CSRD ESRS E1: road transport caught up by CO₂ reporting

The CSRD directive (Corporate Sustainability Reporting Directive) enters its second wave in 2026. After large companies (first reporting in 2024), listed and unlisted mid-caps with more than 250 employees and €50m revenue must publish their first ESRS report on the 2025 financial year, to be released in 2026. For the transport sector, it is the ESRS E1 "Climate change" standard that hurts.

ESRS E1: what double materiality demands

ESRS E1 requires reporting Scope 1 emissions (direct combustion, i.e. truck diesel), Scope 2 (purchased electricity, which now includes EV charging stations), and Scope 3 (value chain — for transport, this includes sub-contracted freight). Scope 3 is the problem: for a carrier sub-contracting 30-40% of its rounds to charterers, how do you estimate their emissions without them reporting themselves?

Double materiality, the central concept of CSRD, requires reporting both the company's impact on the environment (impact materiality) and the environment's impact on the company (financial materiality). Concretely: a carrier must describe its carbon-risk exposure (taxation, shipper disengagement, fuel price), not just its emissions.

The GLEC method: the standard everyone asks for

The Global Logistics Emissions Council (GLEC) publishes a methodological framework adopted by nearly all large European shippers (Carrefour, Decathlon, L'Oréal, Unilever). When a shipper asks a carrier for per-round emissions, it is almost always in GLEC v3.0 methodology (2024 update).

GLEC requires per-trip data: vehicle type, load factor, fuel type, empty distance, loaded distance, real itinerary. This data exists in TMS systems, but is rarely consolidated in ESRS format. End-of-month calculation, for a 50-truck carrier, takes 2-3 person-days.

Calculation pitfalls

The emission factor isn't universal

The diesel emission factor varies by source (ADEME, DEFRA, EPA), vehicle type (Euro VI, Euro V, older), fuel type (B7, B30, HVO). A carrier using HVO (Hydrotreated Vegetable Oil) at 90% emissions reduction must be able to justify it — without HVO supplier delivery notes, the auditor falls back to standard diesel factor.

Empty returns weigh heavily

The empty-returns / total-kilometres ratio is one of the KPIs shippers watch most. In long-haul road transport, this ratio is 18-25% depending on the segment. A carrier that doesn't calculate it (or calculates it on driver-declarative basis, hence underestimated) ends up with Scope 1 underestimated by 8-15%, which will be flagged in audit.

Sub-chartering creates a hole

When a carrier sub-charters a round to a peer, the emission is in Scope 3. But if the peer doesn't provide their data (which is the case 70% of the time), the carrier must estimate via "average data" method (kilometres × sector mean factor). This estimate is documented in the report, but weighs unfavorably on the carbon profile.

The 2027 horizon: sectoral transport ESRS

EFRAG (the body that drafts ESRS) is preparing a sectoral transport standard for 2027. It will impose additional indicators: carbon intensity per tonne-km, fleet energy mix, quantified decarbonization plan, exposure to low-emission zones. For a carrier, that means turning the management system into a carbon-steering tool, not just an operations tool that happens to report.