The European regulatory landscape is transforming at an unprecedented pace, imposing new demands for sustainability and transparency. At the heart of this evolution, the Corporate Sustainability Reporting Directive (CSRD) and the Carbon Border Adjustment Mechanism (CBAM) have become essential pillars for companies operating in logistics. These regulations are not mere administrative formalities; they redefine the competitiveness and resilience of supply chains, particularly for European freight forwarders and shippers.

The urgency to act is palpable. According to a 2023 European Commission report, transport accounts for approximately a quarter of the EU's greenhouse gas emissions, and this share is increasing. The pressure to decarbonize is intensifying, and with it, the need to measure, report, and reduce the carbon footprint of every link in the supply chain. Ignoring these new obligations means exposing oneself not only to financial penalties but also to a loss of competitiveness and reputation in an increasingly demanding market for sustainability.

CSRD: Enhanced Transparency for Logistics

The Corporate Sustainability Reporting Directive (CSRD) came into force on January 5, 2023, replacing the Non-Financial Reporting Directive (NFRD). It significantly expands the scope and granularity of sustainability reporting. Approximately 50,000 European companies will be affected, compared to 11,000 previously. For the logistics sector, this means an obligation to disclose detailed information on the environmental, social, and governance (ESG) impact of their operations, including scope 1, 2, and 3 greenhouse gas (GHG) emissions.

Double materiality is a key concept of the CSRD: companies must report both the impact of their activities on the environment and society, and the impact of sustainability issues on their own value. For a freight forwarder, this involves documenting not only the CO₂ emissions of its fleet (scope 1 and 2), but also those generated by subcontracted carriers (scope 3), as well as risks related to extreme weather events on maritime or land routes. Compliance requires robust and verifiable data collection, often via integrated information systems.

CBAM: A Carbon Border Mechanism Impacting Freight

The Carbon Border Adjustment Mechanism (CBAM), which entered its transitional phase on October 1, 2023, aims to prevent "carbon leakage" and encourage the decarbonization of global industry. It imposes a carbon price on imports of certain carbon-intensive goods (cement, iron and steel, aluminum, fertilizers, electricity, hydrogen) into the EU, equivalent to the price European producers already pay through the Emissions Trading System (EU ETS). The carbon price in the EU ETS fluctuated around €80-100/ton of CO₂e in 2023.

While CBAM directly targets goods producers, it has major implications for logistics players. Importers will have to declare the embedded emissions of imported goods, and these emissions include those related to their transport to the EU. For example, if a Chinese steel manufacturer exports to the EU, the European importer will have to declare the CO₂ emissions of the steel and of maritime transport. This requires precise traceability of freight emissions, potentially influencing the choice of low-carbon transport modes or routes to reduce CBAM costs.

The Carbon Axis: Measuring and Optimizing Freight Emissions

Accurate measurement of freight CO₂ emissions is now imperative. Recognized methodologies, such as the ISO 14083 standard and the Global Logistics Emissions Council (GLEC) Framework v3, provide a framework for calculating GHG emissions across the entire transport chain. These standards require a granular approach, taking into account the mode of transport (maritime, road, rail, air), fuel type, distance traveled, weight transported, and load factor.

For a 20-foot equivalent unit (TEU) container carrying 10 tons of goods, emissions can vary significantly:

  • Transcontinental maritime transport (e.g., China-Europe): approximately 0.5 to 1.5 kg CO₂e per ton-km. For a 20,000 km journey, this represents 10 to 30 tons of CO₂e per container, or 1 to 3 tons of CO₂e per ton of goods.
  • Road transport (e.g., 500 km in Europe): approximately 0.1 to 0.2 kg CO₂e per ton-km. For 10 tons over 500 km, this results in 0.5 to 1 ton of CO₂e per container.
  • Rail transport (e.g., 500 km in Europe): approximately 0.01 to 0.05 kg CO₂e per ton-km. For 10 tons over 500 km, this represents 0.05 to 0.25 tons of CO₂e per container, offering a significant advantage.

These orders of magnitude highlight the importance of choosing optimized transport modes and routes. An ISO 14083/GLEC v3 compliant CO₂ calculator is essential for obtaining reliable data exportable for CSRD reports and for estimating CBAM costs related to transport.

Anticipating Disruptions and Optimizing Routes

Regulatory compliance is intrinsically linked to operational resilience. Recent events, such as the Suez Canal crisis or port strikes, have demonstrated the vulnerability of supply chains. These disruptions not only cause delays and additional costs: they also impact carbon emissions.

A vessel rerouted via the Cape of Good Hope can add 10 to 15 days of transit and increase CO₂ emissions by 20 to 30% on an Asia-Europe journey, due to the additional distance and potentially increased speed to catch up. Proactive risk management, based on real-time data (AIS, GPS, EDI) and AI, not only optimizes ETAs but also allows transport plans to be adapted to minimize the carbon footprint and additional costs linked to delays or CBAM penalties. For example, predicting port congestion can prompt redirecting a container to an alternative port with lower CO₂ emissions for the last mile.

Operational Implementation: Key Steps

To transform these regulatory challenges into competitive advantages, a structured approach is necessary. Here are the key steps for supply chain directors and transport managers:

  1. Audit existing data flows: Identify relevant data sources (BL, VGM, EDI, AIS, GPS) for goods and emissions traceability. Evaluate the quality and completeness of current information for each mode of transport.
  2. Implement an emissions calculation system: Adopt a CO₂ calculator compliant with ISO 14083 and GLEC v3 standards. This will provide reliable scope 3 emissions data for CSRD reports and for CBAM. Prioritize integrating this data into your existing reporting tools.
  3. Strengthen collaboration with partners: Work closely with your carriers and subcontractors to collect activity data (fuel consumption, vehicle type, distance) necessary for accurate emissions calculation. Contractual clauses including carbon data sharing can be considered.
  4. Deploy an orchestration cockpit: Use a platform that aggregates tracking data (AIS, GPS, EDI) for real-time visibility of your containers. Integrate an AI radar to anticipate disruptions (weather, strikes, congestion) and dynamically adjust your transport plans.
  5. Optimize routes and transport modes: Analyze emissions data to identify reduction levers. Prioritize rail or inland waterway transport when possible. Optimize container and vehicle fill rates. For maritime flows, assess the carbon impact of different shipping routes and fuel options (VLSFO, LNG, biofuels).
  6. Train teams: Raise awareness and train your teams (operations, CSR, procurement) on the challenges of CSRD and CBAM, as well as new procedures for collecting and analyzing emissions data. Internal adoption is crucial for the success of the initiative.

Frequently Asked Questions

Q: Does CSRD apply to my transport SME if I'm not directly covered? A: Indirectly, yes. If you are a supplier to a large company subject to CSRD, they will request data on your emissions for their own scope 3 reports. Preparing this data will give you a competitive advantage.

Q: Does CBAM directly concern freight forwarders? A: No, CBAM targets the final importer of goods. However, the freight forwarder can play a key role by providing their importer client with transport-related emissions data, thus becoming a strategic partner for CBAM compliance.

Q: What is the main difficulty in calculating scope 3 emissions in logistics? A: The main difficulty is collecting reliable and granular data from a large number of subcontracted carriers, often disparate in terms of information systems. Standardization of calculation methods (ISO 14083/GLEC) is essential.

Q: How can I concretely reduce CBAM-related transport costs? A: By opting for less emitting transport modes (rail, inland waterways for the last mile), by optimizing container filling, and by choosing more direct routes when possible. Transparency on these emissions will allow importers to make informed choices.

To learn more

  • Discover how to orchestrate your flows and anticipate disruptions: Logistics
  • Calculate your CO₂ emissions according to ISO 14083: ISO 14083 CO₂ Calculator
  • Integrate your AIS/GPS/EDI data with BYOK: BYOK