Accounting of greenhouse gas emissions of transport services

The Swedish Aviation Industry Group (SAIG) is a non-profit making industry association which promotes, protects and ensures that its member companies are not neglected with respect to political issues and lobbies for the continued survival and well-being of the Swedish air transport industry.

The German Transport Forum is the only cross-modal economic association in the mobility sector for passenger and freight transport in Europe. We understand ourselves as a lawyer for mobility. We are about maintaining and improving mobility conditions as a prerequisite for growth and employment. We bring together companies and associations, producers, service providers, consultants and representatives of users.

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The BDL supports the objective of presenting transport services in a transparent and comparable manner by standardising the methodology and the use of generally binding emission factors to calculate emissions of transport services. In particular, the following elements are to be welcomed in the draft: —The application of the internationally recognised standard (EN ISO 14083:2023) as a basis for the Regulation.

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The Federation of German Industries (BDI) welcomes the efforts of the European Commission for a transparent and harmonised calculation of transport-related greenhouse gas emissions. To provide incentives for climate protection in passenger and freight transport and effectively reflect emissions of logistics chains, a technology-neutral design of the regulatory approach is required across all modes of transport and…

CNR is the concessionary of the French state for the management of the Rhône river, with 3 historical missions: producing hydroelectricity, irrigation for agricultural uses and the development of navigation. CNR welcomes the European union recent regulations and proposals for transport and its greening, which includes CountEmissions Regulation.

The International Air Transport Association (IATA) is the global trade association of the worlds airlines representing more than 300 airlines globally. Overall, IATA welcomes the EU Commission`s legislative proposal that aims to move towards a harmonized calculation methodology to calculate transport-related greenhouse gas emissions.

Cefic supports the Commission's proposal for a common methodology based on the ISO 14083 standard. However, it remains important to continuously monitor other valuable sources and references which are consolidated in the market and may offer more accurate guidance for GHG emissions calculation and reporting. The use of primary data should be encouraged as much as possible to ensure more precise calculations.

ecoinvent welcomes the proposal on the accounting of greenhouse gas emissions of transport services and appreciates the possibility of providing feedback on the proposal, which the European Commission adopted on July 11, 2023.

The German Biogas Association (FvB) welcomes the European Commissions proposal for a Regulation on the accounting of greenhouse gas emissions of transport services, which sets a common regulatory framework for GHG emissions.

IRU welcomes the introduction of a common EU methodology to calculate and disclose greenhouse gas (GHG) emissions. Emissions accounting is a useful instrument to facilitate efforts made by commercial road transport operators to improve their environmental footprint and contribute to achieving the objectives of the European Green Deal and Fit for 55 package.

Measuring greenhouse gas emissions is a key tool to drive sustainability, innovation and behavioural change and is already being used in various sectors of the economy. In the transport sector, there is not yet a generally accepted framework for measuring greenhouse gas emissions from different transport services.

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Following our initial feedback, BEUC would like to raise new elements: BEUC's main concern is the way in which the data from the methodology will be presented to consumers. In our view, article 9.3 leaves the door open to "disguising" the raw data by stating "the output data as a minimum shall consist total mass of carbon dioxide equivalent (CO2e) per transport service, and, in relation to a type of transport…

ACEA supports the move towards a harmonized emissions calculation framework in the EU. We believe that this will enhance the accuracy and comparability of emissions data and support companies in their sustainability efforts. However, it is essential that these new rules are carefully designed to align with existing regulations and avoid unnecessary duplication.

Founded in 1980, European Regions Airline Association (ERA) is a non-profit trade association representing over 55 airlines plus around another 160 companies involved in the European air transport value chain. ERA is the only association that brings together the entire spectrum of companies involved in European aviation.

Nordsol welcomes the European Commissions proposal for a Regulation on the accounting of greenhouse gas emissions of transport services. Most importantly, Nordsol applauds the decision to adopt a Well-to-Wheel (WtW) methodology, allowing for a complete assessment of the environmental impact of the energy used in transport operations.

The European Biogas Association (EBA) welcomes the European Commissions proposal for a Regulation on the accounting of greenhouse gas emissions of transport services, which sets a common regulatory framework for GHG emissions accounting across the entire multimodal transport chain.

EIM, the European Association representing Rail Infrastructure Managers (IMs), welcomes the initiative related to provide more transparent information regarding transport-related greenhouse gas (GHGs) emission to monitor and reduce emissions and to improve the efficiency of transport services. Nonetheless, EIM believes that some key points are not adequately addressed.

ePURE, representing the EU producers of sustainable ethanol from crops, waste, and residues and accounting for 85% of the EU renewable ethanol production appreciates the opportunity to input into the Commission consultation on the CountEmissionsEU proposal, specifically highlighting that: The European Commission should ensure that this proposal does not create overlaps or contradictions with existing legislation.We…

Eurogas and Gmobility are committed to the decarbonisation of the transport sector, notably through the increasing role of gaseous fuels, including biomethane (bioCNG/bioLNG) as sustainable and immediately available fuels with lower GHG footprints.

HAROPA PORT, the Major river-sea Port of the Seine axis merging the ports of Le Havre, Rouen and Paris welcomes the Commissions proposal for a Regulation setting out a common framework to calculate and communicate transport-related greenhouse gas emissions. As the biggest French port and major European logistics hub, HAROPA PORT fully endorses the implementation of the Sustainable and Smart Mobility strategy.

CER is glad to see carbon accounting on the European decision making agenda thanks to the legislative proposal for the 'CountEmissionsEU' Regulation. For decades CER has been calling for the full implementation of the polluter pays and user pays principles in the transport sector. CountEmissionsEU should be an enabler to internalise greenhouse gas (GHG) emissions from transport.

A common and harmonised baseline for measuring CO2e emissions from companies’ transport activities has been high for many years on the ITD’s and its members’ desirability. This is in order to monitor and make visible their own performance, but also to respond to increasing demands for GHG reporting from clients, investors, collaborators, etc., not least as a result of the EU’s CSRD.

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GBTA Welcomes EU Push for Harmonised Emissions Measurement As the Global Business Travel Association (GBTA) we support the European Commission's proposal, CountEmissionsEU, as a way to harmonise how emissions are calculated across all modes of transport.

Fleet Cards Europe (FCE) welcomes the introduction of the EU Greening Transport Package, which was published by the European Commission on 11 July 2023. FCE members fully support the aim underlying these measures - to increase sustainability within the transport sector and help it cut CO2 emissions by 90% by 2050 compared with 1990 - as set forth in the European Green Deal.

CONFEBUS takes note of the Proposal for a Regulation of the European Parliament and of the Council on the accounting of greenhouse gas emissions from transport services. With it, the European Commission proposes a common framework for calculating greenhouse gas (GHG) emissions from door-to-door transport services, based on an internationally accepted standard.

The SNCF Group supports the CountEmissionsEU initiative, which aims to encourage people and companies to use sustainable modes of transport. This initiative is a first step towards achieving a level playing field across the EU between transport modes. However, if the Commission's proposal goes in the right direction, it is not strong enough to generate a real change in the behavior of travelers and shippers.

UITP welcomes initiatives to stimulate and facilitate greenhouse gas emission reduction. Correctly implemented, the GHG emissions accounting should be able to incentivize companies, customers, and passengers to take up efficient public transport solutions and stimulate the market for cleaner vehicles.

Hello, I am contacting you to call for the ISO 14083: 2023 standard to be adapted to CountEmissions EU emission calculation methodology. Indeed, ISO 14083: 2023 leads to a tension in the method of allocating CO2e emissions in the case of air freight transport, which makes arbitrage between air cargo flights and passenger flights less virtuous.

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The Multimodal Services Committee of Catalonia (from now on: CSM) is an initiative of the Catalan Government aiming at the promotion and support of multimodal freight transportation. It has the technical support of the General Council of Chambers of Commerce of Catalonia.

CLECAT, the European Association for Forwarding, Transport, Logistics and Customs Services welcomes the CountEmissions EU initiative. The freight forwarding sector is of the view that much can be achieved to support the transport and logistics sector to reduce its emissions but only with the correct market-based and supportive instruments.

ANWB is an association representing the interests of more than 5 million consumers in the Netherlands on issues related to traffic, road safety and tourism & leisure. ANWB is targeting at triple zero goals for 2050: zero traffic victims, zero traffic jams and zero emissions concerning mobility (CO2, NOx, particulate matters).

With currently more than 21 million members, ADAC e.V. is the largest automobile club in Europe and the second largest in the world. The four letters in its name stand for an association which offers its members assistance, protection and advice around the clock and is a powerful stakeholder on all mobility issues.

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Danish Shipping welcomes the proposal and supports the regulation's objective to ensure a consistent and coherent calculation methodology across the transport sector. Danish maritime shipping is among the most climate ambitious globally, and climate and energy performance are crucial competitive parameters.

The practical implementation of the accounting of greenhouse gas emissions of transport services has been a focal point for Topsector Logistics (https://topsectorlogistiek.nl/over-topsector-logistiek/) in the last decade. We are pleased to see that the Commission has taken an approach in the proposed regulation that aligns with our practical experience.

fleetenergies™ : an evolution of alertgasoil™, welcomes the opportunity to comment on Count Emissions EU Impact Assessment consultation and offers its support through the comments in the attached document: Logistic value chains business is changing [K. F. J. &. P. J. Dopfer, "Micro-meso-macro," Journal of evolutionary economics, vol. 14, no. 3, p. pp.

Smart Freight Centre welcomes that the European Commission is bringing this initiative forward and fully agrees on the crucial importance of addressing the stated problem. Although we see a constant increase in the uptake of GHG emission accounting practices within the freight industry, it remains insufficient and varies greatly between stakeholders.

Neste welcomes the initiative of the European Commission to provide a common framework for calculating GHG emissions of transport operations in the freight and passenger transport sectors. We share the concerns of the EU Commission about the rising levels of GHG emissions of the transport sector.

In order to achieve the ambitious goal of CO2-neutral aviation by 2050, the companies of the German aviation industry presented a joint ‘Master Plan Climate Protection in Aviation’ in 2020. The German airlines, airports and air traffic control have committed themselves to seven fields of action, which are actively pursued: •Renew fleets by deploying lower-emission aircraft •Replace fossil kerosene with sustainable…

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Europe’s aviation industry, including CANSO, has committed to decarbonise air transport and accelerate efforts to make Europe a carbon neutral continent by 2050 through the reduction of CO2 emissions in absolute terms, supported by a robust decarbonisation roadmap published in February 2021. CANSO welcomes this initiative by the European Commission.

EEA members are committed to reducing their carbon footprint. The monitoring and calculation of GHG emissions can hereby be instrumental to improve companies’ environmental performance. EEA member companies are already measuring their carbon footprint in the context of non-financial reporting to identify hotspots in own operations and as part of commercial contracts with customers.

BigMile appreciates the opportunity to comment on Count Emissions EU Impact Assessment consultation. BigMile would like to elaborate on the challenges of standardization, the way forward, and the availability of proven technology. We believe standards for the calculation of CO2 emissions are a prerequisite for transparency and comparability.

While the “Sustainable and Smart Mobility Strategy" reveals the main guidelines towards a neutral emission mobility in the forthcoming decades, a transparent and common European methodology is still needed. “CountEmissions EU” is a largely expected initiative that can contribute to the transparent and widespread comparability of GHG emissions.

We consider it very important to inform consumers about the climate-damaging GHG emissions associated with their consumption in order to encourage them to change their behaviour, and have repeatedly called for it in feedback and consultations. We therefore expressly welcome the intention to record emissions from transport and to inform consumers about emissions.

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The Federation of German Industries (BDI) supports the Commission's goals of creating a level playing field for GHG calculations in the transport (freight and passenger services) and logistics sector with a uniform framework for calculating GHG emissions, while facilitating behavioural changes by users.

GE Aviation supports the European Commission’s ambition to align GHG emission reporting methodologies. This will reduce the fragmentation that currently exists across the transport modalities and ultimately promote the uptake of emission reporting. Given the multitude of frameworks that are already in existence and/or currently being developed, there are certain considerations that should be taken into account.

Network for Transport and Environment, NTM-MARLOG, was formed as an NGO network initiated by transport and industrial companies in collaboration with knowledge institutions in 2011. NTM-MARLOG is part of the Danish national cluster for maritime and logistics sectors, Marlog.

Decathlon is fully aware of its social and environmental responsibility. Every day, we observe and listen to our users, we design products, we test, we make, we sell BUT, every day at Decathlon, we create waste, we use the Planet resources, we are responsible for products travelling long distances, we use energy: we do have an impact... so WE ACT.

As the world’s road transport organisation, IRU represents nearly 1 million road transport companies in Europe. IRU is in favour of a harmonised approach in carbon measuring and counting of road and multimodal transport and logistics operations but would prefer this to be agreed upon by market players, and not imposed by the EU Institutions through legislation.

BEUC is supportive of the objective of this initiative. However, some principles need to be guaranteed to bring real benefits to consumers: - The methodology should be based on sound scientific evidence and real-world emissions; - The methodology (and the way it is communicated to consumers) should focus on absolute greenhouse gas emissions.

The La Poste Group supports the establishment of a harmonised framework for measuring emissions for the transport sector and stresses the importance of taking into account the specificities of the logistics sector of the first and last mile (km) in this context.

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Volvo Group welcomes initiatives to stimulate and facilitate greenhouse gas emission reduction. Correctly implemented, the GHG emissions accounting should be able to incentivize companies, customers and passengers to take up fossil free and efficient transport solutions and stimulate the market for these vehicles.

We welcome the European Commission's initiative concerning transport emissions. We expect that the Count your transport emissions Initiatives will ensure harmonisation across the EU and create a needed level playing field when it comes to transportation emissions.

PostEurop is fully committed to play its part in addressing global environmental challenges within the framework of the EU Green Deal and by supporting the delivery of the UN Sustainable Development Goals. Indeed, postal companies all over Europe have been actively measuring and reducing their GHG emissions for several years.

GBTA welcomes the opportunity to contribute to the European Commission’ call for evidence through its feedback consultation on a potential CountEmissions EU Regulation that would establish a single GHG emissions measuring mechanism to account for the greenhouse gases produced by the different stakeholders involved in the transportation sector.

Please, see document attached (in English). HAROPA PORT - le Grand Port fluvio-maritime de l'axe Seine - est le premier port de France est un hub logistique européen majeur. HAROPA PORT souscrit pleinement la mise en œuvre de la stratégie de "Mobilité Durable et Intelligente" de la Commission Européenne.

1. We are of the opinion that the topic is very relevant to the work of UEIL's Sustainability Committee and the Carbon Footprint groups. Depending on the type of the business of a particular UEIL member, emissions arising out of transportation can be very relevant and the determining factor. 2. We feel that there are already a lot of existing frameworks for calculating and reporting transport-related GHG emissions.

UIP, the International Union of Wagon Keepers, is welcoming the European Commission’s objective to establish a transparent and up-to-date methodology enabling a level playing for GHG emissions accounting in the transport and logistics sectors.

As Connekt we strongly support the CountEmissions EU initiative. We have been exercising with the practical application of the pending ISO ISO14083 standard in logistics through our Lean & Green program and network of 500+ participating companies in 13 European countries and Canada.

Driving the transition to zero-emission mobility as required by the EU Green Deal will only be possible by placing the right incentives to transport users. Achieving the 90% greenhouse gas emission reduction in the transport sector by 2050 requires a basket of measures that include a robust carbon pricing, taxation, infrastructure charging and CO2 standards for vehicles complemented by financial incentives to…

Verifavia values the opportunity to comment on Count Emissions EU Impact Assessment consultation. Verifavia Shipping strives to be the maritime industry’s first choice for the provision of emissions verification and hazardous materials preparation and maintenance services.

SNAM welcomes this initiative to set a common methodology to calculate and monitor GHG emissions of transport and logistics. The standard EN 16258 "Methodology for calculation and declaration of energy consumption and greenhouse gas emissions of transport services" provides a standard which, although it is considered insufficiently precise, can be used by freight forwarders in a targeted approach.

EPF welcomes the European Commission’s initiative to create an EU framework for harmonised measurement of transport and logistics emissions – ‘CountEmissions EU’. In order to be able to make an informed choice, passengers need a neutral, comprehensive and reliable overview of available – multimodal – travel options.

The eFuel Alliance fully supports the European Commission’s initiative to harmonise the measurement of transport and logistics emissions and welcomes the commitment to make available comparable information. This is essential to provide the transparency needed to allow informed decisions to be made on how to target emissions reductions and how to achieve climate-neutrality by 2050.

A commitment to sustainability is an integral part of Deutsche Post DHL Group's corporate culture. Since 2008, the Group has had ambitious sustainability targets, for example with regard to CO2 reduction. In 2017, the Group became the first logistics company in the world to set a target of reducing its greenhouse gas emissions to net zero by 2050.

European Commission’s Call for evidence on the new ‘CountEmissions EU’ initiative CLIA Europe welcomes the possibility to comment on the call for evidence on the new ‘CountEmissions EU’ initiative and in principle could support the idea to have a consistent framework.

Rolls-Royce pioneers the power that matters to connect, power, and protect society. Our family of turbofan aircraft engines have set new performance benchmarks for civil aviation. On land and sea, we are the leading supplier of power for safety-critical installations and integrated drives for marine, heavy off-road, rail applications, emergency power and decentralized energy.

The Spanish bus and collecting transport Confederation (CONFEBUS) takes note of this initiative which actions to provide a common framework for calculating greenhouse gas emissions from road transport. According to a recent survey conducted by the European Commission, most importantly the totality of public opinion in Spain (97 %) is concerned with environmental sustainability.

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ECSA welcomes the possibility to comment on the call for evidence on the new ‘CountEmissions EU’ initiative. ECSA would like to highlight that shipping is already required to monitor, report and verify the carbon dioxide emissions of vessels under the EU MRV system (Regulation (EU) 2015/757).

We strongly support this initiative on the provision of a common framework for calculating GHG emissions of transport operations in the freight and passenger transport sectors. At this moment the information on GHG emissions related to transport activity of passengers and freight is generally not shared with the users of transport, while there is strong evidence that carbon footprinting can lead to better decisions…

ERA welcomes the opportunity to comment on Count your transport emissions initiative and supports a “door-to-door” approach. • ERA understands the objective of such initiative, to offer a common framework to calculate GHG emissions among all transport modes and allow passengers to make informed decisions when choosing transport modes.

A standard for calculating emissions from the transport sector is necessary in order to create the right initiatives for the necessary transition towards a sustainable transport system within the EU and globally. In particular, economic instruments type “polluter pays” must be based on much more agreed common calculation standards than today.

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The European Cyclists' Federation (ECF) welcomes the Commission’s CountEmissions EU initiative. In order to give a complete picture of sustainable transport and mobility options, it is important that active mobility modes like walking and cycling be included in the assessment and compared to other modes of transport and mobility. You can find our detailed feedback and recommendations in the attachment.

We strongly support this initiative, provided that the common framework pushes for : - accounting of emissions based on primary data as opposed to modelling (“calculating”) emissions based on general emission intensity factors - integration of recording and accounting for CO2 in standard IT systems used in the industry - allocation of emissions to the value added by the transportation and storage activities, being…

As a company with extensive knowledge and experience in the field of determining global transport emissions and the associated harmonization of calculation methodology, we are happy to take the opportunity to comment on the planned project "CountEmissions EU": 1.

• UNIFE - the association of the European rail supply industry - welcomes the European Commission (EC) decision to proactively work on a proposal aiming to set up a framework for calculating greenhouses gases (GHG) emissions of transport operations in the freight and passenger transport sectors.

www.travelandclimate.org is a research based platform providing a simple tool and knowledge base which makes it easier for people to choose to travel with a low climate impact. Principal for the project is the Centre for Tourism at the University of Gothenburg, where Erik Lundberg is project owner.

Finnish Biocycle and Biogas Association finds it important to develop common framework to calculate and report transport-related greenhouse gas emissions. We acknowledge that the work is demanding and laborious. For instance, the JRC has developed the PEF method for a decade. More relevant question is how to use the method.

Danish Shipping appreciates the opportunity to comment on the call for evidence on the new ‘Count Emissions EU’ initiative. Danish Shipping appreciates the proposal for a transparency measures but would like to highlight that the shipping industry is already required to disclose CO2 data through the EU MRV system, through which the data is subsequently made publicly available.

The International Air Transport Association (IATA) welcomes the opportunity to comment on Count Emissions EU Impact Assessment consultation. IATA is the global trade association of the world’s airlines representing more than 290 airlines.

The EBA considers as important the development of a common framework to calculate and report transport-related greenhouse gas emissions. We acknowledge that the task is demanding and laborious. We do not ignore that the development of the PEF calculation method by the JRC took 10 years. One of the most determinant issues is how to use the calculation method.

Bosch welcomes the COM initiative to provide a uniform framework for quantifying GHG emissions in the transport sector. The goal to promote new business models and to initiate a strong dynamic in the reduction of CO2 emissions in the transport sector is also supported form our part.

The Public and Rail Transport Union (UTP) thanks the Commission for this opportunity to share its views on the establishment of an EU framework for harmonised measurement of transport and logistics emissions — “CountEmissions EU”. UTP is the French professional organisation of urban public transport and railway undertakings.

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It is a fact that the logistics and distribution business lacks a frame that let measure, monitor, and compare solutions and operations, as well as address the correct actions to address the sustainable goals, which use to be represented within the strategic goals of the majority of the organisations in the sector.

SkyNRG supports the EU's efforts in establishing a single GHG emissions monitoring mechanism to account for all the greenhouse gases emitted through its transportations sector. At SkyNRG we are developing the market for the sustainable aviation fuel (SAF) sector.

It's excellent to see the Commission bring this initiative forward. Over the past ten years a lot of collaborative work has gone into developing the building blocks upon which this initiative can be built involving leading industry players, the research community, technology providers, and public authorities. The call for evidence acknowledges this in section D.

The "CountEmissions EU initiative" should use Remote Sensing technology to have a deeper and real-world understanding about real-driving emissions. As thousands or millions of vehicles will be measured every year on European roads and streets, it would be wise to use this information within this Innitiative.

Measurement of GHG emissions for transport is definately a must in the light of the urgent decarbonization needs which we face globally, but also within Europe. It shall be noted that CO2 and GHG measurement must be designed observing three different purposes, no only one: 1. The measurement and reporting in itself. We only can manage what we can measure. 2.

1. CONTROLLING ALL TRANSPORT EMISSIONS: Road transport emissions including other pollutants, such as NOx and CH4, which are directly or indirectly connected to Global Warming. Other gases are also a major source of air pollution, causing human health and eco-system damage.

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