main consultation activities, depicts the range of stakeholders consulted,
and presents a succinct analysis of their views and the main issues raised. The full analysis of
the consultation results is presented in the stakeholder consultation report annexed to the
technical support study.
The objectives of the consultation activities were the following:
 to collect information and opinions of stakeholders on the key problems and associated
drivers, the definition of relevant policy objectives linked to those problems, and the
identification and screening of policy measures that could be considered in this Impact
Assessment;
 to gather information and opinions on likely impacts of the policy measures and options.
OVERVIEW OF CONSULTATION ACTIVITIES
The consultation strategy was developed from the start of the project and included as key
stakeholders the following groups: citizens, companies, business associations, public authorities,
NGOs, consumer organisations, academia, trade unions, environmental organisations. The
consultation tools were placed in sequence to ensure appropriate feedback during the
development of the respective stages of the Impact Assessment.
Consultation activities took place in 2021 and 2022, and specifically included:
Feedback on the Call for Evidence
As part of the initial feedback mechanism, interested parties had the possibility to provide
feedback on the Call for Evidence published on the “Have your say” webpage152
on 19 November
2021 and open until 17 December 2021. In principle, the Call for Evidence collected feedback
regarding the Commission’s plans concerning the CountEmissions EU initiative, and general
opinions on the issues related to accounting emissions in the transport sector.
Open Public Consultation
The Open Public Consultation (OPC) questionnaire was accessible on “Have Your Say”
webpage from 25 July to 20 October 2022. The OPC specifically inquired about the current
situation and motivations for emissions accounting in transport, related problems and problem
drivers, and measures to address these on the EU market.
Targeted consultation
Two rounds of interviews were held:
152
Count your transport emissions – ‘CountEmissions EU’ (europa.eu)
62
 Exploratory interviews during the technical support study inception phase, aimed at
tackling general issues from different user perspectives and targeting subsequent
engagement with a broader group of stakeholders (Q2 2022).
 In-depth interviews to plug information gaps and assess the expected impacts of policy
measures (Q2, Q3 and Q4 2022).
Two rounds of surveys were carried out:
 A survey questionnaire to substantiate the problem analysis and to assess the impacts of
policy measures (Q3 and Q4 2022).
 A short follow-up survey questionnaire targeting selected Member States (Q4 2022);
One expert workshop was held, focusing on the problem tree and proposed measures (on
27 October 2022).
STAKEHOLDER GROUPS CONSULTED
This section provides a short overview of the main types of stakeholders identified and targeted
as part of the stakeholders’ consultation.
Overall, the consultation activities attracted interest from various types of stakeholders, which
resulted in a good participation level and numerous contributions received. The participation in
all consultation activities is shown in the table below.
Table 18: Overview of stakeholder consultation results
Consultation activity
Number of
stakeholders invited
Number of responses Number of
documents
provided153
‘Have your say’ Call
for Evidence
Not applicable 64 60 154
Open Public
Consultation
Not applicable After analysing the data, 188 non-
duplicates, of which 184155
contain
answers to the questionnaire and not just
a document (position paper) attached.
SMEs are 100 of the responses.
27156
Exploratory interviews 4 4 0
153
Position papers or other contributions in addition to the responses to the questions
154
The total number of written contributions was 64, but taking into account duplications, the number of unique
written contributions that have been reviewed is equal to 60.
155
It is possible that 6 out of the 184 answers to the Open Public Consultation questionnaire are part of a coordinated
campaign.
156
A total of 31 submissions were obtained, of which 4 were duplicate entries and were removed. From the
remaining 27, 22 contain information related to the scope of this initiative, 3 contain information about related
topics, and 2 do not contain information related to the scope of this initiative.
63
Targeted survey 70 After analysing and filtering the data, 38
questionnaires, of which 26 were fully
completed. SMEs are 8 of the responses.
22157
Targeted interviews 44 32 0158
Short survey
questionnaire
4 1 3159
Stakeholder workshop 43160
33161
0162
Source: Ecorys and CE Delft (2023), Impact assessment support study
It should be noted that given the concurrent engagement mechanisms, most stakeholders have
chosen not to participate in all opportunities that were made available to them. For example,
some stakeholders had contributed to the OPC or had undertaken targeted interviews and
therefore did not feel the need to participate in the targeted survey.
Call for Evidence
60 unique contributions were received, with a large majority of respondents belonging to
categories described as company/business organisations and business associations (25 and 24
out of 60, or 42% and 40%, respectively). With respect to the place of origin of the participating
respondents, 24 out of 60 (or 40%) of the responses came from Belgium, where business
associations usually establish head offices and act as umbrella organisations on behalf of
associated national or industrial members. Other opinions derive mostly from western and
northern EU Member States. Two contributions were also submitted from non-EU countries (the
UK and the US).
Open Public Consultation
The OPC was open to the general public, with 184 stakeholders participating. The responses to
the OPC were mostly populated by respondents representing company/business organisations
and business associations, followed by individual citizens (34%, 32% and 15%, respectively).
157
A total of 27 written contributions from 14 different stakeholders were received as part of this process in addition
to the responses to the questionnaire, of which 4 are duplicates, and 1 more was already submitted as a contribution
to the Open Public Consultation.
158
A number of written contributions were received from a limited number of stakeholders, but they are duplicates
of other submissions that have been received in other stakeholder engagement tools.
159
The only Member State to respond provided 2 links to websites and 1 link to an online-hosted document.
160
A total of 60 individual representatives were invited, representing 43 different stakeholder organisations.
161
In total there were 43 representatives attending the workshop, representing 33 different stakeholders.
162
One stakeholder sent a position paper as follow-up to the workshop, however it is a duplicate of documents
received as attachments to the Open Public Consultation.
64
Figure 4: Number of Open Public Consultation respondents by type of respondent
Source: Ecorys and CE Delft (2023), Impact assessment support study
In terms of the geographical representation, the respondents originated from across the EU,
mostly from the western and northern Member States, and in particular from Belgium. A number
of responses were also submitted from non-EU countries, namely the US, Switzerland, the UK,
Serbia, Canada and Brazil.
Figure 5: Participating stakeholders: countries of origin
Source: Ecorys and CE Delft (2023), Impact assessment support study
65
Targeted consultation
Exploratory interviews
4 stakeholders were interviewed in exploratory interviews The represented specifically: a
passenger transport association, a shippers’ association, a non-profit environmentally oriented
organisation and a green transport programme.
Targeted interviews
32 stakeholders responded positively to the invitation to participate in targeted interviews,
representing 12 individual companies, 9 transport associations, 4 public authorities, 2 consumer
and passenger associations, 1 academia/research institution and 4 other types of stakeholders.
Targeted survey
Questionnaires were sent to 70 addressees across the identified groups. Eventually 38 responses
were collected from stakeholders, 26 of which had completed the survey in full.
Figure 6: Number of targeted survey respondents by type of respondent
Source: Ecorys and CE Delft (2023), Impact assessment support study
As shown in Figure 7, the majority of the respondents operate in EU-27 countries.
66
Figure 7: Participating stakeholders: countries of origin or respondents
Source: Ecorys and CE Delft (2023), Impact assessment support study
Workshop
A workshop was organised on 27 October 2022 upon direct invitation, with 43 participants
representing 33 different stakeholders participating online: Airbus, Alliance for Logistics
Innovation through Colaboration in Europe (ALICE), Aerospace, Security, and Defense
Industries Association of Europe (ASD), Federation of German Industries (BDI), European
Chemical Industry Council (CEFIC), Community of European Railway and Infrastructure
Companies (CER), CLECAT (European Association for Forwarding, Transport, Logistics and
Customs Services), Deutsche Bahn (DB), Deutsche Post DHL Group (DPDHL), Danish
Transport and Logistics Association (DTL), European Union Aviation Safety Agency (EASA),
European Environment Agency (EEA), Erste Group Services, European Freight and Logistics
Leaders’ Forum, European Shippers’ Council, Federation of European Private Port Operators
(FEPORT), Global Business Travel Association (GBTA), HAROPA Port, International Air
Transport Association (IATA), International Road Transport Union (IRU), ISO workgroup,
Kaufland, Lidl/Schwarz group, Lufthansa, Nordic Logistics Association, Norwegian Truck
Owners Association, Swedish Association of Road Transport Companies - Sveriges
Akeriforetag, Topsector Logistiek, Transporeon, International Union of Wagon Keepers (UIP),
Vendelbo Spedition, World Shipping Council, ZF group.
Short survey questionnaire
Short written questionnaires were sent to selected Member States to complement the
stakeholders’ consultation analysis. Only one Member State (France) provided a response to the
questionnaire.
67
LIMITATIONS OF THE STAKEHOLDER CONSULTATION
Some consultation activities (especially targeted) spread over the European summer period. This
resulted in partial review of the original list of stakeholders. The stakeholders that were not
available for the interview were in almost all cases replaced with similar organisations. The
exception was the e-commerce sector, where despite repeated invites there was limited feedback,
resulting in little direct representation in the interview process.
In addition, due to time constraints and limitations in the availability of the Member States
stakeholders to participate in the interviews, these were substituted with short written
questionnaires sent to Denmark, Estonia, France, and Italy. Only one Member State (France)
provided a response to the questionnaire. However, other input from public authorities, including
Member States, was also collected though the general consultation tools.
Time constraints during the stakeholder workshop meant that not all policy measures were
individually discussed with the same rigour. Stakeholders had a lot to say on the debate around
input and output data, which led to the situation where other policy measures were only briefly
discussed, sometimes as a group of measures only, instead of individual ones. While this reflects
the issues that stakeholders consider the most important, it limited the quality of the input on the
other aspects, not related to the data.
ANALYSIS OF THE KEY RESULTS OF THE STAKEHOLDER CONSULTATION
The remainder of this annex presents key findings from the analysis of stakeholder contributions
to the consultation process.
Feedback received on the problem definition
This section provides an overall view of the stakeholders’ inputs on the proposed definition of
the problem and its underlying drivers.
Figure 8: Extent to which the stakeholders agree with the overall problem diagram
Source: Ecorys and CE Delft (2023), Impact assessment support study
68
It should be acknowledged however, that the public consultation also revealed a clear need for
shifting some elements in the initial problem definition, especially to recognise particular
importance of input data while accounting emissions. Consequently, the problem tree was
reshaped and updated, and its final version is shown in section 2 of this report.
Current situation and motivations
The initiative received an overwhelming support from almost all stakeholders in the Call for
Evidence (57 out of 60, or 95%) and the targeted survey (28 out of 31, or 90%). While the OPC
did not explicitly include this type of question, the received responses indirectly point to a similar
conclusion. This view was also notably expressed in the targeted interviews and was confirmed
during the stakeholders’ workshop.
Figure 9: Summary of the overall support of stakeholders for the initiative, expressed in the Call for Evidence
Source: Ecorys and CE Delft (2023), Impact assessment support study
Stakeholders generally recognised that a harmonised measurement and calculation framework is
needed as emissions accounting becomes increasingly embedded in the broader policy
ecosystem and the decision-making processes of transport services users. Better measurement of
emissions is also considered by many as a way to establish and monitor specific sustainability
targets.
In the Call for Evidence, targeted survey and interviews, stakeholders pointed to the on-going
harmonisation efforts concerning emissions accounting in transport (such as ISO 14083, GLEC,
Green Freight Europe, COFRET, CEN EN 16258), although they also admitted the lack of the
necessary implementation regimes. This finding was also confirmed during the stakeholders’
workshop.
The consultation also showed that emissions measurement and calculation is more mature and
harmonised in the freight transport segment. However, as evidenced during the targeted
interviews, passenger transport operators do acknowledge that emissions data is a factor that is
increasingly looked into, especially during transport procurement processes.
When asked about their motivation to measure emissions, the respondents to the targeted survey
indicated without exception their environmental awareness and willingness to contribute to
meeting emissions reduction targets (22 out of 22 consider it important or very important).
Targeted interviews further suggested that emissions accounting is also perceived as an element
of risk management for private sector organisations. They are aware that emissions data would
be increasingly important for preserving their competitiveness (or investor relations) and are
69
therefore investing in systems to both measure or calculate emissions and communicate them
effectively.
All consultation activities, however, consistently revealed that information on emissions is not
yet a primary factor in decision-making for acquiring products and services. From the targeted
survey, it is clear that price, time and reliability (quality) remain the primary motivators, with
environmental aspects amongst the secondary considerations (12 out of 32, or 38%). SMEs are
even less likely to consider the environmental dimension in their business practice than large
companies (only 1 out of 7 SMEs, or 14%). On the other hand, the targeted interviews and the
workshop showed that currently it is difficult to consider these aspects during the decision-
making process, since information on emissions is hardly available at a point of sale, either for
freight or passenger transport.
Views on problems
– Problem 1: Limited comparability of results of GHG emissions accounting in transport
and logistics
The vast majority of the consulted stakeholders see the lack of reliable and comparable
information on GHG emissions data as a relevant issue. These findings were in principle
confirmed by the results of the OPC, with 136 out of 169, or 80% respondents reiterating the
prevalence of this problem and considering it significant or very significant. What is more, 103
out of 157 (66%) indicate it as a real concern for their professional or private activities.
In addition, the respondents to the Call for Evidence point to substantial divergences in emission
data calculation results and to the lack of comparability, which ultimately diminishes the
usefulness of GHG measurement and calculation, when it comes to taking informed travel and
transport decisions. The respondents also emphasised that the status quo does not allow
providing the end users with clear price signals and acknowledged that this situation hinders the
effectiveness of GHG measurement and calculation as a policy measure to incentivise
environmentally friendly transport and mobility choices.
Also, the stakeholders joining the workshop acknowledged large differences between emissions
data calculated for transport services and shared in the transport chain, recognising the
proliferation of methodological choices, and large variability in the input data.
Finally, 22 out of 31 respondents to the targeted survey pointed to better comparison of GHG
emissions data as a key feature describing the added value of CountEmissions EU.
– Problem 2: Limited uptake of emission accounting in usual business practice
Respondents of the OPC agree that while obtaining information on GHG emissions of transport
services is important or very important (145 out of 175, or 83%), and they are not given enough
information when planning a journey or transport of goods (45 out of 56 organisations, or 80%;
61 out of 70 individuals, or 87%; and 60 out of 65 online customers, or 92%), which seems to
confirm this problem. Respondents to the targeted survey also estimated the current uptake of
emissions accounting as low or very low (26 out of 31, or 84%) and interviewees agreed, adding
that while companies are starting to take up emissions accounting, this is not yet a commonplace,
a notion that was also mentioned by the stakeholders that participated in the workshop.
On the other hand, the outcomes of various consultation activities show that many stakeholders
already perform some form of emissions measurement and calculation. The results of the
targeted survey suggest that 29 out of 37, or 78% measure emissions, but in most cases this is
done only for certain activities, and not necessarily frequently. It is also not a common practice
70
to measure, calculate or communicate transport emissions at the service or trip level (only by 9
out of 26, or 35% of the respondents who declared to measure their transport emissions), which
is necessary to influence transport choices of operators and users.
These factors together confirm that emissions accounting in business practice is very limited at
least in uptake, completeness, frequency, and precision. The targeted survey showed that the
majority of respondents (30 out of 31) would adopt a harmonised emissions measurement
framework if established at EU level.
Feedback received on problem drivers
– No set of common methodological principles to apply GHG emissions accounting
The lack of a harmonised method appeared as a major problem driver across various consultation
activities.
The respondents to the Call for Evidence recognised it as an important factor hampering the
ability to accurately measure and compare the environmental impact of various transport
activities. In this context, a number of contributions pointed to the harmonisation efforts being
undertaken at various levels, however without having significantly improved the situation on the
market.
In the OPC, 90% (157 out of 174) of the respondents replied that the existence of various GHG
accounting methods and calculations leading to the provision of incomparable GHG emissions
data poses a significant or very significant problem. When asked if this problem was affecting
their private or professional activities, 69% (113 out of 163) replied affirmatively, while 20%
(33 out of 163) considered this phenomenon to affect them only to a limited extent.
– No set of harmonised input data to apply GHG emissions accounting
In the initial problem definition presented to the stakeholders, this driver was integrated with
another one addressing the lack of common methodological principles. However, based on the
feedback from the stakeholders suggesting that the issues associated with input data (i.e. primary
data and default values) need a more prominent place in the problem definition, ‘No set of
harmonised input data to apply GHG emissions accounting’ was included in the problem tree as
a separate problem driver.
In this context, looking at the results of the targeted survey, the vast majority of the respondents
replied that the issue of various methodological principles and input data together, is either
relevant or highly relevant (77%, 24 out of 31).
The Call for Evidence, the targeted interviews and especially the stakeholders’ workshop clearly
demonstrated that there is large variance in the accounting results depending on the input data
used, even when using some already established methodologies. Especially debates at the
workshop focused on the importance of this problem driver and suggested an EU action may be
needed, for instance to incentivise the use of primary data.
– Reluctance to share (sensitive) data
The reluctance to share data that is necessary for emissions accounting and decision-making
processes was strongly discussed during interviews, mainly with transport service providers and
their associations. Reasons given included the need to preserve sensitive information on costs
and operations, especially among SMEs. The contributions in the stakeholders’ workshop, as
well as the replies to the survey questionnaire (19 out of 31 respondents, or 61% rank it as
relevant or highly relevant) and the questionnaire sent to Member States further reiterated the
71
importance of this driver in the problem definition. Specifically, France clearly indicated that
CountEmissions EU should provide rules addressing the exchange of information on GHG
emissions with an appropriate level of security and privacy.
– Lack of trust concerning GHG emissions output data
This driver was not initially provided in the first set of targeted interviews, targeted survey and
the OPC, but it was included in the workshop discussion, because feedback obtained from
stakeholders at previous stages of the consultation process pointed to the consistent lack of trust
concerning GHG emissions output data as an important issue to be tackled. For instance, OPC
respondents (145 out of 175, or 84%) acknowledged that access to reliable and accurate GHG
emissions data is important or very important.
During the workshop, a number of stakeholders contributing to the discussion mentioned the
need for more reliable emissions accounting results as a relevant factor. The lack of trust in
reliability and comparability of the GHG emissions figures was commonly considered a reason
for lower demand for such figures and hence lower uptake of GHG emissions accounting. In this
context, the need for a credible and harmonised verification mechanism for the output shared or
published has been constantly raised as an issue by many stakeholders.
– Complexity and high costs of GHG emissions accounting
In general, stakeholders regarded complexity and high costs of GHG emissions accounting as
strongly associated with calculation processes, and sharing of GHG emissions figures in the
transport networks. The majority of the respondents (20 out of 31, or 64%) that replied to the
targeted survey, consider this problem driver relevant or highly relevant. Respondents to the
OPC also ranked this as the third most relevant driver, only after the limited availability of data
within organisations and along the supply chain. These findings were also broadly confirmed by
the stakeholders participating in the targeted interviews.
Feedback received on possible solutions
General expectations from a harmonised emissions measurement framework
When asked to rank specific criteria relevant for the harmonised GHG emissions measurement
method (from 1 - most important to 5 - least important), respondents to the targeted survey
pointed to the comparability of results over time as their first or second choice (16 out of 26, or
61%). This aspect was followed by the choices related to the consistency/reproducibility of the
measurement method (12 out of 27, or 44%) and its relevance (11 out of 27, or 41%).
72
Figure 10: Summary of the views of stakeholders in regards to their ranking of importance of different criteria for a
harmonised emissions measurement method.
Source: Ecorys and CE Delft (2023), Impact assessment support study
The need for a consistent approach to measuring GHG emissions was also raised by the
respondents to the OPC (167 out of 178, or 94%).
Interaction of the common emissions accounting method with currently existing
methods
Regarding the design of the initiative, there is strong support across all the consultation activities
for an approach that considers already existing or emerging emissions accounting harmonisation
efforts. In this regard, the response obtained from the Member State questionnaire suggests that
the success of the measure can be highly dependent on being based on well-established and
robust methodologies, especially those with global scope, as otherwise it could open the way for
a dispute.
According to the Call for Evidence, interviews, and workshop, it was highlighted that it is also
important that organisations are not subjected to diverging requirements, either across countries
or regions, as that would greatly increase complexity of emissions accounting and the associated
costs.
Inclusion of sector specificities in the common emissions accounting method
The targeted survey (23 out of 28, or 82%), interviews and workshop revealed that the majority
of stakeholders believe sector specific guidelines based on common rules are necessary, with a
possible role for each sector in collaboratively developing and implementing them in its
respective networks. However, the interviews and workshop did show that some stakeholders
also see these decentralised developments as a risk leading to uncontrolled divergences between
the quantification processes in various sectors and resulting in producing inconsistent emissions
output data. According to discussions with stakeholders, this phenomenon may be mitigated by
73
specific measures, such as a centralised approval of sectorial guidelines, or harmonised
implementation rules applicable across the board. Moreover, during the workshop some parties
mentioned that the uptake of primary input data could minimise the need for these guidelines in
general.
Mandating the use of the common emissions accounting method
According to the results obtained across the various consultation tools, there is a significant
preference of stakeholders for an instrument including certain mandatory components. This may
be especially demonstrated by the results of the targeted survey, where 26 out of 28 respondents
(93%) indicated this preference, with the majority of them (17 out of 28, or 61%) suggesting
mandatory calculation and reporting of emissions for at least some classes of organisations in
the transport system. The survey also shows that the participating SMEs have a bigger propensity
to prefer optional approaches, or, alternatively, derogations in the mandatory instrument (4 out
of 7, or 57%, compared to 9 out of 28 or 32% overall). This could be due to disproportionate
impact of the mandatory instrument on SMEs, a comment that appeared during interviews and
workshops. Some transport associations that participated in the interviews in particular suggested
large businesses should take on more of the early costs associated with CountEmissions EU, and
then gradually involve the SMEs in their ecosystems to facilitate the knowledge and process
transfer.
Unsurprisingly, the survey also revealed that stakeholders believe that the initiative will be more
impactful if a mandatory instrument is used. Respondents felt that in this case positive effects
for the transport system would substantially increase (respondents were asked to rank the
magnitude of a number of potential impacts and the large majority foresaw an increase in positive
impacts). However, they did not expect large emissions reductions from the accounting
emissions alone (only 10 out of 23, or 43% foresaw emissions reductions), since CountEmissions
EU should be seen rather as an enabler for more efficient transport options, and not a measure
that can make the change directly. The insights from the interviews and the workshop broadly
confirmed this finding.
Scoping and boundaries of the common emissions accounting method
The stakeholders’ consultation provided useful input to the analysis of various design
alternatives when discussing methodological choices for CountEmissions EU163
.
In principle, the Call for Evidence, survey and interviews clearly demonstrated that GHG (CO2
equivalents) are the preferred emissions scope for the common method. The interviews and the
survey (16 out of 28, or 57%) also showed that the transport service level accounting is the one
most favoured by the stakeholders (which is also the case for the Member State questionnaire
response), followed by the product-level approach. In all consultation activities, as already
mentioned above, there was a strong preference for a methodology that would have a global
scope, facilitating emissions accounting in the international transport chains.
In terms of the activity boundaries, the Well-to-Wheel (WTW) approach was the most preferred
by stakeholders across various consultation activities. However, the full lifecycle assessment
(LCA) was equally strongly supported in the OPC (i.e. 75 out of 164 respondents or 46% each),
especially among citizens. In this context, there appears a division among beneficiaries of
transport services (individuals and businesses not directly participating in transport activities)
more inclined towards the LCA approach, and stakeholders that are a more integral part of the
163
See Annex 8 for more technical details.
74
transport system expressing their favour towards the WTW. From the regulatory side, a response
from France, benefitting from long experience in emissions accounting in transport, revealed a
preference for the WTW boundaries as well.
Verification of the emissions data
A dedicated system for verification of the emissions data and calculation processes featured
prominently across all the consultation activities. In the targeted survey, for instance, out of 28
responses received, there was no opinion against the verification system to be implemented. This
finding can be confirmed by the results of the OPC with 158 out of 178 (89%) respondents
suggesting this measure should be tackled by CountEmissions EU. Also the participants of the
stakeholders’ workshop suggested a system where the emissions calculation methods and GHG
data can be verified, expressing at the same time their strong preference towards using primary
information.
On the other hand, the consulted stakeholders were not clear on how this verification system
should be designed and which functionalities it should bear. In the OPC, an important share of
answers (43 out of 178, or 24%) indicated that specific exemptions to the verification could be
possible if it would prove to be too burdensome and costly.
Provision of the technical support tools and data sharing
Stakeholders see the provision of technical support tools (such as calculators and specific
software) as useful enablers to facilitate the uptake of the common emissions accounting
methodology. Based on the targeted survey, 18 out of 28, or 64% of the respondents would likely
or very likely use these tools in their business practice, a result that should be corroborated with
the outcome of the OPC (123 out of 175, or 70% of the respondents pointed to the need for
additional support tools under CountEmissions EU). This OPC finding is particularly strong
among business associations (46 out of 57, or 81%) and NGOs (5 out of 6, or 83%). Comments
in this regard highlighted that these tools could be most beneficial to lighten the administrative
burden of SMEs.
On the other hand, there was no consensus on where these technical support tools should be
developed or provided from. In particular, the respondents to the OPC and targeted survey were
not clear on the potential role of the public and private sectors in developing and providing these
tools to organisations that need/want to calculate their GHG emissions from transport services.
Otherwise, stakeholders participating in the interviews and the workshop suggested that the
private sector is better positioned to provide specific tools for businesses, while these should
undergo some form of a public sector verification. The latter finding broadly aligns with the
views expressed in the targeted survey (by 23 out of 28, or 82% of the respondents), that the
technical support tools, regardless where they come from, should be certified by an independent
entity.
In addition, during various consultation activities, stakeholders also raised the topic of sharing
emissions data between various entities in the transport chain. According to these stakeholders,
some actions would be necessary to ensure an appropriate level of security and confidentiality
of these data (for instance by appointing neutral third parties or establishing/allowing for
dedicated emissions data sharing platforms). During the workshop, an idea was also brought up
for the EU to define clear rules on handling these data by businesses in a proper manner.
75
ANNEX 3: WHO IS AFFECTED AND HOW?
1. PRACTICAL IMPLICATIONS OF THE INITIATIVE
Summary of the implementation of the preferred policy option
The focus of the initiative is to provide a harmonised framework for accounting GHG emissions
of transport services, and to incentivise its uptake on the transport market.
The framework is conceived to stimulate the behavioural change among businesses and
customers to effectively lower GHG emissions of transport. The preferred policy option (PO4)
establishes the binding opt-in application of CountEmissions EU, accompanied by a set of
provisions ensuring a high level of harmonisation of the GHG emissions data, and facilitating
the use of the framework for various groups of stakeholders. According to the analysis performed
in the Impact Assessment, PO4 provides a structure for the efficient implementation of the
framework without creating a disproportionate burden and costs for the stakeholders concerned.
Specifically, the impacts of the measures included in the preferred policy option are expected to
fall on different stakeholder groups:
 Stakeholders involved in transport services activities;
o transport service organisers and hub operators;
o transport service users;
o other entities involved in accounting of GHG emissions of transport services;
 National public authorities responsible for transport statistics;
 National Accreditation Bodies (NABs);
 Society as a whole.
Stakeholders involved in transport services activities
Transport service organisers and hub operators164, including transport operators, transport
intermediaries165
(e.g. travel agencies, freight forwarders, logistics service providers) and
operators of freight and passengers hubs (e.g. terminals, logistics platforms, ports, airports) will
bear the major share of the costs estimated for the preferred policy option. The costs will in
particular be associated with the implementation of the methodological requirements based on
the new ISO standard 14083 (adjustment costs). However, given that these requirements will
apply only to entities that decide to quantify and share their GHG emissions data, this cost
category is estimated to remain at a relatively moderate level. Other costs for transport service
organisers and hub operators will mostly relate to the verification of the GHG emissions data
generated under CountEmissions EU and the processes used for their quantification.
Nonetheless, these costs will be borne mainly by large enterprises, since the SMEs are exempted
from this provision, unless they decide to undergo this verification voluntarily.
164
To simplify the reading they are referred throughout the document as transport service organisers
165
Transport intermediaries might take the role of transport service users, depending on the type of activity
performed in the transport chain. For instance, a freight forwarding company may serve as a transport service
organiser in relation to a manufacturer/shipper and as a transport service user for a transport operator.
76
On the other hand, transport service organisers will benefit from a unique and harmonised
framework for emissions accounting, including clear instructions and specific provisions
facilitating its implementation in business practice (such as certified emissions calculation tools,
recognised databases of emission factors, implementation guidelines and harmonised rules for
GHG emissions output data). The comparability and reproducibility of GHG emissions figures
accounted by using CountEmissions EU will allow for better transparency as regards the
performance of various transport services, and will lead to more informed business decisions,
reduced fuel/energy consumption, lower operational costs and intangible reputational benefits
vis a vis transport service users and society in general. Overall, it is estimated that for this
category of stakeholders the initiative will lead to net benefits, as demonstrated in Annex 4
below.
Transport service users, be them passengers, customers, public authorities,
manufacturers/shippers, wholesalers, retailers, transport service intermediaries166
or data
intermediaries167
will mostly benefit from the clear, comparable and correct information on GHG
emissions offered by the harmonised emissions accounting framework. This transparency will
allow users for making informed choices as regards specific transport options, thus incentivising
the behavioural change towards sustainable transport options and emissions reduction. However,
the impact of these benefits, potentially large, cannot be directly quantified.
On the other hand, additional costs may arise for some users, especially those accounting
emissions from their transport chains (e.g. shippers, logistic service providers, freight
forwarders, travel agencies etc.). However, these costs are expected to be offset by the clear
accounting rules, harmonised data and implementation support.Other entities involved in
accounting of GHG emissions of transport services, include notably the providers of GHG
emission calculators and other tools facilitating emissions accounting, such as business sector
associations. This group of stakeholders will be mostly concerned by the requirements and costs
related to the certification of tools they offer on the market and the quality check of
sectorial/national default values databases. However, these additional costs will be outweighed
by the benefits from the increased demand for these tools and databases.
National public authorities responsible for transport statistics are not expected to change
their reporting and enforcement modalities, but the necessary adjustments to the GHG emissions
data output formats, and efforts related to the acknowledgment of the new emissions accounting
rules will result in additional costs of a limited scale.
National Accreditation Bodies (NABs), would incur some minor costs for getting familiar with
relevant provisions of CountEmissions EU, as well as for additional efforts related to the
accreditation of bodies that will perform the verification and certification activities foreseen
under CountEmissions EU.
166
Certain categories of users, like manufacturers/shippers, wholesalers, retailers may to some extent execute
transport services with using their internal resources. This has been accounted in the assessment
167
A data intermediary may be considered as a specific category of a user that collects information on a transport
services from transport organisers and operators and discloses it further on the market.
77
Implications for society as a whole will include the improved transparency of information on
the performance of transport services, implying the behavioural changes towards more
sustainable transport choices and the related reduction of the GHG emissions, associated with
positive impact on human’s health.
SUMMARY OF COSTS AND BENEFITS
I. Overview of Benefits (total for all provisions) – Preferred Option (Policy option 4)
Description Amount Comments
Direct benefits
Benefits for passengers from
avoided fuel used, expressed
as present value over 2025-
2050 relative to the baseline
EUR 108.1 million Benefits to passengers due to more sustainable
transport choices leading to energy costs savings,
estimated at EUR 108.1 million, expressed as
present value over 2025-2050 relative to the
baseline. This is mostly due to the improved
comparability of the data on which passengers
can make informed decisions.
Benefits for transport
service providers from
avoided fuel used, expressed
as present value over 2025-
2050 relative to the baseline
EUR 2.3 billion Benefits to transport service providers due to
more sustainable transport choices leading to
energy costs savings, estimated at EUR 2.3
billion, expressed as present value over 2025-
2050 relative to the baseline. This is mostly due
to the improved comparability of the data on
which passengers can make informed decisions.
Indirect benefits
Reduction in external costs
of GHG emissions,
expressed as present value
over 2025 2050, relative to
the baseline
EUR 674.1 million Indirect benefit to society at large, due to the
tonnes of GHG emissions saved, enabled by more
sustainable transport choices by passengers and
transport service providers. The reduction in the
external costs of GHG emissions is estimated at
EUR 674.1 million, expressed as present value
over the 2025-2050 horizon relative to the
baseline.
Reduction in external costs
of air pollutant emissions,
expressed as present value
over 2025 2050, relative to
the baseline
EUR 163.5 million Indirect benefit to society at large, due to the
tonnes of air pollutant emissions saved, enabled
by more sustainable transport choices by
passengers and transport service providers. The
reduction in the external costs of GHG emissions
is estimated at EUR 163.5 million, expressed as
present value over the 2025-2050 horizon relative
to the baseline.
Reduction in external costs
of road accidents (fatalities
and injuries), expressed as
present value over 2025
2050, relative to the baseline
EUR 645.2 million Indirect benefit to society at large, due to the lives
saved and injuries avoided, enabled by more
sustainable transport choices by passengers and
transport service providers and thus a reduction
in the road transport activity relative to the
baseline. The reduction in the external costs of
road accidents is estimated at EUR 645.2 million,
expressed as present value over the 2025-2050
horizon relative to the baseline.
Administrative cost savings related to the ‘one in, one out’ approach*
- - -
78
II. Overview of costs – Preferred option (Policy option 4)
Citizens/Consumers Businesses Administrations
One-off Recurrent One-off Recurrent One-off Recurrent
Direct adjustment costs,
expressed as present value
over 2025-2050, relative to
the baseline
- - For transport
service
organisers
(TSO), transport
service users
(TSU) and hub
operators (HO):
EUR 0.9 billion
For other entities
involved in
accounting of
GHG emissions
of transport
services
(business sector
associations):
EUR 0.1 million
For transport
service
organisers
(TSO),
transport
service users
(TSU) and hub
operators (HO):
EUR 0.6 billion
For
national
public
authorities:
EUR 0.1
million
For EEA:
EUR 0.7
million
For EEA: EUR 3.2
million
Direct administrative costs,
expressed as present value
over 2025-2050, relative to
the baseline
- - - For other
entities
involved in
accounting of
GHG emissions
of transport
services
(business sector
associations):
EUR 0.2
million
For other
entities
involved in
accounting of
GHG emissions
of transport
services
(calculation
tool
developers):
EUR 0.3
million
For
National
Accreditati
on Bodies
(NABs):
EUR 0.1
million
-
79
II. Overview of costs – Preferred option (Policy option 4)
Citizens/Consumers Businesses Administrations
One-off Recurrent One-off Recurrent One-off Recurrent
Indirect costs - - - - - -
Costs related to the ‘one in, one out’ approach
Total Direct
adjustment costs,
expressed as
present value
over 2025-2050,
relative to the
baseline
- - For transport
service
organisers
(TSO), transport
service users
(TSU) and hub
operators (HO):
EUR 0.9 billion
For other entities
involved in
accounting of
GHG emissions
of transport
services
(business sector
associations):
EUR 0.1 million
For transport
service
organisers
(TSO),
transport
service users
(TSU) and hub
operators (HO):
EUR 0.6 billion
Indirect
adjustment costs
- - - -
Administrative
costs (for
offsetting),
average per
year relative to
the baseline
- - - For business
sector
associations
and calculation
tools
developers:
EUR 26,419
per year on
average,
relative to the
baseline
RELEVANT SUSTAINABLE DEVELOPMENT GOALS
III. Overview of relevant Sustainable Development Goals – Preferred Option (Policy option 4)
Relevant SDG Expected progress towards the Goal Comments
80
SDG No 13 - Take urgent
action to combat climate
change and its impacts
431.5. thousand tonnes of GHG saved in 2030 and
27.3 thousand tonnes of GHG saved in 2050
The reduction in the GHG emissions is
mainly driven by the behavioural changes
towards higher use of more sustainable
transport options. In cumulative terms, over
2025-2050, the preferred policy option is
expected to result in 5.6 million tonnes of
GHG emissions saved.
SDG No 7 - Ensure access to
affordable, reliable,
sustainable and modern
energy for all
Better and comparable data will provide the base
for a more informed decisions making in
passengers choices and freight transport.
The WTW GHG emission will consider the
production, distribution and use of
energy/fuels for transport services, making
different energy sources comparable, even if
used for the same type of transport.
SDG No 12 - Ensure
sustainable consumption and
production patterns
EUR 2.4 billion of fuel saved by 2050, of which
EUR 2.3 billion for operators and EUR 108
million for consumers.
The availability of better quality and
comparable data will induce saving
behaviours towards greener mobility and
transport choices.
ANNEX 4: ANALYTICAL METHODS
1. Description of the analytical methods used
The main model used for developing the baseline scenario for this initiative is the
PRIMES-TREMOVE transport model by E3Modelling, a specific module of the PRIMES models.
The model has a successful record of use in the Commission's energy, transport and climate policy
assessments. In particular, it has been used for the impact assessments underpinning the “Fit for 55”
package168
, the impact assessments accompanying the 2030 Climate Target Plan169
and the Staff
Working Document accompanying the Sustainable and Smart Mobility Strategy170
, the Commission’s
proposal for a Long Term Strategy171
as well as for the 2020 and 2030 EU’s climate and energy policy
framework. Building on the PRIMES-TREMOVE model results, the baseline projections for the
number of users of GHG quantification tools has been developed by CE Delft et al. in the context of
the impact assessment support study172
.
For the assessment of the impacts of the policy options, an Excel-based tool has been developed by CE
Delft et al. in the context of the impact assessment suport study. The proposed measures are assumed
to be implemented from 2025 onwards, so that the assessment has been undertaken for the 2025-2050
168
Delivering the European Green Deal | European Commission (europa.eu)
169
SWD(2020)176 final.
170
EUR-Lex - 52020SC0331 - EN - EUR-Lex (europa.eu)
171
Source: 2050 long-term strategy (europa.eu)
172
Ecorys and CE Delft (2023), Impact assessment support study.
81
period andrefers toEU27. Costs andbenefits areexpressedas presentvalueover the2022-2050period,
using a 3% discount rate.
PRIMES-TREMOVE model
ThePRIMES-TREMOVEtransport model projects the evolution of demand for passengers and freight
transport, by transport mode, and transport vehicle/technology, following a formulation based on
microeconomic foundation of decisions of multiple actors. Operation, investment and emission costs,
various policy measures, utility factors and congestion are among the drivers that influence the
projections of the model. The projections of activity, equipment (fleet), usage of equipment, energy
consumption and emissions (and other externalities) constitute the set of model outputs.
The PRIMES-TREMOVE transport model can therefore provide the quantitative analysis for the
transport sector in the EU, candidate and neighbouring countries covering activity, equipment, energy
and emissions. The model accounts for each country separately which means that the detailed
long-term outlooks are available both for each country and in aggregate forms (e.g. EU level).
In the transport field, PRIMES-TREMOVE is suitable for modelling soft measures (e.g. eco-driving,
labelling); economic measures (e.g. subsidies and taxes on fuels, vehicles, emissions; ETS for transport
whenlinked withPRIMES;pricingofcongestionand other externalities suchas airpollution,accidents
andnoise; measures supportingR&D); regulatorymeasures (e.g.CO2 emissionperformancestandards
for new light duty vehicles and heavy duty vehicles; EURO standards on road transport vehicles;
technology standards for non-road transport technologies, deployment of Intelligent Transport
Systems) and infrastructure policies for alternative fuels (e.g. deployment of refuelling/recharging
infrastructure for electricity, hydrogen, LNG, CNG). Used as a module that contributes to the PRIMES
energy system model, PRIMES-TREMOVE can show how policies and trends in the field of transport
contribute to economy-wide trends in energyuse and emissions. Using data disaggregated per Member
State, the model can show differentiated trends across Member States.
The PRIMES-TREMOVE has been developed and is maintained by E3Modelling, based on, but
extending features of, the open source TREMOVE model developed by the TREMOVE173
modelling
community. Part of the model (e.g. the utility nested tree) was built following the TREMOVE
model.174
Other parts, like the component on fuel consumption and emissions, follow the COPERT
model.
Data inputs
173
Source: https://www.tmleuven.be/en/navigation/TREMOVE
174
Several model enhancements were made compared to the standard TREMOVE model, as for example: for the
number of vintages (allowing representation of the choice of second-hand cars); for the technology categories which
include vehicle types using electricity from the grid and fuel cells. The model also incorporates additional fuel types,
such as biofuels (when they differ from standard fossil fuel technologies), LPG, LNG, hydrogen and e-fuels. In
addition, representation of infrastructure for refuelling and recharging are among the model refinements, influencing
fuel choices. A major model enhancement concerns the inclusion of heterogeneity in the distance of stylised trips;
the model considers that the trip distances follow a distribution function with different distances and frequencies.
The inclusion of heterogeneity was found to be of significant influence in the choice of vehicle-fuels especially for
vehicles-fuels with range limitations.
82
The main data sources for inputs to the PRIMES-TREMOVE model, such as for activity and energy
consumption, come from EUROSTAT databases and from the Statistical Pocketbook "EU transport in
figures175
. Excise taxes are derived from DG TAXUD excise duty tables. Other data comes from
different sources such as research projects (e.g. TRACCS and New Mobility Pattern projects) and
reports.
In the context of this exercise, the PRIMES-TREMOVE transport model is calibrated to 2005, 2010
and 2015 historical data. Available data on 2020 market shares of different powertrain types have also
been taken into account.
Excel-based tool for CountEmissions EU
An excel-based tool has been developed for projecting the numbers of businesses that are
quantifying the GHG emissions at transport service level and quantifying the costs based on the
Standard Cost Model.
The main data source, for the levels of business activity in the transport sector176
, is Eurostat business
statistics by employment size class between 2015 and 2020. This provides data for each of the EU27
Member States and at EU27 level, per year, per company size, and per economic activity. The sources
for the number of persons employed in the passenger and freight transport are the EUROSTAT
database and the Statistical Pocketbook "EU transport in figures”177
. Other data comes from UNECE,
World Tourism Organisation,national databases and some national/social representatives’ reports. The
company size is defined based on the number of employees. Data on turnover draws on the same
data sources. The economic activities for which the data was extracted represent the transport sector
(those under NACE code H), manufacturing (NACE code C), trade (NACE code G), and the tourism
industry (Eurostat aggregate under code TI).
On the basis of this information, the NACE-code classification has been further elaborated to link the
transport-related activities with the type of enterprises in the transport ecosystem, namely: (i) transport
service organiser (TSO) (e.g. transport operators, travel agencies, logistics service providers, freight
forwarders), (ii) transport service user (TSU) (e.g. shippers) or hub operator (HO)178
.
Table 19 shows the average number of companies involved in the transport ecosystem for 2015-
2020 by NACE-code, by type of activity and by size. It should be noted that the vast majority of
companies (i.e. 99.7%) falls under the definition of small and medium-sized enterprises (SMEs).
When it comes to the type of activity, the majority of enterprises in the manufacturing, wholesale
and retail, and tourism sectors are users of transport services179
.
Table 19: Number of companies involved in the transport ecosystem by NACE-code, by type of activity and by size
(average value for 2015-2020)
Transport mode Eurostat NACE-code Type
of
activity
Number of companies Share
SMEs > 250 Total SMEs > 250
175
Source: https://ec.europa.eu/transport/facts-fundings/statistics_en
176
Services by employment size class (NACE Rev. 2, H-N, S95) [SBS_SC_1B_SE_R2__custom_3944403]
177
https://transport.ec.europa.eu/media-corner/publications_en
178
A transport hub operator is defined as an enterprise that organises transport services converging at nodes, like
warehouses or logistic centres, where cargos are exchanged between vehicles or transport modes.
179
Only those that are estimated to perform transport on own account are reported in this table and relevant for this
initiative.
83
Passenger Interurban rail TSO 150 35 185 81.1% 18.9%
Other transport over land TSO 339,572 549 340,121 99.8% 0.2%
Maritime TSO 5,745 38 5,783 99.3% 0.7%
Inland navigation TSO 3,892 2 3,894 99.9% 0.1%
Air TSO 3,748 70 3,818 98.2% 1.8%
Freight Road TSO 543,186 641 543,827 99.9% 0.1%
Rail TSO 561 37 598 93.8% 6.2%
Inland navigation TSO 5,550 2 5,552 100.0% 0.0%
Maritime TSO 3,835 51 3,886 98.7% 1.3%
Air and space TSO 503 9 512 98.2% 1.8%
Postal activities TSO 88,545 314 88,859 99.6% 0.4%
Hub operators Warehousing and storage HO 13,860 195 14,055 98.6% 1.4%
Support activities for transportation HO 121,038 1,032 122,070 99.2% 0.8%
Other Manufacturing TSU 31,998 1,529 33,527 95.4% 4.6%
Wholesale and retail TSU 578,130 702 578,832 99.9% 0.1%
Tourism TSU 27,389 532 27,921 98.1% 1.9%
Total 1,767,702 5,738 1,773,440 99.7% 0.3%
Source : Ecorys and CE Delft (2023), Impact assessment support study
The number of entreprises currently measuring transport GHG emissions was estimated based on
inputs from stakeholders. Two dimensions were considered. The first was at the entreprise level (for
example, the level of detail commonly associated with the annual reporting for publicly listed
companies) and the second was at the service level (for example, for individual services delivered by
an operator). The evidence collected suggests that while quite a high proportion of entreprises already
consider their transport emissions at aggregate level, there are very few who consider emissions at the
service level.
Considerations for the uptake of GHG emissions accounting on the market
Uptake of GHG emissions accounting of transport services is an essential element to identify the
impacts. In this context specific considerations were given to voluntary, or semi voluntary
(binding opt-in) approaches (which cover PO2 to PO5), where the decision on whether to
calculate emissions is not specifically required by law. In the case of a voluntary policy
instrument (with no requirement to use the harmonised framework) it was assumed that some
businesses would choose to use the harmonised framework, while others would continue with
other available methods, in particular those they were already familiar with. In the binding opt-
in cases, it was assumed that any business that chose to measure or calculate emissions at the
service level would do so using the harmonised framework. In the cases where transport
emissions measurement and calculation is binding opt-in, the assumption was made that no
additional business entities above the baseline in 2050 would be incentivised to take up emissions
accounting at the service level. It means in practice that the 2050 baseline uptake acts as an upper
bound of ‘climate aware’ business entities, but regulators can incentivise those climate aware
entities to engage in emissions measurement and calculation earlier than they would have
otherwise. This may be a conservative assumption since it is entirely possible that European
support of the existing methodology would encourage new businesses to measure and calculate
emissions that would not have considered doing so otherwise. It was, however, thought to be
unlikely that the existence of a harmonised transport emissions measurement and calculation
methodology in itself could incentivise business entities to become ‘climate aware’. The
84
transition to ‘climate aware’ status would rather occur as a result of external pressure from
investors/ clients or separate legislative measures, for instance requiring to calculate or/and
report emissions based on CountEmissions EU framework. While there is no specific evidence
to estimate the maximum magnitude of this additional factor on the binding opt-in approach,
especially in the theoretical situation where it leads to establishing a de facto standard on the
market, the mandatory policy options 1 and 6 show the impact of the use of CEEU on all
concerned businesses in the baseline.
Overall, the reason for building this level of assumptions lies in the fact that a harmonised
approach such as CountEmissions EU does not exist yet. To further assess and recognise the
limitations, a two-scenario sensitivity analysis has been performed to support the assessment of
impacts.
2. Baseline scenario
In order to reflect the fundamental socio-economic, technological and policy developments, the
Commission prepares periodically an EU Reference Scenario on energy, transport and GHG
emissions. The socio-economic and technological developments used for developing the baseline
scenario for this impact assessment build on the latest “EU Reference scenario 2020” (REF2020)180
.
The same assumptions have been used in the policy scenarios underpinning the impact assessments
accompanying the “Fit for 55” package181
.
Main assumptions of the Baseline scenario
The main assumptions related to economic development, international energy prices and technologies
are described below.
Economic assumptions
The modelling work is based on socio-economic assumptions describing the expected evolution of the
European society. Long-term projections on population dynamics and economic activity form part of
the input to the model and are used to estimate transport activity, particularly relevant for this impact
assessment.
Population projections from Eurostat182
are used to estimate the evolution of the European population,
which is expected to change little in total number in the coming decades. The GDP growth projections
are from the Ageing Report 2021183
by the Directorate General for Economic and Financial Affairs,
which are based on the same population growth assumptions.
Table 20: Projected population and GDP growth per Member State
Population GDP growth
2020 2025 2030 2020-‘25 2026-‘30
EU27 447.7 449.3 449.1 0.9% 1.1%
Austria 8.90 9.03 9.15 0.9% 1.2%
Belgium 11.51 11.66 11.76 0.8% 0.8%
180
EU Reference Scenario 2020 (europa.eu)
181
Policy scenarios for delivering the European Green Deal (europa.eu)
182
EUROPOP2019 population projections: Eurostat - Data Explorer (europa.eu)
183
The 2021 Ageing Report : Underlying assumptions and projection methodologies The 2021 Ageing Report:
Underlying Assumptions and Projection Methodologies | European Commission (europa.eu)
85
Population GDP growth
2020 2025 2030 2020-‘25 2026-‘30
Bulgaria 6.95 6.69 6.45 0.7% 1.3%
Croatia 4.06 3.94 3.83 0.2% 0.6%
Cyprus 0.89 0.93 0.96 0.7% 1.7%
Czech Republic 10.69 10.79 10.76 1.6% 2.0%
Denmark 5.81 5.88 5.96 2.0% 1.7%
Estonia 1.33 1.32 1.31 2.2% 2.6%
Finland 5.53 5.54 5.52 0.6% 1.2%
France 67.20 68.04 68.75 0.7% 1.0%
Germany 83.14 83.48 83.45 0.8% 0.7%
Greece 10.70 10.51 10.30 0.7% 0.6%
Hungary 9.77 9.70 9.62 1.8% 2.6%
Ireland 4.97 5.27 5.50 2.0% 1.7%
Italy 60.29 60.09 59.94 0.3% 0.3%
Latvia 1.91 1.82 1.71 1.4% 1.9%
Lithuania 2.79 2.71 2.58 1.7% 1.5%
Luxembourg 0.63 0.66 0.69 1.7% 2.0%
Malta 0.51 0.56 0.59 2.7% 4.1%
Netherlands 17.40 17.75 17.97 0.7% 0.7%
Poland 37.94 37.57 37.02 2.1% 2.4%
Portugal 10.29 10.22 10.09 0.8% 0.8%
Romania 19.28 18.51 17.81 2.7% 3.0%
Slovakia 5.46 5.47 5.44 1.1% 1.7%
Slovenia 2.10 2.11 2.11 2.1% 2.4%
Spain 47.32 48.31 48.75 0.9% 1.6%
Sweden 10.32 10.75 11.10 1.4% 2.2%
Beyond the update of the population and growth assumptions, an update of the projections on the
sectoral composition of GDP was also carried out using the GEM-E3 computable general equilibrium
model. These projections take into account the potential medium- to long-term impacts of the COVID-
19 crisis on the structure of the economy, even though there are inherent uncertainties related to its
eventual impacts. Overall, conservative assumptions were made regarding the medium-term impacts
of the pandemic on the re-localisation of global value chains, teleworking and teleconferencing and
global tourism.
International energy prices assumptions
Alongside socio-economic projections, transport modelling requires projections of international
fuel prices. The table below shows the oil prices assumptions of the baseline and policy options
of this impact assessment, that draw on the modelling underpinning the REPowerEU package184
.
Table 21: Oil prices assumptions
184
SWD(2022)230 final.
86
Oil 2015 2020 2030 2040 2050
in $'15 per boe 52.3 39.8 92.1 97.4 117.9
in €'15 per boe 47.2 35.8 83.0 87.8 106.3
Technology assumptions
Modelling scenarios is highly dependent on the assumptions on the development of technologies, both
in terms of performance and costs. For the purpose of the impact assessments related to the “Climate
Target Plan” and the “Fit for 55” policy package, these assumptions have been updated based on a
rigorous literature review carried out byexternal consultants in collaboration with the JRC. Continuing
the approach adopted in the long-term strategy in 2018, the Commission consulted on the technology
assumption with stakeholders in 2019. In particular, the technology database of the PRIMES and
PRIMES-TREMOVE models (together with GAINS, GLOBIOM, and CAPRI) benefited from a
dedicated consultation workshop held on 11th
November 2019. EU Member States representatives also
had the opportunityto comment on the costs elements during a workshop held on 25th
November 2019.
The updated technology assumptions are published together with the EU Reference Scenario 2020185
.
The same assumptions have been used in the context of this impact assessment.
Policies in the Baseline scenario
Building on REF2020, the baseline has been designed to include the initiatives of the ‘Fit for 55’
package proposed by the Commission on 14 July 2021186
and the initiatives of the RePowerEU
package proposed by the Commission on 18 May 2022187
. In terms of GHG emissions
accounting, the Baseline scenario assumes no further EU level intervention beyond the current
initiatives in place at national level and enterprise level.
The baseline also incorporates foresight megatrends188
and developments captured in the 2022
Strategic Foresight Report189
. Among others, it captures the trend of increasing demand for
transport as population and living standards grow as well as the links between the digital and
green transition. In particular, the projected transport activity draws on the long-term population
projections from Eurostat and GDP growth from the Ageing Report 2021190
by the Directorate
General for Economic and Financial Affairs.
Baseline scenario results
Transport activity. In the Baseline scenario, EU transport activity is projected to grow post-2020,
following the recovery from the COVID pandemic. Road transport would maintain its dominant
role within the EU by 2050. Rail transport activity is projected to grow significantly faster than
for road, driven in particular by the completion of the TEN-T core network by 2030 and of the
comprehensive network by 2050, supported by the CEF, Cohesion Fund and ERDF funding, but
also by measures of the ‘Fit for 55’ package that increase to some extent the competitiveness of
rail relative to road and air transport. Passenger rail activity is projected to go up by 24% by 2030
185
EU Reference Scenario 2020 (europa.eu)
186
https://ec.europa.eu/info/strategy/priorities-2019-2024/european-green-deal/delivering-european-green-deal_en
187
https://ec.europa.eu/commission/presscorner/detail/en/IP_22_3131
188
https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore
189
COM(2022) 289 final of 29 June 2022.
190
The 2021 Ageing Report : Underlying assumptions and projection methodologies The 2021 Ageing Report:
Underlying Assumptions and Projection Methodologies | European Commission (europa.eu)
87
relative to 2015 (67% for 2015-2050). High speed rail activity, in particular, would grow by 68%
by 2030 relative to 2015 (165% by 2050), missing however to deliver on the milestone of the
SSMS of doubling its traffic by 2030 and tripling it by 2050. Freight rail traffic would increase
by 42% by 2030 relative to 2015 (91% for 2015-2050) also not delivering on the milestone of
the SSMS of increasing the traffic by 50% by 2030 and doubling it by 2050.
GHG emissions and air pollutant emissions. Well-to-wheel GHG emissions from transport
including international aviation and maritime, are projected to be 26% lower by 2030 compared
to 2015, and 89% lower by 2050. NOx emissions are projected to go down by 56% between
2015 and 2030 (87% by 2050), mainly driven by the electrification of the road transport and in
particular of the light duty vehicles segment. The decline in particulate matter (PM2.5) would be
slightly lower by 2030 at 53% relative to 2015 (91% by 2050).
Number of businesses in the transport sector and other sectors performing transport on own account.
The number of enterprises in the transport sector and other sectors performing transport on own
account is estimated at 1.8 million in 2020 and is projected to remain stable over time.
Evolution of number of businesses performing GHG emissions accounting at service level. The
evidence collected suggests that while quite a high proportion of enterprises already considers
their transport emissions at aggregate (i.e. enterprise) level and their share will continue to
increase over time, there are very few who consider emissions at the service level. In addition,
the growth in the number of business entities who measure transport emissions at the service
level is expected to be low in the baseline but also to differ between large enterprises and SMEs.
The shares of large enterprises performing GHG emissions accounting at service level in the
total number of large enterprises in the baseline scenario for 2020-2050 are provided in Table
22, while the total number of large enterprises performing GHG emissions accounting at service
level is provided in Table 23Table .
Table 22: Shares of large entreprises performing GHG emissions accounting at service level in the baseline
scenario
Transport mode Eurostat NACE-code 2020 2025 2030 2040 2050
Passenger Interurban rail 8.6% 14.3% 17.1% 25.7% 34.3%
Other transport over land 0.7% 0.7% 0.7% 0.7% 0.7%
Maritime 13.2% 18.4% 23.7% 28.9% 36.8%
Inland navigation 0.0% 0.0% 0.0% 0.0% 0.0%
Air 22.9% 25.7% 30.0% 37.1% 44.3%
Freight Road 13.7% 18.3% 22.6% 30.4% 37.6%
Rail 8.1% 13.5% 18.9% 27.0% 35.1%
Inland navigation 0.0% 0.0% 0.0% 0.0% 0.0%
Maritime 13.7% 17.6% 21.6% 29.4% 37.3%
Air and space 22.2% 22.2% 33.3% 44.4% 44.4%
Postal activities 8.6% 13.7% 18.2% 26.4% 34.1%
Hub operators Warehousing and storage 2.1% 3.1% 4.1% 5.6% 7.7%
Support activities for transportation 1.0% 2.0% 3.0% 4.9% 6.8%
Other Manufacturing 6.3% 11.2% 15.8% 24.4% 32.2%
Wholesale and retail 6.3% 11.2% 15.8% 24.4% 32.2%
88
Transport mode Eurostat NACE-code 2020 2025 2030 2040 2050
Tourism 1.7% 3.9% 6.0% 10.0% 13.5%
Source : Ecorys and CE Delft (2023), Impact assessment support study
Table 23: Number of large entreprises performing GHG emissions accounting at service level in the baseline
scenario
Transport mode Eurostat NACE-code 2020 2025 2030 2040 2050
Passenger Interurban rail 3 5 6 9 12
Other transport over land 4 4 4 4 4
Maritime 5 7 9 11 14
Inland navigation 0 0 0 0 0
Air 16 18 21 26 31
Freight Road 88 117 145 195 241
Rail 3 5 7 10 13
Inland navigation 0 0 0 0 0
Maritime 7 9 11 15 19
Air and space 2 2 3 4 4
Postal activities 27 43 57 83 107
Hub operators Warehousing and storage 4 6 8 11 15
Support activities for transportation 10 21 31 51 70
Other Manufacturing 96 171 242 374 492
Wholesale and retail 44 78 111 172 226
Tourism 9 21 32 53 72
Total 318 507 687 1,018 1,320
Source: Ecorys and CE Delft (2023), Impact assessment support study
The shares of SMEs performing GHG emissions accounting at service level in the total number
of SMEs in the baseline scenario for 2020-2050 are provided in Table 24 while the total number
of SMEs performing GHG emissions accounting at service level is provided in Table 25.
Table 24: Shares of SMEs performing GHG emissions accounting at service level in the baseline scenario
Transport mode Eurostat NACE-code 2020 2025 2030 2040 2050
Passenger Interurban rail 0.0% 0.0% 0.0% 0.0% 0.7%
Other transport over land 0.0% 0.0% 0.0% 0.0% 0.0%
Maritime 3.4% 4.6% 5.6% 7.6% 9.4%
Inland navigation 0.2% 0.4% 0.5% 0.8% 1.1%
Air 1.1% 1.3% 1.5% 1.9% 2.2%
Freight Road 2.8% 3.7% 4.5% 6.1% 7.5%
Rail 0.0% 0.2% 0.2% 0.2% 0.4%
Inland navigation 0.3% 0.7% 1.0% 1.6% 2.2%
Maritime 3.4% 4.6% 5.6% 7.6% 9.4%
Air and space 5.6% 6.6% 7.6% 9.3% 10.9%
Postal activities 4.4% 6.8% 9.0% 13.2% 17.0%
Hub operators Warehousing and storage 0.0% 0.0% 0.0% 0.1% 0.1%
Support activities for transportation 0.0% 0.0% 0.0% 0.0% 0.1%
Other Manufacturing 0.3% 0.6% 0.8% 1.2% 1.6%
89
Wholesale and retail 0.3% 0.6% 0.8% 1.2% 1.6%
Tourism 0.6% 1.3% 2.1% 3.4% 4.6%
Source : Ecorys and CE Delft (2023), Impact assessment support study
Table 25: Number of SMEs performing GHG emissions accounting at service level in the baseline scenario
Transport mode Eurostat NACE-code 2020 2025 2030 2040 2050
Passenger Interurban rail 0 0 0 0 1
Other transport over land 25 25 25 25 25
Maritime 197 263 324 438 540
Inland navigation 9 15 20 31 42
Freight Air 42 50 57 70 82
Road 14,938 19,857 24,518 33,118 40,840
Rail 0 1 1 1 2
Inland navigation 19 37 55 90 123
Maritime 132 175 216 292 360
Air and space 28 33 38 47 55
Postal activities 3,874 5,995 8,004 11,713 15,042
Warehousing and storage 3 4 5 8 11
Other Support activities for transportation 12 24 36 59 82
Manufacturing 100 179 253 391 515
Wholesale and retail 1,807 3,229 4,577 7,065 9,298
Tourism 156 366 564 931 1,261
Total 21,342 30,253 38,693 54,279 68,279
Source : Ecorys and CE Delft (2023), Impact assessment support study
Costs for enterprises performing GHG emissions accounting. Table 26 provides a breakdown of the
unit costs per transport service for performing GHG emissions accounting, by cost category and type
of cost (i.e. one-off and recurrent costs). The unit costs are differentiated between transport service
organisers (TSO), transport service users (TSU) and hub operators (HO), and also between SMEs and
large companies. Labour costs are derived based on the tariff rates from the Eurostat’s structure of
earnings survey and labour force survey, considering the category ISCO 2 (professionals)191
. The
number of hours worked and thus the unit costs per transport service are assumed to go down over
time, by 15% by 2050 relative to 2020, due to the learning effects192
.
Table 26: Unit costs per transport service associated with GHG emissions accounting, by type of activity in 2020
(in EUR, 2022 prices)
TSO
(SME)
TSU
(SME)
HO
(SME)
TSO
(Large)
TSU
(Large)
HO
(Large)
1) One-off costs for implementing a new GHG
emission accounting method
1,748 2,033 1,748 4,802 6,625 4,802
191
The tariff rate for ISCO 2 is EUR 40.9 per hour in 2022 prices. Source: Eurostat Structure of earnings survey,
Labour Force Survey data for Non-Wage Labour Costs.
192
Taking into account possible savings resulting from the facilitation of corporate reporting required under other
legislation (such as CSRD).
90
TSO
(SME)
TSU
(SME)
HO
(SME)
TSO
(Large)
TSU
(Large)
HO
(Large)
2) Recurrent annual costs with no verification 1,139 570 1,139 3,190 2,734 3,190
3) Recurrent costs for verification of calculation
processes (use of certified tool)
399 570 399 638 1,048 638
4) Recurrent costs for the use of calculation
tools
257 514 514 1,799 3,597 3,597
Source: Ecorys and CE Delft (2023), Impact assessment support study
Total costs are calculated by multiplying the number of services for which the enterprises count GHG
emissions withtheunit valuespresentedin costs pertransportserviceandarereportedinTable 27Table
. In the baseline scenario, they are projected to increase from EUR 36.4 million in 2020 to EUR 61.4
million in 2030 and EUR 92.7 million in 2050. The largest share of the costs is associated to SMEs.
2021 2030 2040 2050
All enterprises 106.5 200.4 294.4 378.8
SME 93.3 171.7 250.1 320.6
Large enterprises 13.3 28.7 44.2 58.2
Source: Ecorys and CE Delft (2023), Impact assessment support study
Further details on the costs associated with GHG emissions accounting for SMEs and large enterprises
are provided in Table 27.
Table 27: Total costs for SMEs and large enterprises associated with GHG emissions accounting at service level in
the baseline (in million EUR, 2022 prices)
2020 2025 2030 2040 2050
1a) One-off costs for implementing a new GHG emission accounting method 3.4 3.4 3.1 2.7 2.2
SME 3.2 3.2 2.9 2.5 2.1
Large companies 0.2 0.2 0.2 0.2 0.1
1b) One-off costs for switching to a new GHG emission accounting method 0.0 0.0 0.0 0.0 0.0
SME 0.0 0.0 0.0 0.0 0.0
Large companies 0.0 0.0 0.0 0.0 0.0
2) Recurrent annual costs with no verification 24.1 33.8 41.7 54.6 64.0
SME 23.1 32.3 39.8 51.9 60.8
Large companies 0.9 1.5 2.0 2.7 3.3
3) Annual costs for verification activities 2.0 2.9 3.6 4.9 5.7
SME 1.8 2.5 3.2 4.2 4.9
Large companies 0.2 0.3 0.5 0.7 0.8
4) Annual costs for tools use 6.9 10.2 12.9 17.4 20.7
SME 6.0 8.8 11.0 14.7 17.4
Large companies 0.9 1.4 1.9 2.7 3.4
Total costs 36.4 50.3 61.4 79.6 92.7
SME 34.1 46.8 56.9 73.3 85.1
Large companies 2.2 3.5 4.6 6.3 7.6
Source: Ecorys and CE Delft (2023), Impact assessment support study
3. Costs of individual policy measures
91
This section explains the inputs used and provides the assessment of costs of the policy measures
included in the policy options. The estimation of the costs draws on the impact assessment support
study193
, including input collected through desk research and stakeholder interviews during the impact
assessment process. It should be however noted that these costs and costs savings should only be
regarded as an estimation of the order of magnitude, drawing mainly on stakeholder interviews. The
presentation distinguishes between different stakeholders’ groups (national public authorities including
NABs, businesses and business associations, European Commission and EEA) and between one-off
and recurrent (annual) costs, and provides the present value for 2025-2050 assuming a discount rate of
3%.
In order to calculate the total costs of the policy options, different levels of uptake of GHG emissions
accounting at transport service level have been assumed on the basis of:
 The policy measures related to the methodology (ISO 14083 – PM1, PEFCR – PM2 or ISO 14083
with additional elements and increased accuracy – PM3);
 The policy measures for the applicability (mandatory – PM13, binding opt-in – PM14, voluntary
opt-in – PM15).
Drawing on desk research and interviews with operators and experts194
in the context of the impact
assessment support study, Table 28 to Table 37 summarise the increase in the share of enterprises
performing GHG emissions accounting at service level for each NACE category, separated between
large enterprises and SMEs, for each policy option relative to the baseline.
Table 28: Increase in the share of enterprises performing GHG emissions accounting at service level in PO1 and
PO6 relative to the baseline (percentage points increase relative to the baseline)
2025 2030 2035 2040 2045 2050
SME
Passenger Interurban rail 5% 53% 100% 100% 100% 99%
Other transport over land 5% 52% 100% 100% 100% 100%
Maritime 8% 51% 93% 92% 91% 91%
Inland navigation 8% 53% 99% 99% 99% 99%
Air 6% 52% 98% 98% 98% 98%
Freight Road 7% 51% 95% 94% 93% 92%
Rail 5% 52% 100% 100% 100% 100%
Inland navigation 6% 52% 99% 98% 98% 98%
Maritime 8% 51% 93% 92% 91% 91%
Air and space 8% 50% 91% 91% 90% 89%
Postal activities 10% 50% 89% 87% 85% 83%
Hub operators Warehousing and storage 5% 53% 100% 100% 100% 100%
Support activities for
transportation
5% 53% 100% 100% 100% 100%
Other Manufacturing 6% 52% 99% 99% 99% 98%
Wholesale and retail 6% 52% 99% 99% 99% 98%
Tourism 7% 52% 97% 97% 96% 95%
193
Ecorys and CE Delft (2023), Impact assessment support study.
194
Ecorys and CE Delft (2023), Impact assessment support study.
92
2025 2030 2035 2040 2045 2050
Large companies (250 or more)
Passenger Interurban rail 14% 47% 77% 74% 69% 66%
Other transport over land 5% 52% 99% 99% 99% 99%
Maritime 16% 43% 74% 71% 66% 63%
Inland navigation 5% 53% 100% 100% 100% 100%
Air 16% 41% 66% 63% 60% 56%
Freight Road 16% 44% 73% 70% 66% 62%
Rail 16% 46% 78% 73% 70% 65%
Inland navigation 5% 53% 100% 100% 100% 100%
Maritime 17% 46% 73% 71% 67% 63%
Air and space 27% 41% 67% 56% 56% 56%
Postal activities 15% 46% 78% 74% 70% 66%
Hub operators Warehousing and storage 22% 59% 95% 94% 93% 92%
Support activities for
transportation
22% 59% 96% 95% 94% 93%
Other Manufacturing 15% 47% 80% 76% 72% 68%
Wholesale and retail 15% 47% 80% 76% 72% 68%
Tourism 9% 51% 92% 90% 88% 87%
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 29: Type and size of impacted enterprises in PO1 and PO6 as a percentage of all enterprises targeted by CountEmissions
EU
2025 2030 2040 2050
SME
Passenger Interurban rail 5% 53% 100% 100%
Other transport over land 5% 53% 100% 100%
Maritime 12% 56% 100% 100%
Inland navigation 8% 54% 100% 100%
Air 7% 53% 100% 100%
Freight Road 11% 55% 100% 100%
Rail 5% 53% 100% 100%
Inland navigation 6% 53% 100% 100%
Maritime 12% 56% 100% 100%
Air and space 15% 57% 100% 100%
Postal activities 17% 59% 100% 100%
Hub operators Warehousing and storage 5% 53% 100% 100%
Support activities for transportation 5% 53% 100% 100%
Other Manufacturing 6% 53% 100% 100%
Wholesale and retail 6% 53% 100% 100%
Tourism 8% 54% 100% 100%
Total SMEs 8% 54% 100% 100%
Large (250 or more)
Passenger Interurban rail 29% 63% 100% 100%
Other transport over land 6% 53% 100% 100%
Maritime 34% 66% 100% 100%
Inland navigation 0% 50% 100% 100%
Air 43% 71% 100% 100%
Freight Road 34% 67% 100% 100%
Rail 30% 65% 100% 100%
93
Inland navigation 0% 50% 100% 100%
Maritime 35% 67% 100% 100%
Air and space 44% 78% 100% 100%
Postal activities 29% 64% 100% 100%
Hub operators Warehousing and storage 26% 63% 100% 100%
Support activities for transportation 25% 62% 100% 100%
Other Manufacturing 26% 63% 100% 100%
Wholesale and retail 26% 63% 100% 100%
Tourism 13% 57% 100% 100%
Total large companies (250 or more) 24% 62% 100% 100%
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 30: Increase in the share of enterprises performing GHG emissions accounting at service level in PO2
relative to the baseline (percentage points increase relative to the baseline)
2025 2030 2035 2040 2045 2050
SME
Passenger Interurban rail 0.0% 0.7% 0.7% 0.7% 0.7% 0.1%
Other transport over land 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Maritime 1.8% 3.8% 2.7% 1.8% 0.9% 0.2%
Inland navigation 0.3% 0.6% 0.4% 0.3% 0.1% 0.0%
Air 0.3% 0.7% 0.5% 0.3% 0.2% 0.0%
Freight Road 1.5% 3.0% 2.2% 1.4% 0.7% 0.1%
Rail 0.0% 0.2% 0.2% 0.2% 0.0% 0.0%
Inland navigation 0.6% 1.2% 0.9% 0.6% 0.3% 0.1%
Maritime 1.9% 3.8% 2.7% 1.8% 0.9% 0.2%
Air and space 1.8% 3.4% 2.4% 1.6% 0.8% 0.2%
Postal activities 3.9% 7.9% 5.8% 3.8% 1.8% 0.4%
Hub operators Warehousing and storage 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Support activities for
transportation
0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Other Manufacturing 0.4% 0.8% 0.6% 0.4% 0.2% 0.0%
Wholesale and retail 0.4% 0.8% 0.6% 0.4% 0.2% 0.0%
Tourism 1.3% 2.5% 1.9% 1.2% 0.6% 0.1%
Large companies (250 or more)
Passenger Interurban rail 8.6% 17.1% 11.4% 8.6% 2.9% 0.6%
Other transport over land 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Maritime 7.9% 13.2% 10.5% 7.9% 2.6% 0.5%
Inland navigation 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Air 7.1% 14.3% 10.0% 7.1% 4.3% 0.9%
Freight Road 7.3% 15.0% 10.9% 7.2% 3.4% 0.7%
Rail 8.1% 16.2% 13.5% 8.1% 5.4% 1.1%
Inland navigation 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Maritime 7.8% 15.7% 9.8% 7.8% 3.9% 0.8%
Air and space 11.1% 11.1% 11.1% 0.0% 0.0% 0.0%
Postal activities 7.6% 15.9% 11.8% 7.6% 3.8% 0.8%
Hub operators Warehousing and storage 1.5% 3.6% 2.6% 2.1% 1.0% 0.2%
Support activities for
transportation
1.8% 3.8% 2.8% 1.8% 1.0% 0.2%
Other Manufacturing 8.0% 16.3% 11.9% 7.7% 3.8% 0.8%
Wholesale and retail 8.0% 16.3% 11.9% 7.7% 3.8% 0.8%
Tourism 3.7% 7.4% 5.4% 3.5% 1.7% 0.3%
94
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 31: Type and size of impacted enterprises in PO2 as a percentage of all enterprises targeted by CountEmissions EU
2025 2030 2040 2050
SME
Passenger Interurban rail 0.0% 0.7% 0.7% 0.7%
Other transport over land 0.0% 0.0% 0.0% 0.0%
Maritime 6.4% 9.4% 9.4% 9.6%
Inland navigation 0.7% 1.1% 1.1% 1.1%
Air 1.7% 2.2% 2.2% 2.2%
Freight Road 5.1% 7.5% 7.5% 7.7%
Rail 0.2% 0.4% 0.4% 0.4%
Inland navigation 1.3% 2.2% 2.2% 2.3%
Maritime 6.4% 9.4% 9.4% 9.6%
Air and space 8.3% 10.9% 10.9% 11.1%
Postal activities 10.7% 17.0% 17.0% 17.4%
Hub operators Warehousing and storage 0.1% 0.1% 0.1% 0.1%
Support activities for transportation 0.0% 0.1% 0.1% 0.1%
Other Manufacturing 1.0% 1.6% 1.6% 1.6%
Wholesale and retail 1.0% 1.6% 1.6% 1.6%
Tourism 2.6% 4.6% 4.6% 4.7%
Total SMEs 2.5% 3.9% 3.9% 3.9%
Large (250 or more)
Passenger Interurban rail 22.9% 34.3% 34.3% 34.3%
Other transport over land 0.7% 0.7% 0.7% 0.7%
Maritime 26.3% 36.8% 36.8% 36.8%
Inland navigation 0.0% 0.0% 0.0% 0.0%
Air 32.9% 44.3% 44.3% 45.7%
Freight Road 25.6% 37.6% 37.6% 38.2%
Rail 21.6% 35.1% 35.1% 35.1%
Inland navigation 0.0% 0.0% 0.0% 0.0%
Maritime 25.5% 37.3% 37.3% 37.3%
Air and space 33.3% 44.4% 44.4% 44.4%
Postal activities 21.3% 34.1% 34.1% 34.7%
Hub operators Warehousing and storage 4.6% 7.7% 7.7% 7.7%
Support activities for transportation 3.9% 6.8% 6.8% 7.0%
Other Manufacturing 19.2% 32.2% 32.2% 32.9%
Wholesale and retail 19.2% 32.2% 32.2% 32.9%
Tourism 7.5% 13.5% 13.5% 13.9%
Total large companies (250 or more) 14.3% 23.0% 23.0% 23.5%
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 32: Increase in the share of enterprises performing GHG emissions accounting at service level in PO3
relative to the baseline (percentage points increase relative to the baseline)
2025 2030 2035 2040 2045 2050
SME
Passenger Interurban rail 0.0% 0.7% 0.7% 0.7% 0.7% 0.0%
Other transport over
land
0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Maritime 1.2% 2.7% 1.6% 0.7% 0.0% 0.0%
Inland navigation 2.6% 5.2% 5.1% 5.0% 4.8% 4.7%
95
2025 2030 2035 2040 2045 2050
Air 0.6% 0.9% 0.7% 0.6% 0.4% 0.3%
Freight Road 0.7% 1.7% 0.9% 0.1% 0.0% 0.0%
Rail 0.0% 0.2% 0.2% 0.2% 0.0% 0.0%
Inland navigation 0.6% 1.2% 0.9% 0.6% 0.3% 0.0%
Maritime 2.7% 4.7% 3.7% 2.8% 1.9% 1.0%
Air and space 3.0% 4.6% 3.6% 2.8% 2.0% 1.2%
Postal activities 5.2% 9.6% 7.4% 5.4% 3.5% 1.6%
Hub operators Warehousing and
storage
0.2% 0.4% 0.3% 0.3% 0.3% 0.3%
Support activities for
transportation
0.2% 0.4% 0.3% 0.3% 0.3% 0.3%
Other Manufacturing 0.5% 1.0% 0.7% 0.5% 0.3% 0.2%
Wholesale and retail 0.5% 1.0% 0.7% 0.5% 0.3% 0.1%
Tourism 1.5% 3.0% 2.3% 1.6% 1.0% 0.4%
Large companies (250 or more)
Passenger Interurban rail 8.6% 20.0% 14.3% 11.4% 5.7% 2.9%
Other transport over
land
0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Maritime 10.5% 18.4% 15.8% 13.2% 7.9% 5.3%
Inland navigation 0.0% 50.0% 50.0% 50.0% 50.0% 50.0%
Air 11.4% 18.6% 14.3% 11.4% 8.6% 4.3%
Freight Road 10.8% 18.9% 14.8% 11.1% 7.3% 3.9%
Rail 10.8% 18.9% 16.2% 10.8% 8.1% 2.7%
Inland navigation 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Maritime 11.8% 19.6% 13.7% 11.8% 7.8% 3.9%
Air and space 22.2% 22.2% 22.2% 11.1% 11.1% 11.1%
Postal activities 10.2% 19.1% 15.0% 10.8% 7.0% 3.2%
Hub operators Warehousing and
storage
17.4% 34.4% 33.3% 32.8% 31.8% 30.8%
Support activities for
transportation
17.4% 35.0% 34.0% 33.0% 32.2% 31.2%
Other Manufacturing 10.2% 19.3% 14.9% 10.7% 6.8% 3.0%
Wholesale and retail 10.2% 19.3% 14.9% 10.7% 6.8% 3.0%
Tourism 4.4% 8.6% 6.6% 4.7% 2.9% 1.2%
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 33: Type and size of impacted enterprises in PO3 as a percentage of all enterprises targeted by CountEmissions EU
2025 2030 2040 2050
SME
Passenger Interurban rail 0.0% 0.7% 0.7% 0.7%
Other transport over land 0.0% 0.0% 0.0% 0.0%
Maritime 5.8% 8.3% 8.3% 9.4%
Inland navigation 3.0% 5.8% 5.8% 5.8%
Air 1.9% 2.5% 2.5% 2.5%
Freight Road 4.3% 6.2% 6.2% 7.5%
Rail 0.2% 0.4% 0.4% 0.4%
Inland navigation 1.3% 2.2% 2.2% 2.2%
Maritime 7.2% 10.4% 10.4% 10.4%
Air and space 9.5% 12.1% 12.1% 12.1%
Postal activities 11.9% 18.6% 18.6% 18.6%
96
Hub operators Warehousing and storage 0.2% 0.4% 0.4% 0.4%
Support activities for transportation 0.2% 0.4% 0.4% 0.4%
Other Manufacturing 1.1% 1.8% 1.8% 1.8%
Wholesale and retail 1.1% 1.8% 1.8% 1.8%
Tourism 2.8% 5.0% 5.0% 5.0%
Total SMEs 2.4% 3.6% 3.6% 4.0%
Large (250 or more)
Passenger Interurban rail 22.9% 37.1% 37.1% 37.1%
Other transport over land 0.7% 0.7% 0.7% 0.7%
Maritime 28.9% 42.1% 42.1% 42.1%
Inland navigation 0.0% 50.0% 50.0% 50.0%
Air 37.1% 48.6% 48.6% 48.6%
Freight Road 29.0% 41.5% 41.5% 41.5%
Rail 24.3% 37.8% 37.8% 37.8%
Inland navigation 0.0% 0.0% 0.0% 0.0%
Maritime 29.4% 41.2% 41.2% 41.2%
Air and space 44.4% 55.6% 55.6% 55.6%
Postal activities 23.9% 37.3% 37.3% 37.3%
Hub operators Warehousing and storage 20.5% 38.5% 38.5% 38.5%
Support activities for transportation 19.5% 38.0% 38.0% 38.0%
Other Manufacturing 21.3% 35.2% 35.2% 35.2%
Wholesale and retail 21.4% 35.2% 35.2% 35.2%
Tourism 8.3% 14.7% 14.7% 14.7%
Total large companies (250 or more) 19.2% 31.7% 31.7% 31.7%
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 34: Increase in the share of enterprises performing GHG emissions accounting at service level in PO4
relative to the baseline (percentage points increase relative to the baseline)
2025 2030 2035 2040 2045 2050
SME
Passenger Interurban rail 0.0% 0.7% 0.7% 0.7% 0.7% 0.0%
Other transport over land 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Maritime 2.8% 5.0% 3.9% 3.0% 2.1% 1.2%
Inland navigation 0.3% 0.6% 0.4% 0.3% 0.1% 0.0%
Air 0.6% 1.0% 0.8% 0.6% 0.5% 0.3%
Freight Road 2.2% 4.0% 3.2% 2.4% 1.7% 1.0%
Rail 0.0% 0.2% 0.2% 0.2% 0.0% 0.0%
Inland navigation 0.7% 1.4% 1.1% 0.8% 0.5% 0.2%
Maritime 2.8% 5.0% 3.9% 3.0% 2.1% 1.2%
Air and space 3.0% 4.8% 3.8% 3.0% 2.2% 1.4%
Postal activities 5.4% 10.1% 7.9% 5.9% 4.0% 2.1%
Hub operators Warehousing and storage 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Support activities for
transportation
0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Other Manufacturing 0.5% 1.0% 0.8% 0.6% 0.4% 0.2%
Wholesale and retail 0.5% 1.0% 0.8% 0.6% 0.4% 0.2%
Tourism 1.6% 3.1% 2.4% 1.8% 1.2% 0.6%
Large companies (250 or more)
Passenger Interurban rail 8.6% 20.0% 14.3% 11.4% 5.7% 2.9%
Other transport over land 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
97
2025 2030 2035 2040 2045 2050
Maritime 10.5% 18.4% 15.8% 13.2% 7.9% 5.3%
Inland navigation 0.0% 50.0% 50.0% 50.0% 50.0% 50.0%
Air 11.4% 18.6% 14.3% 11.4% 8.6% 4.3%
Freight Road 10.8% 18.9% 14.8% 11.1% 7.3% 3.9%
Rail 10.8% 18.9% 16.2% 10.8% 8.1% 2.7%
Inland navigation 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Maritime 11.8% 19.6% 13.7% 11.8% 7.8% 3.9%
Air and space 22.2% 22.2% 22.2% 11.1% 11.1% 11.1%
Postal activities 10.2% 19.1% 15.0% 10.8% 7.0% 3.2%
Hub operators Warehousing and storage 17.4% 34.4% 33.3% 32.8% 31.8% 30.8%
Support activities for
transportation
17.4% 35.0% 34.0% 33.0% 32.2% 31.2%
Other Manufacturing 10.2% 19.3% 14.9% 10.7% 6.8% 3.0%
Wholesale and retail 10.2% 19.3% 14.9% 10.7% 6.8% 3.0%
Tourism 4.4% 8.6% 6.6% 4.7% 2.9% 1.2%
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 35: Type and size of impacted enterprises in PO4 as a percentage of all enterprises targeted by CountEmissions EU
2025 2030 2040 2050
SME
Passenger Interurban rail 0.0% 0.7% 0.7% 0.7%
Other transport over land 0.0% 0.0% 0.0% 0.0%
Maritime 7.4% 10.6% 10.6% 10.6%
Inland navigation 0.7% 1.1% 1.1% 1.1%
Air 1.9% 2.5% 2.5% 2.5%
Freight Road 5.9% 8.5% 8.5% 8.5%
Rail 0.2% 0.4% 0.4% 0.4%
Inland navigation 1.4% 2.4% 2.4% 2.4%
Maritime 7.4% 10.6% 10.6% 10.6%
Air and space 9.5% 12.3% 12.3% 12.3%
Postal activities 12.2% 19.1% 19.1% 19.1%
Hub operators Warehousing and storage 0.1% 0.1% 0.1% 0.1%
Support activities for transportation 0.0% 0.1% 0.1% 0.1%
Other Manufacturing 1.1% 1.8% 1.8% 1.8%
Wholesale and retail 1.1% 1.8% 1.8% 1.8%
Tourism 2.9% 5.2% 5.2% 5.2%
Total SMEs 2.9% 4.4% 4.4% 4.4%
Large (250 or more)
Passenger Interurban rail 22.9% 37.1% 37.1% 37.1%
Other transport over land 0.7% 0.7% 0.7% 0.7%
Maritime 28.9% 42.1% 42.1% 42.1%
Inland navigation 0.0% 50.0% 50.0% 50.0%
Air 37.1% 48.6% 48.6% 48.6%
Freight Road 29.0% 41.5% 41.5% 41.5%
Rail 24.3% 37.8% 37.8% 37.8%
Inland navigation 0.0% 0.0% 0.0% 0.0%
Maritime 29.4% 41.2% 41.2% 41.2%
Air and space 44.4% 55.6% 55.6% 55.6%
Postal activities 23.9% 37.3% 37.3% 37.3%
98
Hub operators Warehousing and storage 20.5% 38.5% 38.5% 38.5%
Support activities for transportation 19.5% 38.0% 38.0% 38.0%
Other Manufacturing 21.3% 35.2% 35.2% 35.2%
Wholesale and retail 21.4% 35.2% 35.2% 35.2%
Tourism 8.3% 14.7% 14.7% 14.7%
Total large companies (250 or more) 19.2% 31.7% 31.7% 31.7%
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 36: Increase in the share of enterprises performing GHG emissions accounting at service level in PO5
relative to the baseline (percentage points increase relative to the baseline)
2025 2030 2035 2040 2045 2050
SME
Passenger Interurban rail 0.0% 0.7% 0.7% 0.7% 0.7% 0.0%
Other transport over land 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Maritime 1.1% 2.5% 1.4% 0.5% 0.0% 0.0%
Inland navigation 2.6% 5.2% 5.1% 5.0% 4.8% 4.7%
Air 0.5% 0.9% 0.7% 0.5% 0.4% 0.2%
Freight Road 0.6% 1.6% 0.8% 0.0% 0.0% 0.0%
Rail 0.0% 0.2% 0.2% 0.2% 0.0% 0.0%
Inland navigation 0.5% 1.0% 0.7% 0.4% 0.1% 0.0%
Maritime 2.6% 4.5% 3.5% 2.5% 1.6% 0.8%
Air and space 2.8% 4.4% 3.4% 2.6% 1.8% 1.0%
Postal activities 4.9% 9.1% 6.9% 4.9% 3.0% 1.1%
Hub operators Warehousing and storage 0.2% 0.4% 0.3% 0.3% 0.3% 0.3%
Support activities for
transportation
0.2% 0.4% 0.3% 0.3% 0.3% 0.3%
Other Manufacturing 0.5% 0.9% 0.7% 0.5% 0.3% 0.1%
Wholesale and retail 0.5% 0.9% 0.7% 0.5% 0.3% 0.1%
Tourism 1.4% 2.8% 2.1% 1.4% 0.8% 0.2%
Large companies (250 or more)
Passenger Interurban rail 8.6% 20.0% 14.3% 11.4% 5.7% 2.9%
Other transport over land 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Maritime 10.5% 15.8% 13.2% 10.5% 5.3% 2.6%
Inland navigation 0.0% 50.0% 50.0% 50.0% 50.0% 50.0%
Air 11.4% 17.1% 12.9% 10.0% 7.1% 2.9%
Freight Road 10.3% 17.9% 13.9% 10.1% 6.4% 3.0%
Rail 10.8% 16.2% 13.5% 8.1% 5.4% 0.0%
Inland navigation 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Maritime 9.8% 19.6% 13.7% 11.8% 7.8% 3.9%
Air and space 22.2% 11.1% 11.1% 0.0% 0.0% 0.0%
Postal activities 9.6% 18.2% 14.0% 9.9% 6.1% 2.2%
Hub operators Warehousing and storage 17.4% 34.4% 33.3% 32.8% 31.8% 30.8%
Support activities for
transportation
17.4% 35.0% 34.0% 33.0% 32.2% 31.2%
Other Manufacturing 9.6% 18.3% 13.9% 9.7% 5.7% 2.0%
Wholesale and retail 9.6% 18.3% 13.9% 9.7% 5.7% 2.0%
Tourism 4.2% 8.2% 6.1% 4.2% 2.4% 0.7%
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 37: Type and size of impacted enterprises in PO5 as a percentage of all enterprises targeted by CountEmissions EU
2025 2030 2040 2050
99
SME
Passenger Interurban rail 0.0% 0.7% 0.7% 0.7%
Other transport over land 0.0% 0.0% 0.0% 0.0%
Maritime 5.7% 8.1% 8.1% 9.4%
Inland navigation 3.0% 5.8% 5.8% 5.8%
Air 1.9% 2.4% 2.4% 2.4%
Freight Road 4.3% 6.1% 6.1% 7.5%
Rail 0.2% 0.4% 0.4% 0.4%
Inland navigation 1.2% 2.0% 2.0% 2.2%
Maritime 7.1% 10.1% 10.1% 10.1%
Air and space 9.3% 11.9% 11.9% 11.9%
Postal activities 11.7% 18.1% 18.1% 18.1%
Hub operators Warehousing and storage 0.2% 0.4% 0.4% 0.4%
Support activities for transportation 0.2% 0.4% 0.4% 0.4%
Other Manufacturing 1.0% 1.7% 1.7% 1.7%
Wholesale and retail 1.0% 1.7% 1.7% 1.7%
Tourism 2.8% 4.8% 4.8% 4.8%
Total SMEs 2.4% 3.5% 3.6% 4.0%
Large (250 or more)
Passenger Interurban rail 22.9% 37.1% 37.1% 37.1%
Other transport over land 0.7% 0.7% 0.7% 0.7%
Maritime 28.9% 39.5% 39.5% 39.5%
Inland navigation 0.0% 50.0% 50.0% 50.0%
Air 37.1% 47.1% 47.1% 47.1%
Freight Road 28.5% 40.6% 40.6% 40.6%
Rail 24.3% 35.1% 35.1% 35.1%
Inland navigation 0.0% 0.0% 0.0% 0.0%
Maritime 27.5% 41.2% 41.2% 41.2%
Air and space 44.4% 44.4% 44.4% 44.4%
Postal activities 23.2% 36.3% 36.3% 36.3%
Hub operators Warehousing and storage 20.5% 38.5% 38.5% 38.5%
Support activities for transportation 19.5% 38.0% 38.0% 38.0%
Other Manufacturing 20.8% 34.1% 34.1% 34.1%
Wholesale and retail 20.8% 34.2% 34.2% 34.2%
Tourism 8.1% 14.3% 14.3% 14.3%
Total large companies (250 or more) 18.8% 31.1% 31.1% 31.1%
Source: Ecorys and CE Delft (2023), Impact assessment support study
PM1: ISO 14083 is set as common reference methodology at EU level
In PM1 (included in PO2, PO4 and PO6), the ISO 14083 methodology is set as common
reference methodology for quantifying GHG emissions at EU level. It covers Well-to-Wheel
GHG emissions related to transport operations, including emissions from the production of fuels.
ISO provides a detailed methodology addressing the segmentation of the transport services and
shows high acceptability by stakeholders. It also provides for alignment to a global standard.
Adjustment costs for businesses
100
The setting of the ISO 14083 methodology as the common reference methodology to quantify
GHG emissions from transport services is expected to lead to additional costs relative to the
baseline for the new businesses performing GHG emissions accounting but also for the
businesses that are already quantifying GHG emissions and would need to switch to ISO 14083.
Businesses already quantifying GHG emissions in the baseline will need to adjust their processes
to be in line with the new ISO 14083 requirements, resulting in one-off adjustment costs that are
different per type and size of business195
. The recurrent adjustment costs196
are expected to be
the same as in the baseline. New businesses performing GHG emissions accounting are expected
to be faced with both one-off adjustment costs for implementing the processes and annual
recurrent costs. Table 38 shows the different unit costs per type of business for adopting ISO
14083 as common reference methodology, based on stakeholder’s feedbacks and desk
research197
. These costs cover labour costs and costs for obtaining the necessary documentation.
Table 38: Unit adjustment costs per type of business due to PM1 in PO2, PO4 and PO6 (in EUR, 2022 prices)
TSO
(SME)
TSU
(SME)
HO
(SME)
TSO
(Large)
TSU
(Large)
HO
(Large)
One-off costs for starting implementing
the GHG emission accounting (i.e. ISO
14083)
1,748 2,033 1,748 4,802 6,625 4,802
One-off costs for switching to the ISO
14083 GHG emission accounting method
589 589 589 1,262 1,262 1,262
Annual recurrent costs 1,139 570 1,139 3,190 2,734 3,190
Source: Ecorys and CE Delft (2023), Impact assessment support study; Note: ‘Large’ stands for large businesses;
Annual recurrent costs for ISO 14083 are the same as for other methods used in the baseline.
The total adjustment costs for PM1 in PO2 (in conjunction with the voluntary application of
CountEmissions EU, due to PM15) are different from those in PO4 (in conjunction with the
binding opt-in application of CountEmissions EU, due to PM14) and in PO6 (in conjunction with
the mandatory application of CountEmissions EU, due to PM13). The one-off and recurrent
adjustment costs for businesses due to PM1 in PO2 for 2025, 2030, 2040 and 2050 relative to
the baseline are provided in Table 39, together with the number of companies that switch from
other methods to ISO 14083 and the additional number of companies that implement ISO 14083
relative to the baseline. The costs are also provided by company size (large and SME). Expressed
as present valueover2025-2050,thetotal adjustment costs duetoPM1areestimated at EUR 0.9billion
in PO2 relative to the baseline, of which EUR 0.6 billion one-off adjustment costs.
Table 39: One-off and recurrent adjustment costs for business due to PM1 in PO2 (in million EUR, 2022 prices),
relative to the baseline
2025 2030 2040 2050
Number companies that switch from other methods to ISO 14083 6,152 1,720 1,546 1,389
SMEs 6,051 1,686 1,515 1,361
Large companies 101 34 31 28
195
The adjustment is assumed to be gradual over time, i.e. 20% of the companies that are quantifying GHG
emissions at service level in the baseline are assumed to switch to the new methodology each year between 2025
and 2030. Post-2030, only the additional number of companies that are quantifying GHG emissions at service level
in the baseline relative to the previous year are assumed to switch to the new methodology.
196
The cost of ISO certification, ISOUpdate.com, 8 July 2020.
197
The number of hours worked and thus the unit costs per transport service are assumed to go down over time, by
15% by 2050 relative to 2020, due to the learning effects.
101
2025 2030 2040 2050
Additional number of companies that implement ISO 14083
relative to the baseline 14,868 30,219 14,302 1,388
SMEs 14,557 29,586 14,000 1,361
Large companies 311 633 302 27
One-off adjustment costs (in million EUR) 31.8 56.4 25.4 2.9
SMEs 29.8 52.7 23.8 2.8
Large companies 2.0 3.7 1.7 0.2
Recurrent adjustment costs (in million EUR) 15.9 31.3 13.9 1.3
SMEs 15.0 29.6 13.1 1.2
Large companies 0.9 1.8 0.8 0.1
Total adjustment costs (in million EUR) 47.7 87.7 39.4 4.2
SMEs 44.8 82.2 36.9 4.0
Large companies 2.9 5.5 2.5 0.2
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 40: type and size of impacted enterprises due to PM1 in PO2 of all enterprises targeted with CountEmissions EU
2025 2030 2040 2050
Number companies switching or implementing ISO 14083 2.6% 3.9% 3.9% 4.0%
SMEs 2.5% 3.9% 3.9% 3.9%
Large companies 14.3% 23.0% 23.0% 23.5%
Source: Ecorys and CE Delft (2023), Impact assessment support study
The one-off and recurrent adjustment costs for businesses due to PM1 in PO4 (in conjunction
with the binding opt-in application of CountEmissions EU, due to PM14) for 2025, 2030, 2040
and 2050 relative to the baseline are provided in Table 41, together with the number of companies
that switch from other methods to ISO 14083 and the additional number of companies that
implement ISO 14083 relative to the baseline. Expressed as present value over 2025-2050, the total
adjustment costs due to PM1 are estimated at EUR 1.4 billion in PO4 relative to the baseline, of which
EUR 0.9 billion one-off adjustment costs.
Table 41: One-off and recurrent adjustment costs for business due to PM1 in PO4 (in million EUR, 2022 prices),
relative to the baseline
2025 2030 2040 2050
Number companies that switch from other methods to ISO 14083 6,152 1,720 1,546 1,389
SMEs 6,051 1,686 1,515 1,361
Large companies 101 34 31 28
Additional number of companies that implement ISO 14083
relative to the baseline 21,595 39,358 23,441 9,139
SMEs 21,003 38,224 22,638 8,638
Large companies 592 1,134 803 501
One-off adjustment costs (in million EUR) 44.8 73.9 41.9 16.0
SMEs 41.3 67.7 37.9 13.8
Large companies 3.4 6.2 4.0 2.2
Recurrent adjustment costs (in million EUR) 23.6 41.6 23.6 9.0
SMEs 21.8 38.3 21.4 7.7
Large companies 1.8 3.3 2.2 1.3
Total adjustment costs (in million EUR) 68.4 115.5 65.4 25.1
SMEs 63.2 106.1 59.2 21.5
Large companies 5.2 9.5 6.2 3.5
102
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 42: type and size of impacted enterprises due to PM1 in PO4 of all enterprises targeted with CountEmissions EU
2025 2030 2040 2050
Number companies switching or implementing ISO 14083 3.0% 4.4% 4.4% 4.4%
SMEs 2.9% 4.4% 4.4% 4.4%
Large companies 19.2% 31.7% 31.7% 31.7%
Source: Ecorys and CE Delft (2023), Impact assessment support study
The one-off and recurrent adjustment costs for businesses due to PM1 in PO6 (in conjunction
with the mandatory application of CountEmissions EU, due to PM13) for 2025, 2030, 2040 and
2050 relative to the baseline are provided in Table 43, together with the number of companies
that switch from other methods to ISO 14083 and the additional number of companies that
implement ISO 14083 relative to the baseline. Expressed as present value over 2025-2050, the total
adjustment costs due toPM1 are estimated at EUR 60.5 billion in PO6 relative tothe baseline, of which
EUR 40.3 billion one-off adjustment costs.
Table 43: One-off and recurrent adjustment costs for business due to PM1 in PO6 (in million EUR, 2022 prices),
relative to the baseline
2025 2030 2040 2050
Number companies that switch from other methods to ISO 14083 6,152 1,720 1,546 1,389
SMEs 6,051 1,686 1,515 1,361
Large companies 101 34 31 28
Additional number of companies that implement ISO 14083
relative to the baseline 110,570 918,003 1,718,143 1,703,841
SMEs 109,689 915,130 1,713,423 1,699,423
Large companies 881 2,873 4,720 4,418
One-off adjustment costs (in million EUR) 210.5 1,660.2 2,913.4 2,698.2
SMEs 205.4 1,644.5 2,889.1 2,677.1
Large companies 5.1 15.8 24.3 21.1
Recurrent adjustment costs (in million EUR) 107.3 835.5 1,463.0 1,353.5
SMEs 104.7 827.2 1,450.2 1,342.3
Large companies 2.6 8.3 12.8 11.2
Total adjustment costs (in million EUR) 317.8 2,495.8 4,376.3 4,051.7
SMEs 310.1 2,471.7 4,339.3 4,019.4
Large companies 7.7 24.1 37.1 32.3
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 44: type and size of impacted enterprises due to PM1 in PO4 of all enterprises targeted with CountEmissions EU
2025 2030 2040 2050
Number companies switching or implementing ISO 14083 8.0% 54.0% 100.0% 100.0%
SMEs 7.9% 54.0% 100.0% 100.0%
Large companies 24.2% 62.0% 100.0% 100.0%
Source: Ecorys and CE Delft (2023), Impact assessment support study
According to stakeholders’ feedback, meetings with experts and desk research, the alignment
with a global standard provided by ISO 14083 would allow for better comparability and usability
by the businesses across the world.
103
PM2: Product Environmental Footprint Category Rules (PEFCR) for GHG emissions in
transport, including rules for transport services, is set as common reference methodology at
EU level
In PM2 (included in PO5), the PEFCR methodology is set as common reference methodology
for quantifying GHG emissions at EU level. It covers Life Cycle GHG emissions related to
transport operations, including emissions from the production of fuels, vehicles and equipment.
PEFCR is taken as the basis to develop Product Environmental Footprint Category Rules for the
transport sector, with a focus on GHG emissions.
Adjustment costs for European Commission
The Category Rules for transport of the Product Environmental Footprint methodology have not been
yet developed. The budget to be dedicated to studies to develop the Category Rules for transport is
estimated at EUR 1.5 million per Category Rule.
Based on previous work done in the context of ESPR198
and aviation label, for covering all transport
services 4 Category Rules are needed (road, maritime and IWW, aviation, rail). However, the work on
aviation has alreadystarted and part of these costs (50%) are included in the baseline. Thus, the one-
off adjustment costs for the European Commission in 2025 are estimated at EUR 5.25 million relative
to the baseline (in 2022 prices).
Adjustment costs for businesses
The setting of the Product Environmental Footprint (PEF) Category Rules as common reference
methodology for CountEmissions EU to quantify GHG emissions from transport services, driven
by PM2 (in PO5), is expected to lead to additional costs relative to the baseline for the new
businesses performing GHG emissions accounting but also for the businesses that are already
quantifying GHG emissions and would need to switch to PEFCR.
Businesses already quantifying GHG emissions in the baseline will need to adjust their processes
to be in line with the PEF requirements, once the Category Rules for transport are developed,
resulting in one-off adjustment costs that are different per type and size of business199
. The
recurrent adjustment costs are also expected to be higher than in the baseline. New businesses
performing GHG emissions accounting are also expected to be faced with one-off adjustment
costs for implementing the processes and annual recurrent costs. Table 45 shows the different
unit costs per type of business for adopting PEFCR as common reference methodology, based
on stakeholder’s feedbacks and desk research200
. These costs cover labour costs. The
documentation for PEFCR is assumed to be free of charge.
198
COM(2022) 142 final
199
The adjustment is assumed to be gradual over time, i.e. 20% of the companies that are quantifying GHG
emissions at service level in the baseline are assumed to switch to the new methodology each year between 2025
and 2030. Post-2030, only the additional number of companies that are quantifying GHG emissions at service level
in the baseline relative to the previous year are assumed to switch to the new methodology.
200
The number of hours worked and thus the unit costs per transport service are assumed to go down over time, by
15% by 2050 relative to 2020, due to the learning effects.
104
Table 45: Unit adjustment costs per type of business due to PM2 in PO5 (in EUR, 2022 prices)
Costs associated with calculation (in
EUR), in 2022 prices
TSO
(SME)
TSU
(SME)
HO
(SME)
TSO
(Large)
TSU
(Large)
HO
(Large)
One-off costs for starting implementing
the GHG emission accounting (i.e.
PEFCR)
3,092 3,619 3,092 11,502 16,560 11,502
One-off costs for switching to the PEFCR
GHG emission accounting method
2,671 3,066 2,671 9,447 13,241 9,447
Annual recurrent costs 2,108 1,054 2,108 5,901 5,058 5,901
Source: Ecorys and CE Delft (2023), Impact assessment support study; Note: ‘Large’ stands for large businesses
The total one-off and recurrent adjustment costs for businesses due to PM2 in PO5 (in
conjunction with the binding opt-in application of CountEmissions EU, due to PM14) for 2025,
2030, 2040 and 2050 relative to the baseline are provided in Table 46, together with the number
of companies that switch from other methods to PEFCR and the additional number of companies
that implement PEFCR relative to the baseline. The costs are also provided by company size
(large and SME). Expressed as present value over 2025-2050, the total adjustment costs due to PM2
are estimated at EUR 1.6 billion in PO5 relative to the baseline, of which EUR 1.1 billion one-off
adjustment costs.
Table 46: One-off and recurrent adjustment costs for business due to PM2 in PO5 (in million EUR, 2022 prices),
relative to the baseline
2025 2030 2040 2050
Number companies that switch from other methods to PEFCR 6,152 1,720 1,546 1,389
SMEs 6,051 1,686 1,515 1,361
Large companies 101 34 31 28
Additional number of companies that implement PEFCR
relative to the baseline 12,202 25,102 9,278 2,783
SMEs 11,629 24,006 8,513 2,320
Large companies 573 1,096 765 463
One-off adjustment costs (in million EUR) 63.1 94.6 38.8 14.6
SMEs 54.2 79.7 29.3 9.6
Large companies 8.9 14.8 9.4 5.0
Recurrent adjustment costs (in million EUR) 29.9 50.0 18.3 6.9
SMEs 26.5 44.0 14.3 4.6
Large companies 3.4 6.0 4.0 2.3
Total adjustment costs (in million EUR) 93.0 144.6 57.1 21.5
SMEs 80.7 123.8 43.7 14.1
Large companies 12.4 20.8 13.4 7.4
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 47: type and size of impacted enterprises due to PM2 in PO5 of all enterprises targeted with CountEmissions EU
2025 2030 2040 2050
Number companies switching or implementing PEF CR 2.4% 3.6% 3.6% 4.1%
SMEs 2.4% 3.5% 3.6% 4.0%
Large companies 18.8% 31.1% 31.1% 31.1%
Source: Ecorys and CE Delft (2023), Impact assessment support study
According to stakeholders’ feedback, meetings with experts and desk research, this measure will
not ensure alignment to a global standard, which may lead to difficulties for the aviation and the
maritime transport sectors that are global in nature. Due to the fact that Category Rules are still
105
to be developed, the costs reported are highly dependent on the future developments of the
methodology.
PM3: A common reference methodology is set at EU level, based on ISO 14083 but with
additional elements and increased accuracy
In PM3 (included in PO1 and PO3), a methodology based on ISO 14083 but with additional
granularity and coverage, i.e. LCA for battery vehicles, is developed and set as common
reference methodology for quantifying GHG emissions at EU level.
Adjustment costs for European Commission
As for PM2, the additional specifications needed to increase the accuracy and stringency of the new
methodology building on ISO 14083, will require as explained in Annex 8 additional investments in
research and development. The budget to be dedicated to such study is included in PM3 and is
estimated at EUR 2.4 million. Thus, the one-off adjustment costs for the European Commission in
2025 are estimated at EUR 2.4 million relative to the baseline (in 2022 prices).
Adjustment costs for businesses
The setting of the new methodology based on ISO 14083, but with additional elements and
increased accuracy, as common reference methodology for CountEmissions EU to quantify
GHG emissions from transport services, driven by PM3 (in PO1 and PO3), is expected to lead
to additional costs relative to the baseline for the new businesses performing GHG emissions
accounting but also for the businesses that are already quantifying GHG emissions and would
need to switch to the new methodology.
Businesses already quantifying GHG emissions in the baseline will need to adjust their processes
to be in line with the new methodology, once the additional requirements to increase accuracy
of data are developed, resulting in one-off adjustment costs that are different per type and size
of business201
. The recurrent adjustment costs are also expected to be higher than in the baseline.
New businesses performing GHG emissions accounting are also expected to be faced with one-
off adjustment costs for implementing the processes and with annual recurrent costs. Table 48
shows the different unit costs per type of business for adopting the modified ISO 14083 as
common reference methodology, based on stakeholder’s feedbacks and desk research202
. These
costs cover labour costs and the costs for obtaining the necessary documentation.
201
The adjustment is assumed to be gradual over time, i.e. 20% of the companies that are quantifying GHG
emissions at service level in the baseline are assumed to switch to the new methodology each year between 2025
and 2030. Post-2030, only the additional number of companies that are quantifying GHG emissions at service level
in the baseline relative to the previous year are assumed to switch to the new methodology.
202
The number of hours worked and thus the unit costs per transport service are assumed to go down over time, by
15% by 2050 relative to 2020, due to the learning effects.
106
Table 48: Unit adjustment costs per type of business due to PM3 in PO1 and PO3 (in EUR, 2022 prices)
TSO
(SME)
TSU
(SME)
HO
(SME)
TSO
(Large)
TSU
(Large)
HO
(Large)
One-off costs for starting implementing
the GHG emission accounting (i.e. ISO
14083 with additional elements and
increased accuracy)
2,439 2,781 2,439 9,044 13,418 9,044
One-off costs for switching to the ISO
14083 with additional elements and
increased accuracy GHG emission
accounting method
912 912 912 1,514 1,514 1,514
Annual recurrent costs 1,367 684 1,367 3,828 3,281 3,828
Source: Ecorys and CE Delft (2023), Impact assessment support study; Note: ‘Large’ stands for large businesses.
The total adjustment costs for PM3 in PO1 (in conjunction with the mandatory application of
CountEmissions EU, due to PM13) are different from those in PO3 (in conjunction with the
binding opt-in application of CountEmissions EU, due to PM14). The one-off and recurrent
adjustment costs for businesses due to PM3 in PO1 for 2025, 2030, 2040 and 2050 relative to
the baseline are provided in Table 49, together with the number of companies that switch from
other methods to ISO 14083 with additional elements and increased accuracy, and the additional
number of companies that implement ISO 14083 with additional elements and increased
accuracy relative to the baseline. The costs are also provided by company size (large and SME).
Expressed as present value over 2025-2050, the total adjustment costs due to PM3 are estimated at
EUR 80.3 billion in PO1 relative to the baseline, of which EUR 56 billion one-off adjustment costs.
Table 49: One-off and recurrent adjustment costs for business due to PM3 in PO1 (in million EUR, 2022 prices),
relative to the baseline
2025 2030 2040 2050
Number companies that switch from other methods
to ISO 14083 with additional elements and increased
accuracy
6,152 1,720 1,546 1,389
SMEs 6,051 1,686 1,515 1,361
Large companies 101 34 31 28
Additional number of companies that implement
ISO 14083 with additional elements and increased
accuracy, relative to the baseline
110,570 918,003 1,718,143 1,703,841
SMEs 109,689 915,130 1,713,423 1,699,423
Large companies 881 2,873 4,720 4,418
One-off adjustment costs (in million EUR) 295.0 2,308.0 4,047.6 3,747.8
SMEs 285.2 2,277.1 4,000.1 3,706.4
Large companies 9.8 30.9 47.5 41.3
Recurrent adjustment costs (in million EUR) 130.2 1,003.0 1,755.9 1,624.5
SMEs 126.9 993.0 1,740.5 1,611.0
Large companies 3.2 10.0 15.4 13.5
Total adjustment costs (in million EUR) 425.2 3,311.0 5,803.5 5,372.2
SMEs 412.2 3,270.1 5,740.6 5,317.4
Large companies 13.0 40.9 62.9 54.8
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 50: type and size of impacted enterprises due to PM3 in PO1 of all enterprises targeted with CountEmissions
EU
2025 2030 2040 2050
107
Number companies switching or implementing to ISO 14083 with
additional elements and increased accuracy 8.0% 54.0% 100.0% 100.0%
SMEs 7.9% 54.0% 100.0% 100.0%
Large companies 24.2% 62.0% 100.0% 100.0%
Source: Ecorys and CE Delft (2023), Impact assessment support study
The one-off and recurrent adjustment costs for businesses due to PM3 in PO3 (in conjunction
with the binding opt-in application of CountEmissions EU, due to PM14) for 2025, 2030, 2040
and 2050 relative to the baseline are provided in Table 51, together with the number of companies
that switch from other methods to ISO 14083 with additional elements and increased accuracy,
and the additional number of companies that implement ISO 14083 with additional elements and
increased accuracy relative to the baseline. Expressed as present value over 2025-2050, the total
adjustment costs due to PM3 are estimated at EUR 1.2 billion in PO3 relative to the baseline, of which
EUR 0.8 billion one-off adjustment costs.
Table 51: One-off and recurrent adjustment costs for business due to PM3 in PO3 (in million EUR, 2022 prices),
relative to the baseline
2025 2030 2040 2050
Number companies that switch from other methods
to ISO 14083 with additional elements and increased
accuracy
6,152 1,720 1,546 1,389
SMEs 6,051 1,686 1,515 1,361
Large companies 101 34 31 28
Additional number of companies that implement
ISO 14083 with additional elements and increased
accuracy, relative to the baseline
13,023 26,745 10,828 3,640
SMEs 12,431 25,611 10,025 3,139
Large companies 592 1,134 803 501
One-off adjustment costs (in million EUR) 43.6 76.3 32.4 12.0
SMEs 37.0 64.3 24.7 7.9
Large companies 6.6 12.0 7.7 4.2
Recurrent adjustment costs (in million EUR) 18.1 33.8 13.1 4.9
SMEs 15.9 29.9 10.4 3.3
Large companies 2.2 4.0 2.7 1.6
Total adjustment costs (in million EUR) 61.7 110.2 45.5 16.9
SMEs 52.9 94.2 35.1 11.2
Large companies 8.8 16.0 10.4 5.8
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 52: type and size of impacted enterprises due to PM3 in PO3 of all enterprises targeted with CountEmissions
EU
2025 2030 2040 2050
Number companies switching or implementing to ISO 14083 with
additional elements and increased accuracy 2.5% 3.7% 3.7% 4.1%
SMEs 2.4% 3.6% 3.6% 4.0%
Large companies 19.2% 31.7% 31.7% 31.7%
Source: Ecorys and CE Delft (2023), Impact assessment support study
According to stakeholders’ feedback, meetings with experts and desk research, the stricter
requirements relative to the global standard are not likely to be followed at global level, which may
lead to challenges for the aviation and maritime transport sectors that are global in nature. The costs
estimates above are dependent on the additional requirements that are still to be developed.
108
PM4: The use of primary data is incentivised and centralised databases for default values
and energy emission factors are established at EU level (by European Environmental
Agency)
Adjustment costs for European Environmental Agency
In PM4 (included in PO1,PO2 and PO5) primary data on transport operations shall be used with
priority. In case this is not possible, the use of emission intensityfactors from a centralised EU database
created and maintained by European Environmental Agency (EEA) is allowed. The energy/fuel
emission factors database will also be maintained at EU level, by EEA.
For developing the databases, 1 full time equivalent (FTEs) is estimated to be needed by EEA in 2025,
2026 and 2027, in addition to EUR 200,000 in infrastructure costs203
. The one-off costs associated to
the development of the databases are thus estimated at EUR 693,149. In addition, one FTE and
operational costs for maintenance would be required for maintaining and updating the databases from
2026 onwards. The recurrent adjustment costs for EEA are estimated at EUR 186,000 per year from
2026 onwards relative to the baseline.
As explained above, PM4 is included in PO1, PO2 and PO5. The total adjustment costs for EEA due
to PM4 relative to the baseline, expressed as present value over 2025-2050, are estimated at EUR 3.6
million of which EUR 0.7 million one-off costs.
PM5: The use of primary data is incentivised and centralised databases for default values are
established at EU level. Quality assurance of external databases operated by third parties is
provided at EU level (by European Environmental Agency).
Adjustment costs for European Environmental Agency
Similarly to PM4, primary data for transport operations shall be used with priority in PM5 (included
in PO3, PO4 and PO6). In case this is not possible, the use of emission intensity factors from a
centralised EU database created and maintained byEEA is allowed. Use of data from sectorial specific
dataset, recognised according to a quality check made by EEA is allowed as well. The energy/fuel
emission factors database will also be maintained at EU level, by EEA.
As for PM4, for developing the databases 1 full time equivalent (FTEs) is estimated to be needed
by EEA in 2025, 2026 and 2027, in addition to EUR 200,000 in infrastructure costs204
. The one-off
costs associated to the development of the databases are thus estimated at EUR 693,149. In
addition, one FTE and operational costs would be required for maintaining and updating the
databases from 2026 onwards. The recurrent adjustment costs for EEA are estimated at EUR
186,000 per year from 2026 onwards relative to the baseline.
In addition, quality assurance of external databases operated by third parties will be provided at EU
level by European Environmental Agency. For each dataset, 15 hours are assumed to be needed for
performing the quality check. The quality check is assumed to be performed for the first time in 2026,
for 24 datasets (more than one for each sector involved in the quantification). The qualitycheck of each
203
Source: EEA
204
Source: EEA
109
dataset is estimated to occur every two years. Thus, operational costs are estimated to be needed every
two years, equivalent to EUR 35,791 every two years205
.
The total one-off adjustment costs for the EEA are estimated at EUR 693,149 in the period 2025-
2027, while the recurrent annual costs at EUR 221,791 in 2030 and in 2050. Expressed as present
value over 2025-2050, the total adjustment costs are estimated at EUR 3.2 million.
Administrative costs for business sector associations
The possibility of using data from sectorial specific datasets recognised through the quality check
performed by EEA will create additional administrative costs for the businesses willing to use this
alternative. According to the feedback received during the stakeholders’ consultation, this option will
not be used at single business level, but rather bysector associations that will collect the data from their
associates and submit them to the EEA for the quality check.
Estimates of costs were based on similar initiatives such as FuelEU Maritime206
and EMSWe207
, and
feedback from stakeholders. The time needed for businesses to submit the databases is estimated at 24
hours per database, and the cost per hour is estimated at EUR 40.9208
in 2022 prices for ISCO 2
category (Professionals), and it is assumed to remain constant over time in real prices. A number of 17
databases is assumed to be submitted, in line with the number of involved sectors. Databases are
expected to be submitted every two years.
The recurrent administrative costs for business sector associations are estimated at EUR 16,686
in 2026 relative to baseline, and every two years up to 2050. Expressed as present value over 2025-
2050, the total administrative costs are estimated at EUR 177,452.
For the purpose of reporting on the application of the ‘one in, one out’ approach209
, the annual
average number of hours per database for businesses to submit the databases has been estimated at
12 hours each year (instead of every two years). The cost per hour is estimated at EUR 40.9 and a
number of 17databases is assumedtobesubmitted.The cost perdatabase forpreparingthesubmission
is estimated at EUR 490.76 per database. Thus, for the purpose of ‘one in, one out’ approach, the
recurrent administrative costs for business sector associations are estimated at EUR 8,343 per
year.
PM6: Harmonised GHG output data formats and metrics are provided at EU level, together
with common rules on the communication and transparency
In PM6, minimum requirements for harmonised formats (unit of measures) are mandated. This
will facilitate the sharing of comparable data between entities along the supply chain, which may
be particularly beneficial as companies have to request/provide data to a large number of other
companies, all using their own data output formats. The reference to the source of the data output
(CountEmissions EU) and its scope (GHG emissions from transport services) will be mandated.
This will enhance transparent communication. Specific requirements for the communication and
205
Source: EEA
206
COM(2021)562
207
Regulation (EU) 2019/1239 establishing a European Maritime Single Window environment
208
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour
209
https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and-
how_en
110
transparency related to any GHG claims on the performance of transport services are included.
This measure is common to all policy measures.
Adjustment costs for national public authorities
The time required for the national statistical offices that are collecting and storing data on transport
GHG emissions to implement the new rules, switching to a unique format for the data resulting from
the calculations, is estimated at 120 hours per statistical office. The average cost per hour is estimated
at EUR 40.9210
in 2022 prices for ISCO 2 category(Professionals) and it is assumed to remain constant
over time in real prices. Thus, the one-off adjustment costs for the national public authorities in 2025
are estimated at EUR 132,504 relative to the baseline (in 2022 prices). This should be regarded as an
upper-bound estimate, as it is very likely that familiarising with the new rules would take place in the
context of the regular activities performed by the statistical offices.
PM7: Horizontal guidelines for the harmonised implementation of CountEmissions EU in
various sectors and segments of the transport market are provided at EU level
In PM7 guidance is provided at EU level on how to calculate emissions using CountEmissions
EU, how to apply primary data and default values, how to develop sectorial guidelines, how to
go through the verification process, and how to safely share emissions data, preserving privacy
and confidentiality (e.g. SCF & CEFIC (2021) for the chemical sector)211
. This measure is
common to all policy options.
Adjustment costs for business sector associations
The workload required by businesses sector associations to adapt sector processes in line with the
guidelines set in the implementing act of CountEmissions EU is estimated at 90 hours per sector
association. The average cost per hour is estimated at EUR 40.9212
in 2022 prices for ISCO 2 category
(Professionals). The number of sectors that will need to adapt processes is estimated to be 17, which
represents an upper bound estimation (including all NACE categories). Thus, the one-off adjustment
costs for business sector associations in 2025 are estimated at EUR 62,571 relative to the baseline (in
2022 prices).
PM8: A mandatory process and data verification for all entities is established at EU level
In PM8, the data and calculation processes of GHG emissions from entities must be verified
annually by bodies accredited at EU level. These bodies are bound by non disclosure. The
verification is done by bodies that are accredited by MS accreditation bodies, following specific
EU rules. These bodies follow the verification rules provided at the EU level, both for data (with
the support of EEA) and processes. Verification for data will be done in conformity with the
requirements for the input data and methodology.
210
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour
211
TFS, The Product Carbon Footprint Guideline for the Chemical Industry, 2021
212
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour
111
Administrative costs for National Accreditation Bodies – NABs213
PM8 mandates for all businesses to be verified by a verifier accredited in line with Regulation
2016/2072214
, which can be extended to the whole transport sector with very small modifications.
Verification is performed by bodies that are accredited by NABs, dealing with accreditation following
specific EU rules.
As regards accreditation, the workload associated to PM8 (included in PO1) for national public
authorities is estimated at 120 hours per Member State. The average cost per hour is estimated at EUR
40.9215
in 2022 prices for ISCO 2 category (Professionals). Thus, the one-off administrative costs for
NABs in 2025 at EU level are estimated at EUR 132,504 relative to the baseline.
Adjustment costs for businesses
As regards verification, in the baseline scenario 80% of large companies and 20% of the SMEs that
perform GHG emissions accounting undergo verification. PM8 mandates the verification of GHG
emissions output data for all businesses. Verification is performed by bodies that are accredited by MS
accreditation bodies, following specific EU rules. A secondary act will define the accreditation rules
and the verification rules for verification bodies. Verification will be performed on annual basis.
The costs for PM8 (included in PO1) build on estimates from the impact assessments accompanying
the Fuel EU Maritime initiative and the MRV Regulation, and inputs from the stakeholder consultation
activities. The unit costs by size of business are provided in Table 53216
.
Table 53: Unit costs for verification activities per business type, due to PM8 in PO1 (in EUR)
TSO
(SME)
TSU
(SME)
HO
(SME)
TSO
(Large)
TSU
(Large)
HO
(Large)
Baseline 399 570 399 638 1,048 638
PO1 273 410 273 465 684 465
Source: Ecorys and CE Delft (2023), Impact assessment support study; Note: ‘Large’ stands for large businesses.
Businesses that already perform verification activities in the baseline are expected to be faced with
costs savings due to the fact that the unit costs per company217
for verification activities are expected
to be lower in PM8 relative to the baseline. On the other hand, the additional number of companies that
perform verification activities (in conjunction with the mandatory application of CountEmissions
EU, due to PM13) lead to an overall increase in adjustment costs for PM8 (see Table 54). Expressed
213
A National Accreditation Body (NAB) is an institution which attests to the competence and impartiality of
conformity assessment bodies (testing and calibration laboratories, certification and inspection bodies), according
to international standards such as ISO/IEC. https://ec.europa.eu/growth/tools-
databases/nando/index.cfm?fuseaction=ab.main
214
Commission Delegated Regulation (EU) 2016/2072 of 22 September 2016 on the verification activities and
accreditation of verifiers pursuant to Regulation (EU) 2015/757 of the European Parliament and of the Council on
the monitoring, reporting and verification of carbon dioxide emissions from maritime transport https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016R2072
215
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour
216
The number of hours worked and thus the unit costs are assumed to go down over time, by 15% by 2050 relative
to 2020, due to the learning effects.
217
The provision of a single standardised set of rules will lead to savings in time to support verification activities.
The verification is conducted on annual basis on random samplings of quantifications. The verifiers will be provided
with specific standardised rules to perform verifications. Source: CE Delft et al. (2023), Impact assessment support
study
112
as present value over 2025-2050, the total adjustment costs for PM8 in PO1 are estimated at EUR 7.2
billion relative to the baseline.
Table 54: Recurrent adjustment costs for business due to PM8 in PO1 (in EUR)
2025 2030 2040 2050
Number of companies that perform
verification activities in the baseline
6,457 8,290 11,670 14,711
SMEs 6,051 7,739 10,856 13,654
Large companies 406 551 814 1,057
Costs for companies switching to ISO+
verification (in million EUR) relative to the
baseline
-0.9 -1.1 -1.5 -1.8
SMEs -0.8 -1.0 -1.3 -1.5
Large companies -0.1 -0.1 -0.2 -0.3
Additional number of companies that perform
verification in PM8
134,873 949,093 1,761,770 1,758,729
SMEs 133,891 946,084 1,756,846 1,754,048
Large companies 982 3,009 4,924 4,681
Costs for additional companies that perform
verification (in million EUR) relative to the
baseline
42.4 297.3 518.7 483.7
SMEs 41.9 295.6 516.2 481.5
Large companies 0.6 1.7 2.5 2.2
Total additional costs relative to the baseline
(in million EUR) relative to the baseline
41.5 296.2 517.2 481.9
SMEs 41.1 294.7 514.9 479.9
Large companies 0.4 1.5 2.3 2.0
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 55: type and size of impacted enterprises due to PM8 in PO1 of all enterprises targeted with CountEmissions
EU
2025 2030 2040 2050
Number companies performing verification 8.0% 54.0% 100.0% 100.0%
SMEs 7.9% 54.0% 100.0% 100.0%
Large companies 24.2% 62.0% 100.0% 100.0%
Source: Ecorys and CE Delft (2023), Impact assessment support study
PM9: A mandatory process and data verification for entities above certain size are
established at EU level
Administrative costs for National Accreditation Bodies – NABs218
PM9 (included in PO3, PO4, PO5 and PO6) mandates for businesses above certain size alone to be
verified by a verifier accredited via Regulation 2016/2072219
. Verification is performed by bodies that
218
A National Accreditation Body (NAB) is an institution which attests to the competence and impartiality of
confor- mity assessment bodies (testing and calibration laboratories, certification and inspection bodies), according
to interna- tional standards such as ISO/IEC. https://ec.europa.eu/growth/tools-
databases/nando/index.cfm?fuseaction=ab.main
219
Commission Delegated Regulation (EU) 2016/2072 of 22 September 2016 on the verification activities and
accreditation of verifiers pursuant to Regulation (EU) 2015/757 of the European Parliament and of the Council on
113
are accredited by NABs dealing with accreditation following specific EU rules. A secondary act will
define the accreditation rules and the verification rules for verification bodies.
As regards accreditation, the workload associated to PM9 (included in PO3, PO4, PO5 and PO6) for
national public authorities is estimated at 120 hours per Member State. The average cost per hour is
estimated at EUR 40.9220
in 2022 prices for ISCO 2 category (Professionals). Thus, the one-off
administrative costs for NABs in 2025 at EU level are estimated at EUR 132,504 relative to the
baseline.
Adjustment costs for businesses
PM9 sets the verification of GHG emissions as mandatory only for companies above a certain size, i.e.
non SMEs. As for PM8, the verification is performed by bodies that are accredited by Member States
accreditation bodies, following specific EU rules. Verification is performed on annual basis.
Notwithstanding its voluntary nature for SMEs, due to their involvement in the supply chain, it is
assumed that 20% of those performing GHG emissions accounting will undergo verification. All large
companies will undergo verification.
The total adjustment costs due to PM9 are different between policy options (in PO3, PO4, PO5 and
PO6) due to the different unit costs per company for verification activities in each option, linked to the
method for GHG accounting applied (ISO 14083 with additional elements and increased accuracy in
PO3 due to PM3, ISO 14083 in PO4 and PO6 due to PM1 and PEFCR in PO5 due to PM2). The unit
costs by size of business and by policy option are provided in Table 56221
.
Table 56: Unit costs for verification activities per business type, due to PM9 in PO3, PO4, PO5 and PO6 (in EUR)
TSO (SME) TSU (SME) HO (SME) TSO (Large) TSU (Large) HO (Large)
Baseline 399 570 399 638 1,048 638
PO3 273 410 273 465 684 465
PO4 228 342 228 387 570 387
PO5 948 1,265 948 1,391 2,150 1,391
PO6 228 342 228 387 570 387
Source: Ecorys and CE Delft (2023), Impact assessment support study
In PO3, businesses that already perform verification activities in the baseline are expected to be faced
with costs savings due to the fact that unit costs per company222
for verification activities are expected
to be lower in PM9 relative to the baseline. On the other hand, the additional number of companies that
perform verification activities (in conjunction with the binding opt-in application of
CountEmissions EU, due to PM14) leads to an increase in the adjustment costs for PM9 (see Table
the monitoring, reporting and verification of carbon dioxide emissions from maritime transport https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016R2072
220
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour
221
The number of hours worked and thus the unit costs are assumed to go down over time, by 15% by 2050 relative
to 2020, due to the learning effects.
222
The provision of a single standardised set of rules will lead to savings in time to support verification activities.
The verification is conducted on annual basis on random samplings of quantifications. The verifiers will be provided
with specific standardised rules to perform verifications. Source: Ecorys and CE Delft (2023), Impact assessment
support study.
114
57). Expressed as present value over 2025-2050, PM9 results in total adjustment costs estimated at
EUR 1 million in PO3 relative to the baseline.
Table 57: Recurrent adjustment costs for business due to PM9 in PO3 (in EUR)
2025 2030 2040 2050
Number of companies that perform verification
activities in the baseline
6,457 8,290 11,670 14,711
SMEs 6,051 7,739 10,856 13,654
Large companies 406 551 814 1,057
Costs for companies switching to ISO+
verification (in million EUR) relative to the
baseline
-0.9 -1.1 -1.5 -1.8
SMEs -0.8 -1.0 -1.3 -1.5
Large companies -0.1 -0.1 -0.2 -0.3
Additional number of companies that perform
verification in PM9
3,179 6,393 3,013 1,395
SMEs 2,486 5,123 2,006 631
Large companies 693 1,270 1,007 764
Costs for additional companies that perform
verification (in million EUR) relative to the
baseline
1.2 2.2 1.1 0.5
SMEs 0.8 1.5 0.6 0.2
Large companies 0.4 0.7 0.5 0.3
Total additional costs relative to the baseline (in
million EUR) relative to the baseline
0.3 1.1 -0.4 -1.3
SMEs 0.0 0.6 -0.7 -1.3
Large companies 0.3 0.5 0.3 0.1
Source: Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs savings,
where relevant.
Table 58: type and size of impacted enterprises due to PM9 in PO3 of all enterprises targeted with CountEmissions
EU
2025 2030 2040 2050
Number companies performing verification 0.5% 0.8% 0.8% 0.9%
SMEs 0.5% 0.7% 0.7% 0.8%
Large companies 19.2% 31.7% 31.7% 31.7%
Source: Ecorys and CE Delft (2023), Impact assessment support study
The recurrent adjustment costs/costs savings for business due to PM9 in PO4 are provided in Table 59.
Expressed as present value over 2025-2050, PM9 results in adjustment costs savings estimated at EUR
3.6 million in PO4 relative to the baseline.
Table 59: Recurrent adjustment costs/costs savings for business due to PM9 in PO4 (in EUR)
2025 2030 2040 2050
Number of companies that perform verification
activities in the baseline
6,457 8,290 11,670 14,711
SMEs 6,051 7,739 10,856 13,654
Large companies 406 551 814 1,057
Costs for companies switching to ISO
verification (in million EUR) relative to the
baseline
-1.2 -1.5 -2.1 -2.4
SMEs -1.1 -1.3 -1.8 -2.1
Large companies -0.2 -0.2 -0.3 -0.3
115
Additional number of companies that perform
verification in PM9
4,892 8,913 5,533 2,492
SMEs 4,199 7,643 4,526 1,728
Large companies 693 1,270 1,007 764
Costs for additional companies that perform
verification (in million EUR) relative to the
baseline
1.4 2.4 1.4 0.6
SMEs 1.0 1.8 1.0 0.4
Large companies 0.3 0.6 0.4 0.3
Total additional costs relative to the baseline (in
million EUR) relative to the baseline
0.1 0.9 -0.6 -1.8
SMEs 0.0 0.5 -0.8 -1.7
Large companies 0.2 0.4 0.1 -0.1
Source: Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs savings,
where relevant.
Table 60: type and size of impacted enterprises due to PM9 in PO4 of all enterprises targeted with CountEmissions EU
2025 2030 2040 2050
Number companies performing verification 0.6% 1.0% 1.0% 1.0%
SMEs 0.6% 0.9% 0.9% 0.9%
Large companies 19.2% 31.7% 31.7% 31.7%
Source: Ecorys and CE Delft (2023), Impact assessment support study
The recurrent adjustment costs for business due to PM9 in PO5 are provided in Table 61. Expressed as
present value over 2025-2050, PM9 results in adjustment costs estimated at EUR 180.3 million in PO5
relative to the baseline.
Table 61: Recurrent adjustment costs for business due to PM9 in PO5 (in EUR)
2025 2030 2040 2050
Number of companies that perform verification
activities in the baseline
6,457 8,290 11,670 14,711
SMEs 6,051 7,739 10,856 13,654
Large companies 406 551 814 1,057
Costs for companies switching to PEF
verification (in million EUR) relative to the
baseline
3.8 4.8 6.4 7.5
SMEs 3.4 4.3 5.7 6.7
Large companies 0.4 0.5 0.7 0.9
Additional number of companies that perform
verification in PM9
3,000 6,033 2,672 1,193
SMEs 2,326 4,801 1,703 467
Large companies 674 1,232 969 726
Costs for additional companies that perform
verification (in million EUR) relative to the
baseline
3.6 6.9 3.1 1.4
SMEs 2.4 4.8 1.7 0.4
Large companies 1.2 2.1 1.5 1.0
Total additional costs relative to the baseline (in
million EUR) relative to the baseline
7.4 11.6 9.5 8.9
SMEs 5.9 9.1 7.3 7.1
Large companies 1.5 2.6 2.2 1.9
Source: Ecorys and CE Delft (2023), Impact assessment support study
116
Table 62: type and size of impacted enterprises due to PM9 in PO5 of all enterprises targeted with CountEmissions
EU
2025 2030 2040 2050
Number companies performing verification 0.6% 0.8% 0.8% 0.9%
SMEs 0.5% 0.8% 0.8% 0.8%
Large companies 14.3% 23.0% 23.0% 23.5%
Source: Ecorys and CE Delft (2023), Impact assessment support study
The recurrent adjustment costs for business due to PM9 in PO6 are provided in Table 61. Expressed as
present value over 2025-2050, PM9 results in adjustment costs estimated at EUR 1.2 billion in PO6
relative to the baseline.
Table 63: Recurrent adjustment costs for business due to PM9 in PO6 (in EUR)
2025 2030 2040 2050
Number of companies that perform verification
activities in the baseline
6,457 8,290 11,670 14,711
SMEs 6,051 7,739 10,856 13,654
Large companies 406 551 814 1,057
Costs for companies switching to ISO verification
(in million EUR) relative to the baseline
-1.2 -1.5 -2.1 -2.4
SMEs -1.1 -1.3 -1.8 -2.1
Large companies -0.2 -0.2 -0.3 -0.3
Additional number of companies that perform
verification in PM9
22,921 186,037 347,609 344,568
SMEs 21,939 183,028 342,685 339,887
Large companies 982 3,009 4,924 4,681
Costs for additional companies that perform
verification (in million EUR) relative to the
baseline
6.3 49.2 86.2 79.8
SMEs 5.8 47.8 84.1 78.0
Large companies 0.5 1.4 2.1 1.9
Total additional costs relative to the baseline (in
million EUR) relative to the baseline
5.0 47.6 84.1 77.4
SMEs 4.7 46.5 82.3 75.9
Large companies 0.3 1.2 1.8 1.5
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 64: type and size of impacted enterprises due to PM9 in PO6 of all enterprises targeted with CountEmissions
EU
2025 2030 2040 2050
Number companies performing verification 1.7% 11.0% 20.3% 20.3%
SMEs 1.6% 10.8% 20.0% 20.0%
Large companies 24.2% 62.0% 100.0% 100.0%
Source: Ecorys and CE Delft (2023), Impact assessment support study
117
PM10: A voluntary process and data verification for all entities is established at EU level
Administrative costs for National Accreditation Bodies – NABs223
PM10 does not mandate for any businesses to be verified by a verifier accredited via Regulation
2016/2072224
. However, the same accreditation-verification mechanism is foreseen. Verification is
performed by bodies that are accredited by NABs dealing with accreditation following specific EU
rules. A secondary act will define the accreditation rules and the verification rules for verification
bodies.
As regards accreditation, the workload associated to PM10 (included in PO2) for national public
authorities is estimated at 120 hours per Member State. The average cost per hour is estimated at EUR
40.9225
in 2022 prices for ISCO 2 category (Professionals). Thus, the one-off administrative costs for
NABs in 2025 at EU level are estimated at EUR 132,504 relative to the baseline.
Adjustment costs for businesses
PM10, included in PO2, keeps the verification of GHG emissions output data voluntary. As for PM8
and PM9, verification is performed by bodies that are accredited by MS accreditation bodies following
specific EU rules. A secondary act will define the accreditation rules and the verification rules for
verification bodies. Verification will be performed on annual basis.
The costs for PM10 (included in PO2) build on estimates from the impact assessments accompanying
the Fuel EU Maritime initiative and the MRV Regulation, and inputs from the stakeholder consultation
activities. The unit costs for verification activities by size of business are provided in Table 65.
Table 65: Unit costs for verification activities per business type, due to PM10 in PO2 (in EUR)
TSO
(SME)
TSU
(SME)
HO
(SME)
TSO
(Large)
TSU
(Large)
HO
(Large)
PO2 228 342 228 387 570 387
Source: Ecorys and CE Delft (2023), Impact assessment support study
The recurrent adjustment costs/costs savings for business due to PM10 in PO2 are provided in Table
66. Expressed as present value over 2025-2050, PM10 results in adjustment costs estimated at EUR
68.1 million in PO2 relative to the baseline.
Table 66: Recurrent adjustment costs for business due to PM10 in PO2 (in EUR)
2025 2030 2040 2050
Number of companies that perform verification
activities in the baseline
6,457 8,290 11,670 14,711
SMEs 6,051 7,739 10,856 13,654
Large companies 406 551 814 1,057
223
A National Accreditation Body (NAB) is an institution which attests to the competence and impartiality of confor- mity
assessment bodies (testing and calibration laboratories, certification and inspection bodies), according to interna- tional standards
such as ISO/IEC. https://ec.europa.eu/growth/tools-databases/nando/index.cfm?fuseaction=ab.main
224
Commission Delegated Regulation (EU) 2016/2072 of 22 September 2016 on the verification activities and accreditation of
verifiers pursuant to Regulation (EU) 2015/757 of the European Parliament and of the Council on the monitoring, reporting and
verification of carbon dioxide emissions from maritime transport https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32016R2072
225
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour
118
2025 2030 2040 2050
Costs for companies switching to ISO
verification (in million EUR) relative to the
baseline
-1.2 -1.5 -2.1 -2.4
SMEs -1.1 -1.3 -1.8 -2.1
Large companies -0.2 -0.2 -0.3 -0.3
Additional number of companies that perform
verification in PM10
16,770 27,173 23,793 21,461
SMEs 16,358 26,404 23,287 21,171
Large companies 412 769 506 290
Costs for additional companies that perform
verification (in million EUR) relative to the
baseline
4.2 6.7 5.5 4.6
SMEs 4.0 6.3 5.2 4.4
Large companies 0.2 0.4 0.2 0.1
Total additional costs relative to the baseline (in
million EUR) relative to the baseline
3.0 5.2 3.4 2.1
SMEs 2.9 5.0 3.5 2.3
Large companies 0.1 0.2 -0.1 -0.2
Source: Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs savings,
where relevant.
Table 67: type and size of impacted enterprises due to PM10 in PO5 of all enterprises targeted with CountEmissions
EU
2025 2030 2040 2050
Number companies performing verification 0.6% 0.8% 0.8% 0.9%
SMEs 0.5% 0.8% 0.8% 0.8%
Large companies 14.3% 23.0% 23.0% 23.5%
Source: Ecorys and CE Delft (2023), Impact assessment support study
PM11: Emissions calculation tools are provided at EU level (by European Commission)
Adjustment costs for European Commission
PM11 (included in PO1 and PO2) foresees that calculation tools following the common reference
methodology are developed and provided at the EU level, while the data sharing is done through
recognised tools such as ISO/IEC 27001 and related standards on information security management.
The development of these calculation tools is expected to be done in the context of a research project
procured by the European Commission. As explained in Annex 8, this will require additional
investments in research and development. Based on the cost of THETIS-MRV and experience with
existing THETIS-EU modules that support various pieces of EU legislation, such IT-developments are
estimated at EUR 300,000 (one-off costs in 2025).
Adjustment costs for businesses
PM11 will provide businesses with calculation tools developed following strict rules by the
European Commission. The use of these calculation tools will require labour costs for
incorporating them into the business practices, and time dedicated to use them. The costs for the
use of calculation tools by type and size of company are provided in Table 68Table 68.
Table 68: Costs for the use of calculation tools by business type, due to PM11 in PO1 and PO2 (in EUR)
TSO (SME) TSU (SME) HO (SME) TSO (Large) TSU (Large) HO (Large)
119
Baseline 257 514 514 1,799 3,597 3,597
PO1 308 377 377 2,158 4,317 4,317
PO2 257 314 314 1,753 3,506 3,506
Source: Ecorys and CE Delft (2023), Impact assessment support study
The total recurrent adjustment costs for calculation tools due to PM11, included in PO1, are
provided in Table 69 and those for PO2 in
2025 2030 2040 2050
Number companies using calculation tools 8.0% 54.0% 100.0% 100.0%
SMEs 7.9% 54.0% 100.0% 100.0%
Large companies 24.2% 62.0% 100.0% 100.0%
Source: Ecorys and CE Delft (2023), Impact assessment support study.
Table 71. Expressed as present value over 2025-2050, PM11 results in adjustment costs estimated at
EUR 7.6 billion in PO1 and EUR 74.6 million in PO2 relative to the baseline.
Table 69: Recurrent adjustment costs for business due to PM11 in PO1 (in million EUR)
2025 2030 2040 2050
Number of companies that use calculation tools in
the baseline
30,760 39,380 55,297 69,599
SMEs 30,253 38,693 54,279 68,279
Large companies 507 687 1,018 1,320
Additional number of companies that need
calculation tools in PM11
110,570 918,003 1,718,143 1,703,841
SMEs 109,689 915,130 1,713,423 1,699,423
Large companies 881 2,873 4,720 4,418
Total costs relative to the baseline (in million EUR) 41.2 312.1 545.8 505.3
SMEs 37.6 301.4 529.4 490.8
Large companies 3.6 10.7 16.4 14.5
Source: Ecorys and CE Delft (2023), Impact assessment support study.
Table 70: type and size of impacted enterprises due to PM11 in PO1 of all enterprises targeted with CountEmissions
EU
2025 2030 2040 2050
Number companies using calculation tools 8.0% 54.0% 100.0% 100.0%
SMEs 7.9% 54.0% 100.0% 100.0%
Large companies 24.2% 62.0% 100.0% 100.0%
Source: Ecorys and CE Delft (2023), Impact assessment support study.
Table 71: Recurrent adjustment costs for business due to PM11 in PO2 (in million EUR)
2025 2030 2040 2050
Number of companies that use calculation tools in
the baseline
30,760 39,380 55,297 69,599
SMEs 30,253 38,693 54,279 68,279
Large companies 507 687 1,018 1,320
Additional number of companies that need
calculation tools in PM11
14,868 30,219 14,302 1,388
SMEs 14,557 29,586 14,000 1,361
Large companies 311 633 302 27
Total costs relative to the baseline (in million EUR) 4.0 8.4 2.6 -1.6
SMEs 3.1 6.6 1.9 -1.6
120
Large companies 0.9 1.8 0.8 0.0
Source: Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs savings,
where relevant; Note: negative values reflect costs savings, where relevant.
Table 72: type and size of impacted enterprises due to PM11 in PO1 of all enterprises targeted with CountEmissions
EU
2025 2030 2040 2050
Number companies using calculation tools 2.6% 3.9% 3.9% 4.0%
SMEs 2.5% 3.9% 3.9% 3.9%
Large companies 14.3% 23.0% 23.0% 23.5%
Source: Ecorys and CE Delft (2023), Impact assessment support study.
PM12: The provision of the emissions calculation tools is left to the market but they are
certified at EU level
Adjustment costs for businesses
PM12 (included in PO3, PO4, PO5 and PO6) foresees that the development of calculation tools
following the common reference methodology is left to the market but certified at EU level. Data
sharing is done through recognised tools such as ISO ISO/IEC 27011. As explained in Annex 8, there
are already a number of tools available on the market and, according to desk research and feedback in
the context of stakeholders’ consultation, the changes needed to adapt to ISO 14083 and the ISO 14083
with additional elements and increased accuracy would not require significant effort. The only
exception represents the calculation tool for PEFCR, for which data on potential costs is very much
dependent on the Category Rules that will be developed in the future.
The costs for the use of calculation tools by type and size of company are provided in Table
73Table 73 and they are different depending on the policy option.
Table 73: Costs for the use of calculation tools by business type due to PM12 (in EUR)
TSO
(SME)
TSU
(SME)
HO
(SME)
TSO (Large) TSU
(Large)
HO
(Large)
Baseline 257 514 514 1,799 3,597 3,597
PO3 308 377 377 2,158 4,317 4,317
PO4 257 314 314 1,753 3,506 3,506
PO5 475 951 951 3,328 6,655 6,655
PO6 257 314 314 1,753 3,506 3,506
Source: Ecorys and CE Delft (2023), Impact assessment support study
The total recurrent adjustment costs for calculation tools due to PM12, included in PO3, are
provided in Table 74Table 74, for PO4 in Table 75 and for PO5 in Table 76. Expressed as present
value over 2025-2050, PM12 results in total recurrent adjustment costs estimated at EUR 167.6 million
in PO3, EUR 138.6 million in PO4, EUR 470 million in PO5 and EUR 6.2 billion in PO6 relative to
the baseline.
Table 74: Recurrent adjustment costs for business due to PM12 in PO3 (in million EUR)
2025 2030 2040 2050
Number of companies that use calculation tools in
the baseline
30,760 39,380 55,297 69,599
SMEs 30,253 38,693 54,279 68,279
Large companies 507 687 1,018 1,320
121
2025 2030 2040 2050
Additional number of companies that need
calculation tools in PM12
13,023 26,745 10,828 3,640
SMEs 12,431 25,611 10,025 3,139
Large companies 592 1,134 803 501
Total costs relative to the baseline (in million EUR) 7.5 13.7 7.6 4.5
SMEs 4.9 9.1 4.2 2.1
Large companies 2.6 4.7 3.4 2.4
Source: Ecorys and CE Delft (2023), Impact assessment support study.
Table 75: type and size of impacted enterprises due to PM12 in PO3 of all enterprises targeted with CountEmissions
EU
2025 2030 2040 2050
Number companies using calculation tools 2.5% 3.7% 3.7% 4.1%
SMEs 2.4% 3.6% 3.6% 4.0%
Large companies 19.2% 31.7% 31.7% 31.7%
Source: Ecorys and CE Delft (2023), Impact assessment support study.
Table 76: Recurrent adjustment costs for business due to PM12 in PO4 (in million EUR)
2025 2030 2040 2050
Number of companies that use calculation tools in
the baseline
30,760 39,380 55,297 69,599
SMEs 30,253 38,693 54,279 68,279
Large companies 507 687 1,018 1,320
Additional number of companies that need
calculation tools in PM12
21,595 39,358 23,441 9,139
SMEs 21,003 38,224 22,638 8,638
Large companies 592 1,134 803 501
Total costs relative to the baseline (in million EUR) 6.7 12.3 6.2 1.4
SMEs 4.8 8.9 4.0 0.1
Large companies 1.8 3.4 2.3 1.3
Source: Ecorys and CE Delft (2023), Impact assessment support study.
Table 77: type and size of impacted enterprises due to PM12 in PO4 of all enterprises targeted with CountEmissions
EU
2025 2030 2040 2050
Number companies using calculation tools 3.0% 4.4% 4.4% 4.4%
SMEs 2.9% 4.4% 4.4% 4.4%
Large companies 19.2% 31.7% 31.7% 31.7%
Source: Ecorys and CE Delft (2023), Impact assessment support study.
Table 78: Recurrent adjustment costs for business due to PM12 in PO5 (in million EUR)
2025 2030 2040 2050
Number of companies that use calculation tools in
the baseline
30,760 39,380 55,297 69,599
SMEs 30,253 38,693 54,279 68,279
Large companies 507 687 1,018 1,320
Additional number of companies that need
calculation tools in PM12
12,202 25,102 9,278 2,783
SMEs 11,629 24,006 8,513 2,320
Large companies 573 1,096 765 463
Total costs relative to the baseline (in million EUR) 19.3 31.6 24.4 21.5
122
2025 2030 2040 2050
SMEs 14.7 23.6 17.8 16.1
Large companies 4.6 8.0 6.6 5.4
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 79: type and size of impacted enterprises due to PM12 in PO5 of all enterprises targeted with CountEmissions
EU
2025 2030 2040 2050
Number companies using calculation tools 2.4% 3.6% 3.6% 4.1%
SMEs 2.4% 3.5% 3.6% 4.0%
Large companies 18.8% 31.1% 31.1% 31.1%
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 80: Recurrent adjustment costs for business due to PM12 in PO6 (in million EUR)
2025 2030 2040 2050
Number of companies that use calculation tools in the baseline 30,760 39,380 55,297 69,599
SMEs 30,253 38,693 54,279 68,279
Large companies 507 687 1,018 1,320
Additional number of companies that need calculation tools in
PM12
110,570 918,003 1,718,143 1,703,841
SMEs 109,689 915,130 1,713,423 1,699,423
Large companies 881 2,873 4,720 4,418
Total costs relative to the baseline (in million EUR) 32.5 257.7 451.5 417.3
SMEs 29.8 249.4 438.7 406.1
Large companies 2.7 8.3 12.8 11.1
Source: Ecorys and CE Delft (2023), Impact assessment support study
Table 81: type and size of impacted enterprises due to PM12 in PO6 of all enterprises targeted with CountEmissions
EU
2025 2030 2040 2050
Number companies using calculation tools 8.0% 54.0% 100.0% 100.0%
SMEs 7.9% 54.0% 100.0% 100.0%
Large companies 24.2% 62.0% 100.0% 100.0%
Source: Ecorys and CE Delft (2023), Impact assessment support study
Administrative costs for businesses (calculation tool developers)
As explained, PM12 (included in PO3, PO4, PO5 and PO6) foresees that the development of
calculation tools following the common reference methodology is left to the market but certified at EU
level. A maximum of 34 tools are expected to be certified in addition to the baseline. The cost per tool
for certification, per year, is estimated at EUR 531.65, assuming 13 hours of work per certification at
an average cost per hour estimated at EUR 40.9226
in 2022 prices for ISCO 2 category (Professionals).
Thus,therecurrent administrativecostsforbusinesses areestimatedatEUR 18,076from 2025onwards
relative to the baseline. Expressed as present value over 2025-2050, the total administrative costs are
estimated at EUR 332,840 relative to the baseline.
226
Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour
123
PM13: Mandatory application of CountEmissions EU in the transport sector
PM13 (included in PO1 and PO6) mandates the GHG emissions accounting for transport services
to all businesses in EU27, following a transition period until 2035. The accounting is done
through CountEmissions EU. This measure does not have a direct impact on costs but its indirect
impact on total costs, through the higher number of business that will perform GHG emissions
accounting relative to the baseline, is accounted in the costs of other measures.
PM14: Binding opt-in application of CountEmissions EU in the transport sector
PM14 (included in PO3, PO4 and PO5) leaves the GHG emissions accounting for transport
services voluntary, but it mandates the use of CountEmsissions EU in case GHG emissions are
accounted. This measure does not have a direct impact on costs but its indirect impact on total
costs, through the higher number of business that will perform GHG emissions accounting
relative to the baseline, is accounted in the costs of other measures.
PM15: Voluntary application of CountEmissions EU in the transport sector with a label
PM15 (included in PO2) keeps the GHG emissions accounting for transport services voluntary,
and it does not mandate the use of CountEmsissions EU in case GHG emissions are accounted.
This measure does not have a direct impact on costs but its indirect impact on total costs, through
the higher number of business that will perform GHG emissions accounting relative to the
baseline, is accounted in the costs of other measures.
4. Environmental impacts
CountEmissions EU is expected to contribute to the reduction of GHG emissions from the transport
and logistics sector in two ways. First, the implementation of a harmonised framework for GHG
emissions accounting will provide more transparency with respect to the emissions of different
transport services and thus induce behavioural changes in the transport sector (mode change), which in
turn result in lower GHG emissions227
. Second, CountEmissions EU is also expected to indirectly
contribute to GHG emissions savings, by providing harmonised GHG emission data for transport
services that can be used byother (public and private) initiatives (e.g. in green financing or green public
procurement), effectively contributing to lower GHG emissions and air pollutant emissions in the EU
through improved transport efficiency. While the first set of direct impacts can be estimated, those
triggered by the development of new programs using CountEmissions EU as their tool cannot be
quantified, but are probably much larger than direct savings.
The empirical evidence on the effects between the GHG emissions accounting, changes in
transport activity and the related reduction in the GHG emissions and air pollutants is scarce.
Therefore, a number of assumptions and projections are based on the literature, case studies and
use cases (including those presented in Annex 12), and the feedback from stakeholders’
consultation (summarised in Annex 2).
Given the specific characteristics of the initiative, conceived rather as an enabler and tool for further
measures reducing emissions and improving efficiency of transport services, the path of behavioural
changes resulting from the application of various policy measures was key to identify impacts. This
227
Lewis, A., Dober, K., Ehler, V. et Al., LEARN Project inception Report, 2017.
124
path of behavioural changes is illustrated in Error! Reference source not found. below.
Figure 11: Overview of potential behavioural changes - the supply and demand side of the transport market
Source : Ecorys and CE Delft (2023), Impact assessment support study
Various policy measures and options may affect the transport choices made both on the supply and the
demand side. On the supply side, the information on GHG emissions per transport service (when
compared to similar figures from competitors) may incentivise transport operators to improve their
transport efficiency (e.g. by increasing loading rates, further optimising of routing, shifting to greener
transport solutions, etc.) and fuel efficiency (e.g., by using more fuel efficient vehicles/vessels or
applying a fuel efficient driving style). These behavioural changes may result in a lower transport
demand (in terms of kilometres) or lower GHG intensity per tonne-km and passenger-km. On the
demand side, shippers and passengers are incentivised to take up more sustainable options, either by
choosing more sustainable operators within a mode or by shifting to another mode of transport. The
behavioural changes may also give rise to modal shift impacts as well as lower GHG intensity per
tonne-km and passenger-km. While research on the transport choice behaviour suggest that in many
cases presentingemissions figures to interested individuals might bemore useful to generate awareness
than to produce changes in behaviour, there is evidence that emissions information does improve pro-
environmental behaviour among environmentally aware people and can indeed influence vehicle
purchase choice, mode choice, and route choice.228
228
Brazil, William et al. "An Examination Of The Role Of Emissions Information In Transport Behaviour: The
Results Of A Smart Phone Trial In Dublin, Ireland". Trid.Trb.Org, 2017, https://trid.trb.org/view/1437202.
Accessed 13 Jan 2023, and Silva, João de Abreu e et al. "The Influence Of Information-Based Transport Demand
125
These findings may be evidenced by the results of the relevant EU initiatives and projects
focused on calculation and reporting of emissions, and other sources that are useful in
understanding the effects of the behavioural change (such as Lean and Green, and the US Smart
Way programme mentioned above). A 2021 analysis of a survey amongst 800 European
carriers229
provides an insight into the European road freight SME carriers segment, being the
largest target stakeholder group of this initiative. This analysis shows that calculating GHG
emissions is the first step on a company’s path towards decarbonisation, because it is the
necessary precursor to the setting of meaningful emission reduction targets and monitoring
progress towards achieving them. Additional benefit of monitoring and managing GHG
emissions is therefore correlated with energy savings and lower fuel costs, which improve the
operational efficiency. Furthermore, as large buyers of freight services are now declaring such
targets and applying them to their Scope 3 emissions calculations (which include emissions from
road carriers working on their behalf), carriers will need to have the capability to provide
individual clients with relevant GHG emissions data. It is thus clearly beneficial that one
common calculation standard is adopted by all players in the industry and across the transport
chain to achieve harmonisation and comparability.
The analysis of direct environmental impacts covers GHG emissions, air pollutant emissions and
avoided fuel use. The environmental impacts were quantified with the help of an Excel-based tool
developed by Ecorys and CE Delft.
The main data source, for the levels of transport activity, GHG emissions and air pollutant emissions
from transport, is PRIMES-TREMOVE. The source of the uptakes for GHG emissions accounting at
service level is based on elaborations by CE Delft and Ecorys at NACE-sector level, as explained in
section 1 of Annex 4. Evidence was also based on the case studies summarised in Annex 11.
The model is based on two level assumptions. For the first level assumptions the shares of passengers
and transport service providers making sustainable transport choices are assumed on the basis of the
literature review and stakeholder consultations. The share of climate aware population230
over time
(2025-2050) is based on literature review231
and cross-checked with the feedbacks received during the
stakeholder consultations. These assumptions are instrumental to identify the shares of the activity that
is impacted by CountEmissions EU.
Management Measures On Commuting Mode Choice. Comparing Web Vs. Face-Toface Surveys". Transportation
Research Procedia, vol 32, 2018, pp. 363-373. Elsevier BV, doi:10.1016/j.trpro.2018.10.066. Accessed 17 Jan 2023.
229
Tölke, M. and McKinnon, A. (2021), Op.cit.
230
New Eurobarometer Survey: Protecting the environment and climate is important for over 90% of European
citizens (3 March 2020)
231
Yang, Morgan et al. "An Institutional Perspective On Consumers' Environmental Awareness And Pro‐
Environmental Behavioral Intention: Evidence From 39 Countries". Business Strategy And The Environment, vol
30, no. 1, 2021, pp. 566-575., https://ideas.repec.org/a/bla/bstrat/v30y2021i1p566-575.html. Accessed 16 Jan 2023.
Daziano, R. et al. "Reframing Greenhouse Gas Emissions Information Presentation On The Environmental
Protection Agency’S New-Vehicle Labels To Increase Willingness To Pay". Journal Of Cleaner Production, vol
279, 2021, p. 123669. Elsevier BV, doi:10.1016/j.jclepro.2020.123669. Accessed 17 Jan 2023. Daziano, Ricardo
A. et al. "Increasing The Influence Of CO2 Emissions Information On Car Purchase". Journal Of Cleaner
Production, vol 164, 2017, pp. 861-871. Elsevier BV, doi:10.1016/j.jclepro.2017.07.001. Accessed 17 Jan 2023.
126
On the basis of this information, Table 82 the assumptions232
used for the period 2025-2050 are shown
in the table below. No evidence was identified for using differentiated assumptions over the period.
Table 82: First level assumption values used for identifying the shares of activity for direct environmental impacts
Population Shares over period 2025-2050
Passengers making sustainable choices among the climate aware populations 14%
Climate aware population over time 91%
Source : Ecorys and CE Delft (2023), Impact assessment support study
These values are used as proxyto identifythe potential behavioural changes affectingthe potential shift
towards more sustainable transport modes, but also a potential reduction in activity due to changes in
travelling habits.
The second level assumptions233
are those related to the mode choices impacting the shift of activity
between modes234
and optimisation of trips. The values in Table 83 (passengers transport) and Table
84 (freight transport) arebasedon theliterature235
,relevant casestudies and use cases, andthe feedback
from stakeholders’ consultation. They were also validated through a Peer Review236
.
These values show the share of potential transport activity subject to shifting across modes and
optimisation of trips due to GHG emissions accounting. They are used as proxies for the shift between
modes and optimisation of trips.
Table 83: Second level assumption matrix for the share of potential passenger transport activity subject to shifting across modes
and optimisation of trips due to GHG emissions accounting
Input mode (-) Output mode (+)
Buses
and
coaches
Passe
nger
cars
and
vans P2W Rail
Domestic
and
Internati
onal
intra-EU
(air)
Internation
al extra-
EU (air)
IWW and
domestic
maritime
Intra-
EU
mariti
me
transp
ort
Road transport
Buses and coaches 0% 0% 0% 5% 0% 0% 0% 0%
Passenger cars and
vans (taxis)
0% 0% 0% 2% 0% 0% 0% 0%
P2W 1% 0% 0% 0% 0% 0% 0% 0%
Rail 0% 0% 0% 0% 0% 0% 0% 0%
Air transport
232
Feedbacks from stakeholder consultation and literature review does not provide further evidence for a modal
shift in excess of 10% because of the harmonisation of GHG emissions methodology. Therefore, applying a
conservative approach, the modal shift has been capped at 10%.
233
CE Delft et al. (2023), Impact assessment support study
234
McKinnon, A.C. (2023). Preparing Logistics for the Low-Carbon Economy. In: Merkert, R., Hoberg, K. (eds)
Global Logistics and Supply Chain Strategies for the 2020s. Springer, Cham. https://doi.org/10.1007/978-3-030-
95764-3_6
235
Maja I. Piecyk, Alan C. McKinnon, Forecasting the carbon footprint of road freight transport in 2020,
International Journal of Production Economics, Volume 128, Issue 1, 2010, Pages 31-42, ISSN 0925-5273,
https://doi.org/10.1016/j.ijpe.2009.08.027.
236
CE Delft et al. (2023), Impact assessment support study. Prof. Alan McKinnon (Kuhne University).
127
Domestic and
International intra-EU
0% 0% 0% 50% 0% 0% 0% 0%
International extra-EU 0% 0% 0% 40% 0% 0% 0% 0%
Inland waterway and
domestic maritime
0% 0% 0% 0% 0% 0% 0% 0%
Intra-EU maritime
transport
0% 0% 0% 0% 0% 0% 0% 0%
Source : Ecorys and CE Delft (2023), Impact assessment support study
Table 84: second level assumption matrix for the share of potential freight transport activity subject to shifting across modes
and optimisation of trips due to GHG emissions accounting
Input mode (-) Output mode (+)
Road
freight
transport Rail
IWW and
domestic
maritime
International
maritime
activity
Road transport 0% 40% 0% 0%
Rail 0% 0% 0% 0%
Inland waterway and domestic maritime 0% 10% 0% 0%
International maritime activity 0% 0% 0% 0%
Source : Ecorys and CE Delft (2023), Impact assessment support study
The proxies above together with the difference between the uptake of GHG emissions accounting in
the different POs and the uptake in the baseline are used to derive the changes in transport activity in
each policy option relative to the baseline (see Table 85). In the following step, energy intensity and
emission intensity factors from PRIMES-TREMOVE are used to calculate the changes in emissions
and fuel used.
More specifically, the energy use by policy option is derived based on the transport activity by
transport mode corresponding to each option and the projected energy intensity per transport
mode from the baseline scenario. The energy intensity is expressed in ton of oil equivalent (toe)
per tonne-kilometre and takes into account all energy forms, including green electricity and
hydrogen. The energy savings are computed by taking the difference between the energy use in
the policy options and the baseline. Finally, projected average fuel costs in EUR per toe for each
transport mode from the baseline scenario is used to monetise the energy savings. The average
fuel costs takes into account all the energy forms used by transport mode, including green
electricity and hydrogen. It needs to be clarified that the baseline scenario of this initiative
includes significant reductions in the energy intensity of all modes over time. This is because it
reflects the ‘Fit for 55’ and the REPowerEU packages. Yet, the rail transport shows significantly
lower energy intensity per tonne-kilometres than other modes, as also the case today.
Similarly to the energy use, the GHG emissions by policy option is derived based on the transport
activity by transport mode corresponding to each option and the projected emissions intensity
per transport mode from the baseline scenario. The GHG emissions savings are computed by
taking the difference between the energy use in the policy options and the baseline.
Table 85: Changes in transport activity due to CountEmissions EU relative to the baseline (% change relative to the baseline)
2025 2030 2040 2050
PO1
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2025 2030 2040 2050
Total passenger transport activity (Gpkm) 0.0% 0.0% -0.1% -0.1%
Road transport 0.0% 0.0% 0.0% 0.0%
Buses and coaches 0.0% 0.0% -0.1% -0.1%
Passenger cars and vans 0.0% 0.0% 0.0% 0.0%
P2W 0.0% 0.0% 0.0% 0.0%
Rail 0.1% 0.5% 0.8% 0.8%
Air transport 0.0% -0.3% -0.5% -0.5%
Domestic and International intra-EU 0.0% -0.3% -0.6% -0.6%
International extra-EU 0.0% -0.3% -0.5% -0.5%
Inland waterway and domestic maritime 0.0% 0.0% 0.0% 0.0%
Intra-EU maritime transport 0.0% 0.0% 0.0% 0.0%
Total freight transport activity (Gtkm) 0.0% 0.0% 0.0% 0.0%
Road transport 0.0% -0.3% -0.5% -0.5%
Rail 0.1% 0.4% 0.7% 0.7%
Inland waterway and domestic maritime 0.0% 0.0% 0.0% 0.0%
International maritime activity 0.0% 0.0% 0.0% 0.0%
2025 2030 2040 2050
PO2
Total passenger transport activity (Gpkm) 0.0% 0.0% 0.0% 0.0%
Road transport 0.0% 0.0% 0.0% 0.0%
Buses and coaches 0.0% 0.0% 0.0% 0.0%
Passenger cars and vans 0.0% 0.0% 0.0% 0.0%
P2W 0.0% 0.0% 0.0% 0.0%
Rail 0.1% 0.2% 0.1% 0.0%
Air transport -0.1% -0.1% 0.0% 0.0%
Domestic and International intra-EU -0.1% -0.1% -0.1% 0.0%
International extra-EU 0.0% -0.1% 0.0% 0.0%
Inland waterway and domestic maritime 0.0% 0.0% 0.0% 0.0%
Intra-EU maritime transport 0.0% 0.0% 0.0% 0.0%
Total freight transport activity (Gtkm) 0.0% 0.0% 0.0% 0.0%
Road transport 0.0% -0.1% 0.0% 0.0%
Rail 0.1% 0.1% 0.1% 0.0%
Inland waterway and domestic maritime 0.0% 0.0% 0.0% 0.0%
International maritime activity 0.0% 0.0% 0.0% 0.0%
2025 2030 2040 2050
PO3
Total passenger transport activity (Gpkm) 0.0% 0.0% 0.0% 0.0%
Road transport 0.0% 0.0% 0.0% 0.0%
Buses and coaches 0.0% 0.0% 0.0% 0.0%
Passenger cars and vans 0.0% 0.0% 0.0% 0.0%
P2W 0.0% 0.0% 0.0% 0.0%
Rail 0.0% 0.1% 0.0% 0.0%
Air transport 0.0% -0.1% 0.0% 0.0%
Domestic and International intra-EU 0.0% -0.1% 0.0% 0.0%
International extra-EU 0.0% -0.1% 0.0% 0.0%
Inland waterway and domestic maritime 0.0% 0.0% 0.0% 0.0%
Intra-EU maritime transport 0.0% 0.0% 0.0% 0.0%
Total freight transport activity (Gtkm) 0.0% 0.0% 0.0% 0.0%
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2025 2030 2040 2050
Road transport 0.0% -0.1% 0.0% 0.0%
Rail 0.0% 0.1% 0.0% 0.0%
Inland waterway and domestic maritime 0.0% 0.0% 0.0% 0.0%
International maritime activity 0.0% 0.0% 0.0% 0.0%
2025 2030 2040 2050
PO4
Total passenger transport activity (Gpkm) 0.0% 0.0% 0.0% 0.0%
Road transport 0.0% 0.0% 0.0% 0.0%
Buses and coaches 0.0% 0.0% 0.0% 0.0%
Passenger cars and vans 0.0% 0.0% 0.0% 0.0%
P2W 0.0% 0.0% 0.0% 0.0%
Rail 0.1% 0.2% 0.1% 0.1%
Air transport -0.1% -0.1% -0.1% 0.0%
Domestic and International intra-EU -0.1% -0.2% -0.1% 0.0%
International extra-EU -0.1% -0.1% -0.1% 0.0%
Inland waterway and domestic maritime 0.0% 0.0% 0.0% 0.0%
Intra-EU maritime transport 0.0% 0.0% 0.0% 0.0%
Total freight transport activity (Gtkm) 0.0% 0.0% 0.0% 0.0%
Road transport -0.1% -0.1% -0.1% 0.0%
Rail 0.1% 0.2% 0.1% 0.0%
Inland waterway and domestic maritime 0.0% 0.0% 0.0% 0.0%
International maritime activity 0.0% 0.0% 0.0% 0.0%
2025 2030 2040 2050
PO5
Total passenger transport activity (Gpkm) 0.0% 0.0% 0.0% 0.0%
Road transport 0.0% 0.0% 0.0% 0.0%
Buses and coaches 0.0% 0.0% 0.0% 0.0%
Passenger cars and vans 0.0% 0.0% 0.0% 0.0%
P2W 0.0% 0.0% 0.0% 0.0%
Rail 0.0% 0.1% 0.0% 0.0%
Air transport 0.0% -0.1% 0.0% 0.0%
Domestic and International intra-EU 0.0% -0.1% 0.0% 0.0%
International extra-EU 0.0% -0.1% 0.0% 0.0%
Inland waterway and domestic maritime 0.0% 0.0% 0.0% 0.0%
Intra-EU maritime transport 0.0% 0.0% 0.0% 0.0%
Total freight transport activity (Gtkm) 0.0% 0.0% 0.0% 0.0%
Road transport 0.0% -0.1% 0.0% 0.0%
Rail 0.0% 0.1% 0.0% 0.0%
Inland waterway and domestic maritime 0.0% 0.0% 0.0% 0.0%
International maritime activity 0.0% 0.0% 0.0% 0.0%
2025 2030 2040 2050
PO6
Total passenger transport activity (Gpkm) 0.0% 0.0% -0.1% -0.1%
Road transport 0.0% 0.0% 0.0% 0.0%
Buses and coaches 0.0% 0.0% -0.1% -0.1%
Passenger cars and vans 0.0% 0.0% 0.0% 0.0%
P2W 0.0% 0.0% 0.0% 0.0%
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2025 2030 2040 2050
Rail 0.1% 0.5% 0.8% 0.8%
Air transport 0.0% -0.3% -0.5% -0.5%
Domestic and International intra-EU 0.0% -0.3% -0.6% -0.6%
International extra-EU 0.0% -0.3% -0.5% -0.5%
Inland waterway and domestic maritime 0.0% 0.0% 0.0% 0.0%
Intra-EU maritime transport 0.0% 0.0% 0.0% 0.0%
Total freight transport activity (Gtkm) 0.0% 0.0% 0.0% 0.0%
Road transport 0.0% -0.3% -0.5% -0.5%
Rail 0.1% 0.4% 0.7% 0.7%
Inland waterway and domestic maritime 0.0% 0.0% 0.0% 0.0%
International maritime activity 0.0% 0.0% 0.0% 0.0%
Source : Ecorys and CE Delft (2023), Impact assessment support study
5. Sensitivity analysis
The sensitivity analysis builds on the following scenarios:
 In the first case (-A), we assumed a decrease by 40% in the share of passengers making
sustainable choices among the climate aware population. Second level assumptions are
kept unchanged.
 In the second case (-B), we assumed a decrease by 30% in the shares of activity shifted
to more sustainable transport modes and optimisation of trips. First level assumptions are
kept unchanged.
The results of the sensitivity analysis presented below for all policy options show that while the
magnitude of the expected benefits may be somewhat lower, the ranking of the policy options
remains unchanged.
Table 86: First case (-A) - Summary of costs and benefits of the policy options – net present value for 2025-2050 compared to
the baseline (in million EUR), in 2022 prices
Difference to the Baseline
PO1-A PO2-A PO3-A PO4-A PO5-A PO6-A
National public authorities (including NABs)
Adjustment costs 0.1 0.1 0.1 0.1 0.1 0.1
Administrative costs 0.1 0.1 0.1 0.1 0.1 0.1
EEA
Adjustment costs 3.6 3.6 3.9 3.9 3.6 3.9
European Commission
Adjustment costs 2.7 0.3 2.4 0.0 5.3 0.0
Businesses
Adjustment costs 95,010.8 1,084.6 1,374.4 1,542 2,283.7 67,927.7
Administrative costs 0.0 0.0 0.5 0.5 0.3 0.5
Benefits
Avoided fuel used (operators and passengers) 8,290.3 1,268.4 574.6 1,932.7 504.4 8,290.3
Reduction in external costs of GHG emissions 2,303.1 356.3 160.0 539.3 139.9 2,303.1
Reduction in external costs of air pollution emissions 480.4 88.7 42.5 130.8 37.6 480.4
Reduction in external costs of accidents 2,208.4 339.5 153.8 516.2 134.9 2,208.4
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Total costs 95,017 1,089 1,381 1,547 2,293 67,932
Total benefits 13,282.3 2,052.9 930.8 3,119 816.8 13,282.3
Net benefits -81,735.0 964.1 -450.6 1,572.4 -1,476.3 -54,650.0
Benefits to costs ratio 0.1 1.9 0.7 2.0 0.4 0.2
Table 87: Second case (-B) - Summary of costs and benefits of the policy options – net present value for 2025-2050 compared
to the baseline (in million EUR), in 2022 prices
Difference to the Baseline
PO1-B PO2-B PO3-B PO4-B PO5-B PO6-B
National public authorities (including NABs)
Adjustment costs 0.1 0.1 0.1 0.1 0.1 0.1
Administrative costs 0.1 0.1 0.1 0.1 0.1 0.1
EEA
Adjustment costs 3.6 3.6 3.9 3.9 3.6 3.9
European Commission
Adjustment costs 2.7 0.3 2.4 0.0 5.3 0.0
Businesses
Adjustment costs 95,010.8 1,084.6 1,374.4 1,542 2,283.7 67,927.7
Administrative costs 0.0 0.0 0.5 0.5 0.3 0.5
Benefits
Avoided fuel used (operators and passengers) 7,561.3 1,154.2 522.5 1,759.3 458.6 7,561.3
Reduction in external costs of GHG emissions 2,028.7 315.3 141.8 476.8 124.0 2,028.7
Reduction in external costs of air pollution emissions 431.8 80.0 38.4 117.9 34.0 431.8
Reduction in external costs of accidents 1,934.7 297.4 134.7 452.2 118.2 1,934.7
Total costs 95,017 1,089 1,381 1,547 2,293 67,932
Total benefits 11,956.6 1,846.9 837.3 2,806 734.8 11,956.6
Net benefits -83,060.8 758.1 -544.1 1,259.7 -1,558.4
-
55,975.7
Benefits to costs ratio 0.1 1.7 0.6 1.8 0.3 0.2
6. Interest and motivations of main groups of stakeholders involved in transport
services activities
Specific interests of various stakeholders groups have been taken in due account while
constructing and assessing various policy options. These are elaborated in the table below.
Table 88: Main interest of different stakeholders with respect to the objectives of the initiative
Specific Objective Stakeholder groups Main interests
SO1: Ensure
comparability of results
from GHG emissions
accounting of transport
services
Transport service
organisers (operators)
- Clear methodological guidance, and clear rules on input
data establishing a level playing field on the market;
- Methodological (regulatory) predictability;
- Support for the business decision making;
- Support for marketing of green transport services;
- Support for corporate sustainability strategies.
Transport service users - Comparability of emissions data of various transport
services, to make informed transport choices;
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- Methodological (regulatory) predictability (mostly for
companies);
- Support for business decision making (mostly for
companies);
- Support for the marketing of green transport services
(mostly for companies – transport intermediaries);
- Support for corporate sustainability strategies (mostly
for companies).
Other entities involved in
accounting GHG
emissions of transport
services (calculation tools
developers, business sector
associations, emissions
data intermediaries etc.)
- Stable and clear GHG emissions accounting rules for
designing tools;
- Stable environment for providing GHG emissions
accounting services
SO2: Facilitate the
uptake of GHG
emissions accounting
of transport services in
business practice
Transport service
organisers (operators)
- Decrease in costs of calculations over time;
- Complete, accurate and trustful information on
emissions from various transport services as an input to
the business decision making;
- Clear rules on commercially sensitive data;
- Corporate strategies
Transport service users - Better clarity and transparency on the available transport
services due to the increase of quantity of data;
- Trust in the available GHG emission figures.
Other entities involved in
accounting GHG
emissions of transport
services (calculation tools
developers, business sector
associations, emissions
data intermediaries etc.)
- Increased demand for the use of the calculation tools;
- Clear rules on commercially sensitive data
The stakeholders’ consultation provided useful insights on different motivations to apply GHG
emissions accounting, especially by transport service organisers (operators). The respondents to
the survey indicated that “environmental awareness” is the most important motivation to account
for emissions (see Annex 2). This motivation is supported by the evidence from the literature as
reported in section 2.2 of the main report when explaining PD 4 and PD 5. The evidence points
to the existence of corporate sustainability programmes, which often translate into sets of
sustainability performance and improvements targets for operators and users alike, driven by
corporate strategies and values, as for example the management’s belief in the company’s
environmental responsibility and the company's value system displayed towards customers and
third parties.
There may also be various commercial reasons for applying GHG emissions accounting. The
need to address requirements from customers, users or passengers is, according to the
respondents to the stakeholder survey, another important motivation for applying GHG
emissions accounting. In some cases, it is related to contractual aspects when information on
GHG emissions of transport activities is e.g. part of tendering requirements. Three interviewed
transport associations and one transport management system supplier mentioned a third
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commercial reason to account emissions for transport operators: to optimise one’s own
operational efficiency. For example, detailed insight in GHG emissions can be used to optimise
fuel use. Particularly large transport operators are expected to use the results of GHG emissions
calculations for that purpose, while smaller transport operators are often not able to apply the
sufficiently detailed GHG emission calculations (based on primary data) that would allow for
operational optimisation. Finally, companies may also apply GHG emissions accounting to
comply with (future) policies. These considerations are already reflected in Annex 2 and the IA
Support Study.
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ANNEX 5: COMPETITIVENESS CHECK
OVERVIEW OF IMPACTS ON COMPETITIVENESS
Dimensions of
Competitiveness
Impact of the
initiative
(+ +/+/0/-/- -/n.a.)
References to sub-sections of the
main report or annexes
Cost and price
competitiveness
+ Section 6.1.5 of the SWD
International
competitiveness
+ Section 6.1.5 of the SWD
Capacity to innovate ++
Annex 4, 7 and section 6.1.5 of the
SWD
SME competitiveness + Section 6.1.7 of the SWD and Annex 10
SYNTHETIC ASSESSMENT
Cost and price competitiveness
The preferred Policy Option 4 (PO4) establishes the binding opt-in application of the initiative
on the EU market, requiring the use of the CountEmissions EU framework only by those entities
that decide or are mandated to account GHG emissions of transport services. This approach will
streamline the emissions quantification process, and provide businesses with clear guidance,
supporting the forefront position of the EU on zero emissions vehicles, high-speed rail and
intelligent transport systems, without excessive pressure on costs.
Given the increased uptake of the framework from the implementation year (2025) onwards, this
choice will lead to adjustment costs for the businesses involved (see Annex 3), mostly associated
with the necessary adaptations or establishment of the internal processes and systems. The
adjustment costs will therefore include labour, IT and external services costs, the latter related
with the use of specific technical tools and expertise. For large entities, these expenses will also
be topped up with the mandatory verification of data and processes. These costs are expected to
decrease gradually over time, given the regulatory and methodological clarity provided by the
common framework, as well as the availability of specific facilitating measures, namely the
implementation guidelines and technical support tools. Furthermore, as shown in Section 6 and
Annex 4, the implementation of the initiative will lead to direct and indirect benefits for
economic operators, resulting from better transparency on the performance of transport
operations. These benefits will translate into energy savings, increased efficiency of transport
activities, improved reputational image of businesses and overall societal costs decrease.
Therefore, the overall impact on this dimension is considered positive.
International competitiveness
The regulatory and methodological clarity provided by the harmonised framework, and related
benefits stemming from its use, are expected to improve the competitive position of EU
companies on the international market. In principle, the framework will accelerate the
deployment of low and zero emissions transport options, and contribute to increasing the market
135
share of alternative fuels in the EU. Furthermore, by establishing the global ISO 14083 standard
as the common reference methodology, PO 4 will enable EU entities to calculate emissions
beyond the internal EU transport chains only, and provide an opportunity for a global
methodological alignment, depending on the adherence to the ISO standard by third countries.
This effect would have positive impact on the international cooperation, and additional benefits
resulting from increased efficiency and emissions reduction. No other direct impacts on
international competitiveness can be foreseen.
Capacity to innovate
The deployment of CountEmissions EU will lead to more sustainable and efficient transport
decisions by final users, thus stimulating the innovation (including process innovation) and faster
technology uptake by transport service organisers (especially operators). What is more, the
increased sharing of transport emissions data will trigger further efforts of companies towards
digital solutions, which may be particularly relevant for SMEs, and specifically microenterprises.
Therefore, this assessment leads to a high score for ‘Capacity to innovate’ dimension.
SME competitiveness
Given that SMEs represent a substantial part of the transport market (especially road), the
assessment on the overall cost and price competitiveness aspect as provided above, is applicable
also for this dimension to a large extent . It should be noted that SMEs in general have lower
capacity (resources) to bear additional requirements, which may result in a relatively higher
proportion of the adjustment costs compared to their overall cost structure. However, PO4 has
been designed to minimise negative impacts on SMEs, including the exemption of SMEs from
the mandatory verification of GHG data and processes, the provision of implementation
guidelines and certified technical support tools, as well as the establishment of a harmonised
framework for the input data.
CountEmissions EU will therefore contribute to the establishment of the level playing field on
the transport market, thus improving the position of SMEs, and at the same time enabling the
surfacing of sustainable solutions concerning last mile, door-to-door mobility and logistics. This
eventually results in a positive score for this competitiveness check dimension.
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ANNEX 6: DISCARDED POLICY MEASURES
During the Impact Assessment process, a number of possible policy measures have been discarded, based on the analytical work and feedback from the
stakeholders. This annex provides more detailed information on these measures and reasons for their discarding.
Policy measure Relevant
Driver
Short description Reason for discarding
EU develops an entirely new reference
methodology for accounting emissions
from transport services
PD1 A completely, new, tailor-made reference
methodology including all relevant design
alternatives and the necessary level of detail in
terms of the scope and method of the emission
calculation, as well as the allocation of emissions
to transport services.
More details are provided in Annex 8.
Discarded due to the lack of proportionality.
The analysis demonstrated limited added value for the achievement
of the policy objectives, given the existence of other robust and
widely accepted methods and initiatives for emissions accounting.
This policy measure was not supported by the stakeholders due to:
 the legacy methods for accounting emissions from
transport services (such as ISO 14083 or CEN EN 16258
standards),
 the uncertainty concerning the technical process related to
the development and implementation of the methodology
at the EU level.
EU establishes the CEN standard EN 16258
as the common reference methodology for
PD1 The CEN standard EN 16258 was published in
2012, and until February 2023, it was the only
initiative offering specific emissions accounting
methodology on the calculation and declaration of
Discarded due to the lack of relevance.
CEN standard EN 16258 does not reflect the latest scientific
knowledge related to the quantification of GHG emissions from
137
Policy measure Relevant
Driver
Short description Reason for discarding
accounting emissions from transport
services
energy consumption and GHG emissions related to
transport services. The methodology is in wider
use on the EU transport market.
More details are provided in Annex 8.
transport services and leaves considerable room for users to make
their own methodological choices.
In February 2023, based on specific arrangements between CEN
and ISO, EN 16258 was withdrawn and substituted by the new ISO
standard 14083.
EU establishes the common reference
methodology for accounting emissions
from transport services based on Article L.
1431-3 of the French Transport Code
PD1 Article L. 1431-3 of the French Transport Code
establishes provisions and a methodology for
specific information disclosure, mandating
transport service providers to inform users of their
carbon dioxide emissions while performing
respective transport services. The disclosure
requirement became mandatory in 2013.
More details are provided in Annex 8
Discarded due to the lack of relevance.
Article L. 1431-3 of the French Transport Code was designed for
use only in France; therefore, this methodology does not meet the
expectations of stakeholders, preferring a global geographical scope
of the GHG emissions accounting.
In addition, building on the CEN standard EN 16258, this method
will become redundant following the adoption of the new ISO
14083 methodology.
EU establishes the general framework of
the Product Environmental Footprint (PEF)
as the common reference methodology for
accounting emissions from transport
services
PD1 The Product Environmental Footprint framework
was developed by the European Commission (EC)
in the context of the Single Market for Green
Products Initiative. PEF provides a horizontal and
cross-sectoral method for the measurement of the
environmental performance of a good or service
throughout its full life cycle.
More details are provided in Annex 8
Discarded due to the lack of relevance.
The general PEF framework does not cover emissions generated at
the level of transport services, thus preventing the provision of
sufficient and adequate guidance for potential users performing
activities related to transporting cargo or/and passengers. This
method is not specifically recognised nor used in the business
practice in the transport sector.
138
Policy measure Relevant
Driver
Short description Reason for discarding
EU establishes the Corporate Value Chain
Standard of the GHG Protocol as the
common reference methodology for
accounting emissions from transport
services
PD1 The GHG Protocol Corporate Accounting and
Reporting Standard of 2001 was a pioneering
initiative establishing global standardised
frameworks to measure and manage GHG
emissions from private and public sector
operations. The GHG Protocol enables to account
indirect emissions from value chain activities,
including from transport and logistics.
More details are provided in Annex 8
Discarded due to the lack of relevance.
Although highly valuable for accounting GHG emissions of
companies, this methodology is less complete and accurate for
addressing emissions stemming from the specific transport service
level. Therefore, similarly as in the case of PEF, it does not provide
sufficient and adequate guidance for potential users performing
activities related to transporting cargo or/and passengers.
EU mandates the use of primary
information to economic operators and
other entities accounting emissions from
transport services
PD2 Primary information on the actual fuel/energy
consumed is required from economic operators and
other relevant entities quantifying GHG emissions
from transport services. The use of activity-based
default values, i.e. emission intensity factors and
modelled data is therefore not allowed.
Discarded due to the lack of proportionality.
The consultation activities and desk research identified limited
availability of primary information for certain categories of
stakeholders (especially operators representing SMEs and
microenterprises) and certain types of transport services (such as
last mile operations). Therefore, the mandatory requirements for the
exclusive use of primary information would create an excessive
and disproportionate burden on businesses and other entities
quantifying emissions of transport services.
EU provides recommendations for
harmonized formats of emissions output
data
PD3 The EC provides recommendations on the
harmonised format and metrics (unit of measures)
of any GHG data generated under the
CountEmissions EU framework. The measure
aims to facilitate the comparability and
benchmarking of this data for better transparency
on the market and informed decision making by
data users.
Discarded due to the lack of effectiveness.
The consultation activities and desk research identified that
companies or groups of companies operating in particular segments
of the transport sector very often use their own and specific data
formats. Therefore, the recommendation as a policy instrument
would not be effective enough to reach the full comparability of
various data shared in the transport chain.
139
Policy measure Relevant
Driver
Short description Reason for discarding
EU certifies specific sectorial
implementation guidelines provided by the
market
PD5 This measure establishes the mandatory
certification of specific sectorial implementation
guidelines developed by the market. These
guidelines may include issues related to the
interpretation of the common reference
methodology, formulas for the calculation
processes, best practices and default emission
factors. For some sectors, such guidelines already
exist (e.g. SCF & CEFIC (2021) for the chemical
sector).
Discarded due to the lack of proportionality.
The internal analysis demonstrated the separate certification
process for sectorial implementation guidelines would be
disproportionate and redundant. This conclusion was based on the
fact that the retained policy measures already ensure a high level of
methodological harmonisation, namely:
 common emissions quantification method,
 harmonised framework of input data (emission factors),
 rules on a harmonised format and metrics of the output
data,
 verification system for GHG emissions data and
calculation processes applied,
 certified technical calculation tools,
 horizontal guidelines for the harmonised implementation
of CountEmissions EU across various segments of the
transport sector.
EU provides specific implementation
guidelines for each segment of the transport
sector
PD5 The EU provides detailed implementation
guidelines for each relevant segment of the
transport sector. These guidelines include topics
related to the interpretation of the common
reference methodology, formulas for the
calculation processes, best practices and default
emission factors.
Discarded due to the lack of effectiveness.
This measure would be associated with substantial costs, efforts and
timescale thus leading to low efficiency and limited value added for
achieving the objectives of the initiative. Moreover, it would bear
the additional risk of misalignment of various sectorial approaches
due to the lack of specific sectorial expertise and insufficient
flexibility resulting from time-consuming procedures in the EU.
140
Policy measure Relevant
Driver
Short description Reason for discarding
EU allows for GHG emissions calculation
tools provided by the market (without
further conformity check)
PD5 The development and implementation of
calculation tools based on the CountEmissions EU
framework is left to the market.
Discarded due to the lack of effectiveness.
The proliferation of tools and the lack of control on their set-up and
design would not guarantee sufficient alignment and conformity of
these tools to CountEmissions EU, thus creating a risk of inaccurate
and incomparable emissions calculation output figures. This risk
may be particularly meaningful for SMEs that, due to the lack of in-
house resources, are expected to be the main users of emissions
calculation tools offered on the market.
141
ANNEX 7: RETAINED POLICY MEASURES
This annex provides a more detailed description of the retained policy measures and their links to the problem drivers, specific objectives and policy areas.
Driver Policy measure Short description
Link to the
specific
objective
Policy Area
PD1 PM1: ISO 14083 is set as
common reference methodology
at EU level
The EU establishes a common reference methodology for CountEmissions EU based on
the new ISO standard 14083 ‘Quantification and reporting of greenhouse gas emissions
arising from transport chain operations’ (adopted in February 2023). ISO 14083 in principle
addresses Well-to-Wheel GHG emissions, including emissions from the production of fuels.
It builds on the harmonisation efforts led by European stakeholders (including industry and
standardisation bodies), with the support of the EU-financed projects (COFRET, LEARN).
It is currently the only specific standard for accounting emissions from transport services
(replacing CEN EN 16258).
Detailed characteristics and assessment of ISO 14083 is presented in Annex 8.
The EU also establishes rules for the future updates and methodological adjustments of
the common reference methodology237
.
SO1 Methodological
framework
PD1 PM2: Product Environmental
Footprint Category Rules for
GHG emissions in transport,
including rules for transport
The EU establishes a common reference methodology for CountEmissions EU based on
the Product Environmental Footprint Category Rules for GHG emissions in transport,
including rules for transport services. Product Environmental Footprint (PEF) originally
developed by the European Commission in the context of Single Market for Green Products
SO1 Methodological
framework
237
These rules shall account for continuous development of the reference methodology, reflecting the scientific state of the art associated with the emissions accounting. Furthermore, the initiative shall
include a mechanism allowing for additional methodological adjustments in case the use of the common reference methodology risks to result in undue imbalances between transport segments, for instance
in the ex-ante perspective (before the service is provided).
142
Driver Policy measure Short description
Link to the
specific
objective
Policy Area
services, is set as common
reference methodology at EU
level
Initiative, provides a cross-sectoral method for the measurement of the environmental
performance of a good or service throughout its full life cycle. The general PEF framework
does not provide relevant guidance on the calculation of GHG emissions at the transport
service level, therefore the implementation of this method would require specific category
rules (i.e. set of calculation rules) to be developed for the transport sector. These category
rules shall be established by the EU through secondary legislation.
Detailed characteristics and assessment of PEFCR is presented in Annex 8.
The EU also establishes rules for the future updates and methodological adjustments of
the common reference methodology238
.
PD1 PM3: A common reference
methodology is set at EU level,
based on ISO 14083 but with
additional elements and
increased accuracy
The EU establishes a common reference methodology for CountEmissions EU building
on the ISO standard 14083 with additional methodological elements (for instance specific
allocation metrics, LCA for certain vehicle components related to the source of energy, etc.)
to ensure increased accuracy and comparability of the GHG emissions data.
The additional elements complementing the ISO 14083 framework shall be developed by the
EU through the secondary legislation
Detailed characteristics and assessment of the methodology based on upgraded ISO standard
14083 is presented in Annex 8.
SO1 Methodological
framework
238
Idem
143
Driver Policy measure Short description
Link to the
specific
objective
Policy Area
The EU also establishes rules for the future updates and methodological adjustments of
the common reference methodology239
.
PD2
PD3
PM4: The use of primary data is
recognised and centralised
databases for default values are
established at EU level (by
European Environment Agency).
Modelled data is used in
conformity with the reference
methodology
The EU recommends the use of primary information while accounting emissions, to
improve the accuracy and reliability of various GHG emissions output data. The use of
primary information is recognised in line with specific provisions referred to in PM8 and
PM9. In case the primary information is not available for an economic operator, the EU
allows the use of default values derived from a common database of GHG emission
intensity factors established at the central EU level.
The EU also establishes a database of GHG energy emission factors (in case of PO5 this
database will include LCA emission factors) and mandates its use for any calculations under
the CountEmissions EU framework. This database of emission factors shall include values
provided through relevant EU regulatory initiatives, including those forming part of the
upcoming Fit-for-55 package. Specific emission factors shall be developed in line with
relevant methods and provisions recognised by the EU.
The development and maintenance of the databases is executed by the European
Environmental Agency (EEA), supported by the HorizonEurope programme240
.
The use of modelled data is allowed insofar the modelling is conform to the selected
reference methodology and its possible adjustments in line with PM1, PM2 or PM3,
respectively.
SO1 Input data and
sources
239
Idem
240
HORIZON-CL5-2023-D6-01-08: Future-proof GHG and environmental emissions factors for accounting emissions from transport and logistics operations
144
Driver Policy measure Short description
Link to the
specific
objective
Policy Area
PD2
PD3
PM5: The use of primary data is
incentivised and centralised
databases for default values are
established at EU level. Quality
assurance of external databases
operated by third parties is
provided at EU level (by
European Environment Agency).
Modelled data is used in
conformity with the reference
methodology
The EU recommends the use of primary information while accounting emissions, to
improve the accuracy and reliability of various GHG emissions output data. The use of
primary information is recognised in line with specific provisions referred to in PM8 and
PM9. In case the primary information is not available for an economic operator, the EU
allows the use of default values from a core database of GHG emission intensity factors
established at the central EU level, and/or from other relevant databases operated by third
parties at the sectorial and national levels. The databases operated by third parties undergo a
quality check based on specific rules set up by the EU through the secondary legislation.
The EU also establishes a database of GHG energy emission factors and mandates its use
for any calculations under the CountEmissions EU framework. The database of energy
emission factors shall include values provided through relevant EU regulatory initiatives,
including those forming part of the upcoming Fit-for-55 package. Specific energy emission
factors shall be developed in line with relevant methods and provisions recognised by the
EU.
The development and maintenance of the EU-level databases is executed by the European
Environmental Agency (EEA), supported by the HorizonEurope programme241
. EEA also
performs the quality check of external databases operated by third parties.
The use of modelled data is allowed insofar the modelling is conform to the selected
reference methodology and its possible adjustments in line with PM1, PM2 or PM3,
respectively.
SO1 Input data and
sources
241
Ibidem
145
Driver Policy measure Short description
Link to the
specific
objective
Policy Area
PD1
PD3
PD4
PM6: Minimum requirements
for harmonised GHG output data
formats and metrics are provided
at EU level, together with
common rules on
communication and transparency
The EU provides minimum requirements for the harmonised formats and metrics of the
GHG emissions output data, to facilitate and simplify the sharing of these data along the
transport chain.
The EU sets up specific requirements for the communication and transparency with
respect to any claims related to the GHG emissions accounting of transport services, based
on CountEmissions EU242
.
SO1-SO2 Harmonised
emissions output
data and
transparency
PD3
PD4
PD5
PM7: Horizontal guidelines for
the harmonised implementation
of CountEmissions EU in
various sectors and segments of
the transport market are provided
at EU level
The EU provides horizontal guidelines for the harmonised implementation of
CountEmissions EU across sectors and segments of the transport market including:
 Data requirements and management;
 Emissions calculation guidance and best practices;
 Assurance and verification of the emissions data;
 Guidance on data sharing.
SO1-SO2 Sectoral
Implementation
Support
PD4 PM8: Mandatory process and
data verification for all entities
falling under the scope of
CountEmissions EU is
established at EU level
EU establishes a mandatory verification system for the conformity to CountEmissions EU
as regards the GHG emissions data generated from transport services and the processes
applied for their quantification.
SO2 Conformity
242
Including in conformity to the Unfair Commercial Practices Directive (UCPD)
146
Driver Policy measure Short description
Link to the
specific
objective
Policy Area
The verification applies to all economic operators that calculate and disclose GHG emissions
data from transport services. The economic operators are required to perform this verification
at least on annual basis.
The verification shall be based on specific conformity assessment rules established by the
EU243
through the secondary legislation, and shall be undertaken by a verifier accredited by
national accreditation bodies appointed by the Member States pursuant to Regulation (EC)
No 765/2008244
. The conformity assessment rules shall include provisions related to the
recognition of primary data referred to in PM4 and PM5.
The economic operators undergoing the verification of their GHG emissions data and the
calculation processes are entitled to obtain a certificate of conformity to CountEmissions
EU.
PD4 PM9: Mandatory process and
data verification for entities
above a certain size falling under
the scope of CountEmissions EU
is established at EU level
EU establishes a mandatory verification system for the conformity to CountEmissions EU
as regards the GHG emissions data generated from transport services and the processes
applied for their quantification.
The verification applies to all economic operators not falling under the definition of SME245
that calculate and disclose GHG emissions data from transport services. The economic
operators are required to perform this verification at least on annual basis.
SO2 Conformity
243
For instance taking an example of the rules on financial audits
244
This Regulation lays down rules on the organisation and operation of accreditation of conformity assessment bodies performing conformity assessment activities
245
Commission Recommendation 2003/361/EC of 6 May 2003 concerning the definition of micro, small and medium-sized enterprises (OJ L 124, 20.5.2003, p. 36).
147
Driver Policy measure Short description
Link to the
specific
objective
Policy Area
The verification shall be based on specific conformity assessment rules established by the
EU246
through the secondary legislation, and shall be undertaken by a verifier accredited by
national accreditation bodies appointed by the Member States pursuant to Regulation (EC)
No 765/2008. The conformity assessment rules shall include provisions related to the
recognition of primary data referred to in PM4 and PM5.
The economic operators undergoing the verification of their GHG emissions data and the
calculation processes are entitled to obtain a certificate of conformity to CountEmissions
EU.
The verification of conformity may be requested by third parties, including the EU and
Member States, especially in case an entity is reported not to follow CountEmissions EU.
PD4 PM10: Voluntary process and
data verification for all entities
are established at EU level
EU establishes a voluntary verification system for the conformity to CountEmissions EU
as regards the GHG emissions data generated from transport services and the processes
applied for their quantification..
The verification shall be based on specific conformity assessment rules established by the
EU247
though the secondary legislation, and shall be undertaken by a verifier accredited by
national accreditation bodies appointed by the Member States pursuant to Regulation (EC)
No 765/2008. The conformity assessment rules shall include provisions related to the
recognition of primary data referred to in PM4 and PM5.
SO2 Conformity
246
For instance taking an example of the rules on financial audits
247
Ibidem
148
Driver Policy measure Short description
Link to the
specific
objective
Policy Area
The economic operators undergoing the verification of their GHG emissions data and the
calculation processes are entitled to obtain a certificate of conformity to CountEmissions
EU.
The verification of conformity may be requested by third parties, including the EU and
Member States, especially in case an entity is reported not to follow CountEmissions EU.
PD5 PM11: Emissions calculation
tools are provided at EU level (by
the European Commission)
The EU develops and establishes GHG emissions calculation tools at the central EU level,
based on the common reference methodology and a set of default values for the input data.
These tools include a data sharing and exchange mechanism and may be used by any
economic operator and any other relevant entities for quantifying and disclosing GHG
emissions data from transport services. Security and privacy of the data is ensured by the
adherence to the confidentiality standards related to data sharing and exchange.
These tools shall be established based on the secondary legislation.
SO2 Complementary
measures
PD5 PM12: Emissions calculation
tools are provided by the market
but they are certified at EU level
The development and provision of GHG emissions calculation tools is left for the market.
The EU establishes a certification process for any commercial and non-profit tools offered
publicly for the wider use by the EU economic operators and other entities quantifying and
disclosing GHG emissions data from transport services. The EU sets up specific assessment
rules for the certification process through the secondary legislation, to ensure the
conformity of these tools with the CountEmissions EU framework. These rules include
provisions related the security and privacy of data, and the adherence to the confidentiality
standards related to data sharing and exchange. The certification shall be undertaken by a
body accredited by national accreditation bodies appointed by the Member States pursuant
to Regulation (EC) No 765/2008. The economic operators and other entities undergoing the
certification of their GHG emissions calculation tools are entitled to obtain a certificate of
conformity to CountEmissions EU.
SO2 Complementary
measures
149
Driver Policy measure Short description
Link to the
specific
objective
Policy Area
PD5 PM13: Mandatory application of
CountEmissions EU in the
transport sector
The EU mandates all economic operators and other entities organising and providing
transport services on the EU market to quantify GHG emissions from their services
based on the CountEmissions EU framework. A transition period until 2035 is foreseen, after
which all companies involved in transport services should account GHG emissions.
SO2 Applicability
PD5 PM14: Binding opt-in
application of CountEmissions
EU in the transport sector
The EU mandates the use of the CountEmissions EU framework to those economic
operators (including SMEs) and other entities that decide both to quantify and disclose
GHG emissions data from transport services offered and provided on the EU market.
SO2 Applicability
PD5 PM15: Voluntary opt-in
application of CountEmissions
EU in the transport sector with a
label
The EU recommends the use of the CountEmissions EU framework to the economic
operators (including SMEs) and other entities quantifying GHG emissions from their
transport services offered and provided on the EU market. In case an economic operator, or
another entity decides to account GHG emissions based on CountEmissions EU, it is obliged
to correctly apply the common framework. The application of CountEmissions EU is
recognised through a label to be established by the EU.
SO2 Applicability
150
ANNEX 8: ANALYSIS OF METHODOLOGICAL CHOICES FOR
COUNTEMISSIONS EU
The selection of a common reference methodology is one of the key policy areas for
CountEmissions EU. In principle, this choice shall ensure that the emissions calculations
performed across the entire transport sector provide uniform GHG emissions data,
according to a single set of methodological steps. In other words, the methodology needs
to offer a clear guidance on the scope of the emission calculation and provide for consistent
and unambiguous calculation rules. Preferably, it should also be proportionate and avoid
unnecessary complexity that would lead to excessive burden and costs for the market
players.
This annex shows the rationale behind the choice of appropriate methods for
CountEmissions EU. It is composed of three sections. The first section, “Methodological
elements” presents a list of specific technical components and their design alternatives
offered by various emissions accounting methods. The second one “Assessment and
ranking of the methodological elements” includes the analysis of appropriateness of these
components and alternatives in the context of CountEmissions EU. Finally, “Selection of
the reference methodology” provides insights from the evaluation of the emissions
accounting methods, and the selection (based on specific criteria) of those that best fit the
purpose of the initiative, and that should be considered while developing respective policy
measures and options.
The analyses are based on the Impact assessment support study.
7. METHODOLOGICAL ELEMENTS
Two main “clusters” of methodological elements and their design alternatives for the
analysed methods were identified in the context of the impact assessment:
 The scope of GHG emission calculation;
 The method of GHG emission calculation and allocation to transport services.
Table 89Error! Reference source not found. below shows these elements in more detail.
Table 89: Overview of specific methodological elements and relevant design alternatives of various available and
emerging methods.
Element Design alternatives
Scope of GHG emission calculation
Geographical
scope
Global European
Type of
emissions
included
CO2-emisisons non-CO2 GHG
emissions originating
from combustion of
fuel
non-CO2 GHG
emissions
originating from
refrigeration
151
Global warming
effect of
emission of
non-CO2
products (e.g.
water vapour,
contrails, NOx)
at high altitudes
Global warming effect
of black carbon
emissions
Activity
boundaries of the
methodology
Vehicle
propulsion
emissions
related from
energy use
(TTW)
Emissions from
auxiliary processes
(other than propulsion)
during vehicle
operation (TTW) (e.g.
cooling of freight)
Vehicle operation
emissions related
to leakage and
spills
Emissions from
hub activities
Emission from
energy
provision
(WTT),
excluding
energy
infrastructure
construction
Emission from
construction and
dismantling of energy
production
infrastructure
Life cycle GHG
emission of
vehicle
construction and
maintenance
Life cycle GHG
emission of vehicle
infrastructure
construction and
maintenance
Intended users Transport
service operator
Transport service
organiser
Transport service
user (excl.
organiser)
Use perspective Ex-post Ex-ante short term Ex-ante
calculations for
long term
scenarios
Emissions
perspective
Service average
GHG emissions
Time/situation specific
average GHG
emissions
Marginal GHG
emissions
The method of emissions calculation and allocation to transport services
Required
granularity of
calculation
Total GHG of
transport
operator
Total GHG emission
of transport service
user (freight) or
organiser
Transport service
type
Transport chain
element / leg
(average over
period)
Single vehicle Individual trip Total GHG
emissions of hub
operator
Per activity at hub
Allocation
parameter for
allocation to
transport services
Tonne-km passenger-km tonne-km SFD
passenger-km-
SFD
tonne-km GCD passenger-km-
GCD
Allocation
granularity for
allocation to
transport services
On company
level (e.g.
average for
transport
company)
transport leg level (e.g.
average between hubs)
Trip level -
journey specific
Flexibility in
calculation
method
The user can
choose the
calculation
option from a
predefined list.
The required
calculation option
depends on the
stakeholder group
applying the
calculations.
The calculation
options are
ranked from most
preferable to least
preferable
The calculation
option with best
accuracy,
comparability is
prescribed for all
users
152
calculation
option.
Source: Ecorys and CE Delft (2023), Impact assessment support study
8. ASSESSMENT AND RANKING OF THE METHODOLOGICAL ELEMENTS
Seven criteria were established to assess (where applicable) the appropriateness of these
methodological elements and their design alternatives for CountEmissions EU:
 Relevance: The extent to which the element is relevant for the GHG emissions
within the influence sphere of the reporting entity and/ or serves the decision-
making to reduce GHG emissions both internal and external to the company.
 Applicability by stakeholders: The complexity the reporting entity encounters
when applying the element in the quantification of emissions and reporting.
 Acceptability by stakeholders: The extent to which stakeholders are willing to
apply the element in the quantification of emissions and reporting, taking into
account the efforts needed and the value they get out of it.
 Accuracy: The extent to which the reported emissions are free of errors and
faithfully represent the actual emissions.
 Comparability: The extent to which the element allows for meaningful
comparisons of GHG emissions over time and between reporting entities (in
the same market).
 Reproducibility: The extent to which different organisations using the same
methodology and data would arrive at the same GHG emission estimates
 Robustness: The frequency with which the element has to be updated over time
and the amount of effort that requires.
Scoring results per each methodological cluster are presented below.
a) Cluster “Scope of emission calculations”
Geographical scope
The geographical scope relates to the extent to which a method can be applied to account
transport emission in different geographical areas, and can take into account various modes
of transport and different types of fuels and vehicles. In this context, a European and global
scopes were considered.
The objectives of CountEmissions EU focus on the European transport sector. However,
for the EU27, 40% of international trade is performed with countries outside the EU27248
248
Eurostat: “Intra-EU27 (from 2020) trade, by Member State, total product”, and “Extra-EU27 (from 2020)
trade, by Member State, total product” ; year 2019.
153
and 56% of the passengers in aviation is on flights to or from countries outside the EU27249
.
Considering these numbers a strong case can be therefore made for a global scope250
. On
the one hand, this global scope would make the emissions quantification more complex,
partly because different emission factors would have to be used for various countries and
regions. On the other hand, a number of existing methods (like GHG Protocol, GLEC, ISO
14083) already apply the global scope, making it possible to account emissions in a full
transport chain with origins or destinations both inside and outside Europe.
Looking at the targeted stakeholders’ consultation, 20 out of 28 respondents of the survey
favour the global scope for the common accounting methodology.
Table 90 shows the selected and discarded design alternatives for the methodological
element ‘Geographical scope’.
Table 90: Selected and discarded design alternatives for the methodological element ‘Geographical scope’
Selected design alternatives Discarded design alternatives
— Global scope — EU scope
Source: Ecorys and CE Delft (2023), Impact assessment support study
Type of emissions stemming from transport operations
Important greenhouse gasses emitted by transport are carbon dioxide (CO2), methane
(CH4), nitrous (N2O) and chlorofluorocarbons (CFCs), e.g. from air conditioning. These
have global impact on the climate. The greenhouse gasses can be emitted for instance
during the vehicle operation, production of an energy carrier, or the manufacturing of a
transport means.
Besides the GHG emission, global warming is also caused by water and air polluting
emission from aviation at high altitude, leading to clouds and aerosols. The global warming
effect from emissions at high altitude is more regional251
. Finally, black carbon emission,
mainly caused by diesel and fuel oil combustions have a local global warming effect due
to the absorption and scattering of sunlight.
CO2-emisisons
For CountEmissions EU it is clear that CO2-emisisons are fundamental, as they are by far
the main type of GHG emitted by transport (e.g. ca 98% in GHG emissions of gasoline and
diesel combustion252
). CO2-emissions can be accurately calculated from the fuel
consumption and fuel emission factors (kg of CO2 per amount of fuel) as they are linearly
249
Eurostat: “International intra-EU air passenger transport by reporting country and EU partner country”,
and “ International extra-EU air passenger transport by reporting country and partner world regions and
countries”; march 2022.
250
Ehrler, et al., 2016
251
IPCC, 1990
252
IFEU, 2019
154
related to the amount of fuel used. CO2-emission calculations are usually well comparable
and reproducible.
Because of the limited data needed to make a calculation, the methods for calculating
(especially direct) CO2 emissions are considered robust.
Non-CO2 GHG-emissions from fuel combustion
Other greenhouse gasses such methane (CH4) and nitrous oxide (N2O) do not have a very
large contribution in the total GHG emissions of transport in general (e.g. ca 2% in GHG
emissions of gasoline and diesel combustion253
). Nonetheless, they can have important
impacts on the GHG emissions from using specific fuels, such as CNG and LNG, which
can cause significant methane emissions.
For a fair comparison between fuels, it is therefore relevant to include the other greenhouse
gasses, specifically methane and nitrous oxide emissions. Precise calculation for these
gasses is more complex than for CO2, as the emissions do not only depend on fuel
consumption but also on engine technology. However, accurate default factors for fuel-
technology combinations are already available in databases such as the EMEP/EEA
guidebook254
. The global warming potential (GWP) values, needed to express the emission
in CO2 equivalents, are regularly updated with new insights by the Intergovernmental
Panel on Climate Change (IPCC)255
. However, some variations between methods may
exists in case these are not fully aligned with the most recent IPCC values, thus giving a
slightly lower score on robustness than in the case of the CO2 emissions.
Non-CO2 GHG-emissions from refrigeration
Cooling systems in refrigerated transport, and air conditioning often make use of
refrigerants such as hydrofluorocarbons (HFCs) which are fluorinated greenhouse gasses
with a very high global warming potential (GWP). The use of these gasses is regulated by
the F-gas Regulation256
and the MAC Directive257
.
Although the use of F-gases is currently reduced in the business practice, they are still
being used and small losses can have high GHG impacts. The monitoring of refrigerants
losses from air conditioning and cooling systems (or the amount of refilling required) is
therefore very relevant, and for instance has been included in the calculation method of the
upcoming ISO 14083. Including the climate impact of refrigerants in GHG calculations is
less common though, especially when the type of a refrigerant or the exact losses are
unknown. Given the high difference in global warming potential of various refrigerants
(with GWP values below 150 to above 10,000258
), the default factors available for these
types of emissions are characterised by some degree of uncertainty. Finally, new
253
idem
254
https://www.eea.europa.eu/publications/emep-eea-guidebook-2019
255
https://www.ipcc.ch/
256
Regulation (EU) No 517/2014
257
Directive 2006/40/EC
258
According to the GHG protocol, 2016
155
refrigerants with lower GWP are being developed, demanding regular updates of the
emission factors, and thus resulting in medium score on robustness for this alternative.
Global warming effect of non-CO2 emissions at high altitudes
Besides the CO2-emisisons and other GHG emission from fuel burning, aviation
contributes to global warming with non-CO2 climate impacts from NOx, SOx and soot,
and also water vapour emissions at high altitude. In conjunction with the anthropogenic
sources, these emissions modify atmospheric composition (gases and aerosols), hence
radiative forcing and climate259
.
The non-CO2 climate impact of a flight depends on the quantity and type of emissions, but
also on where (altitude, geographical location), and under which conditions (time and local
weather conditions) the flight takes place. The effect is expressed by the metric radiative
forcing, which expresses the difference between incoming solar radiation and outgoing
terrestrial radiation. This metric describes climate impact effects at a certain moment and
cannot be expressed easily in CO2-equivalents, which takes into account the GWP of
emissions measured over a time period of 100 years260
.
Of the available methodologies assessed, only the GHG Protocol mentions the option to
apply a multiplier to cover the effect of non-CO2 climate impacts, but notes that there is
very significant scientific uncertainty around the magnitude of the effect, with a factor of
1 -8.5261
.
The GLEC framework leaves open the option to include it in future updates. The draft of
ISO 14083 does not include the effect in the methodology. At the moment, only average
multipliers are used in some calculation tools (e.g. EcoTransIT) to quantify the effect, but
no accurate methods is present yet, and therefore the existing approaches are often not
widely accepted. Specifically, the average indicators that are applied very often do not
represent trip specific effects and do not allow for a good comparison of emissions. As the
current approaches are not harmonised, results are also not reproducible.
Because of the low scores on the analysis, this design alternative was therefore not put
forward for the present initiative. However, given its relevance for emissions calculations,
the climate impact of this effect is being researched and it might be considered to include
it in the framework at a later stage when more accurate methods are available.
Black carbon emissions
Black carbon is a form of particulate matter emissions and consists of dark carbon particles
produced from the incomplete combustion of fuels. When airborne, black carbon absorbs
and scatter sunlight, which can lead to increased temperatures. When deposited on earth,
259
IPCC, 1999
260
IPCC, 2007; IVE, 2020
261
Jungbluth, 2019
156
especially in the cryosphere, black carbon causes snow and ice to melt faster, due to
reduced reflectivity262
.
The accounting of black carbon itself is quite complex and requires extensive datasets with
emission factors differentiating between fuels, engine types, and by preference, also the
use characteristics. The databases should be regularly reviewed to keep them up-to-date.
After carbon dioxide, black carbon has the second biggest impact on climate forcing in the
atmosphere overall. A coalition, with amongst others Smart Freight Centre, ICCT and
Smartway, has developed a method to account for black carbon emissions, and to measure
it alongside GHG emissions. Respectively, the GLEC framework gives guidance on the
reporting of black carbon alongside GHG emission. This method, however, does not
express the impact of black carbon in global warming terms, which would be very difficult
given the dependency on location and weather.
Although it is considered very relevant, there is no adequate methodology yet to include
the effect of black carbon in GHG accounting in an accurate way at this point of time.
Because of the low scores from the analysis, this alternative is not currently considered for
CountEmissions EU.
Table 91 presents the list of selected and discarded design alternatives for the
methodological element ‘Type of emissions.
Table 91: Selected and discarded design alternatives for the methodological element ‘Type of emissions’
Selected design alternatives Discarded design alternatives
— CO2 emissions
— Non-CO2 GHG emissions from fuel
combustion
— Non-CO2 GHG emissions from
refrigeration
— Global warming effect of non-CO2 emissions (e.g.
water vapour, contrails, NOx) of aviation at high
altitudes.
— Black carbon emissions
Source: Ecorys and CE Delft (2023), Impact assessment support study
The results of the stakeholders’ interviews broadly support this selection of the design
alternatives. As regards the stakeholders who contributed on this issue, 12 preferred CO2-
equivalent emissions in the scope, while only two stakeholders from maritime and aviation
suggested focusing on CO2 emissions only (in line with the scope applied in the schemes
currently used in those sectors, i.e. EU MRV and CORSIA). Both stakeholders did
however mention that an extension to non-CO2 GHG emissions could be considered in the
future.
Activity boundary
The activity boundary sets the scope for the type of activities and events that are to be
included in the methodological framework.
262
SFC, 2017
157
The identified design alternatives are:
 Emission from vehicle propulsion: engines exhaust emissions, also called the Tank-
To-Wheel emissions (TTW);
 Emissions from auxiliary processes (vehicle operation related emissions from
energy use other than propulsion): emissions from auxiliary processes on vehicles,
such as cooling and refrigeration, the operation of on board cranes for transhipment,
and vehicle interior heating;
 Emissions from leakage and spills: vehicle operation related emissions stemming
from the loss of refrigerants from the cooling system, fuel evaporation or boil-off
(e.g. LNG);
 Emissions from hub activities: emissions from activities at locations where
passengers and/or goods switch from one vehicle or mode of transportation to
another (hubs). Hub activities are, for example, transhipments operations in ports,
terminal operations at airports and sorting centres for distribution;
 Emissions from energy provision (WTT), excluding energy infrastructure
construction: all the GHG emissions of operational processes to provide the energy
carrier for use in vehicles or at hubs. They include processes such as extracting,
producing, processing, storing, and transporting of energy carriers;
 Emissions from construction and dismantling of energy production infrastructure:
these emissions are often not included in the WTT as they are not directly related
to the fuel use. As the contribution of energy production infrastructure on the total
emissions of renewable energy sources is relatively high, by including these
emissions a fairer comparison can be made between renewable and fossil energy
use;
 Life-cycle GHG emissions of vehicle construction, maintenance and disposal:
concerns the emissions associated to materials used to construct vehicles, the actual
construction activities, transport of vehicles, maintenance activities and disposal
activities;
 Life-cycle emissions of transport infrastructure construction, maintenance and
disposal: these are the emissions from the materials used, construction and
maintenance activities, demolition of infrastructure, etc.
The analysis of each individual design alternative is provided below.
Vehicle propulsion emissions
The basis for GHG accounting of transport services are the vehicle propulsion emissions,
which should be fundamental to the methodology. The calculation of propulsion emissions
is supported by all available methods. The accuracy, comparability, reproducibility and
robustness for this alternative can in principle be high, particularly when calculations are
based on actual fuel consumption figures.
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All stakeholders participating in the targeted survey and interviews supported the coverage
of these emissions by the harmonised framework.
Emission from auxiliary processes
Not all transport operations include auxiliary processes, but for specific services, such as
cooled transport or the heating system in passenger busses, the impact can be in the order
of 10-30% of the total GHG emission of fuel combustion263
. Sometimes, the auxiliary
processes are driven by the main engine and sometimes by auxiliary engines or generators.
It is therefore important to include the auxiliary processes for a fair comparison between
various transport options.
The inclusion of auxiliary processes is already included by most existing GHG
quantification methods, such as by EN 16258, GLEC, and the French Transport Code. The
calculation of auxiliary processes is similar to that of vehicle propulsion emissions, and
only requires extra information on the fuel consumption of the auxiliary engine or
generator. The applicability, acceptability and the other respective assessment criteria are
therefore attributed the same score as for the design alternative “vehicle propulsion
emissions”.
Emissions from leakage and spills
Leakage and spills include emissions from refrigerants and boil-off of LNG for example.
As explained for CO2-emisissions from refrigeration, and for methane emissions, small
quantities can already have a large GHG effect due to the high GWP values of these
substances. The emissions of leakage and spills can therefore be very relevant264
.
However, calculations of the climate impact of these emissions is less common than for
CO2, as is the provision of default factors for the calculations.
None of the existing methods, except the concept ISO 14083 standard, clearly addresses
this emissions type. Including it in the calculation requires monitoring of refrigerant
refilling or the application of default emissions for certain engine technologies. The
applicability and acceptability therefore have an average score of 3 in the analysis.
Accuracy, comparability, reproducibility and robustness also score average, as the
approach for different kind of spills and leakages is not as well established as for emissions
from the propulsion.
Emissions from hub activities
To allow a good comparison between emissions of different (multimodal) transport chains,
it is very important to include the GHG emission of activities at hubs. For example, the
comparison of a combination of transports by inland waterways and truck with direct truck
transport is only fair when hub activities are considered. CO2-emissions of the
transhipment need to be accounted to determine which option is more CO2-efficient, as
263
Ricardo Energy & Environment, 2021; OV magazine, 2018
264
Saharidis & Konstantzos, 2018
159
hub emissions can be significant (e.g. they may sum up to 5-7% of the total emissions of a
road shipment in the chemical sector265
). Emissions at hubs can be calculated directly from
the energy consumption, with a method comparable to that of vehicle operation. For hub
operators, that have access to the energy consumption figures, emission calculation is
therefore not much more complex than for vehicle propulsion related emissions.
However, default factors are not as common as for vehicle operation. Recently a guideline
and tool have been released266
, also referred to in the concept ISO 14083, but the
development of default emission intensity factors within that project is still on-going.
Therefore, the applicability of these calculations is scored slightly lower than for vehicle
propulsion emissions (2). With a similar method as for vehicle propulsion related
emissions, the criteria on accuracy, comparability, and robustness score equally well.
From the stakeholder interviews, it became clear that the coverage of emissions from hub
activities is strongly supported. Three transport associations, tree research oriented
organisations and one transport operator explicitly voiced the need for including these
emissions. Only one transport association directly discarded this alternative, fearing that it
would complicate the calculation process.
Emissions from the energy provision (excluding energy infrastructure construction)
As GHG emission have global impact, emissions of the energy provision (WTT) are very
relevant to be included in emission accounting to assure a fair comparison between
different fuels and energy carriers in the energy lifecycle (WTW) perspective. This
becomes very clear, for instance, when analysing the electricity as an energy source, where
electric powered vehicles may not be actually zero emissions, in case this electricity is
produced from fossil fuels. Also, for some of the fossil fuels the share of WTT emissions
in the WTW perspective is very significant. For example, for the use of LNG267
in maritime
transport this share may be up to 40%268
.
Most of the current general (not mode specific) GHG methods do include the emissions of
energy provision, and Well-To-Tank fuel emission factors are commonly used. There are,
however, differences in WTT emission factors of fuels, which are not related to physical
differences of the fuel, but to calculation methods or updates. JRC, for example, has
published WTT emission factors for diesel and gasoline based on 2 different approaches,
the marginal and the average269
. Both approaches, together with other emission factors are
applied across methods and tools. The comparability and robustness (emission factors are
unregularly updated) at the level of the transport sector is therefore currently not optimal.
There is a strong support from stakeholders for the inclusion of the emissions from energy
provision. The vast majority (93%, i.e. 26 out of 28 respondents) of the stakeholders who
filled in the targeted survey, prefers the inclusion of these emissions. At the stakeholder
265
McKinnon & Piecyk, 2010)
266
Fraunhofer IML, 2019
267
Liquefied natural gas
268
ICCT, 2021b
269
JRC, 2020
160
interviews, only two representatives from the maritime sector were opposing the inclusion
of WTT emissions at this moment of time.
Emissions from the construction and dismantling of energy production infrastructure
Whereas emissions from the energy provision are included in a number of methods, in
many cases these do not (explicitly) cover emissions from the construction and dismantling
of energy production infrastructure. The upcoming ISO 14083 standard does recommend
the inclusion of these emissions, to account amongst others, emission related to solar cell
and windmill production, recognising that GHG emissions from these infrastructures is not
zero.
The contribution of emissions from the construction and dismantling of energy production
infrastructure in the WTT figures of fossil fuels is limited (2-3%). For the renewable and
nuclear energy the contribution to the total emission is very relevant though270
. GHG
emissions of specific infrastructure is not easily available271
, therefore in this case the
calculation should be based on average life cycle analysis studies or databases. In relation
to the differences in GHG emission between the infrastructure of different energy carriers,
the accuracy in calculating these emissions is still reasonable due to the limited number of
variables and significantly lower complexity than in the case of transport infrastructure.
For businesses, the accounting of these types of emissions would not be associated with
particular efforts and costs. Therefore, the applicability and acceptability of this design
alternative would score reasonably well, as long as the emissions are included in the
available WTT emission factors of energy carriers. However, at this point of time these
effects very often are not directly reflected in the existing datasets and databases, therefore
causing some issues for their full application in regular business practice. This drawback
results in average scores on these criteria.
Life-cycle GHG emissions of vehicle construction, maintenance and disposal
Emissions from vehicle construction, maintenance and disposal can be as high as 20% of
the total life cycle emissions for cars and vans and are much lower for larger vehicles such
as truck, ships and planes272
. The difference in construction, maintenance and disposal
emissions between similar vehicles is only a fraction of this 20% and these emission are
not expected to play a decisive factor in the comparison of transport services with similar
vehicles of the same mode. Between modes, the difference in construction, maintenance
and disposal emissions is larger, as shown in Figure Figure 12 below.
270
CE Delft, 2020
271
The specific source for the energy used is often not known (e.g. coal-fired or gas-fired power plant).
272
CE Delft, 2021
161
Figure 12: Share of processes in LCA GHG emissions for key vehicle categories
Source: CE Delft, 2021
It should be noted however, that data for vehicle construction are not easily available from
vehicle manufacturers, and may be subject of substantial variations and uncertainty, in
particular for those stemming from the production taking place outside the EU. In addition,
translation of the total construction and maintenance emissions of a vehicle to values per
kilometre, strongly depends on the use and lifetime of the vehicle, which is not known on
forehand and therefore less accurate. The comparability and reproducibility are therefore
limited. Also, the default figures should also be regularly updated as the production
processes are continuously changed and improved, giving lower score on robustness.
None of the current transport specific GHG methods that were analysed in the context of
this Impact Assessment, includes vehicle construction maintenance and disposal
emissions273
. Despite low scores on the analysis, this characteristic may be seen as quite
relevant as it may account for the entire spectrum of emissions related to a transport
activity, seen as a product. In addition, this alternative was supported by a number of
stakeholders consulted (see below). However, given important uncertainties of the
underlying factors, it should be taken into account rather for the potential future
development of CountEmissions EU, when more information becomes available. On this
very point, instead of inclusion of all life cycle emission of the vehicle, one might consider
only those elements that make real difference between transport options, such as the
emissions associated with the powertrain274
.
273
These elements would be in general covered by the PEF methodology. However, PEF is not transport
specific and in the absence of specific product category rules, currently it does not cover the vast majority of
lifecycle emissions related to transport activities.
274
In line with the inclusion of emissions from the construction and dismantling of energy production
infrastructure it might be considered to only include the emission of the powertrain production, which for
battery electric vehicles would include the CO2-emission of the production of batteries. There are discussions
on the environmental impact of the battery production and whether this element could be covered by
including it in the scope. The rationale for the inclusion would be that the difference in CO2-emissions
between vehicles with and without batteries is relatively large as compared to the uncertainty in the emission
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Among stakeholders, opinions on the inclusion of full lifecycle emissions differ widely.
The OPC and targeted survey may indicate that citizens and in general transport service
users are more in favour of this approach, while transport operators (and associations
representing them and operators of freight greening programmes) being strongly against275
.
These results would possibly suggest a distinction between the final beneficiaries of
transport services and the stakeholders that are more integral part of the transport system,
and are directly impacted by the provision of a specific emissions quantification
methodology. On the other hand however, these results may have been also affected by the
limited understanding of this technical and complex matter, especially by those who are
not dealing with it in the everyday practice. In the targeted interviews, none of the
participating stakeholders supported the inclusion of lifecycle emissions in the
CountEmissions EU framework (at least at this moment of time), and this opinion was
shared by the attendees of the stakeholder workshop.
Life cycle emissions of infrastructure construction, maintenance and disposal
Infrastructure emissions are estimated to represent up to 20% in transport GHG life cycle
emissions on average. However, the difference in emissions from the existing
infrastructure is not expected to play a decisive factor in the comparison between modes
or within modes, as the impact of vehicle use is strongly dominant for accounting
emissions from transport operations. Both transport service operators and users have very
little influence on the GHG emission of infrastructure construction276
, hence the inclusion
of infrastructure emissions is not relevant for making transport choices based on GHG
emissions data. Instead, information on this type of emissions may be important factor to
support planning and decisions on new investments in transport infrastructure.
What is more, infrastructure emissions for a specific trip are hard to determine accurately
as they depend on many factors, such as the specific infrastructure objects being used, their
properties (including bridges, tunnels, type of road, type of surface etc.), traffic intensity,
the year of construction and lifetime. Emission factors with this accuracy are hardly
available, which makes a reliable comparison impossible. None of the current GHG
transport accounting methods includes infrastructure construction maintenance and
disposal emissions. The PEF methodology allows it under certain conditions, but in the
absence of the Product Category Specific Rules for transport services, it does not provide
specific guidance on how to apply it in business practice.
data. According to CE Delft, 2021, batteries can have up to 10% share in the lifecycle emissions of electric
cars, whereas they are zero for vehicles with only internal combustion engines (ICE), having no batteries.
None of the current transport GHG methodologies, however, includes these emissions in the scope of the
calculation framework.
275
In the targeted survey, 5 of the 9 transport service users indicated that they prefer full life-cycle emissions,
while only 2 out of 8 transport operators/associations share this preference. In the OPC, 17 out of 20 EU
citizens indicated that they prefer full life-cycle emissions over WTW emissions compared to 20 out of 58
companies that shared the same view (34 of them supporting the WTW approach)
276
It can be indirectly associated with new infrastructure investments where the information on transport
demand may play a role in the decision-making. However, the construction on infrastructure is subject to
specific environmental impact assessment, based on relevant methodologies and lifecycle of this
infrastructure
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Because of the low score in the analysis, this characteristic is not considered for
CountEmissions EU.
Table 92 presents selected and discarded design alternatives for the methodological
element ‘Activity boundary’.
Table 92: Selected and discarded design alternatives for the methodological element ‘Activity boundary’
Selected design alternatives Discarded design alternatives
— Vehicle propulsion emissions
— Emissions from auxiliary processes
— Emissions from leakage and spills
— Emissions from hub activities
— Emissions from energy provision (WTT), excluding
energy infrastructure construction
— Emissions from construction and dismantling of energy
production infrastructure
— Life-cycle GHG emissions of vehicle construction,
maintenance and disposal277
— Life-cycle emissions of vehicle
infrastructure construction,
maintenance and disposal.
Source: Ecorys and CE Delft (2023), Impact assessment support study
Intended user
From the analysis of current methodologies and standards, the main groups of users of the
methodological framework for GHG accounting are:
 Transport service organisers and hub operators;
 Transport operators, distinguished here from the first category, given their
important role as entities carrying out physical transports of passengers or freight
as a service;
 Transport service users.
Most of the current methods account for all three types of users as provided above. Article
L. 1431-3 of the French transport code is the sole exception, as it envisages only transport
service organisers and operators to report emissions of their services. Also, it is worth
noting that most methods expect transport operators to calculate emissions based on
primary data (e.g fuel use and transport performance) whereas they allow transport users
and organisers to use default factors and “modelled” emission values.
Transport operators
It is very relevant to include transport operators as they have access to primary energy data
of the vehicles and so are able to calculate GHG emission of transport very accurately.
277
This design alternative has been included in the construction and assessment of the policy options
(specifically PO3 and PO5) with an important caveat that it may not be ready for the full implementation on
the EU transport market in the short and medium term.
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When operators share data with their users, the users can also calculate their emission
accurately based on primary data of the operator.
Transport service organisers
In the passenger segment, transport organisers (like travel agencies) act as intermediaries
between transport operators and end users, and therefore need to be able to account
emissions to provide information on the performance of various transport choices for
passengers.
In freight transport, logistics service providers and freight forwarders are often the contact
point between a manufacturer/shipper (cargo owner) and a transport operator. These can
organise complete transport chains from origin to destination of the goods. Therefore, it is
very relevant that transport organisers have a solid methodology to report the emissions to
users, such that the latter can make decisions based on GHG emissions of transport options.
When transport organisers cannot get information from their transport operators, default
emission factors or models are needed to make GHG calculation. This makes the methods
more complex than for transport operators who can often simply use primary data.
Transport service users
Passenger transport service users can be individual passengers, customers (end users of the
service) or organisation and businesses buying transport for their employees. Individual
passengers would not be the intended users of CountEmissions’ methodology, but rather
be the beneficiaries of the initiative. On the other hand, organisations and businesses
usually need a relevant method to quantify and report on the GHG emissions of business
travels they purchase, especially when this information is not supplied by the transport
service operator or organiser.
Freight transport service users are shippers/cargo owners and individual customers of
online stores. Very often shippers are strongly interested in the emissions of services they
buy, especially for making informed transport choices, and also for regulatory reporting
purposes. It is therefore important and relevant that the Count Emissions EU includes a
suitable method for shippers to calculate these emissions in a consistent way. As regards
the individual customers of online stores, similarly to passengers they would be rather the
beneficiaries of the common methodology than its regular users.
In general, when transport service users cannot get proper and accurate information from
their transport operators or organisers, default emission factors or models are needed to
make GHG calculations. In case a harmonised approach for calculating emissions is
available in the transport sector, the administrative burden to aggregate and compare
various emissions data will be however significantly reduced.
In order to cover emissions accounting along the entire transport chain, it is therefore
recommended that CountEmissions EU methodology applies respectively to transport
service organisers, operators, and users, although the use of the harmonised methodology
by the latter group is considered to be at a lower level than for the other two.
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As shown in Table 93 all these design alternatives should be relevant for the scope of
CountEmissions EU.
Table 93: Selected and discarded design alternatives for the methodological element ‘Intended user’
Selected design alternatives Discarded design alternatives
— Transport service organiser
— Transport operator
— Transport service user
Source: Ecorys and CE Delft (2023), Impact assessment support study
Use perspective
Emission accounting can be made after (ex-post) or before (ex-ante) a service is performed.
Ex-post calculations are often used to report GHG emissions of transport activities to third
parties, and to monitor emissions reduction over years. Ex-ante accounting can be used for
short term decision making (e.g. comparing train and aviation for a certain trip) or applied
for strategic decision making in the longer term (e.g. for investments in infrastructure or
modal shift policies).
The identified use perspectives are therefore the following:
 Ex-post
 Ex-ante for short term decision making
 Ex-ante for long term strategies
Ex-post
All existing methodologies and standards take ex-post calculations into account, based on
the realised transport performance data. As ex-post calculations are based on real practice,
this use perspective is potentially most accurate and comparable and therefore also very
relevant. Having the actual transport data (for transport operations), no estimations need to
be made, thus making the calculation highly reproducible. Also among stakeholders, there
is strong support for ex-post calculations. Only one (a public authority) out of 27
stakeholders participating in the targeted survey indicated that there is no need to cover ex-
post calculations by the harmonised methodological framework.
Ex-ante for short-term decision-making
To allow transport service users for making their transport choices effectively, ex-ante
information on GHG emissions of transport services appears as a very powerful tool for
creating incentives and therefore represents a relevant option for CountEmissions EU. The
ex-ante calculations should be preferably based on ex-post outputs with additional
prognoses on routing and vehicle use. In case only default values are used, these should be
sufficiently reliable and accurate, to prevent from generating incorrect information on
GHG emissions that may lead to perverse incentives and unintended adverse effects on the
166
transport market. Therefore, it is important to determine appropriate parameters and
assumptions reflecting the type of a service concerned and its characteristics, for instance
regarding the re-use of primary data obtained from a similar service, the definition of
service averages, loading and occupancy rates, or the uptake of specific default values.
Most existing methods/standards allow for both kind of calculations (ex-post and ex-ante
for short term decision making), suggesting that stakeholder applicability should not be a
major problem. Finally, there is strong support from stakeholders for this kind of emissions
calculations: 21 out of 27 respondents to the stakeholder survey see the need for ex-ante
calculations
Ex-ante for long term strategies
CountEmissions EU will not directly address long-term strategic decisions and projections
that are based on specific methodological frameworks, and require tailor made estimations
for the future emission factors and vehicle use. Since the ex-ante calculations for long-term
scenarios do not reply to the objectives of CountEmissions EU, this characteristic is not
considered for its future reference methodology.
Selected and discarded design alternatives for the methodological element ‘Use
perspective’ are presented in Table 94.
Table 94: Selected and discarded design alternatives for the methodological element ‘Use perspective’
Selected design alternatives Discarded design alternatives
— Ex-post
— Ex-ante for short term decision making
— Ex-ante for long term strategies
Source: Ecorys and CE Delft (2023), Impact assessment support study
Emission perspective
For the emission perspective we may distinguish three design alternatives:
 Service average GHG emissions: give information on the average performance (in
terms of emissions) of a transport service from a specific transport operator. It
allows a comparison between different transport operators for a particular transport
service.
 Time/situation specific average GHG emissions: take into account differences in
emission levels of a transport service over the day, e.g. due to variance in
occupation rates (higher in peak hours) or traffic situation (e.g. peak hour). This
time differentiation can be used to express the difference in the performance (in
terms of emissions) of the service over the day. In peak hours, for example, the
occupation of a train is higher than during off-peak hours, leading to lower emission
per passenger-kilometre than on average. On the other hand, a taxi will probably
have higher GHG emission per passenger kilometre in peak hours, because of
increased GHG emission per kilometre during time spent in traffic jams.
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 Marginal GHG emissions: whereas average (day average or specific time average)
emissions address the efficiency of a transport service or system, marginal GHG
emissions consider the impacts of changing the utilisation of a service. Marginal
GHG emissions are defined as the extra GHG emissions as a result of an extra
passenger or extra cargo (Bigazzi, 2020). In passenger scheduled (e.g. rail
passenger) transport, the extra passenger will, on average, hardly add to the total
GHG emission (Rietveld, 2001), whereas an extra customer for a taxi will likely
have the same impact as an average taxi passenger. The marginal perspective can
be applied to both service average GHG emissions and time specific average GHG
emissions. When applied to time specific average GHG emissions, off-peak
emissions of public transport will in general be lower than during peak hours, as
these hours extra passengers in public transport might lead to extra vehicle
operations (as existing vehicles do not have capacity to transport additional
passengers), which is unlikely during off-peak hours. The marginal perspective is
particularly relevant for ex-ante GHG emission calculations, as it informs transport
service users on the impact of other transport decisions, such as switching modes
or changing departure times (Bigazzi, 2020).
Service average GHG emissions
Service average emissions are very relevant and give transport service users the possibility
to compare different transport services on their performance. When longer term (e.g.
annual) averages are used, influences of weather conditions or traffic circumstances have
no effect on the calculated emissions. The relevance of transport service average GHG
emissions is therefore high. The calculation of averages does not require a journey specific
information, and therefore the applicability, acceptability and accuracy score high. When
calculated at the service level (especially when using precise ex-post emissions data, based
on primary information), e.g. a flight from Paris to Madrid or a parcel from Berlin to
Warsaw, the average performance of operators can be fairly compared.
Time/ situation specific average GHG emissions
Time specific or situation specific average GHG emissions reflect the GHG emissions of
a service under specific circumstances. For ex-post calculations it can be useful for
transport operators to understand the difference in GHG efficiency between peak hours
and off-peak hours, or the effect of weather circumstances (e.g. temperature effects on the
efficiency of electric vehicles). They can use the information to optimise operations and
improve the overall performance.
Whereas time/situation specific information can be very relevant for self-assessment of a
transport operator, it might be less useful or even misleading for transport service users,
especially in the ex-ante calculation perspective. For instance, while the GHG-emissions
per passenger-kilometre of public transport are lower during peak hours (due to high
occupancy rates), it might not be favourable to attract more passengers during this time (it
may even increase the total level of GHG emissions due to higher weight of a vehicle, or
in case more vehicles have to be scheduled in peak hours to transport additional travelers).
Also, parcel delivery during peak hours might result in higher GHG emissions for this
delivery, but it still might me the best option in the overall delivery system of the transport
operator.
168
Therefore, based on the analysis performed in this Impact Assessment, only mediocre score
can be attributed to the relevance of time/situation specific average GHG emissions.
Similar score should be attributed to the criterion related to the applicability, as more
detailed input data is needed than for calculating the service average GHG emissions. The
acceptability will score average too, because of extra efforts that are required to generate
emissions data, and their limited relevance for transport service users. As regards the
accuracy, comparability, reproducibility and robustness, the time/situation specific average
GHG emission also score lower than service average GHG emissions, due to higher
complexity and additional choices that need to be made, and which can lead to significant
differences between the GHG emissions outputs (e.g. depending on the definition of peak
hours or allocation of fuel to different traffic situations).
Marginal GHG emissions
Marginal emissions are relevant to inform transport service users on the effect of their
choices for a certain transport mode or a certain transport service operator. The
applicability of marginal emissions, however, very much depends on the specific situation
and vary by context. For public transport, the difference between the average emissions
and the marginal emissions will, for example, depend on the population density of the area
where the transport services is provided, the density of the transport network, the actual
occupancy rates and traffic conditions e.g. during rush hour and off-peak. The calculation
of such marginal emissions may require a broad set of specific data and possibly specific
elasticity factors, giving the relation between vehicle use and passenger demand. The
calculations are therefore very complex and burdensome, thus negatively affecting the
applicability and acceptability of this design alternative. A method to calculate marginal
emissions is not yet broadly established and is still subject to scientific research.
Consequently, the accuracy, comparability, and reproducibility are given the average score
too. In addition, to provide correct values, the elasticity values and input data need be
monitored on permanent basis, resulting in a low score on robustness.
As shown in Table 95, the preferred design alternative for CountEmissions EU is the one
related to the service average GHG emissions.
Table 95: Selected and discarded design alternatives for the methodological element ‘Emission perspective’
Selected design alternatives Discarded design alternatives
— Service average GHG emissions — Time/situation specific average GHG
emissions
— Marginal GHG emissions
Source: Ecorys and CE Delft (2023), Impact assessment support study
However, given the specific case of comparative claims between the passenger scheduled
service and on-demand passenger service (such as taxi), additional consideration should
be made for the ex ante comparison of the scheduled passenger services and the on-
demand services, where applying the average based approach may give an undue
advantage to the latter.
b) Cluster “Emission calculation method and allocation to transport services”
169
Minimum level of granularity of emission calculation
GHG emission accounting can be performed with different granularity, which is important
to allow for the comparability of data. The granularity defines the minimum level of
transport activity for which the energy consumption needs to be distinguished. The
following levels of granularity have been identified:
 Total GHG emissions of transport operator;
 Total GHG emissions of transport service user of organiser;
 Total GHG of hub operator;
 Transport service type278
;
 Transport chain element279
.
 Single vehicle;
 Individual trip;
Total emission of transport operator, hub operator and transport service user or organiser
Total emissions of a transport service operator and hub operator can be calculated
relatively easily and accurately from the energy consumption. This reasoning also broadly
applies to transport organisers or users, but in these cases more efforts are needed to
quantify emissions, and the output may be less accurate especially when modelled or
default values are used. Although information on total emissions at the company level is
relevant for the general monitoring purpose, it is useless for the comparability needs, as
transport activities of individual companies vary significantly. This design alternative has
therefore been discarded for CountEmissions EU.
Transport service type
When company data are differentiated per type of service (rail, road, container transport,
etc.), they are better comparable with other services of similar kind. GHG data generated
at this level also give useful information on the efficiency of a given service. Also, in this
case, energy consumption figures or default data and models are available for the emissions
calculation, thus scoring high on the applicability and acceptability. This level of
granularity was supported in the stakeholders’ survey, where 16 out of 28 respondents
(57%) mentioned the service type as the preferred level of granularity. However, at the
generic service type level, the emissions cannot be specified for a particular service user,
and therefore not sufficient neither relevant for CountEmissions EU.
278
Transport service type can be, for example: rail transport, container transport or delivery of packages.
Transport services might include multiple modes and hub operations. Transport service users provide
transport services that include the transport of passengers or goods from A to B.
279
A transport chain element is the transport between two hubs with a single mode. Transport modes can be
changed at hubs.
170
Transport chain elements/ leg (service level)
Breaking down the GHG emission to leg level, means that a company should monitor the
fuel consumption of transport between to hubs (or hubs and destination). Also, some
variance in the definition of transport leg is possible. For example, it can be differentiated
between different types of destinations (e.g. destinations in the inner city, the suburbs and
outside the city). This level of granularity is applied by most of the general methods
(covering all modes) and it is also used in combination with the data on transport
performance on a particular leg, as the basis of allocation (see the next item). It is therefore
very relevant. This level of granularity does require more efforts for calculation, as more
differentiation in the data is needed, but allows for a good comparability between GHG
emissions outputs, at the level of a transport service and service user specific.
Single vehicle level
Emissions at single vehicle level are relevant for monitoring GHG efficiency and can be
used to feed data to be generated at other levels. Fuel consumption, for instance, can be
monitored via refuelling data or on-board computer data, which is relatively easy and
accurate. Information stemming from the single vehicle granularity level may in some
cases feed in quantifying emissions at the operational level, but since it does not directly
allow for comparison between competing transport services, it would be discarded as a
design alternative for the common reference methodology.
Individual trip
Calculation at the level of individual trips may also be relevant and useful for
CountEmissions EU framework. However, it should be noted that the resulting data do not
provide a good representation of the transport service at average, thus affecting the
comparability between various services. For instance, the emissions generated at the level
of an individual trip may substantially depart from typical emissions from this service due
to an accident or other unexpected event taking place while performing the operation. In
addition, this approach requires substantial effort to allocate the fuel consumption of a
vehicle to a specific trip. The relevance, acceptability and accuracy are therefore lower
than for the granularity at transport chain element level.
Per activity at hub
For hubs the comparability GHG emissions data is higher when emissions are expressed
per activity and therefore this alternative was retained for CountEmissions EU. This level
of granularity requires however, that energy consumption per type of machine or activity
is monitored or that these data are available otherwise (via a model or defaults).
Based on the analysis two alternatives are selected for CountEmissions EU, as shown in
Table 96.
171
Table 96: Selected and discarded design alternatives for the methodological element ‘Minimum level of granularity of
emission calculation’
Selected design alternatives Discarded design alternatives
— Transport chain element (service level)
— GHG emissions per activity
— Total GHG emissions of transport operator
and/or hub operator
— Total GHG emissions of transport service user
or organiser
— Transport service type
— Single vehicle
— Individual trip
Source: Ecorys and CE Delft (2023), Impact assessment support study
Parameter for the allocation to transport services
The emissions generated by a transport activity can be derived from a measurement of the
consumed fuel, but can also be estimated by multiplying the actually driven distance with
an emission factor that is representative for the type of vehicle and transport mode that is
used. The distance unit (kilometres) can be measured including the concepts of actually
driven distance (ADD), great circle distance (GCD), and shortest feasible distance
(SFD)280
:
 Actually Driven Distance is the distance driven by the vehicle. This distance can
be for instance measured by the vehicle’s odometer.
 Great Circle Distance. The great circle distance is the shortest distance between
two points on the surface of the Earth, measured along the surface of the Earth. It
is also known as the “as the crow flies” distance: this distance does not consider
any infrastructure, so two points are connected directly, as if there is a straight road
between them. The GCD is associated with the net transport work independent of
the operational details, such as the chosen modality, infrastructure density and
routing of the goods flow. It is considered the most suitable measure for distance
especially for long haul intercontinental trips.
 Shortest Feasible Distance is the shortest distance between two places on a mode-
specific network. The SFD may not be the most optimal route as it may include
slow moving streets, or toll roads. The advantage of the SFD is that it is easily
understood, that it can be computed ex-ante and that under certain conditions it is
the same for all users that use the same software to compute it. Computation of
SFD depends on the software implementation, state of infrastructure and implicit
assumptions, such as avoidance of city centres281
.
To fulfil the objectives of CountEmissions EU, the selected method should allow for the
allocation of GHG emissions data from transport activities to specific users. In case there
280
TNO, 2021
281
idem
172
are a number of users in the same transport chain, this allocation should be performed in a
correct and balanced way.
There are different metrics identified from the current methods that have been taken into
account for the analysis:
 Tonne-km: the amount of freight in tonnes multiplied by the actual distance over
which it is transported;
 Passenger-km: the number of passenger multiplied by the actual distances (in km)
over which they are transported;
 Tonne-km SFD: the amount of freight in tonnes multiplied by the shortest feasible
distance (SFD) between origin and destination;
 Passenger-km SFD: the number of passengers multiplied by the shortest feasible
distance (SFD) between origin and destination;
 Tonne-km GCD: the amount of freight in tonnes multiplied by the shortest feasible
distance (GCD) between origin and destination;
 Passenger-km GCD: the number of passengers multiplied by the shortest feasible
distance (GCD) between origin and destination.
Tonne-km and passenger-km (real/ SFD or GCD) concepts are used across all investigated
methods, as the standard allocation parameters.
Real tonne-km and passenger-km
Allocation of emission based on real passenger- or tonne-kilometre is quite common and
therefore applicable and acceptable. However, the calculation based on the real tonne-
kilometres can be difficult for multimodal transport or multiple distribution trips, as it
requires the monitoring of the real driven kilometres per delivery. Moreover the allocation
in a delivery round, quite arbitrary, depends on the way the route is driven, and therefore
the services at the end of a distribution round may get allocated more GHG emissions. For
(public) passenger transport it is often easier to monitor real passenger kilometres as trains
and public transport busses drive the same routes every time, which makes the metric also
more accurate and reproducible. On the other hand, GHG intensity factors based on real
passenger-kilometres or tonne-kilometres do not allow for a good comparison on
efficiency, as emissions generated on detouring will not be properly reflected282
.
Tonne-km SFD and passenger-km SFD
Applying the allocation based on tonne-km SFD is already included in some of the current
GHG methodologies, such as GLEC, and the concept ISO 14083. The method proves to
be easily applicable as no detailed routing data are needed (score 1). In addition, based on
the discussion with the stakeholders, it appears that is may also feature high on the
282
McKinnon, 2015; TNO, 2021
173
acceptability criterion, although the methods is not commonly known and practiced in the
transport sector, especially in the passenger segment. The allocation based on tonne-km
SFD or passenger-km SFD is independent of the actual route, and may improve accuracy,
comparability, and reproducibility as compared to real-passenger and tonne-km. Shortest
feasible distance can be interpreted in different ways though, and may depend on the route
planner, the mode of transport and the moment in time.
Tonne-km GCD and passenger-km GCD
The allocation based on tonne-km GCD is already included in a number of current GHG
emissions accounting methodologies, such as GLEC, Topsector Logistics, and the concept
ISO 14083. It also features in some of the emissions calculation tools, including BigMile.
The method is assessed as being easily applicable, as no detailed routing data are needed.
Similarly as for the SFD, the acceptability for the freight segment can be scored a bit higher
than for the passenger one, the reason being that for the latter the allocation of passenger-
km based on passenger-km GCD is not being practised yet, except in aviation (mostly to
make the repartition between passengers and freight). Allocation based on tonne-km GCD
or passenger-km GCD improves accuracy, comparability, and reproducibility compared to
real-passenger and tonne-km, and also to the SFD metrics, as the great circle distance
between two locations is a constant factor and does not depend on route planners, new
infrastructure or modes. When Great Circle Distance is applied then only one interpretation
of the metrics is possible giving high accuracy, comparability reproducibility and
robustness (TNO, 2021).
Based on the analysis of the various allocation parameters, all but the real tonne-km are
selected as design alternatives for CountEmissions EU.
Table 97: Selected and discarded design alternatives for the methodological element ‘Allocation parameter’
Selected design alternatives Discarded design alternatives
— Real passenger-km
— Tonne-km SFD and passenger-km SFD
— Tonne-km GCD and passenger-km GCD
— Real tonne kilometre
Source: Ecorys and CE Delft (2023), Impact assessment support study
Granularity for the allocation to transport services
The allocation granularity is closely correlated with the granularity of emission calculation.
However, while the latter gives the level at which fuel/emissions information needs to be
collected, the allocation granularity defines at which level the emission/fuel should be
allocated to services. As shown above, the emissions from a transport service provider can
be allocated based on passenger-km or tonne-km per client. However, this allocation can
be also made from a different perspective, namely:
 at the company level (e.g. average for transport company);
 at the transport leg level (e.g. average between hubs);
 at the trip level - journey specific.
174
The company level (e.g. the average for a transport company)
Allocation of total emissions at the company level provides no data on the emissions
related to a specific transport service. Company level calculations are not complex, as no
detailed input on fuel consumption of a given service or trip is needed. Acceptability and
applicability of this alternative is therefore high amongst the transport operators, and
stakeholders in general. However, since the results cannot be generated for a specific
service, this option scores very low on the accuracy, comparability and relevance.
Consequently, it will not be taken into account for CountEmissions EU.
Transport leg level (e.g. average between hubs.)
Between hubs, where transport activities are performed with similar vehicle types, the
GHG intensity factors calculated for the allocation are usually representative for the
specific type of a service, and can be compared to other ones involving similar activities.
The relevance of this allocation is therefore high, provided that data on fuel consumption
is also detailed at the leg level. These data can be available for most companies, and tools
to perform this kind of allocation are already in use (e.g. BigMile). This option provides a
good insight in the network performance of an operator, and is quite well reflects actual
emissions generated by a specific service, with high accuracy and comparability.
Trip level - journey specific
Trip level allocation provides more detailed information on emissions generated during the
specific trip, and often reflect specific elements, such as weather and traffic conditions.
This results in a high score on the accuracy. Allocation at the trip level requires however
the provision of detailed information, e.g. on fuel consumption for this particular trip,
which makes this option less applicable and acceptable by stakeholders.
To conclude, to compare various transport services, the average performance at the leg
level is sufficient to provide valuable and relevant information, and hence it is most
relevant for the needs of CountEmissions EU. The allocation at the trip level might be
however considered in special cases, especially where more detailed service performance
data is required.
Table 98: Selected and discarded design alternatives for the methodological element ‘Allocation granularity’
Selected design alternatives Discarded design alternatives
— Transport leg level
— Trip level – journey specific
— Company level
Source: Ecorys and CE Delft (2023), Impact assessment support study
Flexibility in the calculation method
A number of the available methods allow for a significant level of flexibility for choosing
relevant methodological elements while calculating emissions. In this respect, several
distinctive approaches may be considered under CountEmissions EU, to account for
specific requirements regarding the choice of these methodological elements:
175
 The user can choose a methodological element from a predefined list, without
further restrictions;
 The choice of a methodological element depends on the stakeholder group applying
the calculations, and is adapted to data availability and common practice of this
stakeholder group;
 The available methodological elements are ranked from most preferable to least
preferable choices. These elements are labelled to express the quality of the
method.
 The methodological element with best accuracy, reproducibility and comparability
is prescribed for all users.
The different design alternatives related to the “Flexibility in the calculation method” and
their scores on the respective assessment criteria are discussed in more detail below.
The user can choose the methodological element from a predefined list without further
restrictions
Some of the current GHG methodologies allow more than one calculation choice. For
example, CEN EN 16258 recommends calculation on real distance metrics, but also
accepts SFD or GCD concepts for the distribution calculations. The applicability and
acceptability are therefore high, as this alternative allows users that are already applying a
specific methodological element to continue it without excessive hassle and
implementation costs. On the other hand, this approach very often leads to increased
ambiguity and may be considered as potentially hindering the comparability and
reproducibility of the emissions output data (TNO, 2021). Therefore, this design option
has not been considered for CountEmissions EU.
The required calculation option depends on the stakeholder group applying the calculations
The choice of a certain methodological element can also be differentiated according to the
type of users and their capability of performing calculations. For example, passenger
transport service operators may use actual data to express CO2-intensity values for the
allocation of emissions, whereas freight transport service operators may be required to use
intensity values based on SFD or GCD. This design alternative would have a good
acceptability and applicability amongst users as it shows a high degree of adaptability. Due
to better alignment in the method amongst stakeholders performing similar type of
activities, the accuracy, comparability and reproducibility of the resulting GHG emissions
data would score higher than in the first alternative above, at least for the individual
stakeholders’ groups.
The calculation options are ranked from most preferable to least preferable (and labelled)
Most of the current methods allow for more than one calculation alternative, but clearly
state a preference for one of the choices offered. For example, the concept ISO 14083
recommends the use of GHG emissions of energy production infrastructure, but allows
leaving them out when the underlying data are not available. The acceptability and
176
applicability therefore score well, and the accuracy, comparability and reproducibility are
marked at the same level as in the previous alternative
For this design alternative one may also consider that these preferences are labelled, clearly
differentiating between the best choice and the less preferred, alternative ones. This
approach would create additional incentives for the methodology users to adopt the best
quality label at the most convenient time..
The calculation alternative with best accuracy, reproducibility and comparability is
mandated for all users
This alternative mandates the most relevant methodological elements, enabling accuracy,
comparability and reproducibility of the GHG emissions data. However, the mandatory
component would likely translate in slightly lower acceptability and applicability by the
stakeholders. On the other hand, some specific requirements might apply as from a certain
date, and this date may be possibly differentiated for certain stakeholders’ groups.
Based on the attributed scores the last three design alternatives were selected for the
analysis of the most relevant reference GHG accounting methodology to be applied under
CountEmissions EU.
Table 99: Selected and discarded design alternatives for the methodological element ‘Flexibility in the calculation
method’
Selected design alternatives Discarded design alternatives
— The required calculation option depends on the
stakeholder group applying the calculations
— The calculation options are ranked from most
preferable to least preferable (and labelled)
— The calculation alternative with best accuracy,
reproducibility and comparability is mandated
for all users
— The user can choose the methodological
element from a predefined list without further
restrictions
Source: Ecorys and CE Delft (2023), Impact assessment support study
c) Preferred methodological design alternatives
Table 100 gives an overview of all 42 design alternatives, distinguished between those
selected as the most appropriate (green) and those that were discarded (orange) for defining
conditions for the proper reference methodology under CountEmissions EU.
Table 100: Overview of selected and discarded design alternatives per methodological element
Element Design options
Scope of emission calculation
Geographical
scope
Global European
Type of
emissions
included
CO2-emisisons non-CO2 GHG
emissions originating
from combustion of
fuel
non-CO2 GHG
emissions
originating from
refrigeration
177
Global warming
effect of
emission of
non-CO2
products (e.g.
water vapour,
contrails, NOx)
at high altitudes
Global warming effect
of black carbon
emissions
Activity
boundaries of the
methodology
Vehicle
propulsion
emissions
related from
energy use
(TTW)
Emissions from
auxiliary processes
(other than propulsion)
during vehicle
operation (TTW) (e.g.
cooling of freight)
Vehicle operation
emissions related
to leakage and
spills
Emissions from
hub activities
Emission from
energy
provision
(WTT),
excluding
energy
infrastructure
construction
Emission from
construction and
dismantling of energy
production
infrastructure
Life cycle GHG
emission of
vehicle
construction and
maintenance
Life cycle GHG
emission of vehicle
infrastructure
construction and
maintenance
Intended users Transport
service operator
Transport service
organiser
Transport service
user (excl.
organiser)
Use perspective Ex-post Ex-ante short term Ex-ante long term
scenarios
Emission
perspective
Service average
GHG emissions
Time/ situation
specific average GHG
emissions
Marginal GHG
emissions
The method of emission calculation and allocation to transport services
Minimum level of
granularity of
emission
calculation
Total GHG of
transport
operator
Total GHG emission
of transport service
user (freight) or
organiser
Transport service
type
Transport chain
element / leg
(average over
period)
Single vehicle Individual trip Total GHG
emissions of hub
operator
Per activity at hub
Allocation
parameter for
allocation to
transport services
Tonne-km passenger-km tonne-km SFD
passenger-km-
SFD
tonne-km GCD passenger-km-
GCD
Allocation
granularity for
allocation to
transport services
On company
level (e.g.
average for
transport
company)
transport leg level (e.g.
average between hubs)
Trip level -
journey specific
Flexibility in
calculation
method
The user can
choose the
calculation
option from a
predefined list.
The required
calculation option
depends on the
stakeholder group
applying the
calculations.
The calculation
options are
ranked from most
preferable to least
preferable
calculation option
and includes
labelling.
The calculation
option with best
accuracy,
comparability is
prescribed for all
users
178
Source: Ecorys and CE Delft (2023), Impact assessment support study
9. SELECTION OF THE REFERENCE METHODOLOGY
The reference methodology for CountEmissions EU may be newly developed within the
initiative, but may also be based on an existing or emerging method. This section provides
the rationale behind the choice of the most relevant methods, to be further included in
respective policy measures and policy options.
a) Overview of the existing and emerging methods
Table 101 outlines the most important GHG emissions accounting standards and
methodologies. Detailed description and assessment of these methods, as well as various
emissions calculating tools is provided in the technical support study
Table 101: Overview of the main standards and methodologies for GHG emissions accounting in the transport sector
Standard/methodology Transport
modes
covered
Geographical
coverage
Type of
instrument
Corporate value chain (scope 3) standard
of the GHG protocol
All modes World-wide Standard
CEN standard EN 16258 All modes EU Standard
ISO 14083 All modes World-wide Standard
Product Environmental Footprint (PEF) All modes EU Legislation with
methodology
Article L. 1431-3 of the French transport
code (Objectif CO2)
All modes* France Legislation with
methodology and
program (Objectif
CO2)
Parcel Delivery Environmental Footprint All modes
involved in
parcel
delivery
EU Standard
GLEC framework v1.0 All freight
modes*
World-wide Methodology
framework
SmartWay program All freight
modes*
North America Program and
methodology
Topsector Logistics method All freight
modes*
EU (mainly applied in
NL)
Methodology
Clean Cargo Working Group Carbon
Emissions Accounting Methodology
Sea transport
of containers
World-wide Program and
methodology
179
EU MRV Sea shipping EU Legislation with
methodology
IMO DCS Sea shipping World-wide Legislation with
methodology
CORSIA Aviation World-wide Program and
methodology
ICAO/IATA RP1678 Aviation
freight
World-wide Standard
IATA Recommended practice per-
passenger CO2-calculation Methodology
Aviation
passenger
World-wide Standard
EU ETS aviation Aviation EU Legislation with
methodology
Source: Ecorys and CE Delft (2023), Impact assessment support study
b) Shortlisted methods
Out of all the standards and methodologies presented above, five methods cover both
freight and passenger segments of the transport sector, and all transport modes. This is the
condition sine qua non for a single method for the quantification of emissions from all
types of transport services in the multimodal perspective. These methods were therefore
shortlisted as the potential reference methodologies for CountEmissions EU:
 Article L. 1431-3 of the French transport code (Objectif CO2)
 Corporate value chain (scope3) standard of the GHG protocol
 Product Environmental Footprint (PEF)
 CEN standard EN 16258
 ISO 14083.
These shortlisted methods were consequently compared and analysed with respect to the
design alternatives identified under section 2 as the most relevant for CountEmissions EU.
This is presented in Table 102 below.
Table 102: Comparing the shortlisted methods to the selected design alternatives
Policy elements Article L. 1431-
3 of the French
transport code
Corporat
e value
chain
(scope3)
PEF CEN standard
EN 16258
concept ISO 14083
Scope of emission calculation
Geographical
scope
France Global
Type of GHG
emissions
CO2-eq of combustion and refrigeration
180
Policy elements Article L. 1431-
3 of the French
transport code
Corporat
e value
chain
(scope3)
PEF CEN standard
EN 16258
concept ISO 14083
Activity
boundaries
WTW
propulsion and
auxiliary
processes (excl.
energy infra)
WTW propulsion and
auxiliary processes
(incl. energy infra) +
hubs leakages and
spills
WTW
propulsion and
auxiliary
processes (excl.
energy infra)
WTW propulsion and
auxiliary processes
(incl. energy infra) +
hubs, leakages and
spills
Intended user Transport
service operator,
organiser and
user
Transport
service
organiser
and user
Transport service operator, organiser and user
Use Perspective Ex-post and ex-ante short term
Emission
perspective
Service average
GHG emissions
Not defined (focus on
product/ company
average GHG
emission)
Service average GHG emissions
The method of emission calculation and allocation to transport services
Minimum level
of granularity of
emission
calculation and
allocation
leg level and trip
level
not
defined
not
defined
leg level and trip
level
leg level and trip level
and per hub activity
Metrics for
GHG intensity
factors and
allocation
Based on
passenger-km or
tonne-km
Not
defined
Not
defined
All alternatives Based on tonne-km or
passenger-km SFD or
GCD
Flexibility in
calculation
approach (e.g.
input data and
metrics)
The user can
choose the
metrics from a
predefined list
(not selected)
not
defined
not
defined
The user can
choose the
metrics from a
predefined list
(not selected)
The required
calculation method
depends on the
stakeholder group
applying the
calculations.
Source: Ecorys and CE Delft (2023), Impact assessment support study
As shown in Table 102, most of the selected design alternatives are covered by the existing
methodologies. There are, however, a few important caveats:
 Article L. 1431-3 of the French transport code applies a national scale. All other
methodologies apply a global scale. However, while the PEF methodology can be
technically implemented to account emissions from international transport chains,
it is not used elsewhere, thus creating issues for a potential global alignment.
 Article L. 1431-3 of the French transport code and the CEN standard do not cover
the emissions of leakages and spills, hub activities and the emissions of
construction and dismantling of energy production infrastructure. The other
methodologies do cover the emissions of all relevant transport/logistic activities.
181
 The corporate value chain (scope 3) standard does not consider transport operators,
but only transport users and organisers. The other methodologies do cover all types
of entities.
 The Corporate value chain (scope 3) standard and the PEF do not give specific
guidance on allocation of emissions for transport. Both methods allow for the
allocation rules, but these are not specified across the transport sector283
.
 Article L. 1431-3 of the French Transport Code recommends the use of the real
tonne-kilometres as allocation parameter instead of the preferred SCF or GCD
tonne-kilometres. Both the CEN standard and ISO do allow the use of these
allocation parameters for freight transport. ISO does, however, provide more
guidance on which allocation parameter should be applied.
 As for the methodological element ‘flexibility in calculation approach’, both
Article L. 1431-3 of the French Transport Code and the CEN-standard provide
more than preferred flexibility to the users on the approach to be chosen for the
calculations of GHG emissions. ISO 14084 does provide more specific guidance
on the calculation approach to be applied.
c) Screening the shortlisted methods
These five methodologies were screened on the following criteria:
 Completeness of methodology (does it address the selected design alternatives)
 Acceptability and applicability for users
 Accuracy and comparability
 Coherence with industry initiatives and other policy initiatives
Table 103 presents results of the screening analysis.
Table 103: Screening analysis of existing/emerging methodologies for CountEmissions EU
Methodology Completeness Acceptability and
applicability of
users
Accuracy and
comparability
Coherence with
industry initiatives
and other policy
initiatives
Article L. 1431-3
of the French
transport code
3 3 3 4
Corporate value
chain (scope3)
standard of the
GHG protocol
4 4 4 3
PEF / OEF 4 4 4 3
283
Within the framework of the PEF, currently specific calculation rules (i.e. category rules) are being
developed for aircrafts, which do include specific allocation rules for life cycle emissions of aircrafts.
182
CEN standard EN
16258
3 2 3 4
Draft ISO 14083 2 1 2 2
Scores from 1-5 range from high to low
Source: Ecorys and CE Delft (2023), Impact assessment support study
From the existing methodologies/standards, the (draft) ISO 14083 norm is most complete
on the scope and calculation/allocation methods (as shown in the previous section). It also
received a significant support from the stakeholders participating in various consultation
activities, including in the workshop and some individual interviews. Therefore, its
acceptability features high in the assessment. Accuracy and comparability of output data
were also ranked high, although the methodology leaves some room to users to make their
own decisions, which may slightly lower the score on this criterion. ISO 14083 has been
developed with the support of many stakeholders, based on GLEC and EU financed
research projects (COFRET, LEARN). The coherence with industry activities is therefore
considered to be at the good level. No specific inconsistencies with the policy framework
were identified either. Based on these remarks, the method has been selected as a specific
policy measure to be considered under CountEmissions EU.
From the other existing methodologies/standards, particularly CEN standard EN 16258,
and to a lesser extent, Article L. 1431-3 of the French transport code are considered
reasonable alternatives. Both are already in use, and therefore are very acceptable and
applicable for the market players. However, they have more limited methodological scope
compared to ISO 14083 concept, e.g. emissions of hubs and from leakages and spills are
not included. Also, the methodologies do not give direction on the use of specific
calculation options to be made, leaving considerable room to users to make their own
methodological decisions284
. Therefore, these methodologies produce less accurate and
comparable GHG emissions figures than those expected under ISO 14083. Furthermore,
Article L. 1431-3 of the French transport code is restricted for the use in France only, thus
negatively affecting its acceptability among broader stakeholders’ groups. Finally, EN
16258 has been withdrawn upon the publication of the ISO 14083, and therefore in the
medium and long perspective it would not be any more coherent with relevant industry and
regulatory initiatives. The same applies for Article L. 1431-3 of the French transport code,
which currently relies on EN 16258. For these reasons, CEN EN 16258 and Article L.
1431-3 of the French transport code have been discarded as policy measures.
As mentioned above, the Corporate value chain standard of the GHG protocol and the
general PEF framework do not give specific guidance for allocation of transport emissions
to transport services. Although highly valuable for accounting GHG emissions of
companies or products, these methods are considered less complete and accurate for
quantifying emissions at the specific transport service level. Consequently, they score
lower on the comparability of emissions data produced. Also their acceptability and
applicability do not feature high, since these methods do not give complete guidance on
how to effectively calculate emissions for various type of transport services. Furthermore,
these methods are not sufficiently aligned with specific needs of the transport sector (e.g.
284
For instance, the CEN standard allows the use of all relevant types of allocation parameters
183
concerning allocation rules), resulting in a medium score on the coherence. For these
reasons, also these two methodologies were discarded.
d) New reference methodology
In addition to the methods shortlisted above, a new, specific and tailored reference
methodology may be considered for CountEmissions EU. In this respect, the following
alternatives have been identified:
 A complete new reference methodology. This methodology should provide more
guidance to entities accounting emissions than the current/emerging
methodologies/standards, thus resulting in more accurate and comparable results.
The methodology will cover all preferred design alternatives discussed in Section
II.
 A new reference methodology based on ISO 14083, but with additional elements
and increased accuracy. This idea comes from the fact that ISO 14083 still provides
quite some flexibility to users. This may negatively affect the accuracy and
comparability of the GHG emission figures generated with the use of the common
framework. This new methodology, therefore, builds on ISO 14083 but provides
more guidance on specific methodological elements, including:
- Clear definition of a transport operation category (TOC) per market segment.
In ISO 14083, the transport chain category is defined as a group of operations
of a certain transport operator, with similar characteristics (e.g. the final leg
from a distribution centre to clients). The transport chain category is the level
at which emission are allocated to services, and for which relevant emission
intensity factor is applied (g/ tkm GCD or SFC). Within ISO, it is up to the user
to define the transport operation category. Different competitors might apply
differently the boundaries of a transport operation category, which may lead to
incomparable results. The new methodology may define precisely these rules.
- Time aggregation: ISO 14083 recommends to base the emission calculations
on annual average emissions on each transport leg, trip or hub activity but
allows different time periods as well, when explained by a user. A precise time
aggregation may be put forward by the new methodology per specific transport
segment;
- Allocation parameter: ISO 14083 provides users the opportunity to make use
of tonne-km GCD or SFD (for freight transport) and passenger-km GCD or
SFD (for passenger transport) as the allocation parameter. In this new reference
methodology only allocation based on GCD kilometres may be allowed;
- Alternatives for mass-based allocation: the tonne-km (real, SFD or GCD) is
usually applied as the standard allocation parameter. However, for some types
of freight transport (e.g. parcel delivery) other metrics than tonne-km are more
appropriate, e.g. m3
-km or container-km. ISO 14083 leaves it up to the user
whether they would like to use another metric. In this new methodology, this
metric may be clearly defined (and prescribed) for each transport segment;
184
- Inclusion of GHG emissions from the production of batteries for the electric
vehicles.
 New Product Environmental Footprint category rules for transport, including rules
for transport services. The general PEF framework does not provide much guidance
on the calculation of GHG emissions at the transport service level, as it was
discussed above. For this new methodology, therefore, specific category rules (i.e.
set of calculation rules) for transport may be developed. The PEF method already
offers a guide to develop emission factors (JRC, 2020a) and compliant emission
factors datasets (EC, 2022). With the category specific rules for transport, the
industry can further develop the environmental footprint calculation of their own
product (i.e. the movement of goods or people). Therefore, it is important that these
category rules allow the allocation of GHG emissions to services, like ISO 14083
(instead of physical goods). In line with the general approach followed within the
PEF, these category rules for transport would need to cover life cycle emissions, a
scope which is broader than in the other methodologies reported on the long list.
However, given the scope of CountEmissions EU, only GHG emissions (and not
other emission types and environmental impacts) would be considered.
e) Assessment of the relevance of the new methodologies
Table 104 presents the results of the screening analysis of the new methodologies on the
criteria identified in section III.c
Table 104: Screening analysis of new methodologies for CountEmissions EU
Methodology Completeness Acceptability and
applicability of
users
Accuracy and
comparability
Coherence with
industry initiatives
and other policy
initiatives
A new reference
methodology
1 5 1 N.A.
A new reference
methodology
referring to ISO
14083
1 3 1 3
New PEF category
rules for transport,
including rules for
transport services
2 3 2 3
Source: Ecorys and CE Delft (2023), Impact assessment support study
A completely new reference methodology would offer the opportunity to increase the
accuracy and comparability by providing more direction on specific methodological
elements and choices. However, it would score very low on the acceptability and
applicability of users, mostly due to the existence of specific and well recognised emissions
quantification initiatives that are already (or will be) used in the business practice (such as
ISO 14083 or CEN EN 16258), and the uncertainty concerning the technical process
related to the development and implementation of the methodology in the EU. In addition,
the development of the new methodology would require substantial time and efforts to
complete the work, and to ensure it is robust, consistent and applicable on the market. As
regards the criterion related to the coherence to industry and policy initiatives, it cannot be
185
reasonably assessed at this stage. Given all the arguments above, this alternative was not
retained for CountEmissions EU. This assessment is supported by the results of
stakeholders’ consultation where a number of stakeholders indicated the future
CountEmissions EU reference methodology should build on the existing methods.
If the new reference methodology builds on ISO 14083, it can be reasonably assumed that
it reflects most of the features of the standard, and to large extent takes into account the
results of stakeholders’ consultation organised during the process of its establishment. This
may be translated in fair acceptance and applicability on the market, as well as reasonable
coherence with relevant industry initiatives. On the other hand, the positive assessment
will be adversely affected by more stringent requirements related to specific
methodological choices, as presented above. One should note however, that these stricter
requirements would allow for the increased accuracy and comparability of the output data,
thus providing an argument for considering this method under CountEmissions EU, even
if it results in lower stakeholders’ support.
New Product Environmental Footprint Category Rules (PEFCR) for transport (including
specific rules for transport services) may represent an interesting but significantly more
complex alternative to ISO 14083. First, they are expected to feature fairly well on the
accuracy and comparability criterion, considering that robust rules could be developed to
address GHG WTW emissions, and these could be further complemented with relevant
elements of the LCA approach. As shown in Table 104, PEFCR will nevertheless score
lower on this criterion, given uncertainty on the accuracy of default values addressing
emissions from the production and dismantling of vehicles. Secondly, this method is
considered to be rather complete in terms of the coverage of the preferred methodological
design alternatives, however the level of this completeness cannot be evidenced in the
absence of specific PEFCR. In addition, PEFCR are expected to be much more demanding
on the data to be collected and the calculations to be executed with respect to the life-cycle
approach. Together with substantial efforts and time anticipated to produce a number of
specific PEFCR (however still lower than in the case of a completely new methodology),
these factors lower the score on acceptability and applicability. Finally, the PEFCR are
supposed to be well aligned with specific EU environmental policy initiatives (such as the
Single Market for Green Products) but they may not reach substantial level of alignment
with the leading industry initiatives, which would be rather based on WTW/TTW
emissions boundaries. As mentioned above, the idea of including the full LCA in
CountEmissions EU reference methodology received some support in the stakeholders’
consultation, but still lower than the WTW. However, given all the arguments above, the
new PEFCR for transport were retained for further assessment as a respective policy
measure.
f) Selected methods
Based on the analysis presented in the previous sections three methods were retained for
the assessment under respective policy options:
 ISO 14083;
 A new reference methodology based on ISO 14083, but with additional elements
and increased accuracy;
186
 New Product Environmental Footprint Category Rules for transport, including
rules for transport services.
187
ANNEX 9: EFFECTIVENESS OF THE DIFFERENT POLICY OPTIONS
This annex provides more detailed explanations on the assessment of effectiveness of the policy options, complementing the analysis in section 7.1.
     o     
Extremely
negative
Strongly
negative
Very
negative
Negative Moderately
negative
No or
negligible
impact
Moderately
positive
Positive Very
positive
Strongly
positive
Extremely
positive
PO1 PO2 PO3 PO4 PO5 PO6
Specific policy objective 1: Ensure the comparability of results from GHG emissions accounting of transport services
Expected
improvement of the
comparability of
GHG emissions data
shared in the
transport chains
(based on the relevant
methodology,
generated with
accurate input data,
and communicated
Strongly positive
impact on the
comparability.
The mandatory use of
a precise reference
methodology based
on the ISO standard
14083 (with
additional elements
Moderately positive
impact on the
comparability.
PO2 includes the ISO
standard 14083 as a
reference
methodology, and a
centralised approach
for the input data that,
once combined, may
Very positive impact
on the comparability.
The binding-in
(mandatory for those
that account and
disclose GHG
emissions data of
transport services)
application of a
Strongly positive
impact on the
comparability.
This option envisages
the binding-in
(mandatory for those
that account and
disclose GHG
emissions data of
Positive impact on
the comparability,
although lower than
in PO3.
This option includes a
very comprehensive
future LCA
methodology based
on specific transport-
Strongly positive
impact on the
comparability.
The mandatory use of
a conducive
methodology
established through
ISO standard 14083
will ensure increased
188
from trusted sources
in unambiguous and
clear manner)
and improved
accuracy) will ensure
increased accuracy of
the underlying factors
and formulas behind
the processes related
to the accounting of
emissions. On the
other hand, this
methodology will
require time and
resources to make it
completed and
eventually offered for
the use of
stakeholders in the
EU. In addition,
given the inclusion of
additional
methodological
elements, this choice
may lead to some
inconsistencies
between accounting
emissions practices in
the international
transport networks
(mostly affecting
maritime transport
and aviation).
Secondly, PO1
offer a high level of
comparability of
GHG emission
figures on the market.
However, PO2
envisages a voluntary
application of the
common
methodological
framework that
leaves its use to the
discretional decision
of the concerned
entities. The latter
feature may
eventually result in
lesser methodological
alignment on the
market in the short
and medium term,
thus significantly
lowering the score on
the comparability
criterion for this
option.
precise reference
methodology based
on the ISO standard
14083 (with
additional
components) will
ensure increased
accuracy of the
underlying factors
and formulas behind
the processes related
to the accounting of
emissions. On the
other hand, this
methodology will
require more time and
resources to make it
completed and
eventually offered for
the use of
stakeholders in the
EU. In addition,
given the inclusion of
additional
methodological
elements, this choice
may lead to some
inconsistencies
between accounting
emissions practices in
the international
transport networks
transport services)
application of more
conducive
methodology, namely
the new
(international) ISO
standard 14083. It
does not offer the
same level of
precision as
methodology
embedded in PO1 and
PO2, however it has
already been fully
developed and is
available for the
wider use in the
transport sector. What
is more, this
methodology is based
on a robust research
process, including an
extensive public
consultation, and
offers the opportunity
to align emissions
accounting
approaches in the
international transport
networks.
related Product
Environmental
Footprint Category
Rules. This
methodology will
enable to calculate
emissions in full
lifecycle perspective,
i.e. ‘from cradle to
grave’ and will be
mandated to all those
that account and
disclose GHG
emissions data of
transport services
(binding-in).
However, the
timescale and
resources necessary
to establish specific
PEFCRs would be
more important than
for the methodology
envisaged under PO1
and PO3. PEFCRs
do not exist yet and
would need to be
entirely developed. In
addition, the use of
this methodology will
likely result in even
accuracy of the
underlying factors and
formulas behind the
processes related to the
accounting of
emissions. It does not
offer the same level of
precision as
methodology
embedded in PO1 and
PO2, however it has
already been fully
developed and is
available for the wider
use in the transport
sector. What is more,
this methodology is
based on a robust
research process,
including an extensive
public consultation,
and offers the
opportunity to align
emissions accounting
approaches in the
international transport
networks.
On the other hand,
similarly as in PO3
and PO4, this option
enables, under specific
189
envisages fully
centralised, and EU-
controlled databases
of default values, thus
guaranteeing that all
input data used for
accounting emissions
comes from the same
source.
(mostly affecting
maritime transport
and aviation).
Secondly, this option
also enables, under
specific conditions,
the provision of
external emissions
intensity factors
databases. The
decentralised
approach may offer
more adequate default
values reflecting the
specificity of
respective segments
of the transport
sector, however it
eventually may lead
to some incoherence
between input data
used by various
entities accounting
emissions across the
EU.
On the other hand,
similarly as in PO3
and PO6, this option
enables, under
specific conditions,
the provision of
external emissions
intensity factors
databases. The
decentralised
approach may offer
more adequate
default values
reflecting the
specificity of
respective segments
of the transport
sector, however it
eventually may lead
to some incoherence
between input data
used by various
entities accounting
emissions across the
EU.
larger misalignment
with respect to the
existing emissions
accounting practices
in the transport
sector, and especially
at the international
level.
Secondly, PO1
envisages fully
centralised, and EU-
controlled databases
of default values, thus
guaranteeing that all
input data used for
accounting emissions
comes from the same
source. However, the
accuracy of these
default values may be
compromised by
significant degree of
uncertainty related to
the valuation of
emission factors in
the LCA perspective.
conditions, the
provision of external
emissions intensity
factors databases. The
decentralised approach
may offer more
adequate default
values reflecting the
specificity of
respective segments of
the transport sector,
however it eventually
may lead to some
incoherence between
input data used by
various entities
accounting emissions
across the EU.
PO1 PO2 PO3 PO4 PO5 PO6
Specific policy objective 2: Facilitate the uptake of GHG emissions accounting in business practice
190
(1) Expected increase
of use of the common
methodological
framework by
economic operators
and other relevant
entities
Extremely positive
impact on the use of
the common
methodological
framework
This option will
mandate the uptake of
CountEmissions EU
to all entities that are
involved in transport
services activities in
EU 27. This uptake
will be gradual until
2035, where it will
apply across the
board.
The uptake will be
further strengthened
by measures
increasing confidence
and trust in the GHG
emissions data on the
market: the
mandatory data and
process verification
system, and
centralised emissions
calculation tools
offered on the market
Positive impact on the
use of the common
methodological
framework.
This positive impact
is foreseen despite the
lax application of
CountEmissions EU
on the EU market and
the voluntary
verification system
for processes and
data. This assessment
is driven mostly by
the fact that PO2
includes a more
conducive
methodology (ISO
14083), recognises
the use of
CountEmissions EU
through a label, and
offers dedicated
emissions calculation
tools to be managed at
the central EU level.
The latter feature may
especially attract
interest of SMEs that
represent the majority
of entities operating
Moderately positive
impact on the use of
the common
methodological
framework.
PO3 will require the
use of the
CountEmissions EU
framework only from
those entities that
account and disclose
GHG emissions data
of transport services,
and therefore this
option will not reach
the same level of
uptake in the short and
medium term as it
would be the case of
fully mandatory
application.
What is more, PO3,
envisages the use of a
more comprehensive
methodology based
on ISO 14083, but
with additional
components, leading
to increased costs and
complexity for
businesses. This will
limit the uptake of the
Very positive impact
on the increase
uptakes of the GHG
emissions accounting.
PO4 will require the
use of the
CountEmissions EU
framework only from
those entities that
account and disclose
GHG emissions data
of transport services,
and therefore this
option will not reach
the same level of
uptake in the short and
medium term as it
would be the case of
fully mandatory
application.
However, PO4
envisages the
inclusion of a
conducive and well
recognised (existing)
methodology
provided by the ISO
standard 14083 that is
expected to result in
substantially higher
voluntary market
Moderately positive
impact on the use of
the common
methodological
framework, however
lower than in PO3.
Similarly as for PO3
and PO4, this option
will require the use of
the CountEmissions
EU framework only
from those entities
that account and
disclose GHG
emissions data of
transport services.
Therefore PO5 will
not reach the same
level of uptake in the
short and medium
term as it would be the
case of fully
mandatory
application.
What is more, PO5
envisages the use of
the most
comprehensive LCA
methodology, still to
be developed through
Extremely positive
impact on the use of the
common
methodological
framework
As PO1, this option
will mandate the
uptake of
CountEmissions EU to
all entities that are
involved in transport
services activities in
EU 27. This uptake
will be gradual until
2035, where it will
apply across the board.
PO6 envisages the
inclusion of a
conducive and well
recognised (existing)
methodology provided
by the ISO standard
14083. This process
will be supported
through the provision
of a verification
system for processes
and data (for large
companies), and the
certification of
emissions calculation
191
by the EU.
This option (together
with PO6) proves to
be the most effective
option in terms of
uptake increase,
totalling additional
918,003 companies in
2030 and 1,703,841
companies by 2050
relative to the
baseline. Out of the
total number of
companies
accounting for GHG
emissions of transport
services, 915,130
SMEs and 2,873
large companies by
2030, and 1,699,423
SMEs and 4,418
large companies by
2050 relative to the
baseline.
on this market. PO2
will increase the
uptake by 30,219
companies in 2030
and 1,388 companies
by 2050 relative to the
baseline. Out of the
total number of
companies accounting
for GHG emissions of
transport services,
29,586 SMEs and 633
large companies by
2030, 1,361 SMEs
and 27 large
companies by 2050
relative to the
baseline.
framework, despite
the increased level of
trust in GHG
emissions figures,
ensured through the
provision of a
verification system
for processes and data
(for large companies),
and the certification
of emissions
calculation tools
developed by the
market. PO3 will
increase the uptake
by 26,745 companies
in 2030 and 3,640
companies by 2050
relative to the
baseline. Out of the
total number of
companies
accounting for GHG
emissions of transport
services, 25,611
SMEs and 1,134
large companies by
2030, 3,139 SMEs
and 501 large
companies by 2050
relative to the
baseline.
uptake. This process
will be supported
through the provision
of a verification
system for processes
and data (for large
companies), and the
certification of
emissions calculation
tools to be developed
by the market. PO4
will increase the
uptake by 39,358
companies in 2030
and 9,139 companies
by 2050 relative to
the baseline. Out of
the total number of
companies
accounting for GHG
emissions of transport
services, 38,224
SMEs and 1,134
large companies by
2030, 8,638 SMEs
and 501 large
companies by 2050
relative to the
baseline.
specific PEFCRs.
This choice will lead
to increased
implementation costs
and additional
complexity for
businesses, thus
limiting the uptake of
the framework over
time.
The above factors
will result in slightly
positive score for this
criterion, despite the
increased level of
trust in GHG
emissions figures,
ensured through the
provision of a
verification system
for processes and data
(for large companies),
and the certification
of emissions
calculation tools
developed by the
market. PO5 will
increase the uptake
by 25,102 companies
in 2030 and 2,783
companies by 2050
relative to the
tools to be developed
by the market. This
option (as PO1) proves
to be the most
effective option in
terms of the uptake
increase, totalling
additional 918,003
companies in 2030 and
1,703,841 companies
by 2050 relative to the
baseline. Out of the
total number of
companies accounting
for GHG emissions of
transport services,
915,130 SMEs and
2,873 large companies
by 2030, and
1,699,423 SMEs and
4,418 large companies
by 2050 relative to the
baseline.
192
baseline. Out of the
total number of
companies
accounting for GHG
emissions of transport
services, 24,006
SMEs and 1,096
large companies by
2030, 2,320 SMEs
and 463 large
companies by 2050
relative to the
baseline.
Expected decrease in
the well-to-wheel
GHG emissions
Extremely positive
impact on the
expected decrease in
the well-to-wheel
GHG emissions
The reduction in
WTW GHG
emissions is strongly
correlated with the
level of uptake of the
framework addressed
above.
PO1 will effectively
reduce 22.1 million
tonnes of GHG
cumulative emission
over the period 2025-
Positive impact on the
expected decrease in
the well-to-wheel
GHG emissions
The reduction in
WTW GHG
emissions is strongly
correlated with the
level of uptake of the
framework addressed
above.
PO2 will effectively
reduce 3.7 million
tonnes of GHG
cumulative emission
over the period 2025-
Moderately positive
impact on the
expected decrease in
the well-to-wheel
GHG emissions
The reduction in
WTW GHG
emissions is strongly
correlated with the
level of uptake of the
framework addressed
above.
PO3 will effectively
reduce 1.7 million
tonnes of GHG
cumulative emission
over the period 2025-
Very positive impact
on the expected
decrease in the well-
to-wheel GHG
emissions
The reduction in
WTW GHG
emissions is strongly
correlated with the
level of uptake of the
framework addressed
above.
PO4 will effectively
reduce 5.6 million
tonnes of GHG
cumulative emission
over the period 2025-
Moderately positive
impact on the
expected decrease in
the well-to-wheel
GHG emissions
The reduction in
WTW GHG
emissions is strongly
correlated with the
level of uptake of the
framework addressed
above.
PO5 will effectively
reduce 1.5 million
tonnes of GHG
cumulative emission
over the period 2025-
Extremely positive
impact on the expected
decrease in the well-to-
wheel GHG emissions
The reduction in WTW
GHG emissions is
strongly correlated
with the level of uptake
of the framework
addressed above.
PO1 will effectively
reduce 22.1 million
tonnes of GHG
cumulative emission
over the period 2025-
2050.
193
2050. 2050. 2050. 2050. 2050.
194
ANNEX 10: SME TEST
Step (1) of the SME test (identification of affected businesses).
Directly affected. SMEs in the scope of CountEmissions EU: all SMEs
in the NACE sub-sectors involved in transport services activities
(1,767,702 companies according to Eurostat285
) would fall under the
broad scope of CountEmissions EU. It should be noted that SMEs
represent 99.7% of the companies in the sub-sectors involved in
transport services activities. Based on desk research and information
obtained through the stakeholders’ consultation, it is estimated that the
number of SMEs quantifying their emissions at the transport service
level was around 21,342 in 2020. These SMEs will be directlyaffected.
Indirectly affected. The number of SMEs indirectly affected will be
larger, since they often are part of complex transport chains (especially
in freight transport). Emissions measurement and calculation is
increasingly required to meet expectations of investors or address
specific regulatory requirements. To some extent, large companies will
therefore require the provision of service level emissions information
from SMEs, thus incentivising the uptake of the CountEmissions EU
framework. This assumption has been reflected in the projections made
for the three applicability measures: PM13 (Mandatory application),
PM14 (Binding opt-in application) and PM15 (Voluntary opt-in
application).
See sections 6.1.7
(Impacts on small
and medium
enterprises) and
Annex 4
Step (2) of the SME test (consultation of SME stakeholders).
Targeted questions were included in the consultation activities to sick
the SMEs’ views. The methodological approach consisted in gathering
specific data on SMEs and micro-enterprises from stakeholders
(through the OPC, targeted survey and targeted interviews), notably in
relation to the costs for the GHG accounting,but also potential benefits.
SMEs were requested to identify themselves, thus allowing a specific
analysis of SME responses and a comparison with other respondents.
Targeted consultations. The survey questionnaires and interviews
included tailored questions for SMEs. 10 out of 39 respondents to the
survey questionnaire in the targeted stakeholders’ consultation
identified themselves as SMEs. In addition, 4 of the 39 stakeholder
interviews were conducted with representatives of SMEs. These
activities were complemented with specific case studies on the
experiences of SMEs with emissions accounting at service level.
Open Public Consultation. The OPC was organised from to 25 July to
See Annex 2
(Stakeholder
consultation)
285
https://nacev2.com/en/activity/transportation-and-storage
195
20 October 2022. The public consultation was extended by 3 days in
order to give stakeholders more time to reply. 100 out of 161
respondents to the OPC identified themselves as SMEs (those that
replied to the specific question).
Step (3) of the SME test (assessment of the impacts on SMEs).
Direct impacts on SMEs. Total costs for SMEs are estimated to be the
highest in PO1 (EUR 0.5 billion in 2025, EUR 3.9 billion in 2030 and
EUR 6.3 billion in 2050), followed by PO6 (EUR 344.7 million in
2025, EUR 2.8 billion in 2030 and EUR 4.5 billion in 2050), then at
large distance by PO5 (EUR 101.2 million in 2025, EUR 156.4 million
in 2030 and EUR 37.4 million in 2050), PO4 (EUR 68 million in 2025,
EUR 115.4 million in 2030 and EUR 19.9 million in 2050), PO3 (EUR
57.9 million in 2025, EUR 103.8million in 2030 and EUR 11.9 million
in 2050) and PO2 (EUR 50.9 million in 2025, EUR 93.9 million in
2030 and EUR 4.7 million in 2050). The breakdown of the total costs
between adjustment and administrative costs and by measure is
provided in Table 105 and Table 106. As already explained, while
under PO2, PO3, PO4 and PO5 the application of CountEmissions EU
in the transport sector is voluntary (i.e. voluntary opt-in with a label in
PO2 and binding opt-in in PO3, PO4 and PO5), PO1 and PO6 foresee
the mandatory application and thus leads to significantly higher costs.
At the same time, PO2 results in the lowest total costs among the
options, due to the voluntary opt-in foreseen by this option.
Expressed as present value over 2025-2050, the total costs for SMEs in
PO1 are estimated at EUR 93.8 billion relative to the baseline, for PO6
EUR 67.2 billion relative to the baseline, for PO5 at EUR 1.8 billion,
for PO4 at 1.4 billion, for PO3 at EUR 1.1 billion and for PO2 at 1
billion. The highest share ofthetotal costs for each policyoption relates
to adjustment costs for setting of a common reference methodology at
EU level (94% and 89% of the total costs in PO4 and PO6 respectively
for ISO 14083, 91% in PO3 for ISO 14083 with additional elements
and increased accuracy, 88% in PO2 for ISO 14083, 85% in PO1 for
ISO 14083 with additional elements and increased accuracy and 73%
in PO5 for PEFCR). The second category of costs in terms of the share
of the total costs relates to the use of the calculation tools. On the other
hand, as the verification of data and processes (PM9) is not imposed on
SMEs PO3 and PO4 result in adjustment costs savings related to the
verification activities. Due to the higher number of companies involved
compared to PO3 and PO4, and the assumption that a certain
proportion of SMEs would however undergo the verification activities,
these costs savings do not result in PO6. Administrative costs for the
calculation tools developers, related to the certification of the tools286
,
See sections 6.1.7
(Impacts on small
and medium
enterprises) and
Annex 4
286
In the assessment it has been assumed that the calculation tool developers are SME.
196
represent 0.03% of the total costs in PO3 and 0.02% in PO4 and PO5.
All policy options are expected to incentivise behavioural change,
leading to higher use of more sustainable transport modes and
optimised trips. Thus, all policy options are expected to lead to energy
costs savings for SMEs relative to the baseline (see Table 105 and
Table 106). Expressed as present value over 2025-2050, they are
estimated at EUR 9.9 billion in PO1 and PO6, followed by PO4 (EUR
2.3 billion), PO2 (EUR 1.5 billion), PO3 (EUR 0.7 billion) and PO5
(EUR 0.6 billion).
PO2 and PO4 are estimated to result in net benefits for SMEs relative
to the baseline. PO4 would lead to the highest net benefits estimated at
EUR 43.7 million in 2025, EUR 70 million in 2030 and EUR 28.1
million in 2050 relative to the baseline, while PO2 at net benefits of
EUR 23.1 million in 2025, EUR 46.7 million in 2030 and EUR 2.2
million in 2050. On the other hand, PO1, PO3, PO5 and PO6 are
estimated to result in net costs (see Table 105 and Table 106).
Expressed as present value over 2025-2050, the net benefits for PO2
and PO4 are estimated at EUR 0.5 billion and EUR 0.9 billion,
respectively, while the net costs in PO1 at EUR 83.9 billion, in PO6 at
EUR 66.6 billion, in PO5 at EUR 1.3 billion and in PO3 at EUR 0.4
billion.
Indirect impacts on other SMEs. A higher number of SMEs from
sectors not directly related to transport or performing transport services
on their own may be involved in accounting their GHG emission
performanceduetothe increaseddemand in the context ofthe transport
chains. However, the precise number is not possible to quantify.
Step (4) of the SME test (minimizing negative impacts on SMEs).
Minimizing negative impacts. The following topics appeared as
relevant for the SMEs in the stakeholders’ consultation: the potential
costs (burden), the effects on competitiveness in procurement
processes, and the insufficient number of skilled staff to implement
GHG emissions accounting. As regards the cost element, SMEs’
concerns included the insufficient availability of data (especially
primary data) for the quantification of GHG emissions and additional
resources needed to comply with specific requirements under the
initiative.
Firstly, it should be noted that the voluntary opt-in and binding opt-in
in policy options PO2, PO3, PO4, PO5 give SMEs the possibility to
decide if to undergo GHG emissions accounting of their transport
services according to the harmonised method. Secondly, PO3, PO4,
PO5 but also PO6 envisage a measure exempting SMEs from the
mandatory verification of GHG emissions data (PM9), thus allowing
SMEs to choose, and to lower potential costs. Thirdly, measures
See sections 6.1.7
(Impacts on small
and medium
enterprises), 7
(How do options
compare), 8
(Preferred policy
option), Annex 4
197
dealing with the use of input data (PM4 and PM5) provide relatively
higher benefits for SMEs than for large companies. The problems of
data availability are generally experienced more acutely by SMEs and
such companies tend to rely on default values because of their high
costs to collect primary data. Given the particular difficulties faced by
SMEs with the GHG accounting at service level, the analysis has also
shown that they would benefit more than larger operators of
harmonised guidelines (PM7), as well as, of dedicated calculation tools
either established at the EU level (PM11), or provided by the market
and certified at EU level (PM12). Finally, the harmonised formats for
the output data (PM6) would also result in relatively higher benefits
for SMEs that usually do not have sufficient resources to analyse
various data elements provided by third parties in the transport chain.
Alternative options. The impact assessment considered the alternative
measure of mandating the use of primary data for the quantification of
GHG emissions from transport services. This option was not retained
on the grounds of efficiency and proportionality.
Table 105: Total costs and benefits for SMEs in PO1, PO2 and PO3 relative to the baseline (EU27), in million EUR
(2022 prices)
Difference to the Baseline
PO1 PO2 PO3
2025 2030 2050 2025 2030 2050 2025 2030 2050
Recurrent and one-off costs 490.8 3,866.2 6,288.2 50.9 93.9 4.7 57.9 103.8 11.9
Adjustment costs 490.8 3,866.2 6,288.2 50.9 93.9 4.7 57.8 103.8 11.9
Administrative costs 0.00 0.00 0.00 0.00 0.00 0.00 0.02 0.02 0.02
Benefits (energy costs
savings) 51.7 390.7 775.1 74.0 140.6 6.9 37.2 83.6 2.4
Net costs/costs savings 439.1 3,475.5 5,513.1 -23.1 -46.7 -2.2 20.7 20.2 9.5
Source : Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs
savings, where relevant.
Table 106: Total costs and benefits for SMEs in PO4, PO5 and PO6 relative to the baseline (EU27), in million EUR
(2022 prices)
Difference to the Baseline
PO4 PO5 PO6
2025 2030 2050 2025 2030 2050 2025 2030 2050
Recurrent and one-off costs 68.0 115.4 19.9 101.2 156.4 37.4 344.7 2,767.6 4,501.4
Adjustment costs 68.0 115.4 19.9 101.2 156.4 37.3 344.7 2,767.5 4,501.4
Administrative costs 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02
Benefits (energy costs savings) 111.7 185.4 48.0 33.6 77.0 2.2 111.7 185.4 48.0
Net costs/costs savings -43.7 -70.0 -28.1 67.6 79.5 35.1 233.0 2,582.1 4,453.4
Source : Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs
savings, where relevant.
198
Table 107: Recurrent and one-off costs for SMEs by policy measure in PO1, PO2 and PO3 relative to the baseline
(EU27), in million EUR (2022 prices)
Difference to the Baseline
PO1 PO2 PO3
2025 2030 2050 2025 2030 2050 2025 2030 2050
Adjustment costs 490.8 3,866.2 6,288.2 50.9 93.9 4.7 57.8 103.8 11.9
PM1 - ISO 14083 set as
common reference
methodology
44.8 82.2 4.0
PM2 - PEFCR set as common
reference methodology
PM3 - ISO 14083 with
additional elements and
increased accuracy set as
common reference
methodology
412.2 3,270.1 5,317.4 52.9 94.2 11.2
PM8 - Mandatory process
and data verification for all
entities
41.1 294.7 479.9
PM9 - Mandatory process
and data verification for
entities above certain size
0.0 0.6 -1.3
PM10 - Voluntary process
and data verification for all
entities
2.9 5.0 2.3
PM11 - Emissions calculation
tools are provided at EU level
37.6 301.4 490.8 3.1 6.6 -1.6
PM12 - Emissions calculation
tools are provided by the
market but they are certified
at EU level
4.9 9.1 2.1
Administrative costs 0.00 0.00 0.00 0.00 0.00 0.00 0.02 0.02 0.02
PM12 - Emissions calculation
tools are provided by the
market but they are certified
at EU level
0.02 0.02 0.02
Total net costs 490.8 3,866.2 6,288.2 50.9 93.9 4.7 57.9 103.8 11.9
Source : Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs
savings, where relevant.
Table 108: Recurrent and one-off costs for SMEs by policy measure in PO3, PO4 and PO6 relative to the baseline
(EU27), in million EUR (2022 prices)
Difference to the Baseline
PO4 PO5 PO6
2025 2030 2050 2025 2030 2050 2025 2030 2050
Adjustment costs 68.0 115.4 19.9 101.2 156.4 37.3 344.7 2,767.5 4,501.4
PM1 - ISO 14083 set as common
reference methodology
63.2 106.1 21.5 310.1 2,471.7 4,019.4
PM2 - PEFCR set as common
reference methodology
80.7 123.8 14.1
PM3 - ISO 14083 with additional
elements and increased accuracy set
as common reference methodology
PM8 - Mandatory process and data
verification for all entities
199
PM9 - Mandatory process and data
verification for entities above certain
size
0.0 0.5 -1.7 5.9 9.1 7.1 4.7 46.5 75.9
PM10 - Voluntary process and data
verification for all entities
PM11 - Emissions calculation tools
are provided at EU level
PM12 - Emissions calculation tools
are provided by the market but they
are certified at EU level
4.8 8.9 0.1 14.7 23.6 16.1 29.8 249.4 406.1
Administrative costs 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02
PM12 - Emissions calculation tools
are provided by the market but they
are certified at EU level
0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02
Total net costs 68.0 115.4 19.9 101.2 156.4 37.4 344.7 2,767.6 4,501.4
Source : Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs
savings, where relevant.
200
ANNEX 11: CASE STUDIES AND USE CASES
This annex includes two case studies (the US SmartWay program and the SNCF287
initiative based on Article L. 1431-3 of the French Transport Code) and four use cases
(eco-labelling of transport services, sustainable delivery services, permit to enter low or
zero emissions zones, green public procurement) supporting the evidence underlying the
impacts and potential applications of CountEmissions EU.
1- Case study of United States Environmental Protection Agency SmartWay
Program
Brief Description
SmartWay is a voluntary partnership program established in 2004 by the US
Environmental Protection Agency (EPA) to reduce greenhouse gas emissions and air
pollution from the freight transportation industry. It aims to improve environmental
performance, energy efficiency, and sustainability in the sector, which includes trucking,
rail, maritime, and logistics operations. The EPA has also collaborated with counterparts
in Canada to establish (in 2012) a Canadian branch of the SmartWay program. More than
4000 North American companies are now part of the partnership with at least 3500 of those
coming from the United States. This case study focuses on the US EPA program.
Emissions accounting is a key component of the SmartWay system that helps participants
monitor their environmental performance and identify areas for improvement. The
program provides specific tools and resources (split by mode and activity) for participants
to accurately measure, benchmark, and report their emissions, including: greenhouse gases
(GHG), nitrogen oxides (NOx), and particulate matter (PM).
GHG accounting: drivers, scope, choices in accounting methodology
Key aspects of the SmartWay program's emissions accounting approach include:
 Data collection: participants provide information on their fleet's operations, fuel
consumption, and emissions, which is then used to calculate their environmental
performance.
 Emissions quantification: the EPA has developed tools which use standardised
methodologies and emissions factors to help participants quantify their emissions
and energy consumption. These tools are provided for: logistics companies; truck
carriers; rail carriers; air carriers; barge carriers; and shippers. A user guide is
developed for each tool and partners submit data annually.
 Performance benchmarking: since 2011 the initiative enables participants to
compare their environmental performance with industry averages and peer groups,
which promotes best practices and helps identify opportunities for improvement.
287
Société nationale des chemins de fer français: national rail operator in France
201
 Reporting and recognition: participants are encouraged to report their emissions
data and progress towards meeting their environmental goals. The EPA recognises
high-performing partners with awards and public acknowledgment, promoting a
culture of continuous improvement.
 Collaboration and sharing: the initiative fosters collaboration among stakeholders
to share knowledge, experience, and best practices in emissions reduction and
efficiency.
It is important to acknowledge the benchmarking and reporting dimension of the program,
which provides additional functionality with respect to the current scope of
CountEmissions EU. SmartWay is designed to take advantage of competitive pressures in
the transportation market by providing purchasing managers with environmental
performance information that shippers can use to assess and select firms based on their
environmental performance.
SmartWay has three types of partners: shipper partners (organisations that ship freight);
carrier partners (businesses that carry or move goods for shippers); and logistics company
partners (firms that hire freight carriers and manage freight shipments for shippers). There
is also an ‘affiliates’ category for organisations that do not fall into these categories but
want to participate in SmartWay. Note that deep sea shipping is not included into the scope
at this moment, however SmartWay has a memorandum of understanding (MoU) with the
Clean Cargo Working Group to include their ocean going freight trade lane emission
factors into SmartWay, and SmartWay is initiating coding changes in the tools and
database to execute on this aspect. Emissions from transhipment points (e.g. ports, hubs,
DCs) are not included into the scope at the moment. However, SmartWay is exploring the
potential to include emissions from distribution hubs.
The headline incentive from SmartWay (to encourage voluntary participation) is an
integrated set of no-cost, peer-reviewed sustainability accounting and tracking tools to help
companies make informed freight transport choices. These tools are then supposed to help
registered partners to measure, benchmark, and report emissions and to improve freight
efficiency and environmental performance across their supply chain.
SmartWay computes different KPIs for the different user types as shown directly below288
:
288
Davydenko, I., et al. "Towards harmonization of Carbon Footprinting methodologies: a recipe for
reporting in compliance with the GLEC Framework, Objectif CO2 and SmartWay for the accounting tool
BigMile™." TNO Report 11486 (2019).
202
Table 109: SmartWay KPIs
Source: Ecorys and CE Delft (2023), Impact assessment support study
Methods and tools
SmartWay is centred on the use of tools, which are mentioned in the previous section. The
computations are hidden from the user. The underlying detailed methodology is provided
in the documents related to each tool, which can be found (updated each year) on the
SmartWay website.
The general SmartWay methodological approach is similar to other common carbon
accounting methods for freight transport (e.g. GLEC). Fuel and energy use are converted
to emissions, which are divided by the transport activity to calculate the performance
metrics. Both fuel/energy use and transport activity are input per year and then
disaggregated:
203
Figure 13: SmartWay approach
Source : Ecorys and CE Delft (2023), Impact assessment support study
It should be noted that the SmartWay methodology enables to produce not only CO2
emission output, but also computes emissions of other pollutants (NOx, PM2.5, PM10 and
black carbon). SmartWay provides a conversion table for the quantity of fuel expressed in
gallons to be converted into grams of CO2. The table provides Tank-To-Wheel (TTW)289
conversion factor for CO2 emissions290
. Emissions related to cooling (e.g. reefer) are also
included in the calculation. It should be noted that SmartWay does not include any
guidance on emissions related to infrastructure and vehicles production chain.
Impacts and costs
The impacts associated with the implementation of SmartWay have been reported by EPA
since 2004. SmartWay currently (as of 2022) claims to generate a saving of 357 million
barrels of oil- equivalent along with the avoidance of 152 million metric tons of CO2, 2.7
million short tons of NOx, and 112,000 short tons of PM since 2004 by its partners.291
SmartWay further claims a total fuel cost saving for the industry of USD 47.6 billion,
which contributes directly to lower consumer costs. The program highlights that the
distribution of positive impacts is overwhelmingly in communities near ports, borders and
289
Davydenko, I., et al. "Towards harmonization of Carbon Footprinting methodologies: a recipe for
reporting in compliance with the GLEC Framework, Objectif CO2 and SmartWay for the accounting tool
BigMile™." TNO Report 11486 (2019).
290
https://app4.erg.com/smartwayweb/portal/download/SmartWay_2021_LTL_Carbon_Calculator_Technical
_Documentation.pdf
291
See: https://www.epa.gov/smartway/smartway-program-successes; or alternatively the SmartWay
Program Highlights for 2022 at https://www.epa.gov/system/files/documents/2023-02/420f23007.pdf
204
truck stops. However, the methodology used to arrive at these figures is not officially
provided.
There has not been a large amount of detail collected on costs associated with SmartWay.
The EPA budget allocated directly to SmartWay is not revealed as a line item in EPA
budget plans. However, it is assumed that between 2004 and 2011 the program reportedly
provided more than USD 30 million in financing to help truck owners, especially small-
and medium-sized firms, buy cleaner, more fuel-efficient trucks. It had a direct
administrative budget over that period of USD 1.5 million.
The participating stakeholders classify economic costs in three distinct categories:
administrative, investment and ongoing operational.
Administrative costs: participation in the SmartWay program requires time and resources
for data collection, emissions accounting, and reporting. These efforts may include staff
time, software, and training expenses. Although these are limited with the use of
centralised tools. In addition to the resource demand imposed on carriers, the SmartWay
team at EPA expend a sizable percentage of their staffing budgets on administrative
activities to ensure collection and management of good quality data from the partners
(access to this data is a large part of the value of the program).
Investment costs: to improve environmental performance, participants invest in more fuel-
efficient vehicles, technologies, or infrastructure. Primarily to reduce fuel use or freight
activity. Examples include the adoption of aerodynamic equipment, low-rolling-resistance
tires, or anti-idling technologies. These activities result in additional capital costs, but these
costs are arguably taken based on more transparent and precise information related to the
future emissions reduction and the associated costs savings.
Ongoing operational costs: Companies may face higher ongoing operational costs, such as
increased maintenance expenses or additional training for drivers to adopt more fuel-
efficient driving practices. Again, these costs are evidently incurred based on more
transparent and precise information stemming from the calculated levels of emissions.
The evolution of costs associated with data collection
One of the most critical elements of SmartWay is the data collection and benchmarking.
Trucking companies that participate in SmartWay are responsible for completing annual
reports that require data related to operations, including fleet composition, activity
summaries, fuel consumption, etc. These reports are prepared manually and the time
needed to complete SmartWay submissions varies from a few hours up to several days
according to stakeholder interviews292
. The variation results from: the fleet’s size and
sophistication (in its data recording practices); and familiarity with the SmartWay
reporting process.
The emergence of IT technologies, driven to a large extent by regulatory requirements that
commercial drivers maintain electronic logs, provides a strong future opportunity to
292
Sharpe, Ben. "Modernizing data collection and reporting methods for the SmartWay Program." (2019).
205
standardise and automate data collection, management and reporting processes. In addition
to providing location tracking, telematics systems and electronic logging devices (ELDs)
connect to on-board diagnostic (OBD) ports in vehicles and thus have access to the
extensive operations data collected by various systems such as the engine, emissions
aftertreatment systems, transmission and driveline, and chassis.
Data collection and quality assurance represents a significant percentage of fleets’ overall
time spent engaging with the SmartWay program. Automating SmartWay data collection
and submission is a value proposition for fleets, SmartWay staff, and telematics providers.
All of the interviewees in 2019 research conducted by Ben Sharpe expressed a desire for
SmartWay to modernize the data collection and reporting methods293
. The fleet and
trucking association representatives stated that automating much of the SmartWay data
process could save them time and money and allow them to participate more fully in the
program.294
A common theme in the interviews was also that data privacy must be a major
focus if automatic data collection is to be successfully implemented.295
A telematics
company interviewed, reported that they would soon market automatic SmartWay report
creation to prospective customers. Costs are expected to reduce.
Benefits
As summarised earlier, among the benefits claimed to result directly from the program are:
 Fuel savings: By adopting more fuel-efficient technologies and practices, companies
can save on fuel costs. According to the EPA, from 2004 to 2022, SmartWay partners
saved over 357 million barrels of oil, which translates to a cost savings of more than
USD 47.6 billion.
 Emission reductions: SmartWay partners have significantly reduced their emissions,
improving air quality and mitigating climate change. As of 2022, the EPA reported that
partners had prevented the 152 million metric tons of CO2, 2.7 million short tons of
NOx, and 112,000 short tons of PM.
 Enhanced reputation: By participating in the initiative, companies can demonstrate
their commitment to sustainability and environmental responsibility. This can lead to
improved brand image, customer loyalty, and potential business opportunities.
 Cost-sharing and collaboration: Participation in the SmartWay Initiative provides
opportunities to collaborate with other stakeholders, share best practices, and access
resources to reduce the costs associated with implementing sustainable solutions.
SmartWay enables companies across the supply chain to exchange performance data.
With consistent, quality-checked information and tools, SmartWay helps companies
spend less time figuring out their freight supply chain footprints.
293
Sharpe, Ben. "Modernizing data collection and reporting methods for the SmartWay Program." (2019).
294
Sharpe, Ben. "Modernizing data collection and reporting methods for the SmartWay Program." (2019).
295
Sharpe, Ben. "Modernizing data collection and reporting methods for the SmartWay Program." (2019).
206
 Regulatory compliance: By proactively reducing emissions and adopting cleaner
technologies, companies can stay ahead of potential future regulations and avoid
potential fines and penalties.
While all other benefits are claimed by the program itself, recent (2023) research by Scott
and co-authors evaluates the SmartWay Program by using a method to assess the
investment decisions and performance of the SmartWay partner (trucking) companies
against non-partner companies296
. The results demonstrate that participation in the EPA
SmartWay program can facilitate a significant reduction in greenhouse gas emissions,
especially due to investments in newer trucks and cleaner technologies. The analysis
estimated that between 2012 and 2019 the SmartWay Program reduced commercial
transport-related emissions from operations by 25.2 million metric tons of CO2 (equivalent
of almost 15.2 billion truck-miles) by increasing the incentive to invest in newer, cleaner
trucks alone. These research results suggest the EPA program level claims are credible.
2- Case study of the SNCF GHG calculation methodology for transport services:
application of Article L. 1431-3 of the French Transport Code297
Brief description
The calculation methodology used by the SNCF complies with the methodological guide
published by the French government as regards the calculation and declaration of GHG
emissions of transport298
.
In order to promote lowest emissions in transport, Article L.1431-3 of the French Transport
Code establishes that any persons who market or organize a transport service for people,
goods or removals must provide the beneficiary of the service with information on the
quantity of GHG emitted by the mode or modes of transport used to provide this service.
Articles from D. 1431-1 to D. 1431-23 of the Code set the calculation principles common
to all modes of transport. They specify the procedures for informing the beneficiary as well
as the timetable for implementing the provisions. The methodology is based on the
European standard relating to the calculation and declaration of energy and GHG emissions
from transport services (CEN EN 16258).
The quantities of GHGs taken into account are those emitted during the operation of modes
of transport and those originating from the upstream phase of production of energy sources
(e.g., refining, transport, distribution, etc.). The information on the quantity of GHG
emitted is determined for each segment of the itinerary travelled during the transport
activity.
GHG accounting: drivers, scope, choices in accounting methodology
296
Scott, Alex, et al. "Do voluntary environmental programs matter? Evidence from the EPA SmartWay
program." Journal of Operations Management 69.2 (2023): 284-304.
297
SNCF (2022). Greenhouse gases information for transport services, Social, Territorial and Environmental
Commitment Department. Link available here
298
See Méthodologie pour le calcul et la déclaration de la consommation d'énergie et des émissions de gaz
à effet de serre (GES) des prestations de transport (fret et passagers) (2012). Document available here
207
The French Transport Code describes the general methodology allowing a transport
company to calculate the quantity of energy consumed for each segment of the itinerary,
by performing the product of the distance-based energy consumption rate of the mode of
transport used by the distance travelled. The quantity of energy is multiplied by an
emission factor specific to each type of energy. This factor establishes the correspondence
between the quantity of energy consumed and the quantity of GHG emitted. The values of
the GHG emission factors of the various energy sources are available on the website of the
relevant authority: Agence de l’environnement et de la maîtrise de l’énergie (ADEME).
When it comes to the GHG calculator of the SNCF, emissions of rail passenger activities
are estimated by multiplying the distance travelled299
by the average amount of CO2e
emitted per passenger-km, according to the type of train operated. Notably, the SNCF GHG
calculator distinguishes 4 main types of trains: TGV, Intercités, TER and Transilien.
For each type of train, the average amount of CO2e emitted per km travelled is calculated
for each year by dividing the energy consumption of the previous year (applying a CO2e
emission factor according to the type of energy)300
by the average volume of passengers
transported during the previous year and the distance they travelled (i.e., passenger-km
based on scope 3 input data). Accordingly, the calculation methodology provides the
amount of GHG emitted as follows.
𝐺𝐻𝐺 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 (
𝑔𝐶𝑂2𝑒
𝑘𝑚
) =
∑
𝑒𝑙𝑒𝑐𝑡𝑟𝑖𝑐𝑖𝑡𝑦 𝑐𝑜𝑛𝑠𝑢𝑚𝑝𝑡𝑖𝑜𝑛 ∙ 𝑒𝑙𝑒𝑐𝑡𝑟𝑖𝑐𝑖𝑡𝑦 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛 𝑓𝑎𝑐𝑡𝑜𝑟 +
𝑑𝑖𝑒𝑠𝑒𝑙 𝑐𝑜𝑛𝑠𝑢𝑚𝑝𝑡𝑖𝑜𝑛 ∙ 𝑑𝑖𝑒𝑠𝑒𝑙 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛 𝑓𝑎𝑐𝑡𝑜𝑟 +
𝑏𝑖𝑜𝑑𝑖𝑒𝑠𝑒𝑙 𝑐𝑜𝑛𝑠𝑢𝑚𝑝𝑡𝑖𝑜𝑛 ∙ 𝑏𝑖𝑜𝑑𝑖𝑒𝑠𝑒𝑙 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛 𝑓𝑎𝑐𝑡𝑜𝑟
𝑝𝑎𝑠𝑠𝑒𝑛𝑔𝑒𝑟 ∙ 𝑘𝑚
Following a methodological change introduced by the ADEME for the electricity emission
factor, the SNCF has chosen to introduce the average national energy mix value and no
longer use a specific value for rail traction electricity. On the one hand, this methodological
choice allowed the SNCF to harmonise the calculator with the existing international
practices. On the other hand, it determined an increase of the French emission factors, as
shown in Table 110
Table 110: Emission factors by type of passenger train service (gCO2e/kWh)
Time Intercites TGV Transilien TER
Before 2019 5.29 1.73 4.75 24.81
After 2019 6.73 2.71 7.04 26.93
Variation 27.2% 56.6% 48.2% 8.5%
Source: SNCF (2022)
Eventually, according to the implementing Decree No 2017-639 of 26 April 2017, the
emission factors are as follows:
 Electricity for transport: 60.7 gCO2/kWh in 2019 and 59.9 gCO2/kWh in 2020;
 Off road diesel with emission factor: 3.16 kgC02/litre; and
299
The distance travelled is taken from the kilometric databases for the rail lines.
300
Line losses and all empty journeys are included in the calculations.
208
 Biodiesel B100: 1.21 kgCO2e/litre.
Multimodal aspects of passenger transport services are also considered by the methodology
developed by the SNCF. In this respect, for the SNCF’s passengers travelling with the use
of other transport modes, the methodological approach is as follows:
 For coaches the figures are calculated by the company providing the service, but if
the actual data is not available, the SNCF methodology is applied using emission
factors provided by the SNCF.
 For taxis, cars rented with driver and other transport on demand, the figures are
calculated by the owner of the company, based on the ADEME fuel consumption
and CO2e emissions factors.
 For urban collective transport, the figures used in the SNCF calculator are provided
by the RATP, the regional transport operator of Île-De-France, and the SNCF
provides information to RATP regarding figures for regional service Transilien.301
Table 111 and Table 112, respectively, outline the emissions factors developed for
passengers travelling by SNCF trains (domestic and international) and by collective
transport, road and air services. The tables show also how the emission factors have
evolved over time.
Table 111: Emissions for SNCF passengers (gCO2e/km)
Type of service Type of train 2016 2021 2022
Domestic Intercites 10.80 5.29 6.73
TGV INOUI n. a. 1.90 2.99
TGV OUIGO 3.20 0.73 1.15
Transilien 5.80 4.75 7.04
RER 5.80 4.10 6.20
TER 29.70 24.81 26.93
International Thalys 11.60 6.68 7.32
Eurostar 8.20 6.64 7.48
Lyria 3.20 2.05 3.23
RENFE and SNCF in cooperation 27.00 5.40 6.00
DB and SNCF in cooperation 11.30 4.50 5.00
TGV INOUI Italia n. a. 8.50 10.30
301
See also dedicated page on SNCF website
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Source: SNCF (2016, 2021, 2022)
Table 112: Emissions for passengers travelling by other transport modes (gCO2e/km)
Transport mode 2016 2021 2022
Metro 3.8 2.5 3.8
Tramway 3.3 2.2 3.4
Bus RATP 96.5 98.0 104.0
Bus other operators n. a. 110.0 110.0
Coach interurban 171.0 146.0 146.0
Car average 162.0 111.0 111.0
Car short distance 148.0 134.0 134.0
Car long distance 90.0 75.0 75.0
Domestic flight < 500 km 168.0 167.0 167.0
Domestic flight 500-1000 km n. a. 126.0 126.0
Source: SNCF (2016302
, 2021303
, 2022)
Other considerations
Between 2019 and 2021, the ADEME has set up a working group to calculate the carbon
impact of vehicle manufacturing for inclusion in the transport emissions factors. The SNCF
has contributed to this workgroup. These factors are now available in ADEME's Base
Carbone in the ‘All data’ category. However, these emission factors are not taken into
account in the regulations of Article L1431.3 of the Transport Code and are therefore not
applicable in this context.
Impacts
The main impacts of the application of the SNCF calculator are associated with the
environmental aspects. The use of the calculator results in principle in the improved
awareness at company level, and also among the SNCF users. For the SNCF this is an
important source of information, especially when it comes to plan and implement measures
for low carbon transport services.
302
SNCF (2016). Greenhouse gases information for transport services, Social, Territorial and Environmental
Commitment Department (version dated 2016, July 8th
).
303
SNCF (2021). Greenhouse gases information for transport services, Social, Territorial and Environmental
Commitment Department (version 2021).
210
Based on the emissions factors provided in previous tables, Error! Reference source not
found.Table 113 shows examples of CO2e emissions for passengers travelling on certain
routes by SNCF trains compared to alternative journeys by car.
Table 113: Examples of CO2-eq. emissions for passengers travelling on certain routes by SNCF trains
compared to alternative journeys by car
Type of
train
Origin-Destination
Train Alternative mode
Distanc
e (km)
Emission
(gCO2e/k
m)
Mod
e
Distanc
e (km)
Emission
(gCO2e/k
m)
TGV Paris-Lyon 563 1.7 Car 466 35.0
Paris-Lille 258 0.8 Car 226 17.0
Bordeaux-Paris 617 1.8 Car 587 44.0
Paris-Rennes 374 1.1 Car 350 26.3
Marseille-Paris 883 2.6 Air 627 88.4
Paris-Strasbourg 503 1.5 Car 488 36.6
Paris-Nice 978 2.9 Air 674 95.0
Paris-Toulouse 713 2.1 Air 571 80.5
Lyon-Marseille 381 1.1 Car 314 23.6
Lille-Lyon 794 2.4 Air 558 78.7
OUIGO Nantes-Paris 385 0.4 Car 386 29.0
Lyon-Marseille 320 0.4 Car 314 23.6
Avignon-Marne La Vallee 697 0.8 Car 702 52.7
Lyria Paris-Geneve 692 2.2 Air 408 57.5
Thalys Paris-Bruxelles 314 2.3 Car 312 44.0
Intercites
Clermont Ferrand-Paris
Bercy
420 2.8 Car 425 31.9
Limoges-Paris 400 2.7 Car 394 29.6
Bayonne-Toulose 199 1.3 Car 300 22.5
TER Paris-Trouville Deauville 281 7.6 Car 199 22.1
Grenoble-Lyon 131 3.5 Car 113 12.5
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Marseille-Nice 218 5.9 Car 205 22.8
Geneve-Lyon 129 3.5 Car 150 16.7
Arcachon-Bordeaux 59 1.6 Car 72 8.0
Transilien Paris-Gare de Lyon-Juvisy 20 0.1 Car 21 2.8
Paris-Montp-Versaille-
Chantiers
15 0.1 Car 26 3.5
Paris Nord-Ermont-
Eaubonne
14 0.1 Car 14 1.9
Paris St. Lazare-La Defense 6 0.0 Car 8 1.1
Magenta-Chelles-Gournay 18 0.1 Car 21 2.8
Source: SNCF (2022)
Taking into account estimates based on the calculator, the SNCF has identified a number
of measures to achieve energy savings, improve energy performance and consume new
non-fossil energies. According to SNCF’s financial annual report304
, these measures
constitute an opportunity to improve the share of rail and sustainable mobility in general,
while providing services of passengers and goods. These measures can be summarised as
follows:
 train the train drivers to implement eco-driving saving. According to company’s
estimations eco-driving would allow to save up to 10% energy on a journey;
 during parking, an idle rolling stock consumes 10-30% of the total consumption,
depending on the transport activities. SNCF envisages to save 5-25% of current
parking consumption implementing ‘eco-parking’ device on the passenger
transport activity on all rolling stock, both electric and diesel. For example, the
expected gain for a TER train, the regional passenger transport, is around 48
ktCO2e/year by 2025 (i.e., around 10% of CO2e emissions from TER trains);
 replace fossil fuels with bio-fuels. This measure includes tests carried out for the
services operated between Paris and Granville in the second half of 2021. The
analysis of the impacts of these operations is in progress, however the current
deployment of biofuels (i.e., B100) is estimated to reduce GHG emissions from
diesel trains by 60%;
 design and introduce lighter equipment and superstructures (e.g. catenary systems)
and rolling stock with a lower environmental footprint.
304
See SNCF (2022). Rapport Financier Annuel Groupe SNCF.
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3- Use cases for CountEmissions EU
Eco-labelling of transport services
Aim Inform stakeholders about the (relative) performance of transport
operators.
How it works Participating transport operators will report their emissions to the
manager of the initiative. This manager processes the results of
individual companies and rewards an ECO-label depending on
their performance. A better GHG performance could result in a
higher eco-label.
Example of a
practice application
Lean and Green is a greening program which has started in the
Netherlands around 2010 by the public initiative Connekt305
. Since
then more than 500 companies from 14 European countries have
participated in the program. In the program, participants promise to
reduce CO2 emissions. For different emission reduction levels and
associated efforts, performance ratings (stars) are awarded. This
stimulates companies which want to continue with GHG emissions
as they are able to demonstrate their progress. Also, companies are
anonymously compared against competitors active in the same
market. More information on Lean & Green can be found in Annex
C of the Impact Assessment support study accompanying this
report.
(Expected) GHG
emissions
reduction potential
ECO-labelling offers participants a reason to accelerate GHG
emission reduction. For instance, companies participating in the
Lean & Green program have reduced over 700 kton CO2 emissions
since the start of Lean and Green, or about 0.7% of road transport
emissions in the Netherlands.
Other benefits Eco-labelling may incentivise transport operators and users to
choose for more sustainable options (e.g. modal shift to more
sustainable modes, increased transport efficiency, etc.). Depending
on the actual choices made, this may have a positive effect on the
other externalities (e.g. reducing air pollutant emissions, noise,
congestion) as well, although it is difficult to predict the size and
sign of this effect.
Sources used for the analysis
Smart Freight Centre (SFC, 2019a), Global Logistics Emissions Council Framework for
Logistics Emissions Accounting and Reporting
TK’Blue Agency (ongoing)
305
https://connekt.nl/
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Topsector Logistiek (2021), Richtlijn 18 – Benchmarken
Topsector Logistiek (2022), Lean & Green
Stakeholder interviews
Sustainable delivery B2C services
Aim The aim of using GHG emission data by sustainable delivery
services is fourfold:
 Show customers that the delivery company offers
sustainable transport solutions;
 Let customers be in control with regard to the
environmental impact of the delivery of their goods (e.g.
fast delivery: high CO2 footprint, later delivery date: lower
CO2 footprint);
 Create awareness about the GHG impact of customers’
choices;
 Optimise transport operations in terms of their
environmental impact.
How it works Based on the GHG emission figures, transport companies are able
to calculate the impact of the different delivery services. GHG
emissions of each individual delivery can be calculated and
communicated. Companies can reduce the GHG emissions of their
delivery services by optimising delivery routes and/or offer
differentiated services based on their GHG impact. This can be
realised by giving customers the opportunity to choose between
different timeslots for delivery which makes it possible to, for
example, optimise routing or choose between different modes of
transport.
Example of a
practice application
Multiple companies already apply this in practise. Example are
DHL Go Green, UPS My Choice and Bewust Bezorgd (a Dutch
initiative to calculate CO2-emissions of delivery options of online
retailers).
(Expected) GHG
emissions
reduction potential
The Netherlands is among the European countries with the highest
e-commerce activity (83% of the population buy online). Which
makes them a frontrunner with regard to B2C activities. While in
the Netherlands delivery services of packages accounted for
approximately 4% of the 3.6 Mtons of CO2 resulting from city
logistics in 2015 (Topsector Logistiek, 2017), this share is growing
and therefore the sustainable delivery services may become an
important contributor toward emissions reduction in urban areas.
214
Other benefits Better utilisation of transport infrastructure capacity, positive
impact on noise and other externalities, improved environmental
awareness of customers.
Sources used for analysis
Ignat & Chankov (2020)
Pereira Marcilio Nogueira et al. (2022)
Topsector Logistiek (2017) Outlook City Logistics 2017
Stakeholder interviews
Permit to enter Low or Zero emission zones
Aim To create a healthier environment for the inhabitants and to
contribute to reaching climate reduction targets, city authorities
may decide to introduce a low or zero emission zone for all or a
selection of vehicles.
How it works The Low or Zero emission zone is a predefined area in which
vehicles that emit more than allowed are prohibited to enter.
Checks by the local enforcement agencies can be automated via
cameras and related software (licence plates), or manual based on
supplied permits.
Example of a
practice application
Low emission zones are already common practise in multiple
countries, like the United Kingdom (London and Glasgow),
Belgium (Antwerp and Brussels), France (Paris), Germany (Berlin
and Munich), Spain (Barcelona and Madrid), Italy (Rome and
Milan) and the Netherlands (Amsterdam, Rotterdam and Utrecht).
Zero emission zones are announced for over thirty cities in the
Netherlands for freight transport entering the zone, which is in most
cases the city centre. Also in China such zones for freight transport
are planned (e.g. Shenzen, Foshan and Luoyang).
(Expected) GHG
emissions
reduction potential
Currently, the zones are in general focused more on air pollutants,
than GHG emissions. The entry requirements are often based on
Euro classes from type approvals of vehicles. One of the reasons
for this situation is that standard combustion engines can run also
on biofuels (besides diesel) and that it is difficult to account for
differences in fuel types. However, using information on GHG
emission to establish specific entry requirements may also be
considered to further increase the potential of a zone. Given that
total CO2 emissions from city logistics in the Netherlands was
around 3.6 Mtons per year (with a bandwith of 2.7-4.5 Mtons, the
215
impact of the introduction of 30-40 zero emission zones in the
largest cities in the Netherlands is estimated to be around 1 Mton
of CO2 to be saved (PBL, 2021). On a city level De Bok et al.
(2020) concluded, based on a simulation study for Rotterdam, that
GHG emissions from transport operations can be potentially
reduced by 90% within the zero emission zone, compared to the
current 10% reduction in the total Rotterdam area.
Other benefits Further reduction of other externalities, new sustainable business
models and concepts that may result in less traffic (e.g. through
cargo bundling) but also in more traffic in the city (e.g. through the
use of light electric vehicles which have less loading capacity).
Sources used for analysis
(CE Delft, 2016) , De omvang van stadslogistiek
(De Bok et al., 2020), Simulation of the impacts of a zero emission zone on freight
delivery patterns in Rotterdam
(ICCT, 2021b) , A global overview of zero-emission zones in cities and their
development progress
(PBL, 2021), Klimaat en Energieverkenning 2021
Green public procurement
216
Aim Governmental organisations can be a driving force behind the
transition towards zero or low emission transport. Not only through
imposing environmental regulations, but also by establishing
specific requirements in the public procurement procedures, e.g.
related to the maximum amount of GHG emissions which are
allowed for the requested transport services. If a transport company
cannot comply with these requirements, it does not qualify as a
supplier.
How it works Governmental organisations tend to procure a large amount of
services. Due to the size of a procured service or amount of assets
involved (in case public services require their own vehicles to
execute the service), governmental organisations are able to
influence the operations of the service provider. Where the
assignment is large enough, transport companies are be able to
adjust their fleet and/or operations to fulfil the demand and get the
contract.
Example of a
practice application
Currently, the main factor behind green procurement of transport
services in the EU is the Clean Vehicle Directive, which sets
national targets for the share of clean vehicles in the total number
of vehicles procured by all types of governments. However,
specific GHG emission targets for procured transport services may
be an important enabler to increase the potential of green
procurement in reducing transport related emissions.
(Expected) GHG
emissions
reduction potential
The impact assessment of the Clean Vehicle Directive indicates
that a decrease of 17% of CO2-emissions is possible on all vehicles
procured and subsequently utilised by governments. By using
targets defined in amounts of GHG emissions per transport
services, this reduction potential could be further increased.
Other benefits Higher share of clean vehicles may result in lower levels of air
pollutant emissions.
Sources used for analysis
(EC, 2009b), Staff Working Document Impact Assessment of a Directive amending
Directive 2009/33/EC on the promotion of clean and energy-efficient road transport
vehicles
(Lindfors & Ammenberg, 2021) Using national environmental objectives in green public
procurement: Method development and application on transport procurement in Sweden
Stakeholder interviews
217