Freight Scope 3: revised EU ESRS take effect 10 November, apply from 2027

Market Context & Direct Impact

The EU's revised sustainability reporting standards (ESRS) take effect 10 November 2026. Delegated Regulation (EU) 2026/1563 applies to financial years beginning on or after 1 January 2027; undertakings may opt in for 2026. Directive (EU) 2026/470, in force since 18 March 2026 and due for transposition by 19 March 2027, limits mandatory EU reporting to undertakings above €450 million net turnover and 1,000 employees on average. From financial years starting in 2027, value-chain undertakings averaging up to 1,000 employees, inside or outside the EU, may decline CSRD data requests beyond the datapoints of Delegated Regulation (EU) 2026/1560; per Linklaters, the cap does not limit data other EU or national law requires.

CountEmissionsEU governs service-level data. Regulation (EU) 2026/1030 applies from 2 December 2030 to disaggregated emissions of transport services starting or ending in the EU, only where calculated and disclosed by contract, voluntarily or under another law. Aggregated totals, such as CSRD Scope 3 figures, fall outside it. The method is EN ISO 14083:2023, as updated and specified in the regulation. Transport operators, hub operators and data intermediaries calculating these emissions, except small and medium-sized enterprises (SMEs), need verification by a conformity assessment body; SMEs may opt in.

Core Executive Takeaways

• California Leaves Freight OptionalThe U.S. state of California's SB 253 requires Scope 3 reporting from 2027, but a California Air Resources Board (CARB) staff proposal would require only Categories 1, 3, 5, 6 and 7, leaving transportation (Categories 4 and 9) voluntary; first Scope 1 and 2 reports are due 10 November 2026 if the Office of Administrative Law approves CARB's rule, with first-cycle enforcement discretion: assurance is optional, and entities not collecting data when CARB issued its enforcement notice need not report; a U.S. Chamber of Commerce challenge is pending, though SB 253 is not enjoined.
• GHG Protocol Weighs TighteningIts July 2026 plan weighs mandatory last-mile, backhaul and returns emissions in Categories 4 and 9, with the revised standard estimated for Q4 2028.
• IMO Still DividedThe IMO Net-Zero Framework is unadopted after a September session ended "largely divided," per The Maritime Executive; the working group meets again 23–27 November, and the extraordinary session on adoption is set to resume 4 December 2026, subject to confirmation by MEPC 85.

Strategic Playbook

1. 1
   Standardize on ISO 14083

   Request ISO 14083 shipment-level emissions from carriers; note that, for CSRD purposes, providers averaging up to 1,000 employees may decline anything beyond the voluntary standard.

2. 2
   Plan for 2030 verification

   If you are a non-SME carrier, hub operator or data intermediary that calculates and discloses EU transport-service emissions, budget for third-party verification that applies from 2 December 2030.

Filed 06:15 GMT, 10 October 2026, for the third edition of 8 Oct.
As agents only.

Sources

1. Commission Delegated Regulation (EU) 2026/1563 of 3 July 2026 amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain sustainability reporting standardsEUR-Lex, Official Journal of the European Union, published 21 September 2026
2. Directive (EU) 2026/470 of the European Parliament and of the Council of 24 February 2026 amending Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760 as regards certain corporate sustainability reporting requirements and certain corporate sustainability due diligence requirementsEUR-Lex, Official Journal of the European Union, published 26 February 2026
3. Regulation (EU) 2026/1030 of the European Parliament and of the Council of 29 April 2026 on the greenhouse gas emissions accounting of transport servicesEUR-Lex, Official Journal of the European Union, published 12 May 2026
4. CountEmissionsEU: Implications of Regulation (EU) 2026/1030 for transport and logisticsALICE, European Technology Platform for logistics, published 10 September 2026
5. ISO 14083:2023 Greenhouse gases — Quantification and reporting of greenhouse gas emissions arising from transport chain operationsInternational Organization for Standardization (ISO), published 20 March 2023
6. SB 253 Public Workshop: California Corporate Greenhouse Gas Reporting ProgramCalifornia Air Resources Board (CARB), published 21 July 2026
7. California Corporate Greenhouse Gas Reporting: Guidance for SB 253 2026 Reporting SubmittalsCalifornia Air Resources Board (CARB), published 1 September 2026
8. Consolidated Standard Development Plan, Version 2.0Greenhouse Gas Protocol, published 29 July 2026
9. MEPC 84th sessionInternational Maritime Organization (IMO)
10. IMO Concludes Next Round of Net-Zero Discussions Still DividedThe Maritime Executive, published 4 September 2026
11. CSRD Update: EU Member States Continue to Move Forward on Omnibus TranspositionRopes & Gray, published 27 June 2026
12. EU CSRD: revised ESRS and voluntary reporting standard are published in the Official Journal of the EULinklaters, published 21 September 2026
13. California Climate Disclosure Laws — CARB Finalizes Its Initial Rulemaking, Resets the 2026 Deadline, and Previews the 2027 FrameworkMayer Brown, published 5 August 2026
14. California climate disclosure regulations: SB 253 and SB 261Baker Tilly, published 2 July 2026

Claims ledger: 19 facts and where each comes from

• Commission Delegated Regulation (EU) 2026/1563 of 3 July 2026, amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain sustainability reporting standards, was published in the Official Journal L series on 21.9.2026. Article 3: 'This Regulation shall enter into force on 10 November 2026. It shall apply to the financial years beginning on or after 1 January 2027.'¹
• Delegated Regulation (EU) 2026/1563, Article 2: 'For the financial years starting between 1 January 2026 and 31 December 2026', undertakings within the scope of Delegated Regulation (EU) 2023/2772 may apply the existing standards, the existing standards with listed reliefs, or the sustainability reporting standards set out in Annex I to this Regulation, and must state which version they apply. Linklaters, 21 September 2026: for financial years starting in 2026 undertakings may choose 'the Revised ESRS in full'.¹¹²
• Delegated Regulation (EU) 2026/1563, ESRS 1 paragraph 66: the undertaking 'shall take account of the fact that the upper limit (value-chain cap) of sustainability information which may be required from the protected undertakings in its value chain only comprises the datapoints specified in Annex II to Commission Delegated Regulation (EU) 2026/1560'; 'This limitation also applies to non-EU undertakings in the upstream and downstream value chain of the reporting undertaking.'¹
• Linklaters, 21 September 2026: the value chain cap 'applies from financial years beginning on or after 1 January 2027', covers 'undertakings in their value chain with an average of 1,000 employees or fewer in the preceding financial year', and 'it does not restrict requests needed to comply with other EU or national law obligations.'¹²
• Directive (EU) 2026/470 of 24 February 2026, published in the Official Journal on 26.2.2026, replaces Article 19a(1) of Directive 2013/34/EU so that sustainability reporting applies to 'Undertakings which, on their balance sheet dates, exceed a net turnover of EUR 450 000 000 and an average number of 1 000 employees during the financial year' (that is, EUR 450 million and 1,000 employees).²
• Directive (EU) 2026/470, new Article 19a(3) of Directive 2013/34/EU: a 'protected undertaking' is one that 'does not exceed, on its balance sheet date, an average number of 1 000 employees during the preceding financial year' (1,000 employees) and is in the value chain of a reporting undertaking; 'Protected undertakings shall have the right to decline to provide information exceeding the information specified in the voluntary standards in response to a request made for the purpose of sustainability reporting as required by this Directive.'²
• Ropes & Gray, 27 June 2026: 'The Omnibus I "contents" directive took effect on March 18' (2026); 'Countries are required to transpose it into national law by March 19, 2027.'¹¹
• Regulation (EU) 2026/1030 of 29 April 2026 on the greenhouse gas emissions accounting of transport services (CountEmissionsEU), Official Journal date 12.5.2026. Article 1(1): it 'establishes rules for the greenhouse gas emissions accounting of transport services that start or end on the Union territory, where disaggregated information on those emissions is calculated and disclosed, on a contractual or voluntary basis for commercial purposes, or where such calculation and disclosure are required by applicable Union or national law.'³
• Regulation (EU) 2026/1030, recital 11: calculation and disclosure 'should be carried out in a disaggregated manner, at the level of transport services'; aggregated reporting, including sustainability reporting and environmental accounts under other Union acts, falls outside its scope, although information gathered under the Regulation may feed such reports where methodologies and data are sufficiently compatible.³
• Regulation (EU) 2026/1030, Article 3(1): greenhouse gas emissions from transport services 'shall be calculated on the basis of the common methodology within the meaning of EN ISO 14083:2023 – Greenhouse gases – Quantification and reporting of greenhouse gas emissions arising from transport chain operations' (the 'EN ISO standard'), 'in its updated version, as specified in this Chapter'.³
• Regulation (EU) 2026/1030, Article 12(1)-(2): compliance of output data 'shall be verified by a conformity assessment body'; this applies 'to transport and hub entities and data intermediaries which calculate emissions, with the exception of SMEs'; 'SMEs may undergo a verification pursuant to this Regulation upon their request.' Article 1(2) lists transport operators, transport service organisers and hub operators, and data intermediaries among the entities covered.³
• Regulation (EU) 2026/1030, Article 20: 'This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union. It shall apply from 2 December 2030', with certain listed provisions applying from entry into force. ALICE (ETP-Logistics), 10 September 2026: 'The Regulation was adopted on 29 April 2026 and entered into force on 1 June 2026.'³⁴
• ISO 14083:2023, 'Greenhouse gases — Quantification and reporting of greenhouse gas emissions arising from transport chain operations', edition 1, status 'Published', stage 60.60, publication date 2023-03-20.⁵
• CARB, SB 253 public workshop, 21 July 2026: slide 4, citing SB 253 (HSC § 38532), lists 'Scope 1, 2 and 3 in 2027+'; slide 26: 'staff propose requiring reporting on the five most commonly-reported categories, starting in 2027'; slides 27-28 'Proposed Scope 3 Emissions Reporting': reporting entities shall disclose Scope 3 GHG emissions for Category 1 (Purchased Goods and Services), Category 3 (Fuel and Energy Related Activities), Category 5 (Waste Generated During Operations), Category 6 (Business Travel) and Category 7 (Employee Commuting) beginning in 2027; reporting entities may voluntarily disclose Categories 2, 4 (Upstream Transportation and Distribution), 8, 9 (Downstream Transportation and Distribution), 10, 11, 12, 13, 14 and 15.⁶
• CARB, 'Guidance for SB 253 2026 Reporting Submittals', 1 September 2026: refers to 'the November 10, 2026, GHG emissions reporting deadline' for Scope 1 and Scope 2 reports under CARB's regulation 'if approved by the Office of Administrative Law'; 'Entities that were not collecting data or were not planning to collect data at the time the Enforcement Notice was issued' 'are not expected to submit Scope 1 and 2 reporting data, for this first reporting cycle in 2026 only'; 'CARB will accept submissions whether or not assurance has been obtained for the 2026 cycle.'⁷
• Baker Tilly, updated 2 July 2026: 'The U.S. Chamber of Commerce and other business groups have challenged SB 253 and SB 261'; 'SB 253 is unaffected by this injunction and remains fully in effect.' Mayer Brown, 5 August 2026: 'The Court heard oral argument on January 9, 2026 in the Chamber of Commerce appeal, and a merits decision is awaited'; 'SB 253 is unaffected by the preliminary injunction and remains in effect.'¹³¹⁴
• GHG Protocol Consolidated Standard Development Plan, Version 2.0, 29 July 2026: the consolidated Corporate Standard (Version 3.0) integrates the Corporate Standard, Scope 2 Guidance, Scope 3 Standard and Actions and Market Instruments outputs; milestones 'Consolidated draft standard for public consultation (estimated Q2 2027)' and 'Published revised standard (estimated Q4 2028)'. Under Scope 3 'Transportation and distribution (Category 4 and Category 9)': 'Consider requiring the inclusion of "last-mile", back hauling, and returns (currently optional)'.⁸
• IMO, MEPC 84th session summary (session held 27 April to 1 May 2026; page undated): the Committee agreed to establish an intersessional Working Group on the Net-Zero Framework; 'Two inter-sessional meetings will be scheduled (1 to 4 September and 23 to 27 November)'; MEPC 85 is scheduled for 30 November to 3 December; the Committee 'will resume its Second Extraordinary Session on Friday 4 December 2026', subject to confirmation by MEPC 85.⁹
• The Maritime Executive, 4 September 2026: 'The International Maritime Organization completed its next working group session discussing efforts to reach a decarbonization approach still largely divided, and is now aiming for a potential resolution by the end of 2026.'¹⁰

Every figure above was read from its source on the day of filing and re-checked against that source by a separate fact-check before publication. Found an error? Tell the desk.