Emission Data
Emission Data as an Access Ticket: What CSRD Specifically Requires from Logistics Service Providers
Sometime during the first half of 2024, something started to change. Procurement managers and sustainability coordinators at major shippers began sending emails to their regular transport providers with questions they had never asked before: how much CO2 did the transportation of our goods emit? Per shipment or per year? What methodology was used?
For logistics directors and QHSE managers who were used to discussions about price, delivery times, and availability, these questions came unexpectedly. But these are not isolated cases. They are a direct result of the Corporate Sustainability Reporting Directive, the CSRD, which came into force for the largest European companies for the 2024 reporting year. Even logistics service providers that are not required to report themselves are facing major changes. They now supply the data for a mandatory part of their customers’ reports.
How the CSRD affects logistics suppliers
The CSRD is the successor to the Non-Financial Reporting Directive and requires large European companies to report extensively on their impact on the environment, people, and governance. For the 2024 reporting year, this applies to companies with more than 500 employees that already fell under the previous directive. In 2025, companies with more than 250 employees or annual revenues exceeding 40 million euros will follow. The requirements are laid out in the European Sustainability Reporting Standards, the ESRS. The ESRS E1 standard specifically concerns climate and requires companies to map their scope 1, scope 2, and scope 3 emissions.
Scope 3 is the part that directly affects logistics service providers. These are indirect emissions in a company’s value chain but outside its direct control. Scope 3 consists of fifteen categories. Category 4, upstream transportation and distribution, concerns emissions generated by external parties transporting goods. For a shipper working with a carrier, these are therefore the emissions of that carrier. The shipper must report them and therefore needs data from the service provider. That is how the chain works.
Before the CSRD, sustainability reporting was often voluntary or limited. Scope 3 was frequently estimated or even omitted entirely. That is no longer possible. ESRS E1 requires scope 3 emissions to be substantiated using a clear methodology rather than rough estimates.
What ESRS E1 specifically requires and what it means for transport providers
Many logistics service providers believe the CSRD does not apply to them because they are not required to report themselves. Formally, that is correct, but in practice they are part of their customers’ reporting process. And those customers are imposing increasingly higher demands.
Mandatory calculation methods for scope 3 emissions
ESRS E1 requires scope 3 emissions to be calculated using a recognized methodology. In transport, the primary standards are the GLEC Framework and the European standard EN 16258. The GLEC Framework is used worldwide and calculates emissions based on data such as distance, load factor, vehicle type, and fuel type. EN 16258 defines how energy consumption and emissions must be calculated for transportation activities.
What data transport providers must supply
For transport providers, this means that an annual overview of total diesel consumption is no longer sufficient. Shippers need data per trip, route, or shipment, or at least per customer or product flow. A shipper calculating emissions per product or region cannot use a total figure that cannot be broken down further. Transport providers must therefore supply data that can be directly used in the customer’s calculations.
This involves concrete information such as fuel consumption per vehicle or trip, vehicle type and emission standard, load weight or volume, distance traveled, and fuel type. Alternative propulsion systems must also be included. With this data, emissions can be calculated according to GLEC or EN 16258 in a way that withstands audits and verification.
Where things go wrong in practice
For many mid-sized transport companies, the problem is not the absence of data, but how the data is stored. Information is spread across systems such as trip administration, fuel card systems, planning software, and fleet management tools. The data exists, but it is not connected and therefore not usable for reporting purposes. That is where things currently go wrong.
Warehousing companies are also affected. Scope 3 category 4 concerns not only transportation but also storage and distribution. Shippers increasingly request information about warehouse energy consumption, forklifts, cooling systems, and lighting. Many warehousing companies have not yet properly recorded this information.
Consequences for logistics service providers over the next twelve months
Pressure on logistics service providers will continue to increase in the near future. In 2025, more companies will fall under the CSRD, meaning more shippers will request data. In addition, the first reports for 2024 are being published, increasing pressure from banks and investors for better-quality data.
For transport providers without proper CO2 registration, the risks are clear. They may lose tenders or contracts if they cannot supply data. Major shippers are increasingly including sustainability in their supplier selection criteria. Without data, you become a risk for the customer, both operationally and in terms of reputation and compliance.
Another issue is the additional workload. Without a system, data must be collected and calculated manually for each customer. This takes significant time and often produces inconsistent results that are difficult to defend during audits. In the short term, this may still be manageable, but not once the number of requests increases.
There is still uncertainty. Discussions are ongoing in Europe about possible adjustments to the CSRD. It is not yet clear what exactly will change. But one thing is certain: customers will continue requesting data, regardless of how the regulations evolve.
Wat je nu kunt doen voor jouw logistieke operatie
In the short term, over the next three months, it is important to assess what data is already available. What information is currently recorded in systems such as trip administration, fleet management, and fuel card systems? How detailed is this data? Can fuel consumption be linked to vehicles and trips? This inventory does not have to be complicated, but it should clarify where the gaps are.
It is also wise to centrally track customer requests. Which customers are asking for data, what exactly are they requesting, and in which format? This helps determine priorities and where to start.
In the medium term, over the next three to twelve months, it is necessary to establish a fixed process for emissions data. Choose a standard such as GLEC or EN 16258 and define how calculations are performed. Then assess whether existing systems can be adapted. Can fuel consumption be stored per trip? Can vehicles be linked to emission data?
In addition, knowledge is important. Employees who communicate with customers must understand what scope 3 means and what is being requested. This helps prevent misunderstandings and unrealistic expectations.
Conclusion: what CSRD means for logistics service providers and their emissions data
The question is what a logistics service provider must track in order to meet customers’ data requests under the CSRD. The answer is a clear set of data points such as fuel consumption per vehicle and trip, load information, distance, vehicle type, and fuel type. These must be linked to customers and shipments and calculated according to a recognized methodology such as the GLEC Framework or EN 16258. This is achievable, but it requires a deliberate decision to organize it structurally.
What remains important to monitor are developments surrounding the CSRD and how shippers incorporate sustainability into their contract decisions. The latter is already happening and is independent of legislation. For logistics service providers starting now, this is not only an obligation but also a condition for remaining competitive in the market.
Sources and Background
- European Commission CSRD
https://finance.ec.eu.eu/financial-markets/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en - RVO CSRD
https://www.rvo.nl/onderwerpen/csrd - ESRS E1 Standard
https://www.efrag.org/sites/default/files/media/document/2024-08/ESRS%20E1%20Delegated-act-2023-5303-annex-1_en.pdf - GLEC Framework
https://www.smartfreightcentre.org/en/our-programs/emissions-accounting/global-logistics-emissions-council/calculate-report-glec-framework/ - GLEC Framework v3
https://smart-freight-centre-media.s3.amazonaws.com/documents/GLEC_FRAMEWORK_v3_UPDATED_13_12_23.pdf - EN 16258 Standard
https://www.nen.nl/nen-en-16258-2012-en-178234 - EU Omnibus Package
Omnibus package - Stop-the-clock mechanism
Simplification: Council gives final green light on the ‘Stop-the-clock’ mechanism to boost EU competitiveness and provide legal certainty to businesses