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
Date: 2023-07-11
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: carriage of goods, carriage of passengers, disclosure of information, environmental monitoring, environmental standard, exchange of information, greenhouse gas, pollution control measures, reduction of gas emissions

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}  
 
 
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 

CEN 

CH4 

CO2 

CO2-eq. 

DCS 

EASA 

EPA 

GCD 

GHG 

GLEC 

IATA 

ICAO 

IPCC 

ISO 

kWh 

LCA 

MJ 

MRV 

NABs 

barrels of oil equivalent  

European Committee for Standardisation  

Methane 

Carbondioxide 

Carbondioxide equivalents 

Data Collection System 

European Union Aviation Safety Agency 

Environmental Protection Agency (US) 

Great Circle Distance 

Greenhouse Gas 

Global Logistics Emissions Council 

International Air Transport Association 

International Civil Aviation Association 

Intergovernmental Panel on Climate Change 

International Organisation for Standardisation 

Kilowatt-hour 

Life cycle assessment 

Mega Joule 

Monitoring, Reporting and Verification 

National Accreditation Bodies 

 
 
 
N2O 

NOx 

PEFCR 

pkm 

SFD 

SOx 

tkm 

toe 

TTW 

WTT 

WTW 

Nitrous oxide  

Nitrogen oxides 

Product Environmental Footprint Category Rules 

Passenger kilometre 

Shortest feasible distance 

Sulphur oxides 

Tonne kilometre 

Tons of oil equivalent 

Tank-to-Wheel 

Well-to-Tank 

Well-to-Wheel 

 
 
 
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   

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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) 

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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 
20Such 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/  

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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. 

4 

 
 
                                                 
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 
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  

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13180-Access-to-vehicle-data-

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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 

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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 

7 

 
 
 
                                                 
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 

8 

 
 
                                                 
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.  

9 

 
 
                                                 
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  
EN 16258  
ISO 14083   
PEF   
French transport code (Article L. 1431-3)  
Parcel Delivery Environmental Footprint76  
GLEC   
SmartWay   
Topsector  
Clean Cargo Working Group   
EU MRV  
IMO DCS  
CORSIA  
ICAO/IATA RP1678  
IATA  
EU ETS aviation  

All modes  
All modes  
All modes  
All modes  
All modes  
All modes   
All modes  
All modes  
All modes  
Maritime  
Maritime  
Maritime  
Aviation  
Aviation   
Aviation  
Aviation  

Source: Ecorys and CE Delft (2023), Impact assessment support study 

Passengers & freight  
Passengers & freight  
Passengers & freight  
Passengers & freight  
Passengers & freight  
Parcel  
Freight  
Freight  
Freight  
Freight  
Freight  
Freight  
Passengers & freight  
Freight  
Passengers 
Passengers & freight  

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 

10 

 
 
                                                 
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. 

11 

 
 
                                                 
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. 

12 

 
 
                                                 
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, 

13 

 
 
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 
their  emissions. 
to  perform 
operations/shipments/passengers  and 

the  calculation  of 

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 

14 

 
 
                                                 
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 

15 

 
 
                                                 
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); 

16 

 
 
  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 

results 

P1:  limited  comparability 
of 
from  GHG 
emissions  accounting  of 
in 
services 
transport 
transport and logistics 

P2:  Limited  uptake  of 
emissions  accounting  of 
transport  services  in  usual 
business practice 

-  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. 

-  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. 

17 

 
 
 
 
                                                 
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.  

18 

 
 
 
                                                 
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. 

19 

 
 
 
                                                 
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) 

20 

 
 
                                                 
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.  

21 

 
 
 
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 

22 

 
 
                                                 
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. 

23 

 
 
                                                 
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;  

24 

 
 
 
  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 

PD1 

PD2 
PD3 

PD1 
PD3 
PD4 

PD3 
PD4 
PD5 

SO1 

SO1, 
SO2 

SO2 

PD4 

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 
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. 
PM6: Minimum requirements for harmonised GHG 
output data metrics are provided at EU level, 
together with common rules on communication and 
transparency 
PM7: Horizontal guidelines for the harmonised 
implementation of CountEmissions EU in various 
sectors and segments of the transport market are 
provided at EU level 
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 

25 

PO 
1 

PO 
3 

PO 
2 

√ 

PO 
4 

√ 

PO
6 

√ 

PO 
5 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 
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 

√ 

√ 

√ 

√ 

√ 

PD5 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

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. 

26 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
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. 

27 

 
 
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. 

28 

 
 
                                                 
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 section summarises the main expected economic, social and environmental impacts of each policy 
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 

29 

 
 
  
  
                                                 
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, and PM5 in PO3, PO4 and PO6). The centralised EU databases will be developed and maintained 
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, 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 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, 
for covering all transport services, at least 4 PEFCRs are needed (road, maritime and inland waterways, 
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 

30 

 
 
                                                 
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 policy options 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 mandatory application. 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 among the 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/  

31 

 
 
                                                 
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 
billion one-off adjustment 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 

32 

 
 
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 
standard are not likely to be followed at global level, which may lead to some challenges for the aviation 
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. 

33 

 
 
                                                 
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 3 million in 2025, EUR 5.2 million in 2030 and EUR 2.1 million 
in 2050 relative to the baseline. Expressed as present value over 2025-2050, PM10 results 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 
2025 
2030 
212.9  1,611.3  2,611.7 

2050 

PO2 
2030  2050  2025 
25.8 
1.8 
1.3    

44.9 
31.3 

2025 
22.9 
15.9 

PO3 
2030  2050 
8.2 

48.7 

Adjustment costs  
PM1 - ISO 14083 set as common 
reference methodology 
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. 

34 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
                                                 
Difference to the Baseline 

PO1 
2030 

2025 
130.2  1,003.0  1,624.5    

2050 

2025 

PO2 
2030  2050  2025 
18.1 

PO3 
2030  2050 
4.9 

33.8 

41.5 

296.2 

481.9    

3.0 

5.2 

2.1    

41.2 

312.1 

505.3 

4.0 

8.4 

-1.6    

0.00 

0.00 

0.00 

0.00 

0.00  0.00 

0.3 

1.1 

-1.3 

7.5 

13.7 

4.5 

0.02 
0.00 

0.03  0.03 
0.02  0.02 

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  
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 
Administrative costs  
PM5 - Quality assurance of external 
databases operated by third parties is 
provided at the EU level  

PM12 - Emissions calculation tools 
are provided by the market but they 
are certified at EU level 
8.2 
Total net costs 
Source : Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs savings, 
where relevant.  

212.9  1,611.3  2,611.7 

0.02  0.02 

44.9 

0.02 

22.9 

25.9 

48.7 

1.8 

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 

Adjustment costs  
PM1 - ISO 14083 set as common 
reference methodology 
PM2 - PEFCR set as common 
reference methodology 
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  
PM10 - Voluntary process and data 
verification for all entities 
PM11 - Emissions calculation tools 
are provided at EU level 

PO4 
2030 
54.8 
41.6 

2025 
30.4 
23.6 

2050 
8.6 
9.0    

Difference to the Baseline 
PO5 

2025  2030  2050  2025 

PO6 
2030 

2050 

56.6  93.2  37.3  144.9  1,140.9  1,848.2 
835.5  1,353.5 
107.3 

29.9  50.0 

6.9 

0.1 

0.9 

-1.8 

7.4  11.6 

8.9 

5.0 

47.6 

77.4 

35 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
  
  
  
  
  
  
PO4 
2030 
12.3 

2025 
6.7 

Difference to the Baseline 
PO5 

2050 
1.4 

2025  2030  2050  2025 
32.5 

19.3  31.6  21.5 

PO6 
2030 
257.7 

2050 
417.3 

0.02 
0.00 

PM12 - Emissions calculation tools 
are provided by the market but they 
are certified at EU level 
Administrative costs  
PM5 - Quality assurance of external 
databases operated by third parties is 
provided at the EU level  
PM12 - Emissions calculation tools 
are provided by the market but they 
are certified at EU level 
56.6  93.3  37.4  144.9  1,140.9  1,848.2 
Total net costs 
Source : Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs savings, 
where relevant.  

0.02  0.02  0.02 

0.02  0.02  0.02 

0.03 
0.02    

0.03 
0.02 

0.03 
0.02 

0.02 
0.00 

0.03 
0.02 

0.02 

0.02 

30.4 

0.02 

0.02 

0.02 

54.8 

0.02 

8.7 

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 
2030 

2025 

2050 

2025 

PO2 
2030 

2050  2025 

PO3 
2030 

2050 

31.8 

Adjustment costs   
PM1 - ISO 14083 set as 
common reference methodology 
PM2 - PEFCR set as common 
reference methodology 
PM3 - ISO 14083 with 
additional elements and 
increased accuracy set as 
common reference methodology 
PM7 - Guidelines for 
harmonised implementation 
31.8 
Total costs 
Source : Ecorys and CE Delft (2023), Impact assessment support study 

295.0  2,308.0  3,747.8    

295.1  2,308.0  3,747.8 

0.06    

0.06    

56.4 

2.9    

43.6 

76.3 

12.0 

0.06    

56.4 

2.9 

43.7 

76.3 

12.0 

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 

44.8  73.9  16.0    

210.5  1,660.2  2,698.2 

63.1  94.6  14.6 

Adjustment costs   
PM1 - ISO 14083 set as common reference 
methodology 
PM2 - PEFCR set as common reference 
methodology 
PM3 - ISO 14083 with additional elements 
and increased accuracy set as common 
reference methodology 

PM7 - Guidelines for harmonised 
implementation 
Total costs 
Source : Ecorys and CE Delft (2023), Impact assessment support study  

0.06    

0.06    

0.06 

44.8  73.9  16.0  63.2  94.6  14.6  210.5  1,660.2  2,698.2 

36 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
  
  
  
  
  
  
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
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 to the baseline. Expressed as present value over 2025-2050, 
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 
submission is thus estimated at EUR 490.76 per database. For the purpose of ‘one in, one out’ 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 of more sustainable transport options and optimised trips. This is expected to 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 

37 

 
 
                                                 
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)  

Energy savings for transport service providers (ktoe) 

PO1 
PO2 
PO3 
PO4 
PO5 
PO6 

Reduction in the energy costs for transport service providers (in million EUR)    

2025 

2030 

2050 

32.6 
46.8 
23.6 
70.6 
21.3 
32.6 

259.4 
93.9 
56.0 
123.8 
51.5 
259.4 

385.7 
3.5 
1.2 
24.0 
1.1 
385.7 

PO1 
PO2 
PO3 
PO4 
PO5 
PO6 

776.3 
7.0 
2.4 
48.4 
2.2 
776.3 
Source:  Ecorys  and  CE  Delft  (2023),  Impact assessment  support  study;  Note:  ktoe  stands  for  kilo  tonnes  of  oil 
equivalent.   

52.0 
74.6 
37.6 
112.6 
34.0 
52.0 

391.4 
141.7 
84.5 
186.9 
77.8 
391.4 

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. 

38 

 
 
  
  
  
  
  
  
                                                 
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 
Transport sector 

Manufacturing  

Retail sector 

Fuel suppliers 

PO1 

PO2 

PO3 

PO4 

PO5 

PO6 

Positive 

Small 
positive 
Small 
positive 
No change 

Small 
positive 
No change 

Small 
positive 
No change 

No change 

No change 

No change 

No change 

Positive 

Positive 

Small 
positive 
Positive 

Small 
positive 
No change 

No change 

Small 
positive 

Positive 

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). 

39 

 
 
 
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 
2030 

2050 

Recurrent and one-off costs 

Adjustment costs 
Administrative costs  

2050 
11.9 
11.9 
0.02 
Benefits (energy costs savings) 
2.4 
Net costs/costs savings 
9.5 
Source : Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs savings, 
where relevant.   

2025 
490.8  3,866.2  6,288.2 
490.8  3,866.2  6,288.2 
0.00 
0.00 
775.1 
390.7 
439.1  3,475.5  5,513.1 

2050 
4.7 
93.9 
93.9 
4.7 
0.00  0.00 
6.9 
-2.2 

2025 
50.9 
50.9 
0.00 
74.0 
-23.1 

140.6 
-46.7 

0.00 
51.7 

2025 

PO3 
2030 
57.9  103.8 
57.8  103.8 
0.02 
0.02 
83.6 
37.2 
20.2 
20.7 

PO2 
2030 

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 
2030  2050  2025 

PO5 
2030  2050  2025 

PO6 
2030 

2025 

2050 

Recurrent and one-off costs 

Adjustment costs 
Administrative costs  

Benefits (energy costs savings) 
Net costs/costs savings 

68.0  115.4 
68.0  115.4 
0.02 
0.02 
111.7  185.4 
-70.0 
-43.7 

19.9  101.2  156.4 
19.9  101.2  156.4 
0.02 
0.02 
0.02 
77.0 
33.6 
48.0 
79.5 
67.6 
-28.1 

37.4  344.7  2,767.6  4,501.4 
37.3  344.7  2,767.5  4,501.4 
0.02 
0.02 
775.1 
2.2 
35.1  293.0  2,376.9  3,726.3 

0.02 
390.7 

0.02 
51.7 

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.  

40 

 
 
 
 
                                                 
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   
135https://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  

41 

 
 
                                                 
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 by PO4 (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 

42 

 
 
                                                 
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 of GHG emissions saved relative to the baseline, PO4 in 5.6 million of tonnes of GHG emissions 
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. Notwithstanding this 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. 

43 

 
 
                                                 
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 
from 
emissions 
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 
the 
SO2  -  Facilitate 
uptake 
GHG 
of 
emissions accounting of 
transport 
in 
business practice 

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) 
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. 

44 

 
 
 
                                                 
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.  

45 

 
 
                                                 
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. 

46 

 
 
                                                 
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   
Administrative costs 
EEA 
Adjustment costs   
European Commission 
Adjustment costs   
Businesses 
Adjustment costs  
Administrative costs  
Benefits 
Avoided fuel used (operators and 
passengers) 
Reduction in external costs of 
GHG emissions 
Reduction in external costs of air 
pollution emissions 
Reduction in external costs of 
accidents 
Total costs 
Total benefits 
Net benefits 
Benefits to costs ratio 

0.1 
0.1 

3.6 

2.7 

0.1 
0.1 

3.6 

0.3 

0.1 
0.1 

3.9 

2.4 

0.1 
0.1 

3.9 

0.0 

0.1 
0.1 

3.6 

5.3 

0.1 
0.1 

3.9 

0.0 

95,010.8 
0.0 

1,084.6 
0.0 

1,374.4 
0.5 

1,542 
0.5 

2,283.7 
0.3 

67,927.7 
0.5 

10,362.9 

1,585.5 

718.3 

2,415.9 

630.5 

10,362.9 

2,878.9 

445.4 

200.0 

674.1 

174.9 

2,878.9 

600.6 

110.8 

53.1 

163.5 

47.0 

600.6 

2,760.5 
67,932 
16,602.9 
-51,329.4 
0.2 
Source: Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect net costs. 

2,760.5 
95,017 
16,602.9 
-78,414.4 
0.2 

168.6 
2,293 
1,021.0 
-1,272.1 
0.4 

645.2 
1,547 
3,899 
2,352.1 
2.5 

424.4 
1,089 
2,566.1 
1,477.3 
2.4 

192.2 
1,381 
1,163.6 
-217.9 
0.8 

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, 
included in all POs, are adjustment costs related to the use of calculation tools and verification activities.  

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 respectively at 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 
the higher share of companies expected to implement GHG emissions accounting at service level. PO2, 

47 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
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 data for transport services. This is expected to lead to higher use of more sustainable transport 
options and optimised trips, resulting in energy costs savings for transport operators and consumers, 
and a reduction in the external costs of transport. PO1 and PO6 show the highest total 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 the identified problems, 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%. 

48 

 
 
                                                 
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 

49 

 
 
                                                 
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 
Effectiveness 
Efficiency 
Coherence 
Subsidiarity  and 
proportionality 

PO1 
+++++ 
----- 
+ 

-- 

PO2 
+ 
++++ 
+++ 

++ 

PO3 
++ 
-- 
+ 

-/+ 

PO4 
+++ 
+++++ 
+++++ 

+++++ 

PO5 
+ 
--- 
+ 

-/+ 

PO6 
+++++ 
----- 
+++++ 

-- 

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 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 is scarce. For this reason, a sensitivity analysis 
has been performed, assuming a decrease by 40% in the share of passengers making sustainable choices  
among the climate aware population(scenario A), and a decrease by 30% in the shares of activity shifted 
to more sustainable transport modes and optimisation of trips (scenario B). Methodological details on 
the sensitivity analysis 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. 

50 

 
 
 
                                                 
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 
Share of passengers (A) – 40% lower 
Shares of activity (B) – 30% lower 

-78,414.4  1,477.3  -217.9  2,352.1 
-450.6  1,572.4 
-81,735.0 
-544.1  1,259.7 
-83,060.8 

964.1 
758.1 

-1,272.1 
-1,476.3 
-1,558.4 

-51,329.4 
-54,650.0 
-55,975.7 

Benefits to cost ratio 

Share of passengers and activity - central case 
Share of passengers (A) – 40% lower 
Shares of activity (B) – 30% lower 

0.2 
0.1 
0.1 

2.4 
1.9 
1.7 

0.8 
0.7 
0.6 

2.5 
2.0 
1.8 

0.4 
0.4 
0.3 

0.2 
0.2 
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 

51 

 
 
  
  
  
  
  
 
 
  
  
  
  
 
 
 
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.   

52 

 
 
 
                                                 
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. 

53 

 
 
 
 
 
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 

  EEA (management of the database) 

energy emission factors 

  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) 

54 

 
 
 
Role of EEA 

Stakeholders involved 

  Entities  –  database  developers  (public,  private) 
submitting databases for the quality check (as data 
users and providers) 

55 

 
 
 
 
 
 
 
 
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 
and 
complementarity  of  these  regimes  with  the 
proposed harmonised framework. 

coherence 

addresses 

Further evidence supporting the assumptions 
related  to  the  reduction  of  GHG  emissions  
and 
based  on 

literature 

review 

the 

56 

 
 
(2)  The  report  does  not  provide  a  complete 
and realistic set of options. 

(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. 

(4)  The  report  does  not  well  explain  the 
scoring  methodology  used  when  comparing 
the options. 

stakeholders’ 
addressed in section 6 and Annex 4. 

consultations 

have 

been 

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. 

The revised version of the Annex 4 includes:  

and 

information 

  new  tables  showing  the  relative  (%) 
larger 
impacts  on  SMEs 
companies,  together  with  necessary 
explanations;  
  complementary 

on 
benefits  and  costs  impacting  both 
SMEs  and  larger  companies,  broken 
down  per  specific  qualifier  (fuel 
costs, 
adjustment 
saved, 
administrative costs, etc.); 
on 

  additional 
details 
from 
stemming 
change 
to  support 
underpinning the calculations. 

impacts 
the  behavioural 
the  evidence 

including 

A  new  section  7.5  (Comparison  of  the 
scoring 
options) 
methodology, 
necessary 
clarifications  has  been  added  to  the  revised 
report. 

clearer 
together  with 

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 
transport 
GHG  emissions  accounting  of 
services  have  been  included  in  section  2.5. 
Complementary clarification for the evidence 
underpinning  the  assumed  changes  in  the 
transport  activity  has  been 
in 
sections 6, 8.1, and Annex 4.  

included 

57 

 
 
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. 

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 
further 
opt-in  approaches)  have  been 
explained in Annex 4.  

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. 

(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. 

(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, 

58 

 
 
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.  

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. 

efficiency, 

Section  7.5  has  been  added  to  the  revised 
report.  This  section  further  details 
the 
coherence, 
effectiveness, 
subsidiarity and proportionality of the policy 
options  with  a  clearer  scoring  methodology 
embedded.  Respective 
and 
clarifications  have  also  been  included  in 
Annex 9. 

corrections 

(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 
the 
have  been  factored 
effectiveness 
including 
acknowledging  limits  to  the  analytical  work 
itself. 

in  or  out 

scoring, 

in 

(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.  

59 

 
 
 
 
60 

 
 
 
 
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) 

61 

 
 
                                                 
  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 

‘Have your say’ Call 
for Evidence 

Not applicable 

64 

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. 

Exploratory interviews 

4 

4 

Number of 
documents 
provided153 

60 154 

27156 

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. 

62 

 
 
                                                 
Targeted survey  

70 

After analysing and filtering the data, 38 
questionnaires,  of  which  26  were  fully 
completed. SMEs are 8 of the responses. 

Targeted interviews 

Short survey 
questionnaire 

44 

4 

32 

1 

Stakeholder workshop 

43160 

33161 

22157 

0158 

3159 

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. 

63 

 
 
                                                 
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 

64 

 
 
 
 
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. 

65 

 
 
 
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.  

66 

 
 
 
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 

67 

 
 
 
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 

68 

 
 
 
 
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 

69 

 
 
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 

70 

 
 
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%).  

71 

 
 
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 

72 

 
 
 
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. 

73 

 
 
                                                 
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. 

74 

 
 
 
 
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; 
transport service organisers and hub operators; 
transport service users;  

o 
o 
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. 

75 

 
 
                                                 
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. 

service  users,  be 

authorities, 
them  passengers, 
Transport 
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.  

customers,  public 

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. 

76 

 
 
                                                 
 
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 

Benefits for passengers from 
avoided fuel used, expressed 
as  present  value  over  2025-
2050 relative to the baseline 

transport 
for 
Benefits 
service 
from 
providers 
avoided fuel used, expressed 
as  present  value  over  2025-
2050 relative to the baseline 

GHG 

Reduction  in  external  costs 
of 
emissions, 
expressed  as  present  value 
over  2025  2050,  relative  to 
the baseline 

Reduction  in  external  costs 
of  air  pollutant  emissions, 
expressed  as  present  value 
over  2025  2050,  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 

Direct benefits 

EUR 108.1 million 

EUR 2.3 billion 

Indirect benefits 

EUR 674.1 million 

EUR 163.5 million 

EUR 645.2 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  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  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. 

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. 

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* 

77 

 
 
 
II. Overview of costs – Preferred option (Policy option 4) 

Citizens/Consumers 

Businesses 

Administrations 

One-off  Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

Direct 
costs, 
adjustment 
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 0.6 billion 

For 
national 
public 
authorities: 
EUR 0.1 
million 

For EEA: 
EUR 0.7 
million 

For EEA: EUR 3.2 
million 

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 

Direct  administrative  costs, 
expressed  as  present  value 
over  2025-2050,  relative  to 
the baseline 

- 

- 

- 

- 

For 
National 
Accreditati
on Bodies 
(NABs): 
EUR 0.1 
million  

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 

78 

 
 
 
 
 
 
 
 
 
 
 
 
II. Overview of costs – Preferred option (Policy option 4) 

Citizens/Consumers 

Businesses 

Administrations 

One-off  Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

- 

- 

- 

- 

Indirect costs 

Total   

Direct 
adjustment costs, 
as 
expressed 
present 
value 
over  2025-2050, 
relative 
the 
baseline  

to 

Indirect 
adjustment costs 

Administrative 
costs (for 
offsetting), 
average per 
year relative to 
the baseline 

- 

- 

- 

- 

- 

Costs related to the ‘one in, one out’ approach 

- 

- 

- 

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 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 

79 

 
 
 
 
 
 
 
 
 
 
 
 
 
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 
reliable, 
affordable, 
sustainable 
and  modern 
energy for all 

Better and comparable data will provide the base 
for  a  more 
in 
passengers choices and freight transport.  

informed  decisions  making 

distribution 

The WTW GHG  emission  will consider the 
production, 
of 
energy/fuels  for  transport  services,  making 
different energy sources comparable, even if 
used for the same type of transport. 

and 

use 

-  Ensure 
SDG  No  12 
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 
saving 
behaviours  towards  greener  mobility  and 
transport choices. 

induce 

ANNEX 4: ANALYTICAL METHODS 

1.  Description of the analytical methods used  

this 

the  baseline  scenario  for 

The  main  model  used  for  developing 
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.  

initiative 

is 

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.  

80 

 
 
 
 
                                                 
period and refers to EU27. Costs and benefits are expressed as present value over the 2022-2050 period, 
using a 3% discount rate. 

PRIMES-TREMOVE model  

The PRIMES-TREMOVE transport 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 
when linked with PRIMES; pricing of congestion and other externalities such as air pollution, accidents 
and noise; measures supporting R&D); regulatory measures (e.g. CO2 emission performance standards 
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 energy use 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. 

81 

 
 
                                                 
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 

Number of companies 

Share 

Type 
of 
activity 

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. 

82 

 
 
                                                 
Passenger  

Interurban rail 

Freight 

Other transport over land 

Maritime 

Inland navigation 

Air 

Road 

Rail 

Inland navigation 

Maritime 

Air and space 

Postal activities 

Hub operators 

Warehousing and storage 

TSO 

TSO 

TSO 

TSO 

TSO 

TSO 

TSO 

TSO 

TSO 

TSO 

TSO 

HO 

150 

35 

 185  

339,572 

549 

 340,121  

5,745 

3,892 

3,748 

38 

2 

70 

 5,783  

 3,894  

 3,818  

543,186 

641 

 543,827  

561 

5,550 

3,835 

503 

37 

2 

51 

9 

 598  

 5,552  

 3,886  

 512  

88,545 

13,860 

314 

195 

 88,859  

 14,055  

Support activities for transportation  HO 

121,038  1,032 

 122,070  

Other 

Manufacturing 

Wholesale and retail 

Tourism 

TSU 

TSU 

TSU 

31,998  1,529 

 33,527  

578,130 

702 

 578,832  

27,389 

532 

 27,921  

Total 
Source : Ecorys and CE Delft (2023), Impact assessment support study 

  1,767,702  5,738  1,773,440 

81.1%  18.9% 

99.8%  0.2% 

99.3%  0.7% 

99.9%  0.1% 

98.2%  1.8% 

99.9%  0.1% 

93.8%  6.2% 

100.0%  0.0% 

98.7%  1.3% 

98.2%  1.8% 

99.6%  0.4% 

98.6%  1.4% 

99.2%  0.8% 

95.4%  4.6% 

99.9%  0.1% 

98.1%  1.9% 
99.7%  0.3% 

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 

83 

 
 
  
  
 
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 

EU27 

Austria 

Belgium 

Population 

GDP growth 

2020 
447.7 

8.90 

11.51 

2025 
449.3 

9.03 

11.66 

2030 
449.1 

9.15 

11.76 

2020-‘25 
0.9% 

0.9% 

0.8% 

2026-‘30 
1.1% 

1.2% 

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)   

84 

 
 
 
  
                                                 
Bulgaria 

Croatia 

Cyprus 

Czech Republic 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

Population 

GDP growth 

2020 
6.95 

4.06 

0.89 

10.69 

5.81 

1.33 

5.53 

67.20 

83.14 

10.70 

9.77 

4.97 

60.29 

1.91 

2.79 

0.63 

0.51 

17.40 

37.94 

10.29 

19.28 

5.46 

2.10 

47.32 

10.32 

2025 
6.69 

3.94 

0.93 

10.79 

5.88 

1.32 

5.54 

68.04 

83.48 

10.51 

9.70 

5.27 

60.09 

1.82 

2.71 

0.66 

0.56 

17.75 

37.57 

10.22 

18.51 

5.47 

2.11 

48.31 

10.75 

2030 
6.45 

3.83 

0.96 

10.76 

5.96 

1.31 

5.52 

68.75 

83.45 

10.30 

9.62 

5.50 

59.94 

1.71 

2.58 

0.69 

0.59 

17.97 

37.02 

10.09 

17.81 

5.44 

2.11 

48.75 

11.10 

2020-‘25 
0.7% 

2026-‘30 
1.3% 

0.2% 

0.7% 

1.6% 

2.0% 

2.2% 

0.6% 

0.7% 

0.8% 

0.7% 

1.8% 

2.0% 

0.3% 

1.4% 

1.7% 

1.7% 

2.7% 

0.7% 

2.1% 

0.8% 

2.7% 

1.1% 

2.1% 

0.9% 

1.4% 

0.6% 

1.7% 

2.0% 

1.7% 

2.6% 

1.2% 

1.0% 

0.7% 

0.6% 

2.6% 

1.7% 

0.3% 

1.9% 

1.5% 

2.0% 

4.1% 

0.7% 

2.4% 

0.8% 

3.0% 

1.7% 

2.4% 

1.6% 

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. 

85 

 
 
 
  
                                                 
Oil 

in $'15 per boe 

in €'15 per boe 

2015 

2020 

2030 

2040 

2050 

52.3 

47.2 

39.8 

35.8 

92.1 

83.0 

97.4 

87.8 

117.9 

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 by external 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 opportunity to 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)   

86 

 
 
 
                                                 
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 

2050 

2040 

2020 

2025 

2030 

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% 

Freight  

Maritime 

Inland navigation 

Air 

Road 

Rail 

Inland navigation 

Maritime 

Air and space 

Postal activities 

13.2%  18.4%  23.7%  28.9%  36.8% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

22.9%  25.7%  30.0%  37.1%  44.3% 

13.7%  18.3%  22.6%  30.4%  37.6% 

8.1%  13.5%  18.9%  27.0%  35.1% 

0.0% 

0.0% 

0.0% 

0.0% 

0.0% 

13.7%  17.6%  21.6%  29.4%  37.3% 

22.2%  22.2%  33.3%  44.4%  44.4% 

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% 

Other 

Support activities for transportation 

1.0% 

2.0% 

3.0% 

4.9% 

6.8% 

Manufacturing 

Wholesale and retail 

6.3%  11.2%  15.8%  24.4%  32.2% 

6.3%  11.2%  15.8%  24.4%  32.2% 

87 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
 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 

2025 

2050 

2030 

2040 

2020 

Passenger  

Interurban rail 

Freight  

Other transport over land 

Maritime 

Inland navigation 

Air 

Road 

Rail 

Inland navigation 

Maritime 

Air and space 

Postal activities 

Hub operators 

Warehousing and storage 

Support activities for transportation 

Other 

Manufacturing 

Wholesale and retail 

Tourism 

3 

4 

5 

0 

16 

88 

3 

0 

7 

2 

27 

4 

10 

96 

44 

9 

5 

4 

7 

0 

6 

4 

9 

0 

18 

117 

21 

145 

9 

4 

11 

0 

26 

12 

4 

14 

0 

31 

195 

241 

5 

0 

9 

2 

43 

6 

21 

171 

78 

21 

7 

0 

11 

3 

57 

8 

31 

242 

111 

32 

10 

0 

15 

4 

83 

11 

51 

374 

172 

53 

13 

0 

19 

4 

107 

15 

70 

492 

226 

72 

Total 
Source: Ecorys and CE Delft (2023), Impact assessment support study  

318 

507 

687 

1,018 

1,320 

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 
Passenger  

Freight  

Hub operators 

Other 

 Eurostat NACE-code 
Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and storage 
Support activities for transportation 
Manufacturing 

2020 
0.0% 
0.0% 
3.4% 
0.2% 
1.1% 
2.8% 
0.0% 
0.3% 
3.4% 
5.6% 
4.4% 
0.0% 
0.0% 
0.3% 

2025 
0.0% 
0.0% 
4.6% 
0.4% 
1.3% 
3.7% 
0.2% 
0.7% 
4.6% 
6.6% 
6.8% 
0.0% 
0.0% 
0.6% 

2030 
0.0% 
0.0% 
5.6% 
0.5% 
1.5% 
4.5% 
0.2% 
1.0% 
5.6% 
7.6% 
9.0% 
0.0% 
0.0% 
0.8% 

2050 
2040 
0.7% 
0.0% 
0.0% 
0.0% 
9.4% 
7.6% 
1.1% 
0.8% 
2.2% 
1.9% 
7.5% 
6.1% 
0.4% 
0.2% 
2.2% 
1.6% 
7.6% 
9.4% 
9.3%  10.9% 
13.2%  17.0% 
0.1% 
0.1% 
0.1% 
0.0% 
1.6% 
1.2% 

88 

 
 
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
Wholesale and retail 
Tourism 
Source : Ecorys and CE Delft (2023), Impact assessment support study 

0.3% 
0.6% 

0.6% 
1.3% 

0.8% 
2.1% 

1.2% 
3.4% 

1.6% 
4.6% 

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  

Freight  

Interurban rail 

Other transport over land 

Maritime 

Inland navigation 

Air 

Road 

Rail 

Inland navigation 

Maritime 

Air and space 

Postal activities 

Other 

Warehousing and storage 

Support activities for transportation 

Manufacturing 

Wholesale and retail 
Tourism 

0 

25 

0 

25 

0 

25 

0 

25 

1 

25 

197 

263 

324 

438 

540 

9 

42 

15 

50 

20 

57 

31 

70 

42 

82 

14,938  19,857  24,518  33,118  40,840 

0 

19 

132 

28 

1 

37 

175 

33 

1 

55 

216 

38 

1 

90 

292 

47 

2 

123 

360 

55 

3,874 

5,995 

8,004  11,713  15,042 

3 

12 

4 

24 

5 

36 

8 

59 

11 

82 

100 

179 

253 

391 

515 

1,807 
156 

3,229 
366 

4,577  7,065  9,298 
931  1,261 

564 

Total 
Source : Ecorys and CE Delft (2023), Impact assessment support study 

21,342  30,253  38,693  54,279  68,279 

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). 

89 

 
 
 
 
                                                 
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) 

4) Recurrent costs for the use of calculation 
tools 

399 

570 

399 

638 

1,048 

638 

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 with the unit values presented in  costs per transport service and are reported in Table 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. 

All enterprises 

SME 
Large enterprises 

2021 
106.5 
93.3 
13.3 

2030 
200.4 
171.7 
28.7 

2040 
294.4 
250.1 
44.2 

2050 
378.8 
320.6 
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)  

1a) One-off costs for implementing a new GHG emission accounting method 

SME 
Large companies 

1b) One-off costs for switching to a new GHG emission accounting method 

SME 
Large companies 

2) Recurrent annual costs with no verification 

SME 
Large companies 

3) Annual costs for verification activities 

SME 
Large companies 

4) Annual costs for tools use 

SME 
Large companies 

Total costs 
SME 
Large companies 

Source: Ecorys and CE Delft (2023), Impact assessment support study 

3.  Costs of individual policy measures 

90 

2.7 
2.5 
0.2 
0.0 
0.0 
0.0 

3.4 
3.2 
0.2 
0.0 
0.0 
0.0 

3.1 
2.9 
0.2 
0.0 
0.0 
0.0 

2020  2025  2030  2040  2050 
2.2 
2.1 
0.1 
0.0 
0.0 
0.0 
33.8  41.7  54.6  64.0 
32.3  39.8  51.9  60.8 
3.3 
5.7 
4.9 
0.8 
10.2  12.9  17.4  20.7 
8.8  11.0  14.7  17.4 
3.4 
1.4 
50.3  61.4  79.6  92.7 
46.8  56.9  73.3  85.1 
7.6 

3.4 
3.2 
0.2 
0.0 
0.0 
0.0 
24.1 
23.1 
0.9 
2.0 
1.8 
0.2 
6.9 
6.0 
0.9 
36.4 
34.1 
2.2 

1.5 
2.9 
2.5 
0.3 

2.0 
3.6 
3.2 
0.5 

2.7 
4.9 
4.2 
0.7 

4.6 

3.5 

1.9 

6.3 

2.7 

 
 
 
  
  
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) 
2030 

2025 

2035 

2045 

2040 

2050 

SME 
Passenger  

Freight  

Hub operators 

Other 

Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and storage 
Support activities for 
transportation 
Manufacturing 
Wholesale and retail 
Tourism 

5% 
5% 
8% 
8% 
6% 
7% 
5% 
6% 
8% 
8% 
10% 
5% 
5% 

91% 
99% 
98% 
93% 

93% 
99% 
98% 
95% 

53%  100%  100%  100% 
99% 
52%  100%  100%  100%  100% 
91% 
92% 
51% 
99% 
99% 
53% 
98% 
98% 
52% 
51% 
92% 
94% 
52%  100%  100%  100%  100% 
98% 
98% 
52% 
91% 
92% 
51% 
89% 
91% 
50% 
83% 
87% 
50% 
53%  100%  100%  100%  100% 
53%  100%  100%  100%  100% 

99% 
93% 
91% 
89% 

98% 
91% 
90% 
85% 

6% 
6% 
7% 

52% 
52% 
52% 

99% 
99% 
97% 

99% 
99% 
97% 

99% 
99% 
96% 

98% 
98% 
95% 

193 Ecorys and CE Delft (2023), Impact assessment support study.  
194 Ecorys and CE Delft (2023), Impact assessment support study.  

91 

 
 
 
  
  
  
  
  
  
  
  
  
                                                 
Large companies (250 or more)    
Passenger  

Freight  

Hub operators 

Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and storage 
Support activities for 
transportation 
Manufacturing 
Wholesale and retail 
Tourism 

2025 

2030 

2035 

2040 

2045 

2050 

14% 
5% 
16% 
5% 
16% 
16% 
16% 
5% 
17% 
27% 
15% 
22% 
22% 

66% 
73% 
78% 

77% 
99% 
74% 

69% 
99% 
66% 

66% 
74% 
47% 
99% 
99% 
52% 
43% 
63% 
71% 
53%  100%  100%  100%  100% 
56% 
63% 
41% 
62% 
70% 
44% 
46% 
65% 
73% 
53%  100%  100%  100%  100% 
63% 
71% 
46% 
56% 
56% 
41% 
66% 
74% 
46% 
92% 
94% 
59% 
93% 
95% 
59% 

67% 
56% 
70% 
93% 
94% 

73% 
67% 
78% 
95% 
96% 

60% 
66% 
70% 

Other 

15% 
15% 
9% 
Source: Ecorys and CE Delft (2023), Impact assessment support study 

47% 
47% 
51% 

80% 
80% 
92% 

76% 
76% 
90% 

72% 
72% 
88% 

68% 
68% 
87% 

Table 29: Type and size of impacted enterprises in PO1 and PO6 as a percentage of all enterprises targeted by CountEmissions 
EU 

SME 
Passenger  

Freight  

Hub operators 

Other 

Total SMEs 
Large (250 or more) 
Passenger  

Freight  

2025  2030 

2040 

2050 

5% 
5% 
12% 
8% 
7% 
11% 
5% 
6% 
12% 
15% 
17% 
5% 
5% 
6% 
6% 
8% 
8% 

29% 
6% 
34% 
0% 
43% 
34% 
30% 

53%  100%  100% 
53%  100%  100% 
56%  100%  100% 
54%  100%  100% 
53%  100%  100% 
55%  100%  100% 
53%  100%  100% 
53%  100%  100% 
56%  100%  100% 
57%  100%  100% 
59%  100%  100% 
53%  100%  100% 
53%  100%  100% 
53%  100%  100% 
53%  100%  100% 
54%  100%  100% 
54%  100%  100% 

63%  100%  100% 
53%  100%  100% 
66%  100%  100% 
50%  100%  100% 
71%  100%  100% 
67%  100%  100% 
65%  100%  100% 

Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and storage 
Support activities for transportation 
Manufacturing 
Wholesale and retail 
Tourism 

Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 

92 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Hub operators 

Other 

Total large companies (250 or more) 

0% 
Inland navigation 
35% 
Maritime 
44% 
Air and space 
29% 
Postal activities 
Warehousing and storage 
26% 
Support activities for transportation  25% 
26% 
Manufacturing 
26% 
Wholesale and retail 
13% 
Tourism 
24% 

50%  100%  100% 
67%  100%  100% 
78%  100%  100% 
64%  100%  100% 
63%  100%  100% 
62%  100%  100% 
63%  100%  100% 
63%  100%  100% 
57%  100%  100% 
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  

Freight  

Hub operators 

Other 

Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and storage 
Support activities for 
transportation 
Manufacturing 
Wholesale and retail 
Tourism 

Large companies (250 or more)    
Passenger  

Freight  

Hub operators 

Other 

Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and storage 
Support activities for 
transportation 
Manufacturing 
Wholesale and retail 
Tourism 

93 

0.0% 
0.0% 
1.8% 
0.3% 
0.3% 
1.5% 
0.0% 
0.6% 
1.9% 
1.8% 
3.9% 
0.0% 
0.0% 

0.4% 
0.4% 
1.3% 

0.7% 
0.0% 
3.8% 
0.6% 
0.7% 
3.0% 
0.2% 
1.2% 
3.8% 
3.4% 
7.9% 
0.0% 
0.0% 

0.8% 
0.8% 
2.5% 

0.7% 
0.0% 
2.7% 
0.4% 
0.5% 
2.2% 
0.2% 
0.9% 
2.7% 
2.4% 
5.8% 
0.0% 
0.0% 

0.6% 
0.6% 
1.9% 

8.6%  17.1%  11.4% 
0.0% 
0.0% 
0.0% 
7.9%  13.2%  10.5% 
0.0% 
0.0% 
0.0% 
7.1%  14.3%  10.0% 
7.3%  15.0%  10.9% 
8.1%  16.2%  13.5% 
0.0% 
0.0% 
0.0% 
7.8%  15.7% 
9.8% 
11.1%  11.1%  11.1% 
7.6%  15.9%  11.8% 
2.6% 
3.6% 
1.5% 
2.8% 
3.8% 
1.8% 

8.0%  16.3%  11.9% 
8.0%  16.3%  11.9% 
5.4% 
7.4% 
3.7% 

0.7% 
0.0% 
1.8% 
0.3% 
0.3% 
1.4% 
0.2% 
0.6% 
1.8% 
1.6% 
3.8% 
0.0% 
0.0% 

0.4% 
0.4% 
1.2% 

8.6% 
0.0% 
7.9% 
0.0% 
7.1% 
7.2% 
8.1% 
0.0% 
7.8% 
0.0% 
7.6% 
2.1% 
1.8% 

7.7% 
7.7% 
3.5% 

0.7% 
0.0% 
0.9% 
0.1% 
0.2% 
0.7% 
0.0% 
0.3% 
0.9% 
0.8% 
1.8% 
0.0% 
0.0% 

0.2% 
0.2% 
0.6% 

2.9% 
0.0% 
2.6% 
0.0% 
4.3% 
3.4% 
5.4% 
0.0% 
3.9% 
0.0% 
3.8% 
1.0% 
1.0% 

3.8% 
3.8% 
1.7% 

0.1% 
0.0% 
0.2% 
0.0% 
0.0% 
0.1% 
0.0% 
0.1% 
0.2% 
0.2% 
0.4% 
0.0% 
0.0% 

0.0% 
0.0% 
0.1% 

0.6% 
0.0% 
0.5% 
0.0% 
0.9% 
0.7% 
1.1% 
0.0% 
0.8% 
0.0% 
0.8% 
0.2% 
0.2% 

0.8% 
0.8% 
0.3% 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
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  

Freight  

Hub operators 

Other 

Total SMEs 
Large (250 or more) 
Passenger  

Freight  

Hub operators 

Other 

Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and storage 
Support activities for transportation 
Manufacturing 
Wholesale and retail 
Tourism 

Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and storage 
Support activities for transportation 
Manufacturing 
Wholesale and retail 
Tourism 

Total large companies (250 or more) 

 Source: Ecorys and CE Delft (2023), Impact assessment support study 

0.7% 
0.0% 
9.4% 
1.1% 
2.2% 
7.5% 
0.4% 
2.2% 
9.4% 

0.7% 
0.0% 
9.4% 
1.1% 
2.2% 
7.5% 
0.4% 
2.2% 
9.4% 

0.0% 
0.7% 
0.0% 
0.0% 
6.4% 
9.6% 
0.7% 
1.1% 
1.7% 
2.2% 
5.1% 
7.7% 
0.2% 
0.4% 
1.3% 
2.3% 
9.6% 
6.4% 
8.3%  10.9%  10.9%  11.1% 
10.7%  17.0%  17.0%  17.4% 
0.1% 
0.1% 
0.1% 
0.0% 
1.6% 
1.0% 
1.6% 
1.0% 
4.7% 
2.6% 
3.9% 
2.5% 

0.1% 
0.1% 
1.6% 
1.6% 
4.6% 
3.9% 

0.1% 
0.1% 
1.6% 
1.6% 
4.6% 
3.9% 

0.0% 

0.0% 

0.7% 

0.0% 

0.7% 

0.0% 

22.9%  34.3%  34.3%  34.3% 
0.7% 
0.7% 
26.3%  36.8%  36.8%  36.8% 
0.0% 
0.0% 
32.9%  44.3%  44.3%  45.7% 
25.6%  37.6%  37.6%  38.2% 
21.6%  35.1%  35.1%  35.1% 
0.0% 
0.0% 
25.5%  37.3%  37.3%  37.3% 
33.3%  44.4%  44.4%  44.4% 
21.3%  34.1%  34.1%  34.7% 
7.7% 
4.6% 
7.0% 
3.9% 
19.2%  32.2%  32.2%  32.9% 
19.2%  32.2%  32.2%  32.9% 
7.5%  13.5%  13.5%  13.9% 
14.3%  23.0%  23.0%  23.5% 

7.7% 
6.8% 

7.7% 
6.8% 

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 
Other transport over 
land 
Maritime 
Inland navigation 

0.0% 
0.0% 

0.7% 
0.0% 

0.7% 
0.0% 

0.7% 
0.0% 

0.7% 
0.0% 

0.0% 
0.0% 

1.2% 
2.6% 

2.7% 
5.2% 

1.6% 
5.1% 

0.7% 
5.0% 

0.0% 
4.8% 

0.0% 
4.7% 

94 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Freight  

Hub operators 

Other 

Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and 
storage 
Support activities for 
transportation 
Manufacturing 
Wholesale and retail 
Tourism 

2025 
0.6% 
0.7% 
0.0% 
0.6% 
2.7% 
3.0% 
5.2% 
0.2% 

2030 
0.9% 
1.7% 
0.2% 
1.2% 
4.7% 
4.6% 
9.6% 
0.4% 

2035 
0.7% 
0.9% 
0.2% 
0.9% 
3.7% 
3.6% 
7.4% 
0.3% 

2040 
0.6% 
0.1% 
0.2% 
0.6% 
2.8% 
2.8% 
5.4% 
0.3% 

2045 
0.4% 
0.0% 
0.0% 
0.3% 
1.9% 
2.0% 
3.5% 
0.3% 

2050 
0.3% 
0.0% 
0.0% 
0.0% 
1.0% 
1.2% 
1.6% 
0.3% 

0.2% 

0.4% 

0.3% 

0.3% 

0.3% 

0.3% 

0.5% 
0.5% 
1.5% 

1.0% 
1.0% 
3.0% 

0.7% 
0.7% 
2.3% 

0.5% 
0.5% 
1.6% 

0.3% 
0.3% 
1.0% 

0.2% 
0.1% 
0.4% 

Large companies (250 or more)    
Passenger  

Interurban rail 
Other transport over 
land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and 
storage 
Support activities for 
transportation 
Manufacturing 
Wholesale and retail 
Tourism 

8.6%  20.0%  14.3%  11.4% 
0.0% 
0.0% 

0.0% 

0.0% 

5.7% 
0.0% 

2.9% 
0.0% 

7.9% 

10.5%  18.4%  15.8%  13.2% 
5.3% 
0.0%  50.0%  50.0%  50.0%  50.0%  50.0% 
4.3% 
11.4%  18.6%  14.3%  11.4% 
3.9% 
10.8%  18.9%  14.8%  11.1% 
2.7% 
10.8%  18.9%  16.2%  10.8% 
0.0% 
0.0% 
0.0% 
3.9% 
11.8%  19.6%  13.7%  11.8% 
22.2%  22.2%  22.2%  11.1%  11.1%  11.1% 
10.2%  19.1%  15.0%  10.8% 
3.2% 
17.4%  34.4%  33.3%  32.8%  31.8%  30.8% 

8.6% 
7.3% 
8.1% 
0.0% 
7.8% 

0.0% 

0.0% 

7.0% 

17.4%  35.0%  34.0%  33.0%  32.2%  31.2% 

10.2%  19.3%  14.9%  10.7% 
10.2%  19.3%  14.9%  10.7% 
4.7% 
4.4% 

8.6% 

6.6% 

6.8% 
6.8% 
2.9% 

3.0% 
3.0% 
1.2% 

Freight  

Hub operators 

Other 

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  

Freight  

Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 

95 

0.7% 
0.0% 
8.3% 
5.8% 
2.5% 
6.2% 
0.4% 
2.2% 

0.7% 
0.0% 
8.3% 
5.8% 
2.5% 
6.2% 
0.4% 
2.2% 

0.7% 
0.0% 
0.0% 
0.0% 
9.4% 
5.8% 
5.8% 
3.0% 
2.5% 
1.9% 
7.5% 
4.3% 
0.4% 
0.2% 
2.2% 
1.3% 
7.2%  10.4%  10.4%  10.4% 
9.5%  12.1%  12.1%  12.1% 
11.9%  18.6%  18.6%  18.6% 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Hub operators 

Other 

Total SMEs 
Large (250 or more) 
Passenger  

Freight  

Hub operators 

Other 

Total large companies (250 or more) 

Warehousing and storage 
Support activities for transportation 
Manufacturing 
Wholesale and retail 
Tourism 

0.2% 
0.2% 
1.1% 
1.1% 
2.8% 
2.4% 

0.4% 
0.4% 
1.8% 
1.8% 
5.0% 
3.6% 

0.4% 
0.4% 
1.8% 
1.8% 
5.0% 
3.6% 

0.4% 
0.4% 
1.8% 
1.8% 
5.0% 
4.0% 

0.7% 

0.7% 

22.9%  37.1%  37.1%  37.1% 
Interurban rail 
0.7% 
0.7% 
Other transport over land 
28.9%  42.1%  42.1%  42.1% 
Maritime 
0.0%  50.0%  50.0%  50.0% 
Inland navigation 
37.1%  48.6%  48.6%  48.6% 
Air 
29.0%  41.5%  41.5%  41.5% 
Road 
24.3%  37.8%  37.8%  37.8% 
Rail 
0.0% 
0.0% 
Inland navigation 
29.4%  41.2%  41.2%  41.2% 
Maritime 
44.4%  55.6%  55.6%  55.6% 
Air and space 
23.9%  37.3%  37.3%  37.3% 
Postal activities 
Warehousing and storage 
20.5%  38.5%  38.5%  38.5% 
Support activities for transportation  19.5%  38.0%  38.0%  38.0% 
21.3%  35.2%  35.2%  35.2% 
Manufacturing 
21.4%  35.2%  35.2%  35.2% 
Wholesale and retail 
8.3%  14.7%  14.7%  14.7% 
Tourism 
19.2%  31.7%  31.7%  31.7% 

0.0% 

0.0% 

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  

Freight  

Hub operators 

Other 

Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and storage 
Support activities for 
transportation 
Manufacturing 
Wholesale and retail 
Tourism 

0.7% 
0.0% 
0.0% 
0.0% 
5.0% 
2.8% 
0.6% 
0.3% 
1.0% 
0.6% 
4.0% 
2.2% 
0.2% 
0.0% 
1.4% 
0.7% 
5.0% 
2.8% 
4.8% 
3.0% 
5.4%  10.1% 
0.0% 
0.0% 
0.0% 
0.0% 

0.5% 
0.5% 
1.6% 

1.0% 
1.0% 
3.1% 

0.7% 
0.0% 
3.9% 
0.4% 
0.8% 
3.2% 
0.2% 
1.1% 
3.9% 
3.8% 
7.9% 
0.0% 
0.0% 

0.8% 
0.8% 
2.4% 

0.7% 
0.0% 
3.0% 
0.3% 
0.6% 
2.4% 
0.2% 
0.8% 
3.0% 
3.0% 
5.9% 
0.0% 
0.0% 

0.6% 
0.6% 
1.8% 

Large companies (250 or more)    
Passenger  

Interurban rail 
Other transport over land 

96 

8.6%  20.0%  14.3%  11.4% 
0.0% 
0.0% 

0.0% 

0.0% 

0.7% 
0.0% 
2.1% 
0.1% 
0.5% 
1.7% 
0.0% 
0.5% 
2.1% 
2.2% 
4.0% 
0.0% 
0.0% 

0.4% 
0.4% 
1.2% 

0.0% 
0.0% 
1.2% 
0.0% 
0.3% 
1.0% 
0.0% 
0.2% 
1.2% 
1.4% 
2.1% 
0.0% 
0.0% 

0.2% 
0.2% 
0.6% 

5.7% 
0.0% 

2.9% 
0.0% 

 
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Freight  

Hub operators 

2035 

2030 

2025 

2045 
7.9% 

2050 
2040 
10.5%  18.4%  15.8%  13.2% 
5.3% 
0.0%  50.0%  50.0%  50.0%  50.0%  50.0% 
4.3% 
11.4%  18.6%  14.3%  11.4% 
3.9% 
10.8%  18.9%  14.8%  11.1% 
2.7% 
10.8%  18.9%  16.2%  10.8% 
0.0% 
0.0% 
0.0% 
11.8%  19.6%  13.7%  11.8% 
3.9% 
22.2%  22.2%  22.2%  11.1%  11.1%  11.1% 
3.2% 
10.2%  19.1%  15.0%  10.8% 
17.4%  34.4%  33.3%  32.8%  31.8%  30.8% 
17.4%  35.0%  34.0%  33.0%  32.2%  31.2% 

8.6% 
7.3% 
8.1% 
0.0% 
7.8% 

0.0% 

0.0% 

7.0% 

Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and storage 
Support activities for 
transportation 
Manufacturing 
Wholesale and retail 
Tourism 

Other 

10.2%  19.3%  14.9%  10.7% 
10.2%  19.3%  14.9%  10.7% 
4.7% 
4.4% 
Source: Ecorys and CE Delft (2023), Impact assessment support study 

8.6% 

6.6% 

6.8% 
6.8% 
2.9% 

3.0% 
3.0% 
1.2% 

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  

Freight  

Hub operators 

Other 

Total SMEs 
Large (250 or more) 
Passenger  

Freight  

Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and storage 
Support activities for transportation 
Manufacturing 
Wholesale and retail 
Tourism 

Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 

97 

0.7% 
0.0% 

0.7% 
0.0% 

1.1% 
2.5% 
8.5% 
0.4% 
2.4% 

1.1% 
2.5% 
8.5% 
0.4% 
2.4% 

0.7% 
0.0% 
0.0% 
0.0% 
7.4%  10.6%  10.6%  10.6% 
1.1% 
0.7% 
2.5% 
1.9% 
8.5% 
5.9% 
0.2% 
0.4% 
2.4% 
1.4% 
7.4%  10.6%  10.6%  10.6% 
9.5%  12.3%  12.3%  12.3% 
12.2%  19.1%  19.1%  19.1% 
0.1% 
0.1% 
0.1% 
0.0% 
1.8% 
1.1% 
1.8% 
1.1% 
5.2% 
2.9% 
4.4% 
2.9% 

0.1% 
0.1% 
1.8% 
1.8% 
5.2% 
4.4% 

0.1% 
0.1% 
1.8% 
1.8% 
5.2% 
4.4% 

0.7% 

0.7% 

22.9%  37.1%  37.1%  37.1% 
0.7% 
0.7% 
28.9%  42.1%  42.1%  42.1% 
0.0%  50.0%  50.0%  50.0% 
37.1%  48.6%  48.6%  48.6% 
29.0%  41.5%  41.5%  41.5% 
24.3%  37.8%  37.8%  37.8% 
0.0% 
0.0% 
29.4%  41.2%  41.2%  41.2% 
44.4%  55.6%  55.6%  55.6% 
23.9%  37.3%  37.3%  37.3% 

0.0% 

0.0% 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Hub operators 

Other 

Warehousing and storage 
Support activities for transportation 
Manufacturing 
Wholesale and retail 
Tourism 

Total large companies (250 or more) 

Source: Ecorys and CE Delft (2023), Impact assessment support study 

20.5%  38.5%  38.5%  38.5% 
19.5%  38.0%  38.0%  38.0% 
21.3%  35.2%  35.2%  35.2% 
21.4%  35.2%  35.2%  35.2% 
8.3%  14.7%  14.7%  14.7% 
19.2%  31.7%  31.7%  31.7% 

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) 

SME 
Passenger  

Freight  

Hub operators 

Other 

Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and storage 
Support activities for 
transportation 
Manufacturing 
Wholesale and retail 
Tourism 

2025 

2030 

2035 

2040 

2045 

2050 

0.0% 
0.0% 
1.1% 
2.6% 
0.5% 
0.6% 
0.0% 
0.5% 
2.6% 
2.8% 
4.9% 
0.2% 
0.2% 

0.5% 
0.5% 
1.4% 

0.7% 
0.0% 
2.5% 
5.2% 
0.9% 
1.6% 
0.2% 
1.0% 
4.5% 
4.4% 
9.1% 
0.4% 
0.4% 

0.9% 
0.9% 
2.8% 

0.7% 
0.0% 
1.4% 
5.1% 
0.7% 
0.8% 
0.2% 
0.7% 
3.5% 
3.4% 
6.9% 
0.3% 
0.3% 

0.7% 
0.7% 
2.1% 

0.7% 
0.0% 
0.5% 
5.0% 
0.5% 
0.0% 
0.2% 
0.4% 
2.5% 
2.6% 
4.9% 
0.3% 
0.3% 

0.5% 
0.5% 
1.4% 

0.7% 
0.0% 
0.0% 
4.8% 
0.4% 
0.0% 
0.0% 
0.1% 
1.6% 
1.8% 
3.0% 
0.3% 
0.3% 

0.3% 
0.3% 
0.8% 

0.0% 
0.0% 
0.0% 
4.7% 
0.2% 
0.0% 
0.0% 
0.0% 
0.8% 
1.0% 
1.1% 
0.3% 
0.3% 

0.1% 
0.1% 
0.2% 

Large companies (250 or more)    
Passenger  

Freight  

Hub operators 

0.0% 

0.0% 

5.7% 
0.0% 
5.3% 

2.9% 
8.6%  20.0%  14.3%  11.4% 
0.0% 
0.0% 
0.0% 
2.6% 
10.5%  15.8%  13.2%  10.5% 
0.0%  50.0%  50.0%  50.0%  50.0%  50.0% 
2.9% 
11.4%  17.1%  12.9%  10.0% 
3.0% 
10.3%  17.9%  13.9%  10.1% 
0.0% 
8.1% 
10.8%  16.2%  13.5% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
3.9% 
9.8%  19.6%  13.7%  11.8% 
0.0% 
0.0% 
22.2%  11.1%  11.1% 
2.2% 
9.9% 
9.6%  18.2%  14.0% 
17.4%  34.4%  33.3%  32.8%  31.8%  30.8% 
17.4%  35.0%  34.0%  33.0%  32.2%  31.2% 

7.1% 
6.4% 
5.4% 
0.0% 
7.8% 
0.0% 
6.1% 

Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and storage 
Support activities for 
transportation 
Manufacturing 
Wholesale and retail 
Tourism 

Other 

9.6%  18.3%  13.9% 
9.6%  18.3%  13.9% 
6.1% 
8.2% 
4.2% 
Source: Ecorys and CE Delft (2023), Impact assessment support study 

9.7% 
9.7% 
4.2% 

5.7% 
5.7% 
2.4% 

2.0% 
2.0% 
0.7% 

Table 37: Type and size of impacted enterprises in PO5 as a percentage of all enterprises targeted by CountEmissions EU 

2025 

2030 

2040 

2050 

98 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
SME 
Passenger  

Freight  

Hub operators 

Other 

Total SMEs 
Large (250 or more) 
Passenger  

Freight  

Hub operators 

Other 

Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and storage 
Support activities for transportation 
Manufacturing 
Wholesale and retail 
Tourism 

Interurban rail 
Other transport over land 
Maritime 
Inland navigation 
Air 
Road 
Rail 
Inland navigation 
Maritime 
Air and space 
Postal activities 
Warehousing and storage 
Support activities for transportation 
Manufacturing 
Wholesale and retail 
Tourism 

Total large companies (250 or more) 

Source: Ecorys and CE Delft (2023), Impact assessment support study 

0.7% 
0.0% 
8.1% 
5.8% 
2.4% 
6.1% 
0.4% 
2.0% 

0.7% 
0.0% 
8.1% 
5.8% 
2.4% 
6.1% 
0.4% 
2.0% 

0.7% 
0.0% 
0.0% 
0.0% 
9.4% 
5.7% 
5.8% 
3.0% 
2.4% 
1.9% 
7.5% 
4.3% 
0.4% 
0.2% 
1.2% 
2.2% 
7.1%  10.1%  10.1%  10.1% 
9.3%  11.9%  11.9%  11.9% 
11.7%  18.1%  18.1%  18.1% 
0.4% 
0.2% 
0.4% 
0.2% 
1.7% 
1.0% 
1.7% 
1.0% 
4.8% 
2.8% 
4.0% 
2.4% 

0.4% 
0.4% 
1.7% 
1.7% 
4.8% 
3.5% 

0.4% 
0.4% 
1.7% 
1.7% 
4.8% 
3.6% 

0.7% 

0.7% 

0.0% 

0.0% 

22.9%  37.1%  37.1%  37.1% 
0.7% 
0.7% 
28.9%  39.5%  39.5%  39.5% 
0.0%  50.0%  50.0%  50.0% 
37.1%  47.1%  47.1%  47.1% 
28.5%  40.6%  40.6%  40.6% 
24.3%  35.1%  35.1%  35.1% 
0.0% 
0.0% 
27.5%  41.2%  41.2%  41.2% 
44.4%  44.4%  44.4%  44.4% 
23.2%  36.3%  36.3%  36.3% 
20.5%  38.5%  38.5%  38.5% 
19.5%  38.0%  38.0%  38.0% 
20.8%  34.1%  34.1%  34.1% 
20.8%  34.2%  34.2%  34.2% 
8.1%  14.3%  14.3%  14.3% 
18.8%  31.1%  31.1%  31.1% 

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 

99 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
 
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) 
HO 
(Large) 
4,802 

TSU 
(Large) 
6,625 

TSO 
(Large) 
4,802 

TSO 
(SME) 
1,748 

TSU 
(SME) 
2,033 

HO 
(SME) 
1,748 

One-off costs  for starting implementing 
the GHG emission accounting (i.e. ISO 
14083) 
One-off costs for switching to the ISO 
14083 GHG emission accounting method 
Annual recurrent costs 

589 

1,139 

589 

570 

589 

1,262 

1,262 

1,262 

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 value over 2025-2050, the total adjustment costs due to PM1 are estimated at EUR 0.9 billion 
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 

Number companies that switch from other methods to ISO 14083  

SMEs 
Large companies 

2025 
6,152 
6,051 
101 

2030 
1,720 
1,686 
34 

2040 
1,546 
1,515 
31 

2050 
1,389 
1,361 
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. 

100 

 
 
 
  
                                                 
Additional number of companies that implement ISO 14083 
relative to the baseline 

SMEs 
Large companies 

One-off adjustment costs (in million EUR) 

SMEs 
Large companies 

Recurrent adjustment costs (in million EUR) 

SMEs 
Large companies 

Total adjustment costs (in million EUR) 

SMEs 
Large companies 

2025 

2030 

2040 

2050 

14,868 
14,557 
311 
31.8 
29.8 
2.0 
15.9 
15.0 
0.9 
47.7 
44.8 
2.9 

30,219 
29,586 
633 
56.4 
52.7 
3.7 
31.3 
29.6 
1.8 
87.7 
82.2 
5.5 

14,302 
14,000 
302 
25.4 
23.8 
1.7 
13.9 
13.1 
0.8 
39.4 
36.9 
2.5 

1,388 
1,361 
27 
2.9 
2.8 
0.2 
1.3 
1.2 
0.1 
4.2 
4.0 
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 

Number companies switching or implementing ISO 14083 

SMEs 
Large companies 

Source: Ecorys and CE Delft (2023), Impact assessment support study   

2025 
2.6% 
2.5% 
14.3% 

2030 
3.9% 
3.9% 
23.0% 

2040 
3.9% 
3.9% 
23.0% 

2050 
4.0% 
3.9% 
23.5% 

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 

Number companies that switch from other methods to ISO 14083  

SMEs 
Large companies 

Additional number of companies that implement ISO 14083 
relative to the baseline 

SMEs 
Large companies 

One-off adjustment costs (in million EUR) 

SMEs 
Large companies 

Recurrent adjustment costs (in million EUR) 

SMEs 
Large companies 

Total adjustment costs (in million EUR) 

SMEs 
Large companies 

2025 
6,152 
6,051 
101 

21,595 
21,003 
592 
44.8 
41.3 
3.4 
23.6 
21.8 
1.8 
68.4 
63.2 
5.2 

2030 
1,720 
1,686 
34 

39,358 
38,224 
1,134 
73.9 
67.7 
6.2 
41.6 
38.3 
3.3 
115.5 
106.1 
9.5 

2040 
1,546 
1,515 
31 

23,441 
22,638 
803 
41.9 
37.9 
4.0 
23.6 
21.4 
2.2 
65.4 
59.2 
6.2 

2050 
1,389 
1,361 
28 

9,139 
8,638 
501 
16.0 
13.8 
2.2 
9.0 
7.7 
1.3 
25.1 
21.5 
3.5 

101 

 
 
  
  
  
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 

Number companies switching or implementing ISO 14083 

SMEs 
Large companies 

Source: Ecorys and CE Delft (2023), Impact assessment support study   

2025 
3.0% 
2.9% 
19.2% 

2030 
4.4% 
4.4% 
31.7% 

2040 
4.4% 
4.4% 
31.7% 

2050 
4.4% 
4.4% 
31.7% 

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 to PM1 are estimated at EUR 60.5 billion in PO6 relative to the 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 

Number companies that switch from other methods to ISO 14083  

SMEs 
Large companies 

Additional number of companies that implement ISO 14083 
relative to the baseline 

SMEs 
Large companies 

One-off adjustment costs (in million EUR) 

SMEs 
Large companies 

Recurrent adjustment costs (in million EUR) 

SMEs 
Large companies 

Total adjustment costs (in million EUR) 

SMEs 
Large companies 

2025 
6,152 
6,051 
101 

2030 
1,720 
1,686 
34 

2040 
1,546 
1,515 
31 

2050 
1,389 
1,361 
28 

110,570  918,003  1,718,143  1,703,841 
109,689  915,130  1,713,423  1,699,423 
4,418 
2,698.2 
2,677.1 
21.1 
1,353.5 
1,342.3 
11.2 
4,051.7 
4,019.4 
32.3 

4,720 
2,913.4 
2,889.1 
24.3 
1,463.0 
1,450.2 
12.8 
4,376.3 
4,339.3 
37.1 

2,873 
1,660.2 
1,644.5 
15.8 
835.5 
827.2 
8.3 
2,495.8 
2,471.7 
24.1 

881 
210.5 
205.4 
5.1 
107.3 
104.7 
2.6 
317.8 
310.1 
7.7 

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 

Number companies switching or implementing ISO 14083 

SMEs 
Large companies 

Source: Ecorys and CE Delft (2023), Impact assessment support study   

2025 
8.0% 
7.9% 
24.2% 

2030 

2050 
2040 
54.0%  100.0%  100.0% 
54.0%  100.0%  100.0% 
62.0%  100.0%  100.0% 

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. 

102 

 
 
  
  
  
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 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 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. 

103 

 
 
                                                 
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 
One-off costs  for starting implementing 
the GHG emission accounting (i.e. 
PEFCR) 
One-off costs for switching to the PEFCR 
GHG emission accounting method 
Annual recurrent costs 

TSO 
(SME) 
3,092 

TSU 
(SME) 
3,619 

HO 
(SME) 
3,092 

TSO 
(Large) 
11,502 

TSU 
(Large) 
16,560 

HO 
(Large) 
11,502 

2,671 

3,066 

2,671 

9,447 

13,241 

9,447 

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 

Number companies that switch from other methods to PEFCR 

SMEs 
Large companies 

Additional number of companies that implement PEFCR 
relative to the baseline 

SMEs 
Large companies 

One-off adjustment costs (in million EUR) 

SMEs 
Large companies 

Recurrent adjustment costs (in million EUR) 

SMEs 
Large companies 

Total adjustment costs (in million EUR) 

SMEs 
Large companies 

2025 
6,152 
6,051 
101 

12,202 
11,629 
573 
63.1 
54.2 
8.9 
29.9 
26.5 
3.4 
93.0 
80.7 
12.4 

2030 
1,720 
1,686 
34 

25,102 
24,006 
1,096 
94.6 
79.7 
14.8 
50.0 
44.0 
6.0 
144.6 
123.8 
20.8 

2040 
1,546 
1,515 
31 

9,278 
8,513 
765 
38.8 
29.3 
9.4 
18.3 
14.3 
4.0 
57.1 
43.7 
13.4 

2050 
1,389 
1,361 
28 

2,783 
2,320 
463 
14.6 
9.6 
5.0 
6.9 
4.6 
2.3 
21.5 
14.1 
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 

Number companies switching or implementing PEF CR 

SMEs 
Large companies 

Source: Ecorys and CE Delft (2023), Impact assessment support study 

2025 
2.4% 
2.4% 
18.8% 

2030 
3.6% 
3.5% 
31.1% 

2040 
3.6% 
3.6% 
31.1% 

2050 
4.1% 
4.0% 
31.1% 

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 

104 

 
 
  
  
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. 

105 

 
 
                                                 
Table 48: Unit adjustment costs per type of business due to PM3 in PO1 and PO3 (in EUR, 2022 prices) 
TSO 
(SME) 
2,439 

TSU 
(Large) 
13,418 

TSO 
(Large) 
9,044 

TSU 
(SME) 
2,781 

HO 
(SME) 
2,439 

HO 
(Large) 
9,044 

One-off costs  for starting implementing 
the GHG emission accounting (i.e. ISO 
14083 with additional elements and 
increased accuracy) 
One-off costs for switching to the ISO 
14083 with additional elements and 
increased accuracy GHG emission 
accounting method 
Annual recurrent costs 

912 

912 

912 

1,514 

1,514 

1,514 

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 

Number companies that switch from other methods 
to ISO 14083 with additional elements and increased 
accuracy 
SMEs 
Large companies 

Additional number of companies that implement 
ISO 14083 with additional elements and increased 
accuracy, relative to the baseline 

SMEs 
Large companies 

One-off adjustment costs (in million EUR) 

SMEs 
Large companies 

Recurrent adjustment costs (in million EUR) 

SMEs 
Large companies 

Total adjustment costs (in million EUR) 

SMEs 
Large companies 

2025 
6,152 

2030 
1,720 

2040 
1,546 

2050 
1,389 

6,051 
101 
110,570 

1,686 
34 
918,003 

1,515 
31 
1,718,143 

1,361 
28 
1,703,841 

109,689 
881 
295.0 
285.2 
9.8 
130.2 
126.9 
3.2 
425.2 
412.2 
13.0 

915,130 
2,873 
2,308.0 
2,277.1 
30.9 
1,003.0 
993.0 
10.0 
3,311.0 
3,270.1 
40.9 

1,713,423 
4,720 
4,047.6 
4,000.1 
47.5 
1,755.9 
1,740.5 
15.4 
5,803.5 
5,740.6 
62.9 

1,699,423 
4,418 
3,747.8 
3,706.4 
41.3 
1,624.5 
1,611.0 
13.5 
5,372.2 
5,317.4 
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 

106 

 
 
 
  
  
Number  companies  switching  or  implementing  to  ISO  14083  with 
additional elements and increased accuracy 

SMEs 
Large companies 

Source: Ecorys and CE Delft (2023), Impact assessment support study 

8.0%  54.0%  100.0%  100.0% 
7.9%  54.0%  100.0%  100.0% 
24.2%  62.0%  100.0%  100.0% 

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 

Number companies that switch from other methods 
to ISO 14083 with additional elements and increased 
accuracy 
SMEs 
Large companies 

Additional number of companies that implement 
ISO 14083 with additional elements and increased 
accuracy, relative to the baseline 

SMEs 
Large companies 

One-off adjustment costs (in million EUR) 

SMEs 
Large companies 

Recurrent adjustment costs (in million EUR) 

SMEs 
Large companies 

Total adjustment costs (in million EUR) 

SMEs 
Large companies 

2025 
6,152 

2030 
1,720 

2040 
1,546 

6,051 
101 
13,023 

12,431 
592 
43.6 
37.0 
6.6 
18.1 
15.9 
2.2 
61.7 
52.9 
8.8 

1,686 
34 
26,745 

25,611 
1,134 
76.3 
64.3 
12.0 
33.8 
29.9 
4.0 
110.2 
94.2 
16.0 

1,515 
31 
10,828 

10,025 
803 
32.4 
24.7 
7.7 
13.1 
10.4 
2.7 
45.5 
35.1 
10.4 

2050 
1,389 

1,361 
28 
3,640 

3,139 
501 
12.0 
7.9 
4.2 
4.9 
3.3 
1.6 
16.9 
11.2 
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 

SMEs 
Large companies 

Source: Ecorys and CE Delft (2023), Impact assessment support study 

4.1% 
2.5% 
4.0% 
2.4% 
19.2%  31.7%  31.7%  31.7% 

3.7% 
3.6% 

3.7% 
3.6% 

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.  

107 

 
 
  
  
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 intensity factors 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 by EEA 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 quality check of each 

203 Source: EEA 
204 Source: EEA 

108 

 
 
                                                 
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 by sector 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 17 databases is assumed to be submitted. The cost per database for preparing the submission 
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 

109 

 
 
                                                 
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 

110 

 
 
                                                 
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) 

Baseline 
PO1 
Source: Ecorys and CE Delft (2023), Impact assessment support study; Note: ‘Large’ stands for large businesses. 

TSO 
(SME) 
399 
273 

TSU 
(SME) 
570 
410 

HO 
(SME) 
399 
273 

TSO 
(Large) 
638 
465 

TSU 
(Large) 
1,048 
684 

HO 
(Large) 
638 
465 

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 

ISO/IEC. 

standards 

international 

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 
https://ec.europa.eu/growth/tools-
as 
such 
to 
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 

111 

 
 
 
                                                 
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) 

Number of companies that perform 
verification activities in the baseline 

SMEs 
Large companies 

Costs for companies switching to ISO+ 
verification (in million EUR) relative to the 
baseline 
SMEs 
Large companies 

Additional number of companies that perform 
verification in PM8  

SMEs 
Large companies 

Costs for additional companies that perform 
verification (in million EUR) relative to the 
baseline 
SMEs 
Large companies 

Total additional costs relative to the baseline 
(in million EUR) relative to the baseline 

SMEs 
Large companies 

2025 
6,457 

6,051 
406 
-0.9 

-0.8 
-0.1 
134,873 

133,891 
982 
42.4 

41.9 
0.6 
41.5 

41.1 
0.4 

2030 
8,290 

7,739 
551 
-1.1 

-1.0 
-0.1 
949,093 

946,084 
3,009 
297.3 

295.6 
1.7 
296.2 

294.7 
1.5 

2040 
11,670 

10,856 
814 
-1.5 

2050 
14,711 

13,654 
1,057 
-1.8 

-1.3 
-0.2 
1,761,770 

-1.5 
-0.3 
1,758,729 

1,756,846 
4,924 
518.7 

1,754,048 
4,681 
483.7 

516.2 
2.5 
517.2 

514.9 
2.3 

481.5 
2.2 
481.9 

479.9 
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 

Number companies performing verification 

SMEs 
Large companies 

2025 
8.0% 
7.9% 
24.2% 

2030 
54.0% 
54.0% 
62.0% 

2040 
100.0% 
100.0% 
100.0% 

2050 
100.0% 
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 

interna- 

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 
https://ec.europa.eu/growth/tools-
tional 
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 

standards 

ISO/IEC. 

such 

as 

112 

 
 
  
  
                                                 
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 
PO3 
PO4 
PO5 
PO6 
Source: Ecorys and CE Delft (2023), Impact assessment support study 

570 
410 
342 
1,265 
342 

399 
273 
228 
948 
228 

399 
273 
228 
948 
228 

638 
465 
387 
1,391 
387 

1,048 
684 
570 
2,150 
570 

638 
465 
387 
1,391 
387 

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. 

113 

 
 
 
                                                 
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) 

Number of companies that perform verification 
activities in the baseline 

SMEs 
Large companies 

Costs for companies switching to ISO+ 
verification (in million EUR) relative to the 
baseline 
SMEs 
Large companies 

Additional number of companies that perform 
verification in PM9  

SMEs 
Large companies 

Costs for additional companies that perform 
verification (in million EUR) relative to the 
baseline 
SMEs 
Large companies 

Total additional costs relative to the baseline (in 
million EUR) relative to the baseline 

2025 
6,457 

6,051 
406 
-0.9 

-0.8 
-0.1 
3,179 

2,486 
693 
1.2 

0.8 
0.4 
0.3 

2030 
8,290 

7,739 
551 
-1.1 

-1.0 
-0.1 
6,393 

5,123 
1,270 
2.2 

1.5 
0.7 
1.1 

2040 
11,670 

10,856 
814 
-1.5 

-1.3 
-0.2 
3,013 

2,006 
1,007 
1.1 

0.6 
0.5 
-0.4 

2050 
14,711 

13,654 
1,057 
-1.8 

-1.5 
-0.3 
1,395 

631 
764 
0.5 

0.2 
0.3 
-1.3 

SMEs 
Large companies 

-1.3 
0.1 
Source: Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs savings, 
where relevant.  

-0.7 
0.3 

0.6 
0.5 

0.0 
0.3 

Table 58: type and size of impacted enterprises due to PM9 in PO3 of all enterprises targeted with CountEmissions 
EU 

Number companies performing verification 

SMEs 
Large companies 

2025 
0.5% 
0.5% 
19.2% 

2030 
0.8% 
0.7% 
31.7% 

2040 
0.8% 
0.7% 
31.7% 

2050 
0.9% 
0.8% 
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) 

Number of companies that perform verification 
activities in the baseline 

SMEs 
Large companies 

Costs for companies switching to ISO 
verification (in million EUR) relative to the 
baseline 
SMEs 
Large companies 

2025 
6,457 

6,051 
406 
-1.2 

-1.1 
-0.2 

2030 
8,290 

7,739 
551 
-1.5 

-1.3 
-0.2 

2040 
11,670 

10,856 
814 
-2.1 

2050 
14,711 

13,654 
1,057 
-2.4 

-1.8 
-0.3 

-2.1 
-0.3 

114 

 
 
  
  
  
Additional number of companies that perform 
verification in PM9 

4,892 

8,913 

5,533 

2,492 

SMEs 
Large companies 

Costs for additional companies that perform 
verification (in million EUR) relative to the 
baseline 
SMEs 
Large companies 

Total additional costs relative to the baseline (in 
million EUR) relative to the baseline 

4,199 
693 
1.4 

1.0 
0.3 
0.1 

7,643 
1,270 
2.4 

1.8 
0.6 
0.9 

4,526 
1,007 
1.4 

1.0 
0.4 
-0.6 

1,728 
764 
0.6 

0.4 
0.3 
-1.8 

SMEs 
Large companies 

-1.7 
-0.1 
Source: Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs savings, 
where relevant.  

-0.8 
0.1 

0.5 
0.4 

0.0 
0.2 

Table 60: type and size of impacted enterprises due to PM9 in PO4 of all enterprises targeted with CountEmissions EU 

Number companies performing verification 

SMEs 
Large companies 

2025 
0.6% 
0.6% 
19.2% 

2030 
1.0% 
0.9% 
31.7% 

2040 
1.0% 
0.9% 
31.7% 

2050 
1.0% 
0.9% 
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) 

Number of companies that perform verification 
activities in the baseline 

SMEs 
Large companies 

Costs for companies switching to PEF 
verification (in million EUR) relative to the 
baseline 
SMEs 
Large companies 

Additional number of companies that perform 
verification in PM9 

SMEs 
Large companies 

Costs for additional companies that perform 
verification (in million EUR) relative to the 
baseline 
SMEs 
Large companies 

Total additional costs relative to the baseline (in 
million EUR) relative to the baseline 

SMEs 
Large companies 

2025 
6,457 

6,051 
406 
3.8 

3.4 
0.4 
3,000 

2,326 
674 
3.6 

2.4 
1.2 
7.4 

5.9 
1.5 

2030 
8,290 

7,739 
551 
4.8 

4.3 
0.5 
6,033 

4,801 
1,232 
6.9 

4.8 
2.1 
11.6 

9.1 
2.6 

2040 
11,670 

10,856 
814 
6.4 

5.7 
0.7 
2,672 

1,703 
969 
3.1 

1.7 
1.5 
9.5 

7.3 
2.2 

2050 
14,711 

13,654 
1,057 
7.5 

6.7 
0.9 
1,193 

467 
726 
1.4 

0.4 
1.0 
8.9 

7.1 
1.9 

Source: Ecorys and CE Delft (2023), Impact assessment support study 

115 

 
 
  
  
Table 62: type and size of impacted enterprises due to PM9 in PO5 of all enterprises targeted with CountEmissions 
EU 

Number companies performing verification 

SMEs 
Large companies 

2025 
0.6% 
0.5% 
14.3% 

2030 
0.8% 
0.8% 
23.0% 

2040 
0.8% 
0.8% 
23.0% 

2050 
0.9% 
0.8% 
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) 

Number of companies that perform verification 
activities in the baseline 

SMEs 
Large companies 

Costs for companies switching to ISO verification 
(in million EUR) relative to the baseline 

SMEs 
Large companies 

Additional number of companies that perform 
verification in PM9 

SMEs 
Large companies 

Costs for additional companies that perform 
verification (in million EUR) relative to the 
baseline 
SMEs 
Large companies 

Total additional costs relative to the baseline (in 
million EUR) relative to the baseline 

2025 
6,457 

6,051 
406 
-1.2 

-1.1 
-0.2 
22,921 

21,939 
982 
6.3 

5.8 
0.5 
5.0 

SMEs 
Large companies 

4.7 
0.3 
Source: Ecorys and CE Delft (2023), Impact assessment support study 

2030 
8,290 

7,739 
551 
-1.5 

-1.3 
-0.2 
186,037 

183,028 
3,009 
49.2 

47.8 
1.4 
47.6 

46.5 
1.2 

2040 
11,670 

10,856 
814 
-2.1 

-1.8 
-0.3 
347,609 

342,685 
4,924 
86.2 

84.1 
2.1 
84.1 

82.3 
1.8 

2050 
14,711 

13,654 
1,057 
-2.4 

-2.1 
-0.3 
344,568 

339,887 
4,681 
79.8 

78.0 
1.9 
77.4 

75.9 
1.5 

Table 64: type and size of impacted enterprises due to PM9 in PO6 of all enterprises targeted with CountEmissions 
EU 

Number companies performing verification 

2025 
1.7% 
1.6% 
24.2% 
Source: Ecorys and CE Delft (2023), Impact assessment support study 

SMEs 
Large companies 

2030 
11.0% 
10.8% 
62.0% 

2040 
20.3% 
20.0% 
100.0% 

2050 
20.3% 
20.0% 
100.0% 

116 

 
 
  
  
  
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) 

PO2 
Source: Ecorys and CE Delft (2023), Impact assessment support study 

TSO 
(SME) 
228 

TSU 
(SME) 
342 

HO 
(SME) 
228 

TSO 
(Large) 
387 

TSU 
(Large) 
570 

HO 
(Large) 
387 

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) 

Number of companies that perform verification 
activities in the baseline 

SMEs 
Large companies 

2025 
6,457 

6,051 
406 

2030 
8,290 

7,739 
551 

2040 
11,670 

10,856 
814 

2050 
14,711 

13,654 
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 
https://eur-lex.europa.eu/legal-
from 
content/EN/TXT/?uri=CELEX:32016R2072  
225 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour 

emissions 

maritime 

transport 

dioxide 

carbon 

of 

117 

 
 
 
  
                                                 
Costs for companies switching to ISO 
verification (in million EUR) relative to the 
baseline 
SMEs 
Large companies 

Additional number of companies that perform 
verification in PM10 

SMEs 
Large companies 

Costs for additional companies that perform 
verification (in million EUR) relative to the 
baseline 
SMEs 
Large companies 

Total additional costs relative to the baseline (in 
million EUR) relative to the baseline 

2025 
-1.2 

2030 
-1.5 

2040 
-2.1 

2050 
-2.4 

-1.1 
-0.2 
16,770 

16,358 
412 
4.2 

4.0 
0.2 
3.0 

-1.3 
-0.2 
27,173 

26,404 
769 
6.7 

6.3 
0.4 
5.2 

-1.8 
-0.3 
23,793 

23,287 
506 
5.5 

5.2 
0.2 
3.4 

-2.1 
-0.3 
21,461 

21,171 
290 
4.6 

4.4 
0.1 
2.1 

SMEs 
Large companies 

2.3 
-0.2 
Source: Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs savings, 
where relevant.  

3.5 
-0.1 

5.0 
0.2 

2.9 
0.1 

Table 67: type and size of impacted enterprises due to PM10 in PO5 of all enterprises targeted with CountEmissions 
EU 

Number companies performing verification 

SMEs 
Large companies 

2025 
0.6% 
0.5% 
14.3% 

2030 
0.8% 
0.8% 
23.0% 

2040 
0.8% 
0.8% 
23.0% 

2050 
0.9% 
0.8% 
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) 

118 

 
 
  
  
 
Baseline 
PO1 
PO2 

257 
308 
257 

514 
377 
314 

514 
377 
314 

1,799 
2,158 
1,753 

3,597 
4,317 
3,506 

3,597 
4,317 
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  

Number companies using calculation tools 

SMEs 
Large companies 

2025 
8.0% 
7.9% 
24.2% 

2030 
54.0% 
54.0% 
62.0% 

2040 
100.0% 
100.0% 
100.0% 

2050 
100.0% 
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) 

Number of companies that use calculation tools in 
the baseline 
SMEs 
Large companies 

Additional number of companies that need 
calculation tools in PM11 

SMEs 
Large companies 

Total costs relative to the baseline (in million EUR) 

SMEs 
Large companies 

2025 
30,760 

30,253 
507 
110,570 

109,689 
881 
41.2 
37.6 
3.6 

2030 
39,380 

38,693 
687 
918,003 

915,130 
2,873 
312.1 
301.4 
10.7 

2040 
55,297 

2050 
69,599 

54,279 
1,018 
1,718,143 

1,713,423 
4,720 
545.8 
529.4 
16.4 

68,279 
1,320 
1,703,841 

1,699,423 
4,418 
505.3 
490.8 
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 

Number companies using calculation tools 

SMEs 
Large companies 

2025 
8.0% 
7.9% 
24.2% 

2030 
54.0% 
54.0% 
62.0% 

2040 
100.0% 
100.0% 
100.0% 

2050 
100.0% 
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) 

Number of companies that use calculation tools in 
the baseline 
SMEs 
Large companies 

Additional number of companies that need 
calculation tools in PM11 

SMEs 
Large companies 

Total costs relative to the baseline (in million EUR) 

SMEs 

2025 
30,760 

30,253 
507 
14,868 

14,557 
311 
4.0 
3.1 

2030 
39,380 

38,693 
687 
30,219 

29,586 
633 
8.4 
6.6 

2040 
55,297 

54,279 
1,018 
14,302 

14,000 
302 
2.6 
1.9 

2050 
69,599 

68,279 
1,320 
1,388 

1,361 
27 
-1.6 
-1.6 

119 

 
 
  
  
  
  
Large companies 

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.  

1.8 

0.8 

0.9 

Table 72: type and size of impacted enterprises due to PM11 in PO1 of all enterprises targeted with CountEmissions 
EU 

Number companies using calculation tools 

SMEs 
Large companies 

2025 
2.6% 
2.5% 
14.3% 

2030 
3.9% 
3.9% 
23.0% 

2040 
3.9% 
3.9% 
23.0% 

2050 
4.0% 
3.9% 
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) 

Baseline 
PO3 

TSO 
(SME) 
257 
308 

TSU 
(SME) 
514 
377 

HO 
(SME) 
514 
377 

PO4 
PO5 
PO6 
Source: Ecorys and CE Delft (2023), Impact assessment support study 

257 
475 
257 

314 
951 
314 

314 
951 
314 

TSO (Large) 

1,799 
2,158 

1,753 
3,328 
1,753 

TSU 
(Large) 
3,597 
4,317 

HO 
(Large) 
3,597 
4,317 

3,506 
6,655 
3,506 

3,506 
6,655 
3,506 

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) 

Number of companies that use calculation tools in 
the baseline 
SMEs 
Large companies 

2025 
30,760 

30,253 
507 

2030 
39,380 

38,693 
687 

2040 
55,297 

54,279 
1,018 

2050 
69,599 

68,279 
1,320 

120 

 
 
  
 
  
Additional number of companies that need 
calculation tools in PM12 

SMEs 
Large companies 

Total costs relative to the baseline (in million EUR) 

SMEs 
Large companies 

2025 
13,023 

12,431 
592 
7.5 
4.9 
2.6 

2030 
26,745 

25,611 
1,134 
13.7 
9.1 
4.7 

2040 
10,828 

10,025 
803 
7.6 
4.2 
3.4 

2050 
3,640 

3,139 
501 
4.5 
2.1 
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 

Number companies using calculation tools 

SMEs 
Large companies 

2025 
2.5% 
2.4% 
19.2% 

2030 
3.7% 
3.6% 
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) 

Number of companies that use calculation tools in 
the baseline 
SMEs 
Large companies 

Additional number of companies that need 
calculation tools in PM12 

SMEs 
Large companies 

Total costs relative to the baseline (in million EUR) 

SMEs 
Large companies 

2025 
30,760 

30,253 
507 
21,595 

21,003 
592 
6.7 
4.8 
1.8 

2030 
39,380 

38,693 
687 
39,358 

38,224 
1,134 
12.3 
8.9 
3.4 

Source: Ecorys and CE Delft (2023), Impact assessment support study.  

2040 
3.7% 
3.6% 
31.7% 

2040 
55,297 

54,279 
1,018 
23,441 

22,638 
803 
6.2 
4.0 
2.3 

2050 
4.1% 
4.0% 
31.7% 

2050 
69,599 

68,279 
1,320 
9,139 

8,638 
501 
1.4 
0.1 
1.3 

Table 77: type and size of impacted enterprises due to PM12 in PO4 of all enterprises targeted with CountEmissions 
EU 

Number companies using calculation tools 

SMEs 
Large companies 

2025 
3.0% 
2.9% 
19.2% 

2030 
4.4% 
4.4% 
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) 

Number of companies that use calculation tools in 
the baseline 
SMEs 
Large companies 

Additional number of companies that need 
calculation tools in PM12 

SMEs 
Large companies 

Total costs relative to the baseline (in million EUR) 

2025 
30,760 

30,253 
507 
12,202 

11,629 
573 
19.3 

2030 
39,380 

38,693 
687 
25,102 

24,006 
1,096 
31.6 

2040 
4.4% 
4.4% 
31.7% 

2040 
55,297 

54,279 
1,018 
9,278 

8,513 
765 
24.4 

2050 
4.4% 
4.4% 
31.7% 

2050 
69,599 

68,279 
1,320 
2,783 

2,320 
463 
21.5 

121 

 
 
  
  
  
  
  
SMEs 
Large companies 

2025 
14.7 
4.6 

2030 
23.6 
8.0 

2040 
17.8 
6.6 

2050 
16.1 
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 

Number companies using calculation tools 

SMEs 
Large companies 

2025 
2.4% 
2.4% 
18.8% 

2030 
3.6% 
3.5% 
31.1% 

2040 
3.6% 
3.6% 
31.1% 

2050 
4.1% 
4.0% 
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) 
2030 
39,380 

Number of companies that use calculation tools in the baseline 

2025 
30,760 

2040 
55,297 

2050 
69,599 

SMEs 
Large companies 

Additional number of companies that need calculation tools in 
PM12 

SMEs 
Large companies 

Total costs relative to the baseline (in million EUR) 

SMEs 
Large companies 

30,253 
507 

68,279 
1,320 
110,570  918,003  1,718,143  1,703,841 

38,693 
687 

54,279 
1,018 

109,689  915,130  1,713,423  1,699,423 
4,418 
417.3 
406.1 
11.1 

4,720 
451.5 
438.7 
12.8 

2,873 
257.7 
249.4 
8.3 

881 
32.5 
29.8 
2.7 

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 

Number companies using calculation tools 

2025 
8.0% 
7.9% 
24.2% 
Source: Ecorys and CE Delft (2023), Impact assessment support study 

SMEs 
Large companies 

2030 
54.0% 
54.0% 
62.0% 

2040 
100.0% 
100.0% 
100.0% 

2050 
100.0% 
100.0% 
100.0% 

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, the recurrent administrative costs for businesses are estimated at EUR 18,076 from 2025 onwards 
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 

122 

 
 
  
  
  
  
                                                 
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 by other (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. 

123 

 
 
                                                 
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 presenting emissions figures to interested individuals might be more 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 

124 

 
 
 
                                                 
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. 

125 

 
 
                                                 
 
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 

Climate aware population over time 
Source : Ecorys and CE Delft (2023), Impact assessment support study 

14% 

91% 

These values are used as proxy to identify the potential behavioural changes affecting the 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) are based on the literature235, relevant case studies and use cases, and the 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 (-) 

Road transport 

Buses and coaches 
Passenger cars and 
vans (taxis) 

P2W 

Rail 

Air transport 

Passe
nger 
cars 
and 
vans 

Buses 
and 
coaches 

P2W  Rail 

Output mode (+) 
Domestic 
and 
Internati
onal 
intra-EU 
(air) 

Internation
al extra-
EU (air) 

Intra-
EU 
mariti
me 
transp
ort 

IWW and 
domestic 
maritime 

0% 

0% 

1% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

5% 

2% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

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). 

126 

 
 
  
  
  
                                                 
Domestic and 
International intra-EU 

International extra-EU 
Inland waterway and 
domestic maritime 
Intra-EU maritime 
transport 

0% 

0% 

0% 

50% 

0% 

0% 

0% 

0% 

0% 

0% 

40% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

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 transport 

Rail 

Inland waterway and domestic maritime 

International maritime activity  

Road 
freight 
transport 

Rail 

IWW and 
domestic 
maritime 

International 
maritime 
activity  

0% 

0% 

0% 

0% 

40% 

0% 

10% 

0% 

0% 

0% 

0% 

0% 

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) 
2050 

2030 

2025 

2040 

PO1 

127 

 
 
  
  
  
Total passenger transport activity (Gpkm) 

Road transport 

Buses and coaches 
Passenger cars and vans 
P2W 

Rail 
Air transport 

Domestic and International intra-EU 
International extra-EU 

Inland waterway and domestic maritime 
Intra-EU maritime transport 

Total freight transport activity (Gtkm) 

Road transport 
Rail 
Inland waterway and domestic maritime 
International maritime activity  

PO2 

Total passenger transport activity (Gpkm) 

Road transport 

Buses and coaches 
Passenger cars and vans 
P2W 

Rail 
Air transport 

Domestic and International intra-EU 
International extra-EU 

Inland waterway and domestic maritime 
Intra-EU maritime transport 

Total freight transport activity (Gtkm) 

Road transport 
Rail 
Inland waterway and domestic maritime 
International maritime activity  

PO3 

Total passenger transport activity (Gpkm) 

Road transport 

Buses and coaches 
Passenger cars and vans 
P2W 

Rail 
Air transport 

Domestic and International intra-EU 
International extra-EU 

Inland waterway and domestic maritime 
Intra-EU maritime transport 

Total freight transport activity (Gtkm) 

2025 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.1% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.1% 
0.0% 
0.0% 
2025 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.1% 
-0.1% 
-0.1% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.1% 
0.0% 
0.0% 
2025 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 

2030 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.5% 
-0.3% 
-0.3% 
-0.3% 
0.0% 
0.0% 
0.0% 
-0.3% 
0.4% 
0.0% 
0.0% 
2030 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.2% 
-0.1% 
-0.1% 
-0.1% 
0.0% 
0.0% 
0.0% 
-0.1% 
0.1% 
0.0% 
0.0% 
2030 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.1% 
-0.1% 
-0.1% 
-0.1% 
0.0% 
0.0% 
0.0% 

2040 
-0.1% 
0.0% 
-0.1% 
0.0% 
0.0% 
0.8% 
-0.5% 
-0.6% 
-0.5% 
0.0% 
0.0% 
0.0% 
-0.5% 
0.7% 
0.0% 
0.0% 
2040 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.1% 
0.0% 
-0.1% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.1% 
0.0% 
0.0% 
2040 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 

2050 
-0.1% 
0.0% 
-0.1% 
0.0% 
0.0% 
0.8% 
-0.5% 
-0.6% 
-0.5% 
0.0% 
0.0% 
0.0% 
-0.5% 
0.7% 
0.0% 
0.0% 
2050 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
2050 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 

128 

 
 
  
  
  
  
  
Road transport 
Rail 
Inland waterway and domestic maritime 
International maritime activity  

PO4 

Total passenger transport activity (Gpkm) 

Road transport 

Buses and coaches 
Passenger cars and vans 
P2W 

Rail 
Air transport 

Domestic and International intra-EU 
International extra-EU 

Inland waterway and domestic maritime 
Intra-EU maritime transport 

Total freight transport activity (Gtkm) 

Road transport 
Rail 
Inland waterway and domestic maritime 
International maritime activity  

PO5 

Total passenger transport activity (Gpkm) 

Road transport 

Buses and coaches 
Passenger cars and vans 
P2W 

Rail 
Air transport 

Domestic and International intra-EU 
International extra-EU 

Inland waterway and domestic maritime 
Intra-EU maritime transport 

Total freight transport activity (Gtkm) 

Road transport 
Rail 
Inland waterway and domestic maritime 
International maritime activity  

PO6 

Total passenger transport activity (Gpkm) 
Road transport 
Buses and coaches 
Passenger cars and vans 
P2W 

2025 
0.0% 
0.0% 
0.0% 
0.0% 
2025 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.1% 
-0.1% 
-0.1% 
-0.1% 
0.0% 
0.0% 
0.0% 
-0.1% 
0.1% 
0.0% 
0.0% 
2025 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
2025 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 

2030 
-0.1% 
0.1% 
0.0% 
0.0% 
2030 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.2% 
-0.1% 
-0.2% 
-0.1% 
0.0% 
0.0% 
0.0% 
-0.1% 
0.2% 
0.0% 
0.0% 
2030 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.1% 
-0.1% 
-0.1% 
-0.1% 
0.0% 
0.0% 
0.0% 
-0.1% 
0.1% 
0.0% 
0.0% 
2030 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 

2040 
0.0% 
0.0% 
0.0% 
0.0% 
2040 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.1% 
-0.1% 
-0.1% 
-0.1% 
0.0% 
0.0% 
0.0% 
-0.1% 
0.1% 
0.0% 
0.0% 
2040 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
2040 

-0.1% 
0.0% 
-0.1% 
0.0% 
0.0% 

2050 
0.0% 
0.0% 
0.0% 
0.0% 
2050 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.1% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
2050 

0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
2050 

-0.1% 
0.0% 
-0.1% 
0.0% 
0.0% 

129 

 
 
  
  
  
  
  
  
  
 
 
 
 
Rail 
Air transport 
Domestic and International intra-EU 
International extra-EU 
Inland waterway and domestic maritime 
Intra-EU maritime transport 
Total freight transport activity (Gtkm) 
Road transport 
Rail 
Inland waterway and domestic maritime 
International maritime activity  

2025 
0.1% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.1% 
0.0% 
0.0% 

2030 
0.5% 
-0.3% 
-0.3% 
-0.3% 
0.0% 
0.0% 
0.0% 
-0.3% 
0.4% 
0.0% 
0.0% 

2040 
0.8% 
-0.5% 
-0.6% 
-0.5% 
0.0% 
0.0% 
0.0% 
-0.5% 
0.7% 
0.0% 
0.0% 

2050 
0.8% 
-0.5% 
-0.6% 
-0.5% 
0.0% 
0.0% 
0.0% 
-0.5% 
0.7% 
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 

National public authorities (including NABs) 
Adjustment costs   
Administrative costs 
EEA 
Adjustment costs   
European Commission 
Adjustment costs   
Businesses 
Adjustment costs  
Administrative costs  
Benefits 
Avoided fuel used (operators and passengers) 
Reduction in external costs of GHG emissions 
Reduction in external costs of air pollution emissions 
Reduction in external costs of accidents 

PO1-A 

Difference to the Baseline 
PO2-A  PO3-A  PO4-A  PO5-A 

PO6-A 

0.1 
0.1 

3.6 

0.1 
0.1 

3.6 

0.1 
0.1 

3.9 

0.1 
0.1 

3.9 

2.7 

0.3 

2.4 

0.0 

0.1 
0.1 

3.6 

5.3 

0.1 
0.1 

3.9 

0.0 

95,010.8  1,084.6  1,374.4 
0.5 

0.0 

0.0 

1,542 
0.5 

2,283.7 
0.3 

67,927.7 
0.5 

8,290.3  1,268.4 
356.3 
2,303.1 
88.7 
480.4 
339.5 
2,208.4 

574.6  1,932.7 
539.3 
160.0 
130.8 
42.5 
516.2 
153.8 

504.4 
139.9 
37.6 
134.9 

8,290.3 
2,303.1 
480.4 
2,208.4 

130 

 
 
  
 
  
  
  
  
  
  
 
  
  
  
  
  
 
  
  
  
  
  
 
  
  
  
  
  
 
  
  
  
  
  
 
Total costs 
Total benefits 
Net benefits 
Benefits to costs ratio 

95,017 

1,089 
13,282.3  2,052.9 
964.1 
-81,735.0 
1.9 
0.1 

1,547 
1,381 
930.8 
3,119 
-450.6  1,572.4 
2.0 

0.7 

2,293 
816.8 
-1,476.3 
0.4 

67,932 
13,282.3 
-54,650.0 
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 

National public authorities (including NABs) 
Adjustment costs   
Administrative costs 
EEA 
Adjustment costs   
European Commission 
Adjustment costs   
Businesses 
Adjustment costs  
Administrative costs  
Benefits 
Avoided fuel used (operators and passengers) 
Reduction in external costs of GHG emissions 
Reduction in external costs of air pollution emissions 
Reduction in external costs of accidents 
Total costs 
Total benefits 

Net benefits 
Benefits to costs ratio 

Difference to the Baseline 

PO1-B 

PO2-B  PO3-B  PO4-B 

PO5-B 

PO6-B 

0.1 
0.1 

3.6 

0.1 
0.1 

3.6 

0.1 
0.1 

3.9 

0.1 
0.1 

3.9 

2.7 

0.3 

2.4 

0.0 

0.1 
0.1 

3.6 

5.3 

0.1 
0.1 

3.9 

0.0 

95,010.8  1,084.6  1,374.4 
0.5 

0.0 

0.0 

1,542 
0.5 

2,283.7  67,927.7 
0.5 

0.3 

7,561.3  1,154.2 
315.3 
2,028.7 
80.0 
431.8 
297.4 
1,934.7 
1,089 
95,017 
11,956.6  1,846.9 

522.5  1,759.3 
476.8 
141.8 
117.9 
38.4 
452.2 
134.7 
1,547 
1,381 
2,806 
837.3 

-83,060.8 
0.1 

758.1 
1.7 

-544.1  1,259.7 
1.8 

0.6 

458.6 
7,561.3 
124.0 
2,028.7 
34.0 
431.8 
118.2 
1,934.7 
67,932 
2,293 
734.8  11,956.6 
-
55,975.7 
0.2 

-1,558.4 
0.3 

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 
SO1: Ensure 
comparability of results 
from GHG emissions 
accounting of transport 
services 

Stakeholder groups  
Transport service 
organisers (operators) 

Main interests 

-  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; 

131 

 
 
 
  
  
  
  
  
  
 
  
  
  
  
  
 
  
  
  
  
  
 
  
  
  
  
  
 
  
  
  
  
  
 
 
 
 
-  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). 

Stable and clear GHG emissions accounting rules for 
designing tools; 

Stable environment for providing GHG emissions 
accounting services 

-  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 

Other entities involved in 
accounting GHG 
emissions of transport 
services (calculation tools 
developers, business sector 
associations, emissions 
data intermediaries etc.) 

Transport service 
organisers (operators) 

SO2: Facilitate the 
uptake of GHG 
emissions accounting 
of transport services in 
business practice 

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. 

- 

Increased demand for the use of the calculation tools; 

-  Clear rules on commercially sensitive data 

Other entities involved in 
accounting GHG 
emissions of transport 
services (calculation tools 
developers, business sector 
associations, emissions 
data intermediaries etc.) 

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 

132 

 
 
 
 
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.  

133 

 
 
 
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 

price 

Cost 
competitiveness 

and 

International 
competitiveness  

Capacity to innovate 

SME competitiveness 

+ 

+ 

++ 

+ 

Section 6.1.5 of the SWD 

Section 6.1.5 of the SWD 

Annex  4,  7    and  section  6.1.5  of  the 
SWD  

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 

134 

 
 
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. 

135 

 
 
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 

EU  develops  an  entirely  new  reference 
methodology  for  accounting  emissions 
from transport services 

Relevant 
Driver 

PD1 

Short description 

Reason for discarding 

tailor-made 

including  all 

reference 
A  completely,  new, 
methodology 
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 

136 

 
 
 
 
Policy measure 

Relevant 
Driver 

Short description 

Reason for discarding 

accounting 
services 

emissions 

from 

transport 

EU  establishes  the  common  reference 
methodology  for  accounting  emissions 
from transport services based on Article L. 
1431-3 of the French Transport Code  

PD1 

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.  

information 

Article  L.  1431-3  of  the  French  Transport  Code 
establishes  provisions  and  a  methodology  for 
specific 
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 
transport 
services 

emissions 

from 

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. 

137 

 
 
 
Short description 

Reason for discarding 

Policy measure 

EU establishes the Corporate Value Chain 
Standard  of  the  GHG  Protocol  as  the 
common 
for 
accounting 
transport 
services 

reference  methodology 

emissions 

from 

Relevant 
Driver 

PD1 

establishing 

The  GHG  Protocol  Corporate  Accounting  and 
Reporting  Standard  of  2001  was  a  pioneering 
initiative 
standardised 
global 
to  measure  and  manage  GHG 
frameworks 
emissions 
sector 
operations. The GHG Protocol enables to account 
indirect  emissions  from  value  chain  activities, 
including from transport and logistics.   

from  private  and  public 

EU  mandates 
the  use  of  primary 
information  to  economic  operators  and 
other  entities  accounting  emissions  from 
transport services   

PD2 

More details are provided in Annex 8 

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.  

provides 

EU 
for 
harmonized  formats  of  emissions  output 
data 

recommendations 

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 
and 
the 
benchmarking of this data for better transparency 
on  the  market  and  informed  decision  making  by 
data users. 

comparability 

facilitate 

to 

138 

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.  

Discarded due to the lack of proportionality. 

(especially  operators 

The  consultation  activities  and  desk  research  identified  limited 
availability  of  primary  information  for  certain  categories  of 
stakeholders 
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. 

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. 

 
 
Policy measure 

certifies 

EU 
sectorial 
implementation guidelines provided by the 
market 

specific 

Relevant 
Driver 

PD5 

Short description 

Reason for discarding 

This  measure 
the  mandatory 
establishes 
certification  of  specific  sectorial  implementation 
guidelines  developed  by 
the  market.  These 
guidelines  may  include  issues  related  to  the 
interpretation 
reference 
the  calculation 
methodology, 
processes,  best  practices  and  default  emission 
factors. For some sectors, such guidelines already 
exist (e.g. SCF & CEFIC (2021) for the chemical 
sector). 

common 
for 

of 
the 
formulas 

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. 

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. 

EU  provides 
implementation 
specific 
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, 
the 
calculation  processes,  best  practices  and  default 
emission factors.  

formulas 

for 

139 

 
 
 
Policy measure 

EU allows for GHG emissions calculation 
tools  provided  by  the  market  (without 
further conformity check) 

Relevant 
Driver 

PD5 

Short description 

Reason for discarding 

The  development 
implementation  of 
and 
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.  

140 

 
 
 
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 

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. 

Link to the 
specific 
objective 

SO1 

Policy Area 

Methodological 
framework 

PD1 

PM2:  Product  Environmental 
Footprint  Category  Rules  for 
transport, 
GHG  emissions 
transport 
including  rules 

in 
for 

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). 

141 

 
 
 
 
                                                 
Driver 

Policy measure 

Short description 

Link to the 
specific 
objective 

Policy Area 

is  set  as  common 
services, 
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 
and 
increased accuracy 

elements 

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.  

SO1 

Methodological 
framework 

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. 

238 Idem 

142 

 
 
                                                 
Link to the 
specific 
objective 

Policy Area 

SO1 

Input data and 
sources 

Driver 

Policy measure 

Short description 

PD2 

PD3 

PM4: The use of primary data is 
centralised 
and 
recognised 
databases  for  default  values  are 
established  at  EU 
level  (by 
European Environment Agency). 
in 
Modelled  data 
conformity  with  the  reference 
methodology 

is  used 

The EU also establishes rules for the future updates and methodological adjustments of 
the common reference methodology239. 

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. 

239 Idem 
240 HORIZON-CL5-2023-D6-01-08: Future-proof GHG and environmental emissions factors for accounting emissions from transport and logistics operations  

143 

 
 
 
 
 
                                                 
Link to the 
specific 
objective 

SO1 

Policy Area 

Input data and 
sources 

Driver 

Policy measure 

Short description 

PM5: The use of primary data is 
incentivised 
centralised 
and 
databases  for  default  values  are 
established  at  EU  level.  Quality 
assurance  of  external  databases 
is 
operated  by 
provided  at  EU 
(by 
European Environment Agency). 
in 
Modelled  data 
conformity  with  the  reference 
methodology 

third  parties 

is  used 

level 

PD2 

PD3 

241 Ibidem 

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. 

144 

 
 
                                                 
Driver 

Policy measure 

Short description 

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.  

The  EU  provides  horizontal  guidelines  for  the  harmonised  implementation  of 
CountEmissions EU across sectors and segments of the transport market including: 

SO1-SO2 

  Data requirements and management; 
  Emissions calculation guidance and best practices; 
  Assurance and verification of the emissions data; 
  Guidance on data sharing. 

Link to the 
specific 
objective 

SO1-SO2 

Policy Area 

Harmonised  
emissions output 
data and 
transparency 

Sectoral 
Implementation 
Support 

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 

PD1 

PD3 

PD4 

PD3 

PD4  

PD5 

PD4 

PM6:  Minimum  requirements 
for harmonised GHG output data 
formats and metrics are provided 
together  with 
at  EU 
on 
rules 
common 
communication and transparency 

level, 

PM7:  Horizontal  guidelines  for 
the  harmonised  implementation 
of  CountEmissions  EU 
in 
various  sectors  and  segments  of 
the transport market are provided 
at EU level 

PM8:  Mandatory  process  and 
data  verification  for  all  entities 
the  scope  of 
falling  under 
CountEmissions 
is 
established at EU level 

EU 

242 Including in conformity to the Unfair Commercial Practices Directive (UCPD) 

145 

 
 
 
                                                 
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.  

SO2 

Conformity 

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.  

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). 

146 

 
 
                                                 
 
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..  

SO2 

Conformity 

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. 

246 For instance taking an example of the rules on financial audits 
247 Ibidem 

147 

 
 
                                                 
Driver 

Policy measure 

Short description 

PD5 

PM11:  Emissions  calculation 
tools are provided at EU level (by 
the European Commission) 

PD5 

PM12:  Emissions  calculation 
tools are provided by the market 
but they are certified at EU level 

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. 

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. 

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. 

148 

Link to the 
specific 
objective 

Policy Area 

SO2 

Complementary 
measures 

SO2 

Complementary 
measures 

 
 
 
PD5 

PD5 

PD5 

Driver 

Policy measure 

Short description 

PM13: Mandatory application of 
CountEmissions  EU 
the 
transport sector 

in 

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. 

Link to the 
specific 
objective 

Policy Area 

SO2 

Applicability 

PM14: 
opt-in 
Binding 
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 

PM15: 
opt-in 
Voluntary 
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 

149 

 
 
 
 
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 
Scope of GHG emission calculation 
Geographical 
scope 
Type of 
emissions 
included 

CO2-emisisons 

Global 

Design alternatives 

European 

non-CO2 GHG 
emissions originating 
from combustion of 
fuel 

non-CO2 GHG 
emissions 
originating from 
refrigeration 

150 

 
 
 
 
 
 
Global warming 
effect of 
emission of 
non-CO2 
products (e.g. 
water vapour, 
contrails, NOx) 
at high altitudes 
Vehicle 
propulsion 
emissions 
related from 
energy use 
(TTW) 
Emission from 
energy 
provision 
(WTT), 
excluding 
energy 
infrastructure 
construction 
Transport 
service operator 

Global warming effect 
of black carbon 
emissions 

Emissions from 
auxiliary processes 
(other than propulsion) 
during vehicle 
operation (TTW) (e.g. 
cooling of freight) 
Emission from 
construction and 
dismantling of energy 
production 
infrastructure 

Transport service 
organiser 

Activity 
boundaries of the 
methodology 

Intended users 

Use perspective 

Ex-post 

Ex-ante short term  

Emissions 
perspective 

Service average 
GHG emissions 

Time/situation specific 
average GHG 
emissions 

Vehicle operation 
emissions related 
to leakage and 
spills  

Emissions from 
hub activities  

Life cycle GHG 
emission of 
vehicle 
construction and 
maintenance 

Life cycle GHG 
emission of vehicle 
infrastructure 
construction and 
maintenance 

Transport service 
user (excl. 
organiser) 
Ex-ante 
calculations for 
long term 
scenarios  
Marginal GHG 
emissions 

The method of emissions calculation and allocation to transport services 
Required 
granularity of 
calculation  

Total GHG of 
transport 
operator 

Transport service 
type 

Transport chain 
element / leg 
(average over 
period) 
Per activity at hub 

Total GHG emission 
of transport service 
user (freight) or 
organiser 
Individual trip 

passenger-km 
tonne-km GCD 

Total GHG 
emissions of hub 
operator 
tonne-km SFD 
passenger-km-
GCD 

Allocation 
parameter for 
allocation to 
transport services 
Allocation 
granularity for 
allocation to 
transport services 

Flexibility in 
calculation 
method  

Single vehicle 

Tonne-km 
passenger-km-
SFD 

On company 
level (e.g. 
average for 
transport 
company) 
The user can 
choose the 
calculation 
option from a 
predefined list. 

transport leg level (e.g. 
average between hubs) 

Trip level - 
journey specific 

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 

151 

 
 
 
 
 
 
 
 
 
 
Source: Ecorys and CE Delft (2023), Impact assessment support study 

8.  ASSESSMENT AND RANKING OF THE METHODOLOGICAL ELEMENTS 

calculation 
option. 

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. 

152 

 
 
                                                 
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 
—  Global scope 

Discarded design alternatives 
—  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 

153 

 
 
 
                                                 
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 

154 

 
 
                                                 
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 

155 

 
 
                                                 
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 

—  Global warming effect of non-CO2 emissions (e.g. 
water vapour, contrails, NOx) of aviation at high 
altitudes. 

—  Non-CO2 GHG emissions from 

—  Black carbon emissions 

refrigeration 

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 

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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.  

157 

 
 
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 

158 

 
 
                                                 
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 

159 

 
 
                                                 
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 

160 

 
 
                                                 
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 

161 

 
 
 
                                                 
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 

162 

 
 
                                                 
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 
—  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 

Discarded design alternatives 
—  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.  

163 

 
 
 
                                                 
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. 

164 

 
 
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 

165 

 
 
 
 
 
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.  

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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” 

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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. 

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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.  

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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 

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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 

172 

 
 
                                                 
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. 

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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: 

174 

 
 
 
 
  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 
it  without  excessive  hassle  and 
to  continue 
specific  methodological  element 
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 

175 

 
 
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 
Scope of emission calculation 
Geographical 
scope 
Type of 
emissions 
included 

Design options 

CO2-emisisons 

European 

Global 

non-CO2 GHG 
emissions originating 
from combustion of 
fuel 

non-CO2 GHG 
emissions 
originating from 
refrigeration 

176 

 
 
 
 
 
 
Global warming 
effect of 
emission of 
non-CO2 
products (e.g. 
water vapour, 
contrails, NOx) 
at high altitudes 
Vehicle 
propulsion 
emissions 
related from 
energy use 
(TTW) 
Emission from 
energy 
provision 
(WTT), 
excluding 
energy 
infrastructure 
construction 
Transport 
service operator 

Global warming effect 
of black carbon 
emissions 

Emissions from 
auxiliary processes 
(other than propulsion) 
during vehicle 
operation (TTW) (e.g. 
cooling of freight) 
Emission from 
construction and 
dismantling of energy 
production 
infrastructure 

Transport service 
organiser 

Activity 
boundaries of the 
methodology 

Intended users 

Use perspective 

Ex-post 

Ex-ante short term  

Emission 
perspective 

Service average 
GHG emissions 

Time/ situation 
specific average GHG 
emissions 

Vehicle operation 
emissions related 
to leakage and 
spills  

Emissions from 
hub activities  

Life cycle GHG 
emission of 
vehicle 
construction and 
maintenance 

Life cycle GHG 
emission of vehicle 
infrastructure 
construction and 
maintenance 

Transport service 
user (excl. 
organiser) 
Ex-ante long term 
scenarios  
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 
Individual trip 

Transport service 
type 

Transport chain 
element / leg 
(average over 
period) 
Per activity at hub 

Allocation 
parameter for 
allocation to 
transport services 
Allocation 
granularity for 
allocation to 
transport services 

Flexibility in 
calculation 
method  

Single vehicle 

Tonne-km 
passenger-km-
SFD 

On company 
level (e.g. 
average for 
transport 
company) 
The user can 
choose the 
calculation 
option from a 
predefined list. 

passenger-km 
tonne-km GCD 

Total GHG 
emissions of hub 
operator 
tonne-km SFD 
passenger-km-
GCD 

transport leg level (e.g. 
average between hubs) 

Trip level - 
journey specific 

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 

The required 
calculation option 
depends on the 
stakeholder group 
applying the 
calculations. 

177 

 
 
 
 
 
 
 
 
 
 
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 
of 
Standard/methodology 

Geographical 
coverage  

Type 
instrument  

Transport 
modes 
covered 

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 

Article  L. 1431-3 of the French transport 
code (Objectif CO2) 

All modes* 

France 

Legislation 
methodology 

with 

Legislation 
methodology 
program 
CO2) 

with 
and 
(Objectif 

Parcel Delivery Environmental Footprint  All 

EU 

Standard 

modes 
in 

involved 
parcel 
delivery 

GLEC framework v1.0 

SmartWay program 

freight 

All 
modes* 

World-wide 

Methodology 
framework 

freight 

All 
modes* 

North America 

Program 
methodology 

and 

Topsector Logistics method  

freight 

All 
modes* 

EU (mainly applied in 
NL)  

Methodology 

Clean  Cargo  Working  Group  Carbon 
Emissions Accounting Methodology 

transport 

Sea 
of containers 

World-wide 

Program 
methodology 

and 

178 

 
 
 
 
EU MRV 

IMO DCS 

CORSIA 

Sea shipping 

EU 

Sea shipping  World-wide 

Aviation 

World-wide 

Legislation 
methodology 

with 

Legislation 
methodology 

with 

Program 
methodology 

and 

ICAO/IATA RP1678 

Aviation 
freight 

World-wide 

Standard 

IATA  Recommended 
per-
passenger CO2-calculation Methodology 

practice 

Aviation 
passenger 

World-wide 

Standard 

EU ETS aviation 

Aviation 

EU 

Legislation 
methodology 

with 

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 

PEF 

CEN standard 
EN 16258 

Corporat
e value 
chain 
(scope3)  

concept ISO 14083 

Scope of emission calculation  

Geographical 
scope 
Type of GHG 
emissions 

France 

Global 

CO2-eq of combustion and refrigeration 

179 

 
 
 
 
 
 
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 

Intended user 

WTW 
propulsion and 
auxiliary 
processes (excl. 
energy infra)   
Transport 
service operator, 
organiser and 
user  

WTW propulsion and 
auxiliary processes 
(incl. energy infra)  + 
hubs leakages and 
spills  
Transport 
service 
organiser 
and user  

WTW 
propulsion and 
auxiliary 
processes (excl. 
energy infra)   

WTW propulsion and 
auxiliary processes 
(incl. energy infra)  + 
hubs, leakages and 
spills  

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 
Metrics for 
GHG intensity 
factors and 
allocation  
Flexibility in 
calculation 
approach (e.g. 
input data and 
metrics)  

leg level and trip 
level  

not 
defined 

not 
defined 

leg level and trip 
level  

leg level and trip level 
and per hub activity 

Based on 
passenger-km or 
tonne-km  

Not 
defined 

Not 
defined 

All alternatives   Based on tonne-km or 
passenger-km SFD or 
GCD 

not 
defined 

not 
defined 

The user can 
choose the 
metrics from a 
predefined list 
(not selected)  

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.  

180 

 
 
 
 
 
 
 
  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 

Article L. 1431-3 
of the French 
transport code 
Corporate value 
chain (scope3) 
standard of the 
GHG protocol 
PEF / OEF 

3 

4 

4 

3 

4 

4 

3 

4 

4 

Coherence with 
industry initiatives  
and other policy 
initiatives 
4 

3 

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.  

181 

 
 
 
 
                                                 
3 

CEN standard EN 
16258 
Draft ISO 14083 
Scores from 1-5 range from high to low 

2 

2 

1 

3 

2 

4 

2 

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 

182 

 
 
 
 
                                                 
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: 

to  entities  accounting  emissions 

  A complete new reference methodology. This methodology should provide more 
guidance 
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.  

than 

  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;   

183 

 
 
 
 
 
- 

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 

1 

1 

2 

A new reference 
methodology  
A new reference 
methodology 
referring to ISO 
14083 
New PEF category 
rules for transport, 
including rules for 
transport services  

5 

3 

3 

1 

1 

2 

Coherence with 
industry initiatives  
and other policy 
initiatives 
N.A. 

3 

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 

184 

 
 
 
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; 

185 

 
 
 
 
 
  New  Product  Environmental  Footprint  Category  Rules  for  transport,  including 

rules for transport services.  

186 

 
 
 
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.  

Moderately positive 
impact on the 
comparability. 

The mandatory use of 
a precise reference 
methodology based 
on the ISO standard 
14083 (with 
additional elements 

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. 

Positive impact on 
the comparability, 
although lower than 
in PO3. 

Strongly positive 
impact on the 
comparability.  

This option envisages 
the binding-in 
(mandatory for those 
that account and 
disclose GHG 
emissions data of 

This option includes a 
very comprehensive 
future LCA 
methodology based 
on specific transport-

The mandatory use of 
a conducive 
methodology 
established through 
ISO standard 14083 
will ensure increased 

187 

 
 
 
 
from trusted sources 
in unambiguous and 
clear manner) 

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. 

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 

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 

188 

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 

 
 
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.  

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.  

(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. 

PO1 

PO2 

PO3 

PO4 

PO5 

PO6 

Specific policy objective 2: Facilitate the uptake of GHG emissions accounting in business practice 

189 

 
 
 
 
(1)  Expected  increase 
of use of the common 
methodological 
framework 
economic 
and  other 
entities 

by 
operators 
relevant 

positive 
Extremely 
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 
the 
across 
board. 

The  uptake  will  be 
strengthened 
further 
measures 
by 
increasing  confidence 
and  trust  in  the  GHG 
emissions data  on the 
market: 
the 
mandatory  data  and 
verification 
process 
system, 
and  
centralised  emissions 
tools 
calculation 
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 
voluntary 
the 
system 
verification 
and 
for  processes 
data.  This  assessment 
is  driven  mostly  by 
that  PO2 
the 
fact 
a  more 
includes 
conducive 
(ISO 
methodology 
recognises 
14083), 
of 
use 
the 
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 
the 
of 
CountEmissions  EU 
framework  only  from 
those 
that 
entities 
account  and  disclose 
GHG  emissions  data 
of  transport  services, 
and 
this 
therefore 
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 

190 

the 

Very  positive  impact 
on 
increase 
uptakes  of  the  GHG 
emissions accounting. 

PO4  will  require  the 
use 
the 
of 
CountEmissions  EU 
framework  only  from 
those 
that 
entities 
account  and  disclose 
GHG  emissions  data 
of  transport  services, 
and 
this 
therefore 
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 
those  entities 
from 
and 
that 
account 
disclose 
GHG 
emissions  data  of 
services. 
transport 
Therefore  PO5  will 
not  reach  the  same 
level  of  uptake  in  the 
short  and  medium 
term as it would be the 
case 
fully 
of 
mandatory 
application. 

What  is  more,  PO5 
envisages  the  use  of 
the 
most 
comprehensive  LCA 
methodology,  still  to 
be  developed  through 

positive 
Extremely 
impact on the use of the 
common 
methodological 
framework  

As  PO1,  this  option 
the 
will  mandate 
of 
uptake 
CountEmissions EU to 
all  entities 
that  are 
involved  in  transport 
in 
services  activities 
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 

 
 
 
on  this  market.  PO2 
will 
the 
increase 
uptake  by  30,219 
companies 
in  2030 
and  1,388  companies 
by 2050 relative to the 
baseline.  Out  of  the 
total 
of 
number 
companies accounting 
for GHG emissions of 
transport 
services, 
29,586 SMEs and 633 
large  companies  by 
2030,  1,361  SMEs 
and 
large 
27 
companies  by  2050 
the 
relative 
baseline. 

to 

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. 

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. 

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. 

PEFCRs. 
specific 
This  choice  will  lead 
to 
increased 
implementation  costs 
additional 
and 
for 
complexity 
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 

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. 

191 

 
 
 
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. 

on 

Moderately  positive 
impact 
the 
expected  decrease  in 
well-to-wheel 
the 
GHG emissions 

the 

Very  positive  impact 
on 
expected 
decrease  in  the  well-
GHG 
to-wheel 
emissions 

on 

Moderately  positive 
impact 
the 
expected  decrease  in 
well-to-wheel 
the 
GHG emissions 

Extremely 
positive 
impact on the expected 
decrease in the well-to-
wheel GHG emissions 

reduction 

in 
The 
GHG 
WTW 
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-

reduction 

in 
The 
GHG 
WTW 
emissions  is  strongly 
correlated  with 
the 
level of  uptake of the 
framework  addressed 
above. 

PO5  will  effectively 
reduce  1.5  million 
of  GHG 
tonnes 
cumulative  emission 
over the period 2025-

emissions 

The reduction in WTW 
is 
GHG 
correlated 
strongly 
with the level of uptake 
of 
framework 
addressed above.  

the 

PO1  will  effectively 
reduce  22.1  million 
GHG 
tonnes 
of 
emission 
cumulative 
over  the  period  2025-
2050. 

Expected  decrease  in 
the 
well-to-wheel 
GHG emissions 

on 

positive 
Extremely 
impact 
the 
expected  decrease  in 
well-to-wheel 
the 
GHG emissions 

reduction 

in 
The 
GHG 
WTW 
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 

reduction 

in 
The 
WTW 
GHG 
emissions  is  strongly 
correlated  with 
the 
level of  uptake of  the 
framework  addressed 
above. 

reduction 

in 
The 
GHG 
WTW 
emissions  is  strongly 
correlated  with 
the 
level of  uptake  of the 
framework  addressed 
above. 

PO2  will  effectively 
reduce  3.7  million 
of  GHG 
tonnes 
cumulative  emission 
over the period 2025-

PO3  will  effectively 
reduce  1.7  million 
of  GHG 
tonnes 
cumulative  emission 
over the period 2025-

192 

 
 
2050. 

2050. 

2050. 

2050. 

2050. 

193 

 
 
 
See sections 6.1.7 
(Impacts on small 
and medium 
enterprises) and 
Annex 4 

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 directly affected.  

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). 

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.  

See Annex 2 
(Stakeholder 
consultation) 

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 

285 https://nacev2.com/en/activity/transportation-and-storage  

194 

 
 
                                                 
See sections 6.1.7 
(Impacts on small 
and medium 
enterprises) and 
Annex 4 

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 103.8 million 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 of the total costs for each policy option 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, 

286 In the assessment it has been assumed that the calculation tool developers are SME.  

195 

 
 
                                                 
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 
performance due to the increased demand in the context of the 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.  

See sections 6.1.7 
(Impacts on small 
and medium 
enterprises), 7 
(How do options 
compare), 8 
(Preferred policy 
option), Annex 4  

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 

196 

 
 
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 

Recurrent and one-off costs 

Adjustment costs 
Administrative costs  

2050 

PO1 
2025 
2030 
490.8  3,866.2  6,288.2 
490.8  3,866.2  6,288.2 
0.00 
0.00 

0.00 

2025 
50.9 
50.9 
0.00 

PO2 
2030 

2050  2025  2030  2050 
11.9 
57.9  103.8 
11.9 
57.8  103.8 
0.02 
0.02  0.02 

4.7 
93.9 
93.9 
4.7 
0.00  0.00 

PO3 

Benefits (energy costs 
2.4 
savings) 
Net costs/costs savings 
9.5 
Source : Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs 
savings, where relevant. 

775.1 
390.7 
439.1  3,475.5  5,513.1 

37.2  83.6 
20.7  20.2 

140.6 
-46.7 

74.0 
-23.1 

6.9 
-2.2 

51.7 

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 
2030 

Recurrent and one-off costs 

Adjustment costs 
Administrative costs  

2025  2030  2050  2025  2030  2050  2025 
68.0  115.4  19.9  101.2  156.4  37.4  344.7  2,767.6  4,501.4 
68.0  115.4  19.9  101.2  156.4  37.3  344.7  2,767.5  4,501.4 
0.02 
0.02 
0.02  0.02 
Benefits (energy costs savings) 
77.0 
48.0 
79.5  35.1  233.0  2,582.1  4,453.4 
Net costs/costs savings 
Source : Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs 
savings, where relevant.  

0.02  0.02 
111.7  185.4  48.0 
-70.0  -28.1 
-43.7 

0.02 
2.2  111.7 

0.02 
33.6 
67.6 

0.02 
185.4 

2050 

197 

 
 
 
 
 
 
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 
2030 

PO2 
2030  2050  2025  2030  2050 
11.9 

57.8  103.8 

PO3 

2050 

2025 
2025 
490.8  3,866.2  6,288.2  50.9 
44.8 

11.2 

41.1 

294.7 

479.9    

93.9 
82.2 

4.7 
4.0    

52.9  94.2 

412.2  3,270.1  5,317.4    

Adjustment costs  
PM1 - ISO 14083 set as 
common reference 
methodology 
PM2 - PEFCR set as common 
reference methodology 
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  
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 
Administrative costs  
PM12 - Emissions calculation 
tools are provided by the 
market but they are certified 
at EU level 
11.9 
Total net costs 
Source : Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs 
savings, where relevant.  

490.8  3,866.2  6,288.2  50.9 

0.02  0.02 
0.02  0.02 

0.00  0.00 

57.9  103.8 

0.00  0.00 

0.02 
0.02 

-1.6    

301.4 

490.8 

2.3    

0.00 

0.00 

37.6 

93.9 

-1.3 

4.7 

3.1 

4.9 

9.1 

2.1 

6.6 

0.0 

2.9 

0.6 

5.0 

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) 

Adjustment costs  
PM1 - ISO 14083 set as common 
reference methodology 
PM2 - PEFCR set as common 
reference methodology 
PM3 - ISO 14083 with additional 
elements and increased accuracy set 
as common reference methodology 

PM8 - Mandatory process and data 
verification for all entities 

Difference to the Baseline 

PO4 

PO5 

2025  2030  2050  2025  2030  2050  2025 
68.0  115.4  19.9  101.2  156.4  37.3  344.7  2,767.5  4,501.4 
310.1  2,471.7  4,019.4 
63.2  106.1  21.5    

2050 

PO6 
2030 

80.7  123.8  14.1 

198 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
9.1 

4.7 

0.0 

5.9 

0.5 

7.1 

-1.7 

75.9 

46.5 

PM9 - Mandatory process and data 
verification for entities above certain 
size  
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 
Administrative costs  
PM12 - Emissions calculation tools 
are provided by the market but they 
are certified at EU level 
68.0  115.4  19.9  101.2  156.4  37.4  344.7  2,767.6  4,501.4 
Total net costs 
Source : Ecorys and CE Delft (2023), Impact assessment support study; Note: negative values reflect costs 
savings, where relevant.  

0.02  0.02  0.02  0.02  0.02  0.02  0.02 
0.02  0.02  0.02  0.02  0.02  0.02  0.02 

0.1  14.7  23.6  16.1  29.8 

0.02 
0.02 

0.02 
0.02 

406.1 

249.4 

8.9 

4.8 

199 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
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 

200 

 
 
                                                 
  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, 
the  current  scope  of 
which  provides  additional  functionality  with  respect 
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. 

to 

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). 

201 

 
 
                                                 
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: 

202 

 
 
 
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  

203 

 
 
 
                                                 
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). 

204 

 
 
                                                 
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). 

205 

 
 
                                                 
  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 

206 

 
 
                                                 
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 
After 2019 
Variation 
Source: SNCF (2022)  

5.29 
6.73 
27.2% 

1.73 
2.71 
56.6% 

4.75 
7.04 
48.2% 

24.81 
26.93 
8.5% 

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. 

207 

 
 
 
                                                 
  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 

Domestic 

Intercites 

TGV INOUI 

TGV OUIGO 

Transilien 

RER 

TER 

International 

Thalys 

Eurostar 

Lyria 

2016 

10.80 

n. a. 

3.20 

5.80 

5.80 

29.70 

11.60 

8.20 

3.20 

RENFE and SNCF in cooperation 

27.00 

DB and SNCF in cooperation 

TGV INOUI Italia 

11.30 

n. a. 

2021 

2022 

5.29 

1.90 

0.73 

4.75 

4.10 

6.73 

2.99 

1.15 

7.04 

6.20 

24.81 

26.93 

6.68 

6.64 

2.05 

5.40 

4.50 

8.50 

7.32 

7.48 

3.23 

6.00 

5.00 

10.30 

301 See also dedicated page on SNCF website 

208 

 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Source: SNCF (2016, 2021, 2022) 

Table 112: Emissions for passengers travelling by other transport modes (gCO2e/km) 

Transport mode 

2016 

2021 

2022 

Metro 

Tramway 

Bus RATP 

Bus other operators 

Coach interurban 

Car average 

Car short distance 

Car long distance 

Domestic flight < 500 km 

Domestic flight 500-1000 km 

Source: SNCF (2016302, 2021303, 2022) 

Other considerations 

3.8 

3.3 

96.5 

n. a. 

171.0 

162.0 

148.0 

90.0 

168.0 

n. a. 

2.5 

2.2 

98.0 

110.0 

146.0 

111.0 

134.0 

75.0 

167.0 

126.0 

3.8 

3.4 

104.0 

110.0 

146.0 

111.0 

134.0 

75.0 

167.0 

126.0 

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). 

209 

 
 
 
                                                 
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 

Train 

Alternative mode 

Distanc
e (km) 

Emission 
(gCO2e/k
m) 

Mod
e 

Distanc
e (km) 

Emission 
(gCO2e/k
m) 

Type of 
train 

Origin-Destination 

TGV 

Paris-Lyon 

Paris-Lille 

Bordeaux-Paris 

Paris-Rennes 

Marseille-Paris 

Paris-Strasbourg 

Paris-Nice 

Paris-Toulouse 

Lyon-Marseille 

Lille-Lyon 

OUIGO 

Nantes-Paris 

Lyon-Marseille 

Avignon-Marne La Vallee 

Lyria 

Paris-Geneve 

Thalys 

Paris-Bruxelles 

563 

258 

617 

374 

883 

503 

978 

713 

381 

794 

385 

320 

697 

692 

314 

Intercites 

Clermont 
Bercy 

Ferrand-Paris 

420 

Limoges-Paris 

Bayonne-Toulose 

TER 

Paris-Trouville Deauville 

Grenoble-Lyon 

400 

199 

281 

131 

210 

1.7 

0.8 

1.8 

1.1 

2.6 

1.5 

2.9 

2.1 

1.1 

2.4 

0.4 

0.4 

0.8 

2.2 

2.3 

2.8 

2.7 

1.3 

7.6 

3.5 

Car 

466 

Car 

226 

Car 

587 

Car 

350 

Air 

627 

Car 

488 

Air 

674 

Air 

571 

Car 

314 

Air 

558 

Car 

386 

Car 

314 

Car 

702 

Air 

408 

Car 

312 

Car 

425 

Car 

394 

Car 

300 

Car 

199 

Car 

113 

35.0 

17.0 

44.0 

26.3 

88.4 

36.6 

95.0 

80.5 

23.6 

78.7 

29.0 

23.6 

52.7 

57.5 

44.0 

31.9 

29.6 

22.5 

22.1 

12.5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Marseille-Nice 

Geneve-Lyon 

Arcachon-Bordeaux 

Transilien 

Paris-Gare de Lyon-Juvisy 

Paris-Montp-Versaille-
Chantiers 

218 

129 

59 

20 

15 

5.9 

3.5 

1.6 

0.1 

0.1 

Car 

205 

Car 

150 

Car 

Car 

Car 

72 

21 

26 

22.8 

16.7 

8.0 

2.8 

3.5 

Paris 
Eaubonne 

Nord-Ermont-

14 

0.1 

Car 

14 

1.9 

Paris St. Lazare-La Defense 

Magenta-Chelles-Gournay 

6 

18 

0.0 

0.1 

Car 

Car 

8 

21 

1.1 

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. 

211 

 
 
 
 
 
 
 
 
 
 
 
 
                                                 
3-  Use cases for CountEmissions EU 

Eco-labelling of transport services  

Aim 

Inform stakeholders about the (relative) performance of transport 
operators.   

How it works 

a 
Example 
practice application  

of 

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.   

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/  

212 

 
 
                                                 
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 

the 
environmental  impact  of  the  delivery  of  their  goods  (e.g. 
fast delivery: high CO2 footprint, later delivery date: lower 
CO2 footprint); 

regard 

to 

How it works 

  Create  awareness  about  the  GHG  impact  of  customers’ 

choices; 
  Optimise 

transport  operations 

in 

terms  of 

their 

environmental impact.  

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 
a 
practice application  

of 

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. 

213 

 
 
 
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 

How it works 

Example 
a 
practice application  

of 

(Expected)  GHG 
emissions 
reduction potential 

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.  

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. 

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).   

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 

214 

 
 
 
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  

215 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Aim 

How it works 

Example 
a 
practice application  

of 

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.  

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. 

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 

216 

 
 
 
 
217