【欧州】【Common】
Common – Scope 3 emissions: Reporting Scope 3 emissions of the
upstream and downstream transportation and distribution andemployee commuting in the EU

Andrea Antolini

Former Researcher JTTRI【概要：Summary】

1. Upstream and downstream transportation

The EU is moving towards stricter reportingand distribution, and employee commuting

requirements for Scope 3 emissions, including

Scope 3 emissions include all indirect GHG

those

downstream

emissions generated in a company's value chain,transportation, distribution, and commuting ofand they can account for over 90% of a company’s

employees, as corporate sustainability is coming

totalinto focus under the Corporate Sustainability

Incentives 2024). In 2011, the GHG Protocol, an

Reporting Directive (CSRD). Starting from 2025,

initiative of the World Resources Institutelarge entities in the EU with more than 500(WRI)

employees and non-EU companies with significant

Sustainable Development (WBCSD), published theoperations in the region will be required to“Corporate Value Chain (Scope 3) Accounting andcollect data from their value chain, and report

Reporting Standard” as a calculation standard

annually their Scope 3 emissions.

for an organization’s overall supply chain

However, the data collection for the reporting

emissionsof Scope 3 emissions including upstream andn.d.a). The GHG Protocol’s Scope 3 Standard isdownstream transportation and distribution as

still the only internationally accepted method

wellfor assessing the Scope 3 emissions (GHG Protocol

from

as

the

upstream

commutingchallenging

forcompanies

consuming,

complex

Therefore,

the

and

and

emissions
at

can

it

prone

is

to

CountEmissionsEU

betimeerrors.

initiative

GHG

and

emissions

the

(GHG

World

(T&E

2022,

Business

Protocol2013,

AlignedCouncilGHG

for

Protocoln.d.b, PlanA n.d).
Based

on

the

GHG

Protocol’s

definitions,transportation related Scope 3 emissions in a

could assist companies by providing standardized

company’s

value

chain

tools and methodologies for accurate reportingtransportation and distribution (Category 4),of transport-related Scope 3 emissions.

downstream

Carbon accounting platforms and services will be(category 9) and employee commuting (category 7),

increasingly important for entities to manage

besides

the accounting of Scope 3 emissions.

Protocol 2013). The emissions of transportationtransportation

business

trips

includeand

upstream

distribution(category

6)

(GHG

and distribution activities can cover all modes【記事：Article】

oftransport,

including

air,

rail,

road,

maritime transport and storage of purchased
海外の最新事情・トピック

2024 年8 月号｜JTTRI｜p. 1

products in warehouses, distribution centers,

than a third of jobs in the EU could be done

and retail facilities (GHG Protocol 2013, Carbon

from home, teleworking should be encouraged byanalytics n.d.). Upstream transportation andemployers to reduce these category 7 Scope 3

distribution emissions under category 4 refer toemissions. Working at home three days a weekemissions of products purchased by the reporting

could reduce a household’s fuel bill by aroundcompany and include multi-modal shipping with

EUR 35 a month, even after considering themultiplesuchincreased2013,

Accordingly,

carriers

purchasedintheproducts

Wajon/Farbsteintransportation(GHG2024).
anddeliveryofProtocolIt

also

distribution

includesservicesofenergy

use

the

at

EU’s

home

(IEA

introduction2022).
ofamandatory Scope 3 emission reporting under the
CSRD(Directive

2022/2464)

presentsanthird-parties for products purchased by theimportant opportunity to transform a company’s

reporting company, either directly or through an

commuting practices and embrace sustainableintermediary,alternatives like the use public transport orlogistics,

includingthird-party

in-

and

outboundtransportation

andremote work arrangements (Kintojoin n.d.).

distribution between a company’s own facilities

2. Scope 3 emission reporting in the EU(GHG Protocol 2013).
Scope

3

emissionsoftransportation

andCurrently,

around

2 500

large

EU

companies

distribution of products sold by the reporting

disclose environmental and social informationcompany, e.g. between the reporting company’s

regularly,

operations

companies’

and

the

end

consumer,including

but

there

is

evidencesustainability

thatreports

theareretail and storage in vehicles and facilities

insufficient as they often omit information on

not owned or controlled by the reporting company

the Scope 3 emissions. Therefore, in the EU, thearedownstream

Corporate

Sustainability

Scope(CSRD)(Directive

definedastransportation

category

and9

distribution

3

2022/2464)

2024). Furthermore, category 7 Scope 3 emissions

beginning in the 2024 financial year for reports

relate3

emissions,andincludesto be published in 2025 (European Commission

employees

commutingn.d.a, Directive (EU) 2022/2464). The CSRD will

between between their homes and their worksites,

expand the scope of companies required to reportlocatedowned,

on sustainability, including Scope 3 emissions,operated, or leased by the reporting company (GHG

and mandatory reporting will apply to large

Protocol 2013).

public-interest

In 2022, the EU’s 197 million employed people

500 employees of all sectors, including listed

aged 15-64 years had an average commuting of 48

companies as well as some unlisted companies,

kilometers per day, and more than 12.5 million

designated by Member States (European Commission

employees (6.4% of all employed) commuted to work

2024b, Bernoville 2024). Some non-EU companies

from one region to another within their country

will also have to report if they generate overof residence (Eurostat 2023). Several German

EUR 150 million

regions, including Brandenburg, Arnsberg andCommission n.d.a, 2023b).

Lüneburg,andCompanies will need to disclose comprehensive

Niederösterreich in Austria recorded the mostdata on their environmental impact, including

employed people commuting to a different region

Scope 3 emissions related to transportation andto work (Eurostat 2023). However, since more

distribution.

emissionsderiving

incommutingScope

introduces

mandatory

employeeofDirective

emissions (GHG Protocol 2013, Wajon/Farbsteintoreporting

Reportingfromentities

along

with

海外の最新事情・トピック

and

Pest

facilities

in

Hungary

entities

on

This

the

with

EU market

includes2024 年

more

than(Europeanemissionsfrom

8 月号｜JTTRI｜p. 2

third-party

logistics,

andThe two-year postponement to 30 June 2026 fordistribution centers, as well as the final

the Commission to adopt a sector-specific ESRStransportation

customers

will allow companies to focus on the first set(Directive (EU) 2022/2464, European Commisisonof ESRS (Directive (EU) 2024/1306, European

2023b).

Companies

Parliament 2024a, Council of the EU 2024).

Europeanorofwarehousing,productsmaynational

usetointernational,

guidelines(EuropeanCommission 2024b). However, information reported

3. Calculating emissions from upstream andunder the CSRD will be subject to audits todownstream

ensure the accuracy and reliability of theirdistribution

transportation

andScope 3 emissions data.

When preparing their Scope 3 emission report,

Besides the CSRD, the EU Taxonomy Regulationcompanies should screen their total Scope 3 GHG(Regulationaemissions based on the 15 Scope 3 categories ofclassification system to determine whether an

the GHG Protocol Corporate Standard and GHG

economic activity is environmentally sustainable

Protocol Corporate Value Chain (Scope 3) or based

and aligned with a net zero trajectory by 2050

on categories of EN ISO 14064-1:2018 (Commission(European Commission n.d.b). For companies toDelegated Regulation (EU) 2023/2772). The choiceclaim alignment with the Taxonomy, they mustof method depends on the company’s value chain,assess and report on significant GHG emissions,among others (brightest n.d.).

including Scope 3 emissions of their value

Regarding the selection of calculation method

chain,including transportation and distribution

for scope 3 emissions from transportation, theemissions. The reporting under CSRD is expected

GHG Protocol (2013) recommends three different

to be aligned with the EU Taxonomy requirements

methods

under Regulation (EU) 2020/852.

distance-based method and spend-based method.

On 31 July 2023, the European Commission adopted

The Fuel-based method involves determining fuelthe European Sustainability Reporting Standards

consumption and applying emission factors.

(ESRS) (Commission Delegated Regulation (EU)For transportation, the fuel-based method should2023/2772) for use by all companies subject tobe used when companies can obtain data for fuelthe CSRD (European Commission 2023a). The ESRS

use from transport providers and, if applicable,

areFinancialrefrigerant leakage due to refrigeration ofReporting Advisory Group (EFRAG) to support the

products from vehicle fleets like trucks, trains,implementationaplanes, vessels (GHG Protocol 2013). The fuel-structured approach and detailed guidance on how

based method is best applied if the vehicle

companies should report their Scope 3 emissions

exclusively(European Commission 2023a).

purchased goods and it is more accurate than the

ESRS 1 (“General Requirements”) sets general

distance-based method because fuel consumption

principles to reporting to ESRS and clarifies

is directly related to emissions and therefore

the requirements for CSRD compliance.

more reliable (GHG Prptocol 2013).

ESRS

(EU)

developed

2

essential

on

by

of

2020/852)

the

the

“General
information

providesEuropean

CSRD,

presenting

Disclosures”
forspecify

preparingThe

including

the

ships

the

distance-based

fuel-based

reportingmethodmethod,company’s

multiplies

theadistance traveled by the mass of goods andsustainability statement and is mandatory forrelevant emission factors and is most useful,all companies under the CSRD scope (European

when fuel data is unavailable, or when shipments

Commission 2023b).

are smaller than an entire vehicle or vessel (GHG
Protocol 2013).

海外の最新事情・トピック

2024 年8 月号｜JTTRI｜p. 3

The

Spend-based

methodwhen

calculated using appropriate emission factors

neither fuel nor distance data is available (GHG

for the various modes of transport, provided by

Prptocol 2013).

national

To calculate the CO 2 emissions deriving frominternational bodies like the Intergovernmental

transportation with trucks, the distance thePanel on Climate Change (IPCC) (PlanA n.d.).

truck

fuel

Companies could use the fuel-based method, theisdistance-based method or the average-data method

multiplied by the CO₂ emission factor for theas calculation method for Scope 3 emissions fromtype of fuel the truck uses, giving the total

employee commuting (GHG Protocol 2013).

travelledconsumption.

is

Then,

is

recommended

multiplied

by

the

the

fuel

used

total

environmental

agenciesor

CO₂ emissions (Mathers 2015).
Regarding CO2 emissions from ground/air travel,
they are calculated by multiplying the distance

5. The CountEmissionsEU for accounting GHG
emissions of transport services

a shipment has traveled (D) times the weight ofLaunched under the Greening Freight Transport

the shipment (W) times the transportation mode's

package, the CountEmissionsEU (COM (2023) 441

specific emissions factor (EF) (Sifted n.d.).

final)

initiative

standardized

4. Calculating

emissionsfrom

employeecommuting (Scope 3 Category 7)

aims

frameworktoforestablishaquantifying

GHG

emissions across all transport modes in the EU(Council

of

the

EU

2023).

CountEmissionsEU

The Scope 3 emissions from employee commuting

applies to entities providing or organizing

refer to the emissions from the transportation

freight and passenger transport services in theof employees between their homes and their place

EU,

using

the

Europeanof14083:2023

as

its

work

(GHG

ProtocolCompanies

may

includeemissionsofemployees

entities

like

2013,

their

n.d.).

ENISO

methodology(COM/2023/441 final). It will establiosh rules

relevant

for accounting GHG emissions, particularly inoutsourced

multimodal transport, and will introduce an EU

operations, as well as consultants, contractors,

database of default GHG emission values toand other individuals who are not employees ofimprove data comparability (European Parliament

the company, but commute to facilities owned and2023, European Commission 2023c). It will also

operated by the reporting company (GHG Protocol

introduce a reliable verification system for the2013). The Scope 3 emissions from employees

information on GHG emissions generated from

commuting can include emissions from varioustransport services (European Parliament 2023).

modes

personal

It could enable businesses and customers tovehicles, public transit, carpooling, and otherchoose more sustainable transport options andforms of commuting. Although these emissions

help to avoid greenwashing (European Parliamentare2024d, Antolini 2024).

ofindirectotherfranchises

transportation,

and

not

reportreference

of

the

of

in

PlanA

version

or

such

as

owned

or

directly

controlled by the reporting company, these GHG

Considering the approaches suggested by GHG

emissions are a consequence of its operations,Protocol (2013), and the data sources needed forwhich need to be reported under the CSRD.

the companies’ reporting of Scope 3 emission

To accurately

account

for

under

companies

gatherdata regarding theirinitiative could be a key resource for obtaining

habits,ofnecessary data related to transportation in the

distancescategories 4 and 9 of Scope 3 emissions that also

areneed to be reported under the CSRD.

must

employees’commutingtransportation
travelled.

The

used,
GHG

海外の最新事情・トピック

and

these

the
the

emissionsemissions,

modes

then

the

CSRD,

the

EU’s

2024 年CountEmissionsEU

8 月号｜JTTRI｜p. 4

Although the CSRD and CountEmissionsEU differ insettheir scope, the standardized methodology fromprogress and business growth (Akkermans 2024).

CountEmissionsEU

companies'“Normative” provides a free carbon calculator

broader sustainability reporting under the CSRD

for smaller suppliers, among others (Sweep 2024).

regarding the calculation of GHG emissions for

Clients include Hertz, Topps Tiles, Flying Tiger

transport services, as the standardised GHG

Copenhagen and Hitachi (Sweep 2024, Akkermans

emissions calculations under CountEmissionsEU2024).

could facilitate an accurate, standardized GHG“Coolset” automated carbon accounting software

reporting, aligned with the CSRD’s objectives

helps businesses with their accounting of Scope(European Parliament 2024c, COM/2023/441 final).

1, 2 and 3, and offers solutions for EU CSRD

could

supportofESG

capabilities

forsustainability

compliance (Akkermans 2024).

6. Carbon accounting platforms and providers“Pledge” provides tools and infrastructure to

Since the calculation of Scope 3 emissions ismeasure, report, and offset emissions, focusing

becoming mandatory for EU and non-EU companies

especiallydefined under the CSRD by 2025, businesses arecompanies to calculate emissions from freightincreasingly challenged with calculating theirand other logistics operations (Akkermans 2024).

Scope 3 emissions, which is time-consuming,Withcomplexselection

and

prone

to

human

error

on

transportation

numerousofplatformsasuitableandlogistics

available,
carbontheaccounting(Wajon/Farbstein 2024, Normative n.d.).

software can be a decisive factor for an entity

To manage these emissions effectively, companies

in the accounting, reporting and reduction ofmust use standardized frameworks like the GHG

Scope 3 emissions.

Protocol, and carbon accounting software andplatforms

offer

a

comprehensive,

automated

7. Conclusion and considerations

approach to measure and reduce emissions in a

The accurate reporting of Scope 3 emissions,company’s value chain (Wajon/Farbstein 2024,

especially those related to transportation and

Akkermans 2024). Carbon accounting software,

distribution, poses significant challenges toplatforms and services enable a company tocompanies as they must gather emissions data frommeasure, analyze and manage the reporting ofthird-party logistics providers, suppliers, andScope 3 emissions in transparent and efficient

distributors, requiring robust systems for data

way, although it does come at associated costs

exchange and collaboration across their valueof up to €250.000, excluding implementation fees,

chain. Since the CSRD mandates the use ofaccording to Akkermans (2024). The following

standardized reporting formats and methodologies,

non-exhaustiveanthe CountEmissionsEU initiative could provide afor Scope 3

useful framework for measuring and reporting of

list

of

services

overview of possible solutions

gives

emission accounting.

emissions from transportation by harmonising the“Sweep” offers a graduated model, which is wellcalculation across the EU.

suitedwith

Due to the complexity of the Scope 3 emissions

different levels of data maturity for tracking

accounting, the carbon accounting platforms andScope 3 emissions (Sweep 2024).

providers“Watershed” offers sustainability tools andcompanies to meet the regulatory requirements ofclients include FedEx, BlackRock, Spotify andreporting their Scope 3 emissions in the EU.

Walmart2024).

Under the CSRD, the companies are expected not“Microsoft Sustainability Cloud” is a growing

only to report their Scope 3 emissions but alsotoorganizations(Sweep2024,

海外の最新事情・トピック

of

all

sizes

Akkermansareincreasingly

2024 年

improtantfor

8 月号｜JTTRI｜p. 5

toachievea

GHG

emission

reductionandsustainability targets for their businesses.
However,

if

the

CSRD

will

not

lead

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