CountEmissionsEU: A Global Framework for Measuring Transport Emissions - Why a Life Cycle Methodology Doesn’t Fit the Scope

13 December 2024

As trilogue negotiations between the European Parliament, the Council, and the European Commission begin on the proposed CountEmissionsEU Regulation, CLECAT remains firm in supporting the original Commission proposal without the inclusion of life cycle greenhouse gas (GHG) emissions from transport, mostly stemming from manufacturing, maintenance and disposal of vehicles. While the ambition to provide a comprehensive view of GHG emissions in transport is noteworthy, the addition of a life-cycle methodology in the final text of the Regulation is counterproductive for businesses and the transport sector.

The CountEmissionsEU proposal, as it stands, aims to provide a harmonised framework for calculating GHG emissions stemming directly from transport operations. This 'well-to-wheel' approach, reflected in the ISO 14083 standard, is already aligned with current business practices, offering a practical and tangible method for companies to assess and report emissions. Introducing life-cycle emission accounting, which encompass emissions from vehicle manufacturing, maintenance, and end-of-life processes, would derail this focused approach for several reasons:

1. Lack of Robust Methodologies
There is no robust and universally accepted methodology for calculating emissions associated with vehicle manufacturing, raw material extraction, or end-of-life processes. Developing such methodologies would require extensive research and stakeholder consultations, delaying the implementation of CountEmissionsEU and impeding the adoption of GHG calculation practices by businesses.

2. Scope Creep and Complexity
Including life-cycle emissions would significantly expand the scope of the Regulation beyond transport services. This risks blending the emissions of transport services with the wider footprint of a transport company, leading to confusion among stakeholders. The vast complexity of allocating emissions from vehicle production and destruction to specific transport operations makes the results less transparent and harder to interpret, undermining the purpose of the legislation.

3. Impractical Data Requirements
Calculating life-cycle emissions requires granular data on vehicle production processes, raw material sources, and lifetime emissions information that is often unavailable or unverifiable. For example, assessing the full life cycle impact of an electric vehicle would require knowledge of the origin and processing of rare earth metals used in its batteries. Such data is currently beyond the reach of most companies, creating an undue burden along the supply chain.

4. Counterproductive for Decarbonisation Goals
Rather than incentivising actionable choices based on transport emissions, life-cycle emissions risk diluting the focus on decarbonising operations. The aim of CountEmissionsEU should be to provide businesses with clear, actionable insights into their operational emissions, empowering them to make informed choices on transport modes and drive decarbonisation strategies.

The inclusion of a life cycle methodology in CountEmissionsEU also pre-empts ongoing work at international bodies like the UNECE and creates overlaps with existing legislation such as the planned reviews of CO2 standards for Light-Duty Vehicles (LDVs) and Heavy-Duty Vehicles (HDVs).

Finally, not including life cycle GHG emissions in the scope of CountEmissions EU does not mean that they will never be accounted for: with the proper methodology in place, such emissions could be factored in the annual sustainability reporting of a transport company, for example as an asset purchase, and considered as Scope 3 emissions. But including them in the scope of CountEmissions EU would not provide an accurate and clear view of the GHG emissions stemming from transport operations.

Moving Forward

CLECAT strongly urges policymakers to preserve the integrity of the CountEmissionsEU proposal by rejecting amendments introducing a life-cycle methodology. Instead, the focus should remain on operational emissions, where robust standards like ISO 14083 already exist. CLECAT is committed to help the industry embrace this standard thanks to the publication of its Guide to ISO 14083, aimed at companies willing to implement GHG emissions measuring and reporting. However, CLECAT also emphasises the importance of addressing the underlying challenge of accurate and standardised emission factors, which form the foundation of reliable GHG calculations.

This is where the CLEVER project (Coordinated Low Emission Vehicle Energy Reporting) comes in. CLEVER seeks to fill a critical gap by developing a comprehensive, cross-cutting methodology to establish emission factors that are both scientifically robust and universally applicable. The project covers all transport modes, fuels (including novel low-carbon pathways), and production methods, ensuring relevance across geographies and energy systems. The framework will integrate emissions from the entire energy lifecycle-from production to end use-ensuring that the full impact of energy consumption is accounted for, while preventing emissions shifting between sectors.

CLEVER also aims to standardise emissions for emerging energy sources like hydrogen, e-fuels, and sustainable aviation fuels (SAFs), alongside conventional fossil fuels, ensuring that the data remains relevant as the energy landscape evolves.

The success of CountEmissionsEU will rely heavily on accurate and reliable emission data, and the CLEVER project aims to provide this foundation by developing consistent, accurate, and adaptable emission factors. CLECAT anticipates that the results of CLEVER will become a key element of emissions reporting, offering the clarity and certainty needed by businesses, policymakers, and stakeholders to make informed decisions and drive meaningful progress toward decarbonisation.

By leveraging robust initiatives like CLEVER to address emission factor challenges, CountEmissionsEU can maintain a clear and actionable focus on operational emissions, empowering businesses to reduce their carbon footprint effectively without imposing unnecessary complexity. CLECAT remains committed to collaborating with all stakeholders to ensure this legislation achieves its purpose.

Let's keep CountEmissionsEU practical, effective, and focused!

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