The Corporate Sustainability Reporting Directive (CSRD) has turned freight emissions from a voluntary ESG talking point into a regulated, audited disclosure. For thousands of European shippers, manufacturers, and retailers, the transport of their goods is one of the largest lines in their Scope 3 footprint — and from now on it has to be measured, reported, and externally assured. The problem is that most of that data sits with carriers, not with the reporting company.
This guide explains exactly what CSRD requires for freight, who has to report and when, which transport emissions fall into scope, and how to collect audit-ready data. The reporting standard is unforgiving about estimates, which is why shipment-level carbon visibility — primary emissions calculated from real telematics data rather than industry averages — has moved from a nice-to-have to a compliance requirement.
What CSRD Actually Is
CSRD is the EU directive that replaced the older Non-Financial Reporting Directive (NFRD). It entered into force in January 2023 and dramatically widens both the number of companies that must report on sustainability and the depth of what they must disclose. Reporting follows the European Sustainability Reporting Standards (ESRS), and — critically — it must be filed in the management report alongside financial accounts and subjected to external assurance.
Two principles make CSRD different from the voluntary reporting that came before it:
- Double materiality. Companies report both how sustainability issues affect the business (financial materiality) and how the business affects people and the environment (impact materiality). Freight emissions sit squarely in the second category.
- Mandatory assurance. Disclosures require at least limited assurance from an auditor. A spreadsheet of self-declared averages will not survive that review.
Who Has to Report, and When
CSRD is phased in by company size. The original timeline brought roughly 50,000 EU companies into scope across three waves:
| Wave | Who | First report (original) |
|---|---|---|
| Wave 1 | Large public-interest entities already under NFRD (>500 employees) | FY2024, published 2025 |
| Wave 2 | Other large companies meeting 2 of 3: >250 employees, >€50M turnover, >€25M balance sheet | FY2025, published 2026 |
| Wave 3 | Listed SMEs | FY2026, published 2027 |
The Omnibus simplification package changes this. In 2025 the EU adopted a “stop-the-clock” directive that postponed the reporting obligations for Wave 2 and Wave 3 companies by two years, pushing their first reports to FY2027 and FY2028 respectively. A broader Omnibus proposal — which would raise the main threshold to companies with more than 1,000 employees and narrow Scope 3 data requirements — was still in negotiation between the Parliament and Council as this guide was written. The direction of travel is fewer companies and more proportionate data demands, but the core obligation to report climate impact, including transport, remains intact for large companies.
Even if your company falls out of direct scope under the revised thresholds, you are not off the hook: large customers subject to CSRD will require freight emissions data from you as a supplier. “We can’t report it” increasingly means “we can’t sell to them.”
Where Freight Sits: Scope 3 Categories 4 and 9
Under the GHG Protocol that ESRS E1 (Climate Change) builds on, transport emissions are almost always Scope 3 — indirect emissions in the value chain:
- Category 4 — Upstream transportation and distribution: the movement of purchased goods into and between your facilities, plus outbound logistics paid for by you.
- Category 9 — Downstream transportation and distribution: movement of sold goods that is paid for by others.
For most manufacturers and retailers, Category 4 freight is one of the three largest Scope 3 buckets, behind only purchased goods and the use of sold products. Because road freight dominates intra-European movement, it is also the most data-intensive to quantify accurately — every lane, carrier, vehicle class, load factor, and empty leg changes the number. Reducing those movements is therefore both an emissions and a reporting win, which is why cutting empty miles shows up in almost every credible decarbonisation plan.
How Freight Emissions Must Be Calculated
ESRS E1 does not let you invent a methodology. Freight reporting is expected to follow recognised standards:
- ISO 14083 (2023) — the first global standard for quantifying and reporting GHG emissions from transport chain operations. It now supersedes the older EN 16258 and is the methodology auditors increasingly expect.
- The GLEC Framework — developed by the Smart Freight Centre and fully aligned with ISO 14083. It is the de facto operational standard multinationals already use, expressing intensity in grams of CO₂e per tonne-kilometre.
The standards distinguish between default data (industry-average emission factors) and primary data (measured from the actual vehicles that moved your freight). Default data is allowed as a starting point, but assurance providers and customers are pushing hard toward primary data because averages hide exactly the inefficiencies — low load factors, deadhead running, congested routing — that a real fleet exhibits. A precise number requires fuel or distance data from the trucks themselves, which is why telematics-grade visibility is becoming the backbone of CSRD-ready freight reporting.
The Practical Data Problem — and How to Solve It
The recurring headache is structural: the reporting company rarely operates the trucks. In a fragmented European carrier market where most hauliers run fewer than ten vehicles, a shipper moving 500 loads a month may work with dozens of carriers, each with a different (or no) telematics system. Collecting consistent, shipment-level emissions data across that base is the single hardest part of CSRD freight compliance.
A workable approach has four stages:
- Map the data. Identify which carriers can already supply primary fuel or distance data and which cannot.
- Aggregate at the shipment level. Pull telematics and trip data from every carrier into one layer so each consignment carries its own emissions value, not a portfolio average.
- Calculate to ISO 14083 / GLEC. Apply the standard consistently so the output is audit-defensible.
- Report and reduce. Feed the same data into operational decisions — routing, load consolidation, modal shift — so reporting drives reduction instead of just documenting it.
This is where digital freight platforms earn their place in the compliance stack: by aggregating carrier telematics into per-shipment carbon data, they turn an annual reporting scramble into a continuous, decision-grade feed. The same dataset that satisfies the auditor also surfaces the decarbonisation strategies that actually move the number — and it complements the broader operational and regulatory levers covered in our guide to sustainable freight.
What Happens If You Get It Wrong
CSRD does not set a single EU-wide fine; enforcement and penalties are delegated to member states, and they vary widely — from administrative fines and “name and shame” publication to, in some jurisdictions, director liability. But the commercial risk usually bites before the regulatory one: failing assurance delays the entire annual report, and supplier scorecards that demand verified freight emissions will quietly route volume to competitors who can produce the data. Rising carbon costs add to the pressure, with mechanisms such as the ETS2 carbon price on road transport fuel arriving from 2027.
Frequently Asked Questions
Is freight always Scope 3 under CSRD? For the company whose goods are being moved, yes — almost always Scope 3 Category 4 (upstream) or Category 9 (downstream). It only becomes Scope 1 if you own and operate the trucks yourself.
Can we use industry-average emission factors? Yes, as a starting point, but primary data measured from the vehicles that actually carried your freight is increasingly expected by auditors and demanded by customers. Averages tend to understate the impact of empty running and low load factors.
Did the Omnibus package cancel CSRD? No. It delayed reporting for the second and third waves by two years and proposed raising thresholds and trimming Scope 3 data requirements, but the obligation for large companies to report climate impact — including transport emissions — remains.
Which standard should we calculate to? ISO 14083, in practice via the GLEC Framework, which is fully aligned with it. EN 16258 has effectively been superseded.
We are an SME below the threshold — does CSRD affect us? Often indirectly. CSRD-bound customers will request your freight emissions data as part of their own Scope 3 reporting, so the practical requirement flows down the supply chain regardless of your own filing obligation.
Written by Tamas Domonkos, logistics operations lead at TrucksOnTheMap. Sources include the EU Corporate Sustainability Reporting Directive and ESRS, the GHG Protocol Corporate Value Chain (Scope 3) Standard, ISO 14083 (2023), and the GLEC Framework (Smart Freight Centre).
