There was one final obstacle to opening up to the need for precise measurement of GHG emissions from transport.

Since October1, 2013, decree 2011-1336 of the Grenelle 2 Law has required goods carriers to systematically communicate to their principals the volume of Greenhouse Gas (GHG) emissions generated by the transport operations entrusted to them, at least once every two months, and by any means at their convenience,


Unfortunately, the Grenelle law "forgot" that companies had to take this information into account.


Indeed, the GHG reporting obligations for eligible companies (>500p or >€100M sales) were limited to emissions from scopes 1 and 2 (direct and indirect emissions from energy consumption) and excluded scope 3, which includes emissions from the company's upstream and downstream transport operations.


In fact, most shippers quietly continued to analyze transport offers solely on the basis of the price/time ratio offered, and very few were interested in the actual environmental performance of their choice of transport, or contented themselves with average values that didn't differentiate them, but made them look good.

FINALLY!!! a new decree n° 2022-982

Since July 2022, new regulatory requirements for reporting, defining and demonstrating companies' low-carbon trajectory (transition plan), have been imposed by a new decree n° 2022-982 and with immediate application.

  • While the Scope 3 requirement for companies with more than 500 employees was long-awaited, the "transition plan" is now extremely rigorous.

In fact, it requires a description of the actions implemented in the years following the previous assessment, as well as the results obtained and the overall volume of greenhouse gas emission reductions expected for direct and indirect emissions as a result of the planned actions.

A plan that puts real pressure on companies and imposes :

  • embark on a low-carbon trajectory
  • also calculate their scope 3 emissions, including those of their transport service providers

"For scope 3, just because you make savings on your purchases from an economic point of view doesn't mean you automatically reduce your emissions. The decree of July1 will change this "good price at any price" attitude. This good price will have to be weighted by the lowest possible carbon weight".


Tax bonus

Beyond this regulatory aspect, this reporting action is also imperative with a view (over the next 2 or 3 years) to preparing companies for the introduction of a "carbon tax base" (transcription of the extension of carbon quotas to transport and real estate, and the introduction of a future carbon tax on imports decided in recent months) for all companies.

This wishful thinking on the part of CSR and SD directors for a less carbon-intensive transport chain...can be transformed into reality thanks to CFOs, who are fast approaching this new "carbon tax base" of carbon quotas and import carbon tax, which is likely to weigh down their accounts by hundreds or millions of euros as early as 2024, and by 2025 at the latest.





JORF n°0153 of July 3, 2022 Text n° 47