Transport and ETS2: why the carbon cost of your transport concerns you today

The entry into force of ETS2 in 2028 will structurally change the road transport economy. This European mechanism requires fuel suppliers to buy allowances for each tonne of CO2 emitted, and this cost will be directly reflected in the price of diesel. As a payer, you will pay through your carriers' overloads, between 0.12 and 0.26 €/litre according to carbon price (45 to 100 €/tCO2). The overall impact on European road transport is estimated at EUR 25 billion over the first five years. It is not a marginal subject, and it is not limited to 2028.

But the impact mechanics are not neutral. The simplest and most common scenario is for the carrier to apply a uniform load at the foot of the invoice, calculated on an overall percentage. This approach is convenient. It's also a problem for you.

When the package becomes an unknown

With a uniform foot of invoice, an optimized carrier (new fleet, eco-driving, high load rate) will charge you exactly the same carbon overload as a less efficient competitor. However, emission intensity differences between carriers can range from 30 to 40%. One efficient carrier emits 65 gCO2/t.km where another emits 100. By paying an overload calculated on the average of the sector, you actually subsidize the least virtuous.

The ship's lesson is enlightening. Since 2024, shipping has been subject to ETS1. According to Transport & Environment's maritime report of 2024, in almost 90% of cases, companies charge more than the actual ETS cost, with deviations up to a factor 5 on some routes. These companies have since developed independent audit tools. Road transport will be no exception from 2028 onwards.

The concrete question for your purchasing management is therefore simple: on what basis will the ETS2 overload you will pay be calculated, and will you have the elements to verify it?

A regulatory obligation that works for you

What many do not know is that the legal framework already gives you rights. Since 2013, every carrier is legally required to report the GHG emissions of each service performed, pursuant to article L.1431-3 of the Transportation Code. Since July 2019, companies with more than 50 employees can no longer rely on national generic values: they must use their own real operating data. Since 1 January 2025, breach of this obligation has been administratively punished up to 3,000 € by infringement found.

Your carrier is therefore required to provide you with a specific GHG data calculated according to ISO 14083:2023, per service and within two months. This data, called Level 3 emission intensity, is the only one that can calculate a fair ETS2 cost, reflecting the actual performance of the fleet that completed your transport.

In the absence of these data, the cost is reconstructed on generally unfavourable default values. You lose all visibility about what you actually pay, and any ability to objectively compare your providers.

What ACTE International recommends

Integrate into your tenders and contracts now a clause requiring your carrier's level 3 GHG intensity communication with a documented and auditable method. Explicitly predict that, in the absence of compliant data, you will apply your own reference value to calculate the ETS2 overload, which encourages the carrier to provide its actual data. Structure a mapping of your transport flows by emission intensity, in order to identify providers that expose you to higher than necessary overload. Finally, integrating the carbon criterion into your transport selection criteria: beyond 2028, it is also a driving lever of your Scope 3 CSRD, whose own auditors will check the traceability.

These sites may seem technical, but they are accessible today. The GHG emission measurement and certification tools exist, are operational and provide auditable data in two to three months. What is missing most often is less the technology than the accompaniment to translate these obligations into concrete decisions: what contractual clauses insert, how to qualify its panel of carriers on the carbon criterion, how to integrate these data into its reporting Scope 3.

The contracts you sign today will cover the ETS2 period. The clauses that are now being negotiated will define the rules of the game for the coming years. If you want to take stock of your situation, we are available to discuss it.

Transport Code, articles L.1431-3, L.1431-5, D.1431-1 to D.1431-20. Act No. 2021-1104 of 22 August 2021, Climate and Resilience Act, Article 35. Standard NF EN ISO 14083:2023. Transport & Environment, Marine ETS1 Report, 2024. TK的Blue Agency, Regulatory Obligations and Strategy ETS Road Carriers, March 2026.