Nicole Mooney, Accuvio

On 1 October 2013, Mandatory Disclosure Requirements for Transport Services came into force in France, through the introduction of Article 14 of the French Decree no. 2011-1336 a device of article L1431-3 of the French transport code. Mandatory Reporting had been previously introduced through the passing of Grenelle Law II in June, 2012, requiring companies to report their emissions every three years in their Annual Reports. This new article establishes the principle of CO2 information disclosure from transport services, requiring service providers to inform service users (beneficiaries) of their carbon dioxide emissions (freight and passenger) during each transport service. The disclosure requirement affects all transport activities departing from or travelling to a location in France.

To comply with this new and existing legislation, organisations need to invest time and effort in greenhouse gas (GHG) accounting and reporting. However, due to the lack of knowledge and understanding of the subject many voluntary and mandatory organisations can find it daunting. To successfully report on your GHG emissions, there are a number of important steps to consider.

1. Measuring and Methodology

First the organisation must decide what to measure and how

  • What is the organisational boundary? Define what emissions to take responsibility for using the financial, equity or control approach. Mandatory Transport disclosure takes into account the carbon dioxide emissions of all operations making up the operating phase and upstream phase. This can include scope one two and three emissions.
  • Identify the appropriate methodology? Recommended guideline for Mandatory Transport Disclosure: CO2 information for transport services, Application of Article L. 1431-3 of the French transport code, Methodology guide by ADEME (Environment and Energy Management Agency) and the MEDDE (French Ministry of ecology, Sustainable development and energy) in consultation with OEET (Observatory for Energy and Environment in Transport).

2. Data collection

This is perhaps the hardest part of GHG accounting and reporting as it can be difficult to gather quality data from across the organisation.

  • The organisation must define what data are required for example electricity and natural gas in kWh, road transport- litres of petrol and the frequency of this information (daily, month, yearly), it will be different for each transport activity.
  • Depending on the size of the organisation there may be a need for investment in a data collection system or update the previous system. This will include thinking about sustainability software.

3. Calculation and validation

Once the relevant data is collected from the agreed areas, the data is converted into carbon emissions using emissions factors (conversion factors) established by governmental or environmental organisations. For Frances a set of emission factors have been set out in the methodology guidelines under French Decree no. 2011-1336 of 24 October 2011. The data can then be validated by third party organisation; this is optional depending on the organisations legislation requirements.

4. Reporting and Disclosure

After the data collection and calculation is completed the companies affected must decide on the manner of disclosure to the beneficiary. The service provider must provide the beneficiary with the quantity of carbon dioxide emitted for all upstream and operating phases in kilograms (kg), grams (g) or tonnes (t) of CO2.

The possible methods to communicate this information are numerous and must be adapted to suit the nature of the profession (transport of passengers or goods) and the relationship with the customer (individual customers for passenger transport, or professional customers or shippers). The approved methodology states "By means of any document issued or made available to the beneficiary on real or dematerialised media", for example:

  • By email, SMS, via an electronic link, a notice on the ticket sales website, a display panel at the point of sale (ticket office), information on the issued ticket, or even in some cases verbally is possible.

All figures and statements must be supported with traceable accurate reference documents ensuring the data and calculations are auditable.

  • ManageCO2 is an innovative sustainability software solution purposely built for Greenhouse Gas Emissions, Sustainability and Energy management. To learn more about Greenhouse Gas Disclosure and Mandatory Carbon Reporting visit the ManageCO2 website at or contact them at
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