Transport & Logistics

CSRD in Transport & Logistics: What Small Operators Need to Know

Transport sits at the centre of every other industry's Scope 3 footprint. Whenever a manufacturer, retailer, or wholesaler reports under CSRD, your fleet shows up in their Category 4 (upstream transportation) or Category 9 (downstream transportation) figures. Small and growing transport and logistics businesses (SMEs) — hauliers, couriers, warehouse operators, and 3PLs — therefore face a steady flow of customer questionnaires asking for fuel and emissions data.

Under the 2026 Omnibus revision, CSRD applies directly only to undertakings with more than 1,000 employees and more than €450 million net turnover. Most independent transport operators fall below those thresholds and are not in CSRD scope. The Voluntary Sustainability Reporting Standard for SMEs (VSME) is the practical response to customer data requests, and the Omnibus value-chain cap means in-scope clients cannot demand more than VSME requires from sub-1,000-employee suppliers.

Typical Data Requests from Shipping Customers

• Fleet fuel use — diesel, petrol, CNG, electricity in litres or kWh, broken down by vehicle class (HGV, LGV, van, car)
• Scope 1 emissions — direct fleet emissions in tCO₂e, mapped to VSME B3
• Emissions intensity — gCO₂e per tonne-km, per pallet-km, or per parcel — depending on what your customer reports against
• Fleet composition — vehicle ages, Euro emission standards (Euro 5, Euro 6), proportion of EV / HEV / hydrogen vehicles
• Empty-running and route efficiency — empty-running rate (%) and load factor; some customers ask for telematics-derived idling data
• Warehousing — energy use per m² and per pallet stored, mapped to Scope 2
• Subcontracted haulage — proportion of work passed to subcontractors and any data you can pull from them
• Driver workforce — headcount, training hours, safety incidents (VSME B8 and B9)

Two Paths Forward

Your business can pursue full CSRD if legally required, or adopt VSME voluntarily for customer questionnaires. Most small operators should start with VSME Basic (B1–B11), focusing on fuel records (already collected for fuel-card and tax purposes), telematics extracts, and basic workforce data. The intensity ratios — gCO₂e per tonne-km in particular — are usually the single most-asked figure and can be derived directly from fuel cards and load data.

The articles below cover the practical realities — how to extract Scope 1 from fuel-card data, how to calculate tonne-km for mixed fleets, how to handle subcontracted haulage in your disclosure, and how to respond to large-customer questionnaires without rebuilding your data systems.