How to carry out a road haulier's Bilan Carbone®

The request rarely comes from conviction: a client asks for the emissions of a transported consignment, a tender scores the carbon criterion, a customer subject to CSRD sends its supplier questionnaire. A haulier's Bilan Carbone® answers all 3 situations, with one feature that simplifies the work: most emissions come from the fuel tank, so most of the calculation comes from fuel invoices.

This guide follows the order of actual work: identify the significant sources, gather figures already available in operations, deal with the 2 stumbling blocks (subcontracting and empty running), quantify costs and funding in 2026, then tackle reduction through the 5 levers that matter. Obligations and deadlines come last: they are easier to understand once the method is clear.

1What are a haulier's main emissions sources?

Before calculating anything, you need to identify the sources. A haulier operating its own vehicles has an unusual carbon accounting profile: direct emissions dominate, whereas most companies see most of their footprint at their suppliers. The assessment is structured around 3 sources.

Fleet diesel: 60 to 80% of the total

For a hire-or-reward haulier using its own lorries, fuel accounts for 60 to 80% of emissions. A 40-tonne articulated vehicle consumes 28 to 34 litres per 100 km over long distances, and each litre of diesel emits 3.10 kgCO2e once production is counted (the most common calculation error, detailed below). A tractor unit travelling 100,000 km a year therefore accounts for around 90 to 105 tCO2e on its own.

In Bilan Carbone® nomenclature, these direct emissions form scope 1. It includes a second contributor, inconspicuous on invoices but substantial in the assessment: refrigerants.

Refrigeration: refrigerated lorries and warehouses, the unmonitored source

Refrigeration emits through 2 channels. First, warehouse electricity: a below-zero cold room consumes several times as much as a dry warehouse of the same area, and this consumption enters scope 2 of the assessment. Second, refrigerant leaks: semi-trailer refrigeration units and fixed installations lose a fraction of their charge every year, which the refrigeration technician tops up during maintenance.

Electricity consumption is shown on invoices. Leaks are shown in the refrigeration technician's service records, a document the company already holds and almost nobody thinks to retrieve for the assessment. For a refrigerated fleet, forgetting them means ignoring dozens of tCO2e.

Subcontracted hauliers: up to 90% of a freight forwarder's assessment

Everything running for the company without belonging to it (other hauliers, chartered transport, vehicle hire with a driver) enters the assessment as indirect emissions, scope 3. For a freight forwarder without its own fleet, this source represents 70 to 90% of the total. The boundary follows the activity sold, whatever the vehicle registration: a haulier subcontracting 30% of its consignments counts that 30% alongside its own lorries.

2Everything starts with invoices: where to find figures in the company

Collection is the shortest part of the work for a haulier: the sector already measures everything costly, and what costs money, led by fuel, is also what emits. The document list fits on one page.

Fuel invoices and cards do most of the work

• Fuel cards and supplier invoices provide annual diesel volumes per vehicle, to the litre: this is the assessment's central data.
• On-board IT provides actual consumption per vehicle and driver, useful for moving from an overall assessment to management.
• The TMS and tachograph provide kilometres travelled, loaded and empty, by operating route.
• Site energy invoices detail warehouse electricity and gas month by month, capturing refrigeration seasonality.

A haulage SME tracking consumption through fuel cards has already gathered, without knowing it, the basis for 60 to 80% of its assessment. This is a real advantage over other sectors, where collecting activity data takes up most of the assignment.

Warehouse electricity and refrigeration technician top-ups

For sites, 2 documents suffice: electricity invoices per warehouse, and the refrigeration equipment service register, already required by F-Gas regulation. Every kilogram of refrigerant topped up is recorded there: this directly measures the year's leaks.

A litre of diesel emits 3.10 kgCO2e, including production

The emission factor is the most common error in in-house calculations. Burning a litre of B7 diesel emits 2.49 kgCO2e at the exhaust, but Bilan Carbone® also counts fuel extraction, refining and transport: the full factor is 3.10 kgCO2e per litre in ADEME's Base Empreinte. Using the wrong factor underestimates the main source by 20%, an error an auditor or well-equipped customer spots immediately.

For warehouse electricity, the French mix is favourable: around 0.05 kgCO2e per kWh, among the lowest in Europe. In France, refrigerant leaks therefore account for the largest share of refrigeration's footprint, much more than electricity consumption.

3Subcontracted lorries and empty journeys: how to count them

These 2 topics are where rushed calculations most often go wrong: vehicles run for the company by other hauliers, and vehicles running without a load.

What to count when using other hauliers

The subcontractor has a legal obligation to provide CO2 information for its services (see the end of the guide): the first step is therefore to request it. Without a response, regulation provides default values by vehicle type, published in Base Empreinte. These values are deliberately conservative: staying with default estimates often overestimates the footprint, and therefore the figure subsequently passed to customers.

The approach is progressive, with 4 levels of precision: default values, averages by operating route, subcontractor fleet data, actual measurement per service. Moving up a level is negotiated when renewing the contract: a consumption data transmission clause usually suffices.

17.5% of kilometres are driven empty: they count too

In France, 17.5% of heavy goods vehicle kilometres are driven empty (2024 TRM survey). These kilometres emit without transporting: the method allocates them to the loaded journeys they enable. Ignoring them improves the apparent footprint per tonne delivered by 15 to 20%, distorting the figure passed to customers and failing an audit.

The figure customers request: CO₂ per tonne transported and per kilometre

The annual total in tCO2e serves internal management and statutory BEGES. Customers request a comparable ratio: grams or kilograms of CO2e per tonne transported and per kilometre (the tonne-kilometre, t.km), an order of magnitude allowing comparison between 2 providers. This ratio enters their own assessments and tender grids.

To place the result in context: the 2026 statutory default value for a 34 to 40-tonne articulated vehicle is 0.0875 kgCO2e per t.km, now including vehicle manufacturing. A well-loaded, well-driven fleet falls noticeably below this benchmark, and can prove it: that is the selling point clients seek.

4How much it costs, and what funding is available

A haulier's Bilan Carbone® budget is narrower than average, because collection is quicker. There remains the assignment's cost and, against it, funding that changed considerably between 2024 and 2026: here is the up-to-date picture.

The cost of an assessment for a haulage SME

For a single-site SME with its own fleet, budget €8,000 to €12,000 excl. VAT; with several sites, refrigeration and significant subcontracting, more like €12,000 to €20,000 excl. VAT. Pricing mechanisms deserve a whole guide: how much Bilan Carbone® costs. A sector-specific feature: telematics reduces internal time involved, often 2 to 4 days spread across the assignment.

Diag Décarbon'Action, 2026 version: 12 expert days, €6,000 payable

The Bpifrance-ADEME scheme was suspended in late 2024 then relaunched in May 2025 with unified pricing: a fixed €10,000 excl. VAT, subsidised at 40%, leaving €6,000 excl. VAT payable regardless of headcount. It funds 12 days from an approved expert over a maximum of 10 months, including scopes 1, 2 and 3 and an action plan. Conditions: fewer than 500 employees, at least 1 year of activity, no GHG assessment in the past 5 years. Full instructions appear in our Diag Décarbon'Action guide.

What closed in late 2025, what remains open in 2026

Haulage funding has changed: the Objectif CO2 approach ended on 31 December 2025, as did the EVE programme, and with them free support; AFNOR Certification takes over the labels on a paid basis. Several funding routes remain open:

• Transport CEE (6th period, 2026-2030) funds eco-driving training (measure TRA-SE-101) and on-board telematics (TRA-EQ-103) through energy suppliers, with an agreement to sign before the operation.
• Measure TRA-EQ-129, enhanced since 1 June 2026, brings support for purchasing an electric heavy goods vehicle up to an order of magnitude of €100k for a tractor unit, subject to vehicle assembly in Europe.
• Enhanced tax depreciation (Article 39 decies A of the General Tax Code, extended to late 2030) allows up to 60% additional deduction on a CNG or B100 rigid lorry, and 115% of the additional cost for an electric vehicle.
• Diag Décarbon'Action described above funds measurement, and can be combined with other transition funding.

5The 5 reduction levers that matter

Once the assessment is established, the next step is choosing where to start. The levers below are ranked by accessibility: the first require no equipment investment.

What costs almost nothing: loading, empty running, driving

The first lever is organisational: fill lorries and limit empty returns through freight exchanges, pooling and renegotiating transport plans. Every loading percentage point gained reduces the footprint per tonne delivered without changing the fleet. The second is human: eco-driving supported by telematics maintains 5 to 10% lower consumption over time when monitored, and both training and equipment qualify for CEE. The third is technical: tyre management, speed limiting, refrigeration unit maintenance.

Alternative fuels: B100, HVO, bio-CNG

Some levers require no, or almost no, change of lorry. B100 (rapeseed, compatible diesel engines, restricted to fleets with their own tank) emits 61% less than diesel in life cycle assessment, and its reduced excise rate was maintained by the 2026 Finance Act. HVO avoids up to 82% of emissions when made from used oils, with supply traceability a real point of attention. Bio-CNG reaches -79% for fleets already equipped for CNG. These factors come from Base Empreinte and can therefore be quoted in tenders.

Electric vehicles, now eligible for funding for heavy goods vehicles

The electric heavy goods vehicle's economic equation changed in 2026: between the enhanced CEE measure TRA-EQ-129 (up to an order of magnitude of €100k per tractor unit) and enhanced tax depreciation at 115% of the additional cost, the price gap with diesel closes for intensive uses. The first profitable uses are regular shuttles and high-mileage regional distribution, returning to the depot each evening to charge. Long-distance use will follow with the charging network.

6What lies ahead: obligations and deadlines to 2040

A haulier's Bilan Carbone® is not conducted in a regulatory vacuum: 3 frameworks are tightening in parallel, and 2 already apply.

CO₂ information is already mandatory, with penalties since 2025

It is the sector's most overlooked obligation: since 1 October 2013, every transport provider must communicate CO2 information for services whose origin and destination are in France (Article L.1431-3 of the Transport Code). Long without penalties, it has carried a €3,000 fine since 1 January 2025. The calculation accepts 4 levels of precision, from default values to actual measurement: a Bilan Carbone® provides the data needed to reach higher levels, performing better than defaults.

A single European method: ISO 14083 and CountEmissions EU

The EU CountEmissions EU Regulation, in force since 1 June 2026, harmonises transport emissions calculation around ISO 14083. Full application is scheduled for late 2030: a company publishing a transport emissions figure will then have to follow this common method. Customers are not waiting for this deadline: reporting platforms and purchasing grids are already converging on this format, and a haulier able to provide kgCO2e per t.km calculated under ISO 14083 gains a head start.

Low-emission zones retained, manufacturer standards tightened: the renewal equation

For road access, the abolition of low-emission zones voted for in spring 2026 was struck down by the Constitutional Council on 21 May 2026: the 25 existing zones remain, with Crit'Air 3 restrictions in force in Greater Paris and Lyon and a €135 fine for a heavy goods vehicle. For equipment, EU Regulation 2024/1610 requires manufacturers to reduce new lorry emissions by 45% in 2030, 65% in 2035 and 90% in 2040: the electric range is expanding, and the resale value of new diesel vehicles may suffer. Anticipating renewal therefore belongs as much in the reduction plan as the investment plan, as detailed in our guide to reducing your Bilan Carbone®.

7Key takeaways

A haulier's Bilan Carbone® is among the quickest to prepare, because the data already exists in operations, and among the most commercially useful, because customers request it.

• Diesel accounts for 60 to 80% of an own fleet's emissions, calculated at 3.10 kgCO2e per litre, including production.
• Fuel cards, site energy invoices and refrigeration technician records cover most collection.
• The figure's credibility hinges on subcontracting and empty running: 17.5% of kilometres are driven empty and allocated to loaded journeys.
• Customers expect a ratio in kgCO2e per tonne-kilometre, calculated under ISO 14083, the standard adopted by the EU CountEmissions EU Regulation.
• In 2026, measurement is funded: Diag Décarbon'Action at €6,000 excl. VAT payable, CEE for eco-driving and telematics, an enhanced measure for electric vehicles.

The logical next step depends on your situation: check whether you are subject to statutory BEGES, scope the budget with our price guide, or tackle the reduction plan directly.

Further resources

Frequently asked questions

1How much CO₂ does a 40-tonne lorry emit per kilometre?

Around 0.9 to 1.1 kgCO2e per loaded kilometre, depending on actual consumption (28 to 34 L/100 km) and the full factor of 3.10 kgCO2e per litre of diesel. Expressed per service delivered, the 2026 statutory default value for a 34-40 t articulated vehicle is 0.0875 kgCO2e per tonne-kilometre.

2Is a haulier required to carry out a Bilan Carbone®?

Statutory BEGES applies only to companies with more than 500 employees, every 4 years. However, CO2 information per service has been mandatory for every haulier since 2013 (Article L.1431-3 of the Transport Code), with penalties of up to €3,000 since 1 January 2025. A voluntary Bilan Carbone® remains the most reliable way to produce these figures properly.

3What is the difference between mandatory GHG information and Bilan Carbone®?

GHG information is a figure per service, communicated to the customer and calculable using default values. Bilan Carbone® covers the entire organisation, scopes 1, 2 and 3, and underpins the reduction plan. The two feed each other: a well-prepared assessment moves from statutory defaults to actual data, more favourable for a well-managed fleet.

4How much does a Bilan Carbone® cost for a haulage SME?

Between €8,000 and €12,000 excl. VAT for a single-site SME with its own fleet, €12,000 to €20,000 excl. VAT with several sites, refrigeration and substantial subcontracting. Diag Décarbon'Action reduces the amount payable to €6,000 excl. VAT for 12 days of support, subject to eligibility conditions (fewer than 500 employees, no GHG assessment in the past 5 years).

5How is subcontracted transport counted in the assessment?

It enters scope 3, covering indirect emissions. The first step is to request CO2 information from the subcontractor, which has a legal obligation to provide it, and otherwise apply Base Empreinte's statutory default values. Moving from defaults to the other haulier's actual data refines the assessment and, most often, improves it.

6Does B100 really reduce emissions?

Yes, by around 61% compared with diesel in life cycle assessment according to Base Empreinte, excluding indirect land-use effects, which experts debate. It is restricted to captive fleets with their own tank, and its tax advantage was preserved by the 2026 Finance Act. HVO made from used oils performs even better, subject to supply traceability.

7What CO2 information obligation applies to a road haulier?

Since 1 October 2013, every transport provider must communicate CO2 information to its customer for each service whose origin and destination are in France (Article L. 1431-3 of the Transport Code). Long without penalties, this obligation has carried a €3,000 fine since 1 January 2025. The calculation accepts 4 levels of precision, from statutory default values to actual measurement per service. The EU CountEmissions EU Regulation, in force since 1 June 2026, will harmonise these calculations around ISO 14083 for every company publishing a transport emissions figure, with full application scheduled for late 2030.

8What levers can decarbonise road haulage?

The first lever is organisational: better-loaded lorries and fewer empty returns through freight exchanges and pooling. Eco-driving supported by telematics sustainably reduces consumption by 5 to 10%, and both training and equipment are eligible for CEE funding. Without changing lorries, B100 reduces emissions by around 61% compared with diesel, HVO from used oils by up to 82% and bio-CNG by 79%. Electric heavy goods vehicles become profitable for intensive uses thanks to the enhanced CEE measure TRA-EQ-129 and enhanced tax depreciation at 115% of the additional cost.

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