Do you already have to comply with CountEmissionsEU?

The regulation has been in force since 1 June 2026, but full compliance is phased in: companies get up to 48 months to comply fully, and an EU database of emission factors and a free EU calculation tool for SMEs are still to come. The practical pressure is here now, however, because clients subject to the CSRD are already asking for the CO2 data.

What exactly do clients ask for?

The CO2 figures per shipment and the underlying ISO 14083 methodology, together with an assessment of data quality, including through a free standard form from Topsector Logistiek. Anyone who cannot supply them increasingly comes away empty-handed in a tender.

LogisticsPublished 14 July 20264 min readLast updated 27 July 2026

CountEmissionsEU and ISO 14083: calculating CO2 per shipment with AI, without extra staff

Short answer

CountEmissionsEU has been in force since 1 June 2026 and requires calculation in accordance with EN ISO 14083:2023. The practical pressure, however, already comes from clients who ask for CO2 per shipment. AI can automate the collection and calculation work from fuel, trip and load data, but you remain responsible for the figure you supply.

Since 1 June 2026, the EU regulation CountEmissionsEU has been in force. It prescribes a harmonised method for calculating the greenhouse gas emissions of transport services, based on the EN ISO 14083:2023 standard (European Commission). For most SME hauliers and wholesalers, the issue is not so much the law itself as something far more immediate: large clients are already asking for these CO2 figures per shipment, including through a free standard form from Topsector Logistiek (the Dutch public-private innovation programme for logistics). Anyone who cannot supply them increasingly comes away empty-handed in a tender. In that context, AI is often put forward as the solution. This article takes a sober look at that: what AI can really do here, what the law does and does not ask of you, and how to start without turning it into a project that costs an extra employee.

On this page

What has been in play since 1 June 2026, and what still has runway
Why this is difficult: the data is scattered
What AI does and does not do here
Measure it in euros, and be critical of vendor claims
The human remains responsible for the figure
Where to start in practice

What has been in play since 1 June 2026, and what still has runway

It is important to keep two things apart. The regulation is in force, but full compliance is phased in: companies get up to 48 months to comply fully, an EU database of emission factors will follow within 24 months, and a free EU calculation tool specifically for SMEs (BigMile) within 48 months. So the hard deadline for you personally is not tomorrow.

The practical pressure, however, is here now. Clients subject to the CSRD (Corporate Sustainability Reporting Directive) must report their scope 3 emissions and therefore ask their hauliers for that data. Topsector Logistiek has created a free standard form for this, with which a client requests the CO2 figures and the underlying ISO 14083 methodology, including an assessment of data quality (Supply Chain Magazine). The result: even a small transport company already has the request on its desk, regardless of its own legal deadline.

Why this is difficult: the data is scattered

CountEmissionsEU calls for a door-to-door calculation: emissions are calculated across all legs of a journey and all transport modes in a consistent, comparable and verifiable way (European Commission). That sounds straightforward, but in practice the data you need is scattered across your TMS, the tachograph, the fuel card and sometimes an Excel spreadsheet as well. To arrive at a figure per shipment, it all has to be brought together and allocated in the right way.

That allocation is precisely the hard part. In a Topsector Logistiek pilot on ISO 14083, the core question was how the emissions of a complete vehicle trip should be divided among several shipments that happened to be on the truck together; participants De Rooy and Bricklog had their approach verified by LRQA (Bricklog). That shows the methodology is serious, and that the effort lies in allocating the emissions correctly, not in simple addition.

What AI does and does not do here

Let us be honest about the role of AI. AI changes nothing about the standard or about your actual emissions; it does not calculate away a single kilo of CO2. What it can do is automate the labour-intensive collection and calculation work from your existing systems: combining fuel consumption, trips, load factor and vehicle type, and deriving from them a substantiated emissions figure per customer or shipment according to the ISO 14083 logic. That saves exactly the manual work for which a small company would otherwise have to free up a member of staff.

Nor is compliance the only gain. According to Topsector Logistiek, companies that apply ISO 14083 well can see which customers are both profitable and sustainable, so measuring CO2 also helps to manage profitability. A figure per shipment is therefore not just a mandatory number for a client, but also management information for your own rates and trips.

Measure it in euros, and be critical of vendor claims

Many tools and service providers promising CO2 calculation under ISO 14083 are currently coming onto the market. Their quality, and how well they connect to your own systems, vary widely. So do not ask a vendor for a general savings or accuracy percentage, but for a trial with your own trip and fuel data, so you can see whether the figure is right and whether it matches what your clients ask for.

Make the trade-off explicit too. First establish which of your customers already request CO2 data, how much time it takes you to answer a request manually, and which data you are missing. That is your baseline measurement. Only against that background can you judge whether an investment in software or training pays for itself in time saved and tenders retained.

The human remains responsible for the figure

You must be able to substantiate an emissions figure that you supply to a customer or regulator. An AI that prepares the calculation does not take over that responsibility: you remain liable for what you supply. Good software therefore makes clear which assumptions and which source lie behind a figure, so that you can check and explain it.

In addition, Article 4 of the EU AI Act has applied since 2 February 2025, and since 27 July 2026 it has asked for measures that support the AI literacy of employees who work with AI systems. Since 2 August 2026, the Regulation has been largely applicable, with the Autoriteit Persoonsgegevens (Dutch Data Protection Authority) and the RDI (Dutch Authority for Digital Infrastructure) as the intended Dutch supervisory authorities. For your planners and administrative staff, what matters in practice is that they understand what a calculated figure is based on and where its limits lie. That is exactly what makes a CO2 figure defensible to a critical client.

Where to start in practice

Do not start with a large sustainability project, but with the question of which client will be the first to ask you for CO2 data, and which data you already have for it. Choose a handful of large customers, check whether your fuel and trip data can be brought together, and try to reconstruct emissions per shipment for one month. That immediately gives you the baseline measurement against which you assess any tool or investment.

Our free Practice Scan helps you choose that first step and determine which data you are missing, so that any investment in smart emissions calculation is based on your own situation and on the requirements of your actual clients, not on a general promise.

Sources

Frequently asked questions

Do you already have to comply with CountEmissionsEU?: The regulation has been in force since 1 June 2026, but full compliance is phased in: companies get up to 48 months to comply fully, and an EU database of emission factors and a free EU calculation tool for SMEs are still to come. The practical pressure is here now, however, because clients subject to the CSRD are already asking for the CO2 data.
What exactly do clients ask for?: The CO2 figures per shipment and the underlying ISO 14083 methodology, together with an assessment of data quality, including through a free standard form from Topsector Logistiek. Anyone who cannot supply them increasingly comes away empty-handed in a tender.
Can AI take over the CO2 calculation per shipment?: AI can automate the labour-intensive collection and calculation work: combining fuel consumption, trips, load factor and vehicle type into a substantiated emissions figure per customer or shipment according to the ISO 14083 logic. It changes nothing about the standard or your actual emissions, and you remain responsible for the figure you supply.
Where do you start without extra staff?: Establish which client will be the first to ask you for CO2 data and which data you already have. Choose a handful of large customers, check whether your fuel and trip data can be brought together, and reconstruct emissions per shipment for one month as a baseline measurement.

This article is for information only and is not legal advice. Market prices and schemes mentioned are indications as of the publication date; check current conditions with the official sources. Translated from the Dutch original.