COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF 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

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  EN 

   EUROPEAN COMMISSION  Strasbourg, 11.7.2023  SWD(2023) 442 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT  Accompanying the document   Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF 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) 441 final}  
 
 
Executive Summary Sheet 

Impact assessment on CountEmissions EU 

A. Need for action 

What is the problem and why is it a problem at EU level?  

Greenhouse  gas  (GHG)  emissions  accounting  methods  are  used  in  several  economic  sectors, 
including  transport,  to  generate  data  on  the  emissions  produced  by  specific  activities  of  businesses 
and  individuals.  Businesses  and  consumers  seek  more  transparency  on  how  transport  services  are 
organised  and  provided,  and  demand  is  increasing  for  services  that  minimise  harm  to  the  climate. 
Providing  clear  information  on  GHG  emissions  empowers  customers  to  make  more  efficient  choices 
and influences the business decisions of entities providing transport services on the market. However, 
to  compare  multiple  transport  services  in  a  fair,  transparent  and  meaningful  way,  the  data  on 
emissions must be accurate and reliable. 

Currently,  there  is  a  wide  range  of  standards,  methods,  calculation  tools  and  databases  of  default 
emission  values  available  both  in  the  EU  and  internationally.  These  different  tools  produce  uneven 
and incomparable data on GHG emissions that create confusion, both for industry and for individuals, 
hampering  users'  ability  to  make  informed  transport  choices  and  business  decisions.  In  addition, 
transport  service  organisers  and  operators  lack  sufficient  incentives  to  calculate  and  disclose 
information on the GHG emissions of their services, and users lack accurate information. This is due 
to the reluctance to reveal commercially sensitive information,  the perceived complexity and costs of 
quantifying  GHG  emissions  data  at  transport  service  level,  and  the  lack  of  trust  in  the  emissions 
figures shared on the market. 

What should be achieved?  

This  initiative  seeks  to  overcome  the  barriers  to  the  provision  of  clear,  harmonised  GHG  emissions 
accounting and its uptake on the transport market by creating a common framework and specific rules. 
This framework will encourage behavioural change among businesses and customers to reduce GHG 
emissions and make transport services more efficient.  

On the one hand, the aim of the  initiative  is to ensure that GHG emissions data are comparable, by 
providing operators and users with a common reference method and a harmonised set of input data. 
On the other hand, it aims to encourage the uptake of GHG emissions accounting of transport services 
in  business  practices  by  providing  trusted  calculation  tools,  a  common  verification  scheme  and 
guidance on how to use the framework.  

What is the value added of action at the EU level (subsidiarity)?  

By  setting  up  harmonised  rules  for  GHG  emissions  accounting  of  transport  services,  the  initiative 
encourages  businesses  to  calculate  emissions  and  offers  the  opportunity  to  align  GHG  data  across 
modes  and  national  networks.  This  level  of  harmonisation,  which  mostly  covers  the  methodological 
choices, input data and common rules for verification, cannot be effectively achieved by  action taken 
by individual Member States alone. 

CountEmissions  EU  is  designed  as  an  enabler  for  the  transport  community  to  facilitate  the  green 
transition. By ensuring better transparency on the emission performance of transport services, and by 
supporting consumer use of GHG emissions data to make specific transport choices, it will help create 
incentives to use more sustainable solutions and to innovate on the European transport network. 

B. Solutions 

What are the various options to achieve objectives? Is there a preferred option? If not, why?  
The Commission assessed six policy options in an impact assessment. All options propose solutions 

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to the problems identified, but they vary in terms of the scope of action envisaged at EU level: 

  Option 1 includes a comprehensive calculation methodology based on ISO standard 140831, a 
centralised system for input data, and a single GHG emissions calculation tool created at EU 
level. It also proposes mandatory verification and proposes to make the framework applicable 
to all bodies involved in transport services. 

  Option  2  incorporates  a  more  conducive  methodology  provided  by  the  global  ISO  standard 
140832 coupled with fully voluntary applicability and verification rules. Like Option 1, Option 2 
includes centralised databases for input data and a single GHG emissions calculation tool. 

  Options  3,  4  and  5  have  a  binding  opt-in’  feature  to  use  CountEmissions  EU,  which  means 
that  the  common  framework  applies  only  to  bodies  that  choose  to  calculate  and  disclose 
information on GHG emissions related to transport services. They also take a semi-centralised 
approach to input data so that, under certain conditions, external databases of input data can 
be  used  (except  under  Option  5  with  fully  centralised  EU  databases)  and  giving  flexibility  by 
allowing third parties to provide GHG emissions calculation tools. These options differ in terms 
of  the  methodological  choice,  i.e.  the  upgraded  ISO  standard  14083  for  Option  3,  full  ISO 
standard 14083 for Option 4, and Product Environmental Footprint Category Rules3 for Option 
5. 

  Option  6  includes  almost  an  identical  set  of  policy  measures  as  Option  4,  except  that  the 
regulation  would  be  mandatory  to  all  entities  involved  in  providing  or  organising  transport 
services. 

All options expect to produce an increase in the uptake of emission accounting relative to the baseline. 

Following  the  assessment,  the  Commission  identified  Option  4  as  the  preferred  option.  It  strikes  the 
best balance between the objectives to be achieved and the overall costs. 

What are different stakeholders’ views? Who supports which option?  
Stakeholders  largely  endorsed  the  relevance  of  the  problems  identified,  and  agreed  with  the 
objectives.  They  provided  useful  input  for  calculating  the  baseline  for  the  uptake  of  GHG  emissions 
accounting,  and  contributed  to  developing  and  assessing  relevant  policy  measures  and  options.  In 
response  to  the  question  on  a  common  reference  methodology  for  calculating  emissions,  most 
stakeholders  referred  to  existing  or  emerging  GHG  accounting  approaches,  particularly  those  with  a 
global scope for calculating emissions.  

As  regards  input  data,  stakeholders  suggested  the  EU  should  promote  the  use  of  primary  data  and 
create a common  environment of default values  to use if  these  data are not available  or accessible. 
They also expressed the need for harmonised guidelines on how to implement the framework across 
specific segments of the transport sector, to ensure its uniform understanding in various parts of the 
transport chain. The respondents echoed the need for a dedicated system for verifying emissions data 
and  calculation  processes,  even  if  stakeholders,  especially  SMEs,  had  reservations  about  the 
associated  administrative  burden  and  costs.  On  applicability,  while  some  stakeholders  found  that  a 
mandatory requirement would be the most effective in levelling the playing field, overall they deemed 
the opt-in approach to be the most feasible and efficient. 

Member  States  provided  limited  feedback  to  the  consultation,  but  the  responses  received  showed 
general support for the rationale and objectives of the initiative. 

C. Impacts of the preferred option 

What are the benefits of the preferred option (if any, otherwise of main ones)?  

Direct  benefits  include  a  reduction  in  total  energy  costs  of  EUR 2.4  billion  relative  to  the  baseline, 

1  Using  methodology  provided  by  ISO  standard  14083  (based  on  well-to-wheel  greenhouse  gas  emissions 
stemming  from  both  vehicle  use  and  vehicle  energy  provision)  with  additional  components  and  increased 
accuracy 
2 ISO standard 14083 was transposed in April 2023 to the European standard EN ISO 14083 by the European 
Committee for Standardisation. This initiative refers to the European version of the standard. 
3 Addressing a full lifecycle assessment of GHG emissions generated by the production, distribution, use and 
dismantling of vehicles. 

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expressed  in  current  prices  over  2025-2050.  In  addition,  this  initiative  is  estimated  to  lead  to  a 
reduction  in  the  external  costs  of  GHG  emissions  of  EUR 674  million,  in  air  pollution  emissions  of 
EUR 163.5 million and to reductions in road accidents valued at EUR 47 million. The total benefits of 
the preferred policy option would therefore amount to EUR 3.9 billion relative to the baseline, while the 
net benefits would amount to EUR 2.4 billion relative to the baseline, expressed in current prices over 
2025-2050. 

These  impacts  are  mostly  driven  by  behavioural  change  to  increase  the  use  of  more  sustainable 
methods of transport and to optimise trips.  

What are the costs of the preferred option (if any, otherwise of main ones)?  

The  costs  of  the  preferred  policy  option  are  estimated  at  EUR 1.5 billion  in  addition  to  the  baseline 
costs over the period 2025-2050 (net current value, with discount rate of 3%). 

The  additional  costs  of  the  preferred  policy  option  will  fall  mainly  on  the  businesses  involved  in 
transport  services  that  opt  in  or  are  mandated  to  quantify  and  share  GHG  emissions  data.  A  major 
share of the total costs is in starting, switching and operating the common reference methodology (ISO 
standard 14083). Although the unit costs of  verification activities and calculation tools  are lower than 
the  corresponding  baseline  costs,  they  will  also  give  rise  to  additional  costs  due  to  the  increased 
uptake of GHG emissions accounting in the transport sector. 

The  European  Environment  Agency  will  incur  costs  in  setting  up  and  maintaining  the  EU  databases 
required by this initiative, and in running quality checks of external databases, as required to integrate 
these external databases under the harmonised emissions accounting framework. 

Other  stakeholders  (business-sector  associations,  national  statistical  offices,  national  accreditation 
bodies, calculation tools developers) will bear comparatively lower costs. 

What are the impacts on SMEs and competitiveness?  

The preferred policy option is expected to lower the barriers for SMEs for accounting GHG emissions 
of transport services, especially by providing a single methodology, a common framework of input data 
and  guidelines  to  harmonise  implementation  of  the  initiative  on  the  market.  The  quasi-voluntary 
character of the initiative and the exemption from need to verify GHG emissions data and calculation 
processes will prevent adverse economic impacts on SMEs, especially in terms of the administrative 
burden and costs. 

Since SMEs represent the vast majority of bodies affected by this regulation, they are expected to gain 
the lion's share of total benefits deriving from lower energy costs estimated under the preferred policy 
option, amounting to EUR 2.3 billion. The total costs for SMEs are estimated at EUR 1.4 billion relative 
to the baseline. Both figures are expressed in current prices over the period 2025-2050. 

This  initiative  is  therefore  expected  to  generate  overall  net  benefits  for  SMEs  estimated  at  EUR 0.9 
billion relative to the baseline over the period 2025-2050. 

Will there be significant impacts on national budgets and administrations?  
Most national accreditation bodies and statistical offices that would be affected by this regulation rely 
on  state  funding.  As  they  are  expected  to  bear  only  a  very  small  share  of  costs  associated  with 
implementation of the initiative, it is expected to have a very limited impact on national budgets. 

Will there be other significant impacts?  
The preferred policy option will result in saving 5.6 million of tonnes of GHG emissions relative to the 
baseline over the period 2025-2050. This is mainly driven by behavioural change to make greater use 
of more sustainable transport options and to changes to optimise trips. It is also expected to generate 
positive  impacts  on  air  quality,  competitiveness,  innovation,  on  the  functioning  of  the  internal  market 
and on digitalisation of the transport sector. 

Proportionality 
The  preferred  policy  option  offers  the  most  balanced  set  of  measures  to  reach  the  overall  policy 
objective. It envisages the use of ISO standard 14083, allows third parties to be involved in providing 
input data and calculation tools, and sets proportional requirements on data verification (by exempting 
SMEs). In addition, by enabling users to opt in to apply the harmonised framework, it limits the binding 
requirements  to  the  entities  that  choose  to  quantify  and  share  GHG  emissions  data  of  transport 
services, while creating a level playing field for emissions accounting and making emissions data more 

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comparable across different modes and segments of transport.  

D. Follow up 

When will the policy be reviewed?  
The  regulation  will  be  evaluated  five  years  after  it  becomes  applicable,  i.e.  following  adoption  of  the 
proposal and of secondary legislation laying down detailed rules. 

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