Double Materiality Assessment
for Logistics

Double materiality assessment for Logistics

Logistics and transport companies face a materiality profile concentrated around a small number of high-severity topics. Transport accounts for approximately 25% of EU greenhouse gas emissions (Eurostat 2023), and road freight alone represents nearly 30% of transport emissions. A European haulage company with 400 trucks, 800 drivers, and EUR 90M revenue will find E1 Climate change material before any other topic. The sector's dependence on fossil fuels creates acute double materiality: the entity's fleet emissions contribute to climate change (impact materiality), while fuel price volatility, carbon pricing under the EU ETS extension to road transport (effective 2027), and the capital cost of fleet electrification create financial exposure.

E1 Climate change dominates the assessment. Scope 1 from owned fleet vehicles is typically 80-90% of total emissions for a road haulage operator. Scope 3 includes upstream fuel production and, for 3PL providers, the emissions of subcontracted carriers. The EU's CO2 emission standards for heavy-duty vehicles (Regulation 2024/1610) require a 45% reduction in average fleet emissions by 2030, 65% by 2035, and 90% by 2040, creating direct financial materiality through vehicle replacement costs and potential non-compliance penalties. E2 Pollution is material through NOx, particulate matter, and tyre and brake particle emissions from diesel vehicles. Urban access restrictions (low emission zones in over 300 European cities as of 2024) add financial materiality by limiting where the fleet can operate. S1 Own workforce covers driver working conditions: driving hours compliance (Regulation EC 561/2006), rest period adequacy, health impacts of sedentary work and irregular schedules, and fair compensation structures. For logistics companies using agency drivers or independent owner-operators, S2 Workers in the value chain captures the same risks for non-employee drivers. G1 Business conduct addresses fuel tax compliance, cabotage regulation adherence, and procurement practices in competitive tendering.

Assurance providers reviewing logistics assessments flag two recurring issues. First, entities assess E1 only for their owned fleet and exclude subcontracted carriers from the emissions calculation. For 3PL providers that subcontract a significant share of transport, this can exclude 40-60% of the total transport emissions. ESRS 1.30 requires value chain inclusion. Second, entities underassess the financial materiality of fleet transition. The capital expenditure required to transition from diesel to electric or hydrogen trucks is EUR 100,000-200,000 per vehicle above the diesel equivalent. For a 400-truck fleet, this represents EUR 40-80M in additional capital over the replacement cycle. This is a material financial risk that must be captured in the E1 assessment.

Logistics companies should organise the assessment around fleet segments (owned road, subcontracted road, rail, sea, air) and operational bases. Calculate Scope 1 emissions from fleet fuel consumption data (litres consumed, multiplied by DEFRA or national emission factors). For subcontracted transport, estimate emissions using tonne-kilometre data and the GLEC Framework emission factors. Score E2 based on Euro emission class of the fleet and proximity of operations to sensitive receptors (urban areas, schools, hospitals). For S1, use tachograph data, driver turnover rates, and occupational health records as evidence inputs.