The Commisson's proposal provides for a standardised methodology for calculating CO2 emissions from passenger and freight transport and from the operation of transport hubs. This is to be welcomed. There is a need for reliable and comparable data.

However, AK criticises the fact that the ISO standard on which this regulation is based is not available to the public free of charge. Its adoption into legislation is questionable in terms of the rule of law. Moreover, in contrast to the well-to-wheel approach chosen in the proposed regulation, a standardised methodology must map all climate-damaging value creation processes in transport services.