Freight emissions reporting has two halves that get conflated: how you calculate the number, which is now genuinely standardised, and whether you must disclose it, which changed substantially in 2026 and is still moving. Most of what was written about this in 2024 is now wrong.
Verified against primary sources: EUR-Lex, the SEC, CARB coverage, GHG Protocol chapter guidance and the GLEC Framework itself, in August 2026. Several items below are actively in flux and are flagged; re-check before relying on any deadline.
How the number is calculated: one standard, one guide
| Document | What it is | Status |
|---|---|---|
| ISO 14083:2023 | The international standard for quantifying GHG emissions from transport chain operations: all modes, plus hubs, on a well-to-wheel basis | Published March 2023. In Europe, EN ISO 14083 superseded EN 16258 |
| GLEC Framework | Smart Freight Centre's implementation guide to ISO 14083: default emission factors and practical method | Version 3.2, October 2025. Added an air-pollutant module and updated default factors |
| GHG Protocol Scope 3 | The corporate accounting standard your finance team reports against | Current, but under revision: consultation draft due 2026, final targeted late 2027 |
These are not competitors. GLEC fed into ISO 14083, and after publication Smart Freight Centre folded the ISO standard back into GLEC v3, so the Framework carries inline ISO clause references and functions as the how-to for the standard.
The categorisation mistake nearly everyone makes
Under the GHG Protocol, purchased freight lands in Category 4 (upstream transportation and distribution) and sold-product movement after the point of sale lands in Category 9 (downstream). The instinct is to file inbound in 4 and outbound in 9.
That is wrong. The split is not by direction. It is by who pays. The standard is explicit that outbound transportation purchased by the reporting company is excluded from Category 9 and included in Category 4, because the reporting company bought the service. For a shipper buying freight forwarding, almost all of your freight is Category 4, including your outbound shipments. Category 9 covers movement you do not pay for.
Data quality: primary beats modelled beats default
Every regime accepts modelled or default data and every one states a preference order. GLEC and ISO 14083 rank them:
- Primary data from the actual operator. Use whenever possible.
- Modelled data: prioritised over defaults.
- Default values from a database, matched as closely as possible to the operation, with the source and reasoning documented.
- Data from a contracted operator that has itself used primary or modelled data.
The GHG Protocol ranks its methods the same way: fuel-based, then distance-based, then spend-based, with spend-based reserved for when you lack mass, distance and mode. GLEC concedes the practical reality plainly. A combination is usually necessary, because primary data is not always available.
In practice, road and rail primary data is usually obtainable; air and ocean depend on carrier cooperation. If you are estimating internally in the meantime, the carbon emissions estimator gives an approximate figure by mode, weight and distance: an indication, not a reportable number.
What changed in 2026
CSRD scope was cut sharply. The Omnibus directive (Directive (EU) 2026/470, in force 18 March 2026) replaced the old thresholds with more than 1,000 employees AND more than €450m net turnover. Both conditions, not two of three. The narrowed scope applies to financial years beginning on or after 1 January 2027. Any article citing the original 2023 phase-in is describing a regime that no longer exists.
ESRS were rewritten and simplified. The 2026 delegated act was adopted on 3 July 2026, cutting mandatory datapoints by roughly 60% and total datapoints by around 70%.
The rule that matters most for freight: the Omnibus caps what a reporting company may demand from smaller suppliers. Companies with 1,000 employees or fewer cannot be required to provide more than the voluntary SME standard contains, and may decline. Given that the large majority of European road haulage firms have fewer than ten employees, your ability to compel carrier-level primary data from your own hauliers is now legally limited. Plan for modelled data on road legs.
CountEmissions EU (Regulation (EU) 2026/1030, in force June 2026) mandates EN ISO 14083:2023 as the common method and says entities shall prioritise primary data. It is voluntary in application and does not apply until 2 December 2030, with supporting databases and a free SME tool phased in before then. It is a thing to prepare for, not to comply with now.
United States: less settled than it looks
- The SEC climate rule never took effect. Adopted March 2024, stayed, and the SEC ceased defending it in March 2025. In May 2026 the SEC proposed to rescind it entirely; the comment period closed in August 2026 and no final rescission has been adopted. It is on the books, unenforceable, and proposed for repeal.
- California SB 253 is proceeding, and its deadline moved. It applies to companies with over $1bn total annual revenue doing business in California. The first Scope 1 and 2 reporting deadline was deferred to 10 November 2026: sources still citing 10 August 2026 are out of date. The 2026 reports require no assurance; limited assurance is proposed from 2027.
- California SB 261 is enjoined. The Ninth Circuit granted an injunction pending appeal in November 2025 and heard argument in January 2026; no merits decision has issued. Reporting remains voluntary. This is the most volatile item here: verify before acting.
What to do now
- Work out whether you are in scope at all. Under the new CSRD thresholds many companies that were preparing to report no longer have to.
- Classify freight correctly: purchased transport is Category 4, whichever direction it travels.
- Ask carriers and forwarders for ISO 14083-aligned data and accept modelled figures where primary is unavailable, documenting which you used.
- Do not build a process that depends on small hauliers supplying primary data. The law now lets them decline.
- Record your method and data sources alongside the numbers. Under every regime, the audit trail is the deliverable.
- Separate emissions costs from emissions reporting: the charges on your invoice are a different matter, covered in EU ETS and FuelEU surcharges.
Mode choice remains the largest single lever on the number itself. See sea freight vs air freight and multimodal planning.
Find forwarders and ask what emissions data they can provide, or post a request and make it a quoting requirement.
