Primary Data for Scope 3: Why It Matters in 2026

Accurate emissions accounting is the cornerstone of effective decarbonization in freight and logistics. And in 2026, the demand for high-quality data has never been greater. At the heart of that demand lies one essential element: primary data. 

Primary data is no longer a nice-to-have. It’s a critical component of credible carbon reporting and effective climate action. As normative standards like ISO 14083:2023 and the emerging CountEmissionsEU regulation raise the bar for greenhouse gas (GHG) reporting, understanding what primary data is, and why it matters, is essential for all actors in the freight value chain. At the same time, there is an increasing demand from shippers for primary data to improve transparency on Scope 3 emissions.

What is Primary Data?

According to ISO 14083:2023 (Chapter 3.3.3), primary data is defined as the quantified value of a process or an activity obtained from a direct measurement, or a calculation based on direct measurements.
In practice, this means actual, carrier information, such as real fuel consumption, energy use, and transported freight weight, and distance travelled rather than estimates or averages.

To understand the impact of primary data, we must first look at how emissions are calculated.

Emissions Accounting: Where Primary Data Fits In 

Within ISO 14083, emissions accounting involves three main elements: total emissions, transport activity, and emissions intensity. Because companies are primarily interested in the total amount of emissions (kg CO₂e), we start there and then move to intensity as a supporting KPI.

1. Total emissions
The most important value for companies is the amount of emissions:
The numerator (WTW GHG emissions) is based on actual energy or fuel consumption multiplied by the appropriate emission factor.

2. Transport Activity
The transport activity is needed to relate emissions to the amount of freight moved:
The denominator (transport activity) is calculated from freight mass and distance traveled.

3. Emissions Intensity
Emissions intensity is then calculated as:
If emissions are calculated using primary fuel consumption data, then emission intensity is not the most important value for companies on emission calculation, but it is a key supporting KPI to measure their emission reduction performance. It is also the metric that shows how polluting a service is, and therefore an important lever to decarbonize further.

Primary Energy Data

Primary data refers to directly measured or calculated values for:
- Energy or fuel consumption (in liters, kg, or kWh)
- Supplier-specific fuel emission factors (e.g., specific HVO with traceable feedstock)

These values are fundamental to accurate emission calculations. In particular, the energy consumption is the most critical determinant of whether an emission value qualifies as primary data.

In practice, distance and other transport activity data are therefore primarily relevant for how emissions are distributed and compared (for example, between shipments or services), while primary energy data remains the key element for determining whether the emissions themselves are based on primary data. Keeping this distinction clear helps avoid confusion about how primary data is understood in emissions accounting.

Why Primary Data Matters in 2026

As companies move to comply with ISO 14083 and prepare for the CountEmissionsEU regulation, there is a clear regulatory signal: use primary data as input for transport emissions calculation wherever available. If not available, justify the "fall back" options. This ensures:

- Greater accuracy in reported emissions
- Improved comparability across supply chains
- More meaningful performance tracking over time
- Moreover, primary data provides visibility into the real emissions performance of specific carriers, fuels, and routes; information that is essential for informed procurement, decarbonization planning, and transparent sustainability reporting.

The Challenge: Data Silos in the Supply Chain

Despite its importance, primary data is not widely available. One of the biggest barriers is fragmentation and lack of data sharing between actors in the same physical supply chain.

- Carriers (Transport Service Operators) are typically the only ones with direct access to energy consumption and operational data.
- Logistics Service Providers (Transport Service Organizers) and shippers (Transport Service Users) often rely on secondary data or estimates.
- This is particularly prominent in road freight, which is highly fragmented, composed largely of small carriers operating small fleets, making data sharing more difficult.

The result: even when primary data exists, it often does not reach the actors who need it to account for Scope 3 emissions.

Where Smart Freight Centre Stands

At Smart Freight Centre, we believe that the widespread adoption of primary data is essential to meaningful freight decarbonization. Without it, efforts to reduce emissions risk being based on outdated averages, masking both challenges and opportunities.

Through our work, including the GLEC Framework, SFC Academy courses, and collaboration with policymakers and industry, we are helping organizations:
- Understand the role and value of primary data
- Build the capacity to collect and share it efficiently
- Prepare for emerging standards like ISO 14083 and CountEmissionsEU

Our message to the industry is clear: prioritize primary data, not just to comply with regulations, but to lead the way in sustainable freight.
Looking Ahead

The transition to primary data will require investment, collaboration and time. But the benefits, including improved accuracy, stronger compliance, and more effective climate action, are well worth the effort.

2026 is the year to take a proactive approach. Begin working with your carriers. Request primary data where possible. Build systems for reliable data exchange.

Because without primary data, it is much harder to drive and demonstrate real decarbonization.
Want to learn more about emissions accounting and how to integrate primary data into your reporting? Explore our courses below.

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