Do Delivery SMEs Need to Track Tyre Dust and Air Pollution?

As European sustainability rules evolve, many small delivery and logistics companies are wondering: does the CSRD require us to measure tyre dust and air pollution from vehicles?

The short answer is: no, not in detail — but you do need to account for related emissions in a proportionate way. Here’s what the CSRD and the Voluntary Sustainability Reporting Standard for SMEs (VSME) actually expect.

Do SMEs Have to Measure Tyre Dust Emissions?

No. Under the VSME Standard (Basic Module), small and medium-sized enterprises are not required to calculate particulate matter (PM) emissions from tyre or brake wear.

These non-exhaust emissions are recognised as an environmental issue under ESRS E2 (Pollution) for large companies, but the SME framework applies a proportionate approach.

Instead, SMEs in the transport sector are expected to focus on:

• Fuel and energy use (VSME B3 – Energy and GHG emissions)
• Vehicle maintenance and efficiency practices (VSME B2 – Practices and policies)
• Air pollutant compliance with local laws (if monitored by authorities)

You are not expected to run laboratory tests or model micro-particle emissions.

What About Tailpipe Emissions?

Yes — these count. The exhaust gases from your vans, trucks, and company cars fall under Scope 1 GHG emissions, and should be reported based on fuel use (diesel, petrol, LPG, etc.). Learn more about what counts as Scope 1 vs Scope 2.

That means:

• Track how much fuel you purchase or use each year - see our guide on reporting fuel receipts and invoices
• Convert litres to tonnes of CO₂ equivalent (tCO₂e) using standard factors
• Optionally, note any NOₓ or PM limits you meet under vehicle standards (Euro 6/VI)

Example disclosure:

“All company vehicles comply with Euro VI standards. Fleet fuel use resulted in approximately 75 tonnes CO₂e in 2024.”

Are Air Pollutants Included Anywhere in the VSME Standard?

Yes, but only for companies already monitoring emissions under national regulations.

In VSME B4 – Pollution of air, water and soil, SMEs must disclose air pollutants (e.g. NOₓ, SO₂, PM10, PM2.5) only if:

• They are legally required to report to environmental authorities, or
• They already track these pollutants under an Environmental Management System (EMS).

Otherwise, you can state that the disclosure is “not applicable”.

Example text:

“The company operates light delivery vans and is not required to monitor air pollutants under national regulations. No pollutants are reported under VSME B4.”

Should SMEs Mention Tyre Dust or Urban Pollution at All?

While detailed tracking isn’t required, transparency is encouraged. You can briefly mention:

• Tyre and brake wear as part of your environmental impacts (qualitative)
• Mitigation practices such as:
  • Regular tyre pressure checks and eco-driving
  • Switching to low-emission or electric vehicles
  • Route optimisation to reduce stop–start driving

This demonstrates awareness of wider environmental effects, supporting the CSRD’s “double materiality” principle — considering both your impact on the environment and how environmental issues affect your business.

Practical Example

Company: SwiftDrop Logistics (15 delivery vans) What they report:

• Diesel use: 85,000 litres = 228 tCO₂e (Scope 1)
• All vans meet Euro VI standard (no pollutant reporting required)
• Annual fleet check includes tyre pressure and replacement policy
• Exploring electric van lease options in 2025

This level of detail fully meets VSME Basic Module expectations.

In Summary

Key Terms

• CSRD: Corporate Sustainability Reporting Directive (EU 2022/2464)
• VSME: Voluntary Sustainability Reporting Standard for SMEs (EFRAG, 2024)
• Scope 1 emissions: Direct GHG emissions from owned or controlled sources (e.g. fuel use)
• Air pollutants: Gases or particles that contribute to air quality degradation (e.g. NOₓ, PM)
• Non-exhaust emissions: Particles from tyre, brake, and road surface wear
• Euro standards: EU limits for vehicle exhaust emissions