COUNTEMISSIONSEU: NEW EU RULES APPLICABLE FROM 2030 FOR CALCULATING EMISSIONS GENERATED BY TRANSPORT SERVICES

Regulation (EU) 2026/1030 on the greenhouse gas emissions accounting of transport services, published in the Official Journal of the European Union on 12 May 2026, will apply, in respect of most of its provisions, from 2 December 2030. Before that date, the European Commission must establish a significant part of the technical infrastructure required for the implementation of the Regulation, including a core Union database containing default values for greenhouse gas emission intensities, as well as a simple, free-of-charge and user-friendly online calculation tool.

The new Regulation, also known as CountEmissionsEU, introduces a common Union framework for calculating and disclosing greenhouse gas emissions generated by transport services that start or end in the territory of the Union.

Its purpose is to make transport emissions data more comparable, transparent and reliable. Economic operators may currently use different methodologies, databases and calculation tools. As a result, information concerning the carbon footprint of transport services is not always comparable and may cause confusion for customers, public authorities and contractual partners.

As a general rule, the Regulation does not impose an obligation on all undertakings to calculate and disclose the emissions associated with transport services. It nevertheless applies where such information is calculated and disclosed on a voluntary, contractual or commercial basis, or where its calculation and disclosure are required under applicable Union or national law.

CountEmissionsEU will therefore be particularly relevant to commercial relationships between carriers, logistics operators, freight forwarders and customers, as well as to public procurement procedures, subcontracting chains and sustainability reporting.

The central element of the Regulation is the use of a common methodology: EN ISO 14083:2023, concerning the quantification and reporting of greenhouse gas emissions arising from transport chain operations. The calculation is performed at transport service level and is based on a well-to-wheel approach, meaning that it includes both emissions associated with the provision of energy and emissions generated by the use of vehicles in transport operations and by transport hub operations.

Entities within the scope of the regulation

The Regulation applies to several categories of entities involved in the calculation, provision, intermediation or verification of data relating to emissions generated by transport services. It primarily covers entities that calculate and disclose emissions, namely transport operators, transport service organisers and platform operators. In practice, this may include road, rail, air and maritime carriers, logistics operators, freight forwarders, multimodal service integrators, and operators of terminals, ports, airports, logistics centres or other transhipment infrastructure. The Regulation also applies to shippers where they procure transport services for the carriage of goods and, depending on the circumstances, may act as transport operators, transport service organisers or data intermediaries. It also covers technical entities contributing to the calculation or verification of emissions, including developers of external calculation tools, developers of databases operated by third parties, and conformity assessment bodies.

Disaggregated data at transport service level

A central element of the Regulation is the requirement that information be calculated and disclosed at transport service level. This means that the entities concerned must be able to provide emissions data relating to a specific service, route, transport operation or contractual service. The disclosure of emissions before the transport service is provided is encouraged, as it enables customers, public authorities and consumers to make informed decisions. However, the Regulation also permits disclosure after the service has been provided, particularly in B2B relationships involving complex logistics chains, subcontracting arrangements or the use of primary data.

Primary data, secondary data and default values

Primary data may be derived from actual energy consumption, actual distances travelled, loads, vehicle types, energy sources or other relevant operational data. At the same time, the Regulation recognises that not all entities are able to generate or immediately access complete primary data. The EU framework therefore allows the use of secondary data under clearly defined conditions. Secondary data may include default values for greenhouse gas emission intensities. Such values must be obtained from authorised sources, including the core Union database or third-party databases that have undergone a technical quality assessment.

Core union database

By 2 December 2029, the European Commission, with technical support from the European Environment Agency, must establish a core Union database containing default values for greenhouse gas emission intensities. Wherever possible, the database will include default values for vehicle types commonly used within the Union. It must provide a sufficient level of detail and reflect sectoral, regional and national specificities. Public access to the core Union database will be free of charge.

EU calculation tool

By 2 June 2030, the Commission must adopt implementing acts to make an EU calculation tool publicly available.

Verification, evidence and administrative burden

The Regulation introduces requirements concerning data verification and conformity assessment, while preserving the principle of proportionality. Entities that calculate and disclose emissions data must be able to provide evidence supporting the results disclosed. Such evidence must be made available to competent authorities or third parties where required by legal or contractual obligations.

SMEs are exempt from the verification requirements unless they choose to obtain proof of conformity. This approach is intended to prevent disproportionate costs from being imposed on smaller operators. At the same time, large undertakings must take account of the principle of proportionality when requesting verification of conformity from partners in their value chain, particularly SMEs.

For sectors in which accredited verifiers already operate under other Union legislative acts, such as maritime transport or aviation, the Regulation allows those verifiers to be recognised for the relevant activities, subject to compliance with the applicable conditions.

Liability of data intermediaries

Where a data intermediary merely obtains, combines and discloses emissions data provided by other entities, it should not, in principle, be held liable for non-compliance relating to the calculation or verification of emissions or the certification of calculation tools, unless otherwise provided for in a separate agreement. However, the data intermediary is not exempt from obligations. It must make the necessary efforts to prevent the disclosure of inaccurate or incorrect information, comply with the applicable communication and transparency requirements, and indicate the source of the information.

Contractual and commercial impact

In commercial relationships, customers may request emissions data relating to the services procured. Transport operators and transport service organisers must be able to determine whether the data disclosed constitutes estimates, default values or results based on primary data.

Contracts should specify who calculates the emissions, which methodology is used, who provides the operational data, who is responsible for its accuracy, whether verification is required, and the conditions under which the data may be used for sustainability reporting, public procurement or commercial communication purposes. These matters become even more important in subcontracting chains.

A transport service organiser that provides emissions data to the final customer will often rely on data received from carriers, transport hub operators or digital intermediaries.

Interaction with sustainability reporting and public procurement

The Regulation does not replace sustainability reporting obligations, but it may become an important technical tool for undertakings required to document their indirect transport-related emissions.

For undertakings subject to CSRD reporting requirements, data obtained in accordance with CountEmissionsEU may contribute to improved documentation of emissions generated within the value chain, provided that the information is compatible with the methodology applicable to the relevant reporting framework. In public procurement procedures, standardised emissions data may influence the evaluation of tenders, particularly where public authorities introduce environmental criteria or climate performance requirements.