Position
Proposal of a regulation of the European Parliament and of the Council on the accounting of greenhouse gas emissions of transport services
CountEmissions EU Long title, example: (Arial, 20 pt, bold) Draft bill/ Government draft Act to Modernise the Structure of Network Charges
Federation of German Industries (BDI)
Date: 15.11.2023
Bundesverband der Deutschen Industrie e.V. Status: DD.MM.YYYY
CountEmissions EU
Background The European Commission plans to implement a uniform methodology for calculating greenhouse gas emissions in freight and passenger transport with the CountEmissions EU regulation. The legislative proposal is intended to create transparency for transport service providers and their customers and generate incentives to reduce emissions. The standards set in CountEmissions EU will apply to all organisations within the EU that report their transportrelated greenhouse gas emissions. Summary The BDI welcomes the efforts of the European Commission for a transparent and harmonised calculation of transport-related greenhouse gas emissions. To provide incentives for climate protection in passenger and freight transport and effectively reflect emissions of logistics chains, a technologyneutral design of the regulatory approach is required across all modes of transport and for all drives. The Commission's well-to-wheel approach fulfils this requirement. The regulation should also reflect the internationality of logistics chains and promote globally harmonised reporting policies on transport-related greenhouse gas emissions. As the EU has already developed a multitude of cross-modal and transport-specific regulations for climate and environmental protection in transport, CountEmissions EU must not be used as a vehicle for further pricing or even banning transport services. A harmonised design and implementation of CountEmissions EU with already existing requirements for reporting greenhouse gas emissions is urgently needed to avoid disproportionate bureaucratic costs and compliance efforts resulting from duplicate structures. Against this background, BDI strongly supports that the legislative proposal is based on the ISO 14083:2023 standard, which is already widely used internationally. This takes account of the international nature of logistics chains, supports companies during implementation and reduces costs. In the further legislative process, the BDI believes that the following priorities should be set: Ensure voluntary of greenhouse gas emissions reporting Reporting on greenhouse gas emissions from transport services should be done on a voluntary basis but according to binding criteria. The Commission's proposal rightly provides for this. Especially for small and medium-
BDI – Federation of the German Industries Member association BUSINESSEUROPE
Lobby register number R000534 Home address Breite Straße 29 10178 Berlin Postal address 11053 Berlin Contact Janek Werner T: +32 27921009 E-mail: j.werner@bdi.eu
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CountEmissions EU
sized enterprises (SMEs), which characterise the market of transport service providers, the calculation and reporting of emissions results in considerable efforts. To achieve the highest possible market penetration, attention should not only be paid to increasing market pressure, but also to a practical design of the requirements for calculating and reporting emissions. This ensures proportionality and comparability. Furthermore, the Commission should develop incentive schemes and guidelines for SMEs to facilitate a broad application of the approach in the market. Maintain focus on greenhouse gas emissions and technologyneutral approach The legislative proposal refers to the ISO 14083:2023 standard as a reference method. It is imperative that its well-to-wheel approach is retained to ensure a technology-open and thus fair comparison of all transport and drive modes. In order to promote climate protection in transport and to contribute to a fast market penetration of the CountEmissions EU standards, the focus on greenhouse gas emissions is correct. Including air pollutants and noise emissions would overload the regulation and counteract the goal of a broad application. Use existing standards, make them transparent and develop them further where necessary We expressly support the fact that the Commission is basing its legislative proposal on ISO 14083:2023, which is already in widespread use internationally. BDI also welcomes the acceptance of primary and secondary data in the proposed regulation, especially standard values from third-party suppliers such as subcontractors. This takes account of the complexity and internationality of logistics chains, supports companies in implementation and reduces costs. However, a mandatory prerequisite for an effective and broadly effective application of the standard is that ISO 14083:2023 is made available to the public free of charge and easily accessible. Otherwise, the regulation risks losing acceptance due to a lack of transparency, especially among the public and SMEs. Nevertheless, the requirements should be further developed and specified in specific areas to provide incentives for climate-friendly action and to ensure that the requirements are implemented in a legally secure and practical manner:
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The regulation should reward the use of electricity from renewable sources, hydrogen and sustainable fuels by allowing crediting and reporting of the corresponding greenhouse gas reductions.
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Priority should be given to the collection and use of primary data, where possible and available, to increase the accuracy of greenhouse gas emissions reporting. When calculating electricity-related greenhouse gas emissions, the market-based approach should be prioritised. The market-based approach determines emissions based on the actual share of renewable energy used rather than referring to the national electricity mix.
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When defining the greenhouse gas reductions of climate protection instruments and developing labelling systems, reference should be made to the provisions in the amendment to the Renewable Energy Directive (RED III) as well as the legislations ReFuelEU Aviation and the FuelEU Maritime.
Ensure coherence with existing EU law A harmonised design and implementation of CountEmissions EU with already existing and upcoming requirements for the reporting of greenhouse gas emissions, the distribution of sustainable fuels on the market, environmental reporting and further EU legislation is urgently needed to avoid disproportionate bureaucratic costs and compliance efforts due to duplicate structures. In this respect, we expressly welcome the acceptance of secondary data. With regard to the Corporate Sustainability Reporting Directive (CSRD), the BDI supports the possibility of using data on transport-related greenhouse gas emissions determined via CountEmissions EU for sustainability reporting. This option should remain available on a voluntary basis. We welcome the European Commission's objective of ensuring a harmonised design of the requirements of CountEmisisons EU with the labelling system for air transport envisaged in ReFuelEU Aviation. In addition, harmonisation with the eco-labelling programme of the European Aviation Safety Agency (EASA EcoLabel), which is currently under development, should be sought to generate synergy gains for transport service providers, customers and authorities. The Green Claims Directive, which is currently being drafted, must also not lead to any duplicate structures. Requirements for reporting and
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calculating transport-related greenhouse gas emissions should be formulated solely by CountEmissions EU and apply uniformly throughout Europe. Develop roadmap for globally harmonised reporting on greenhouse gas emissions As leading industrial centres, Germany and Europe are dependent on efficient and seamless links with other world regions. The European Union should therefore strive for a roadmap for harmonising the calculation and reporting of greenhouse gas emissions at global level to increase transparency in international logistics chains. However, the EU must under no circumstances promote special European routes that could result in European companies being placed at a disadvantage. Instead, the EU should develop joint proposals with international organisations such as the International Civil Aviation Organisation (ICAO) and the International Maritime Organisation (IMO). This goal should thus be explicitly set out in CountEmissions EU.
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About the BDI The Federation of German Industries (BDI) communicates German industries’ interests to the political authorities concerned. She offers strong support for companies in global competition. The BDI has access to a wide-spread network both within Germany and Europe, to all the important markets and to international organizations. The BDI accompanies the capturing of international markets politically. Also, she offers information and politico-economic guidance on all issues relevant to industries. The BDI is the leading organization of German industries and related service providers. She represents 39 inter-trade organizations and more than 100.000 companies with their approximately 8 million employees. Membership is optional. 15 federal representations are advocating industries’ interests on a regional level. Imprint Federation of German Industries (BDI) Breite Straße 29, 10178 Berlin www.bdi.eu T: +49 30 2028-0 German Lobby Register Number: R000534 EU Transparency Register: 1771817758-48 Contact Janek Bruno Werner Senior Manager Mobility and Logistics Phone: +32 27921009 j.werner@bdi.eu Marco Kutscher Senior Manager Mobility and Logistics T: +49 30 20281751 m.kutscher@bdi.eu BDI document number: D1854
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