In line with the criteria for large companies and publically listed SMEs listed in the timeline, it is reasonable to conclude that a relatively small portion of tugboat operators meet these criteria, and will thus be directly impacted by the CSRD. Nonetheless, although the CSRD first has to be reported by large and EU-listed companies, the entire value chain of these companies are indirectly impacted. As part of the value chain of larger companies, who are subject to report on the CSRD, tugboats are considered part of their indirect, scope 3, emissions. 

The directive states that information about each actor in the value chain is not required unless it pertains to ‘material’ upstream and downstream value chain information. The concept of “materiality” plays a central role here, indicating that emissions from tugboats would need to be included if they are significant in relation to the vessel operator’s environmental impact. In analyzing the materiality of tugboat operators, companies need to consider their environmental and financial impact. First, if greenhouse gases emissions and other pollutants of tugboat operators contribute significantly to the company’s total environmental impact, they are likely to be deemed material. Next, financial risks and opportunities associated with tugboat operations, such as potential costs related to fuel consumption, emissions regulation compliance must be considered, along with the potential for investment in cleaner technologies. Thus, the emissions from tugboat operations could be substantial enough to warrant consideration under the CSRD’s scope of reporting, particularly if the towage operations have, for example, inefficient fuel usage. In the end, it depends on the context of the company and their tugboat operator. 

Data transparency is required for the whole value chain, and companies are encouraged to strive for the most accurate data possible. Data from other parties in the value chain need to be sent at the request of firms, as these emissions must be included in their annual sustainability reports under the CSRD. Only in cases where precise data is not available or practical to obtain, are companies allowed to use estimates based on average consumption. This can involve using established industry averages, emissions factors, or other estimation methods that reflect the typical emissions produced by such activities. This is particularly important for emissions sources where the company does not have direct control or complete data visibility, such as those involving third-party services. 

It is clear that the scope 3 emissions still leave some uncertainties, specifically regarding the definition of materiality and data transparency. For third-party services such as tugboats and other port operations, answers are likely provided once the sector-specific ESRS guidelines are out by 30 June 2026. While it is possible that the emissions of tugboats can be estimated, it is more likely that they will require accurate measurement, given this is possible. Lastly, a committee has been established to review the act at least every three years, suggesting the framework is evolving. This could lead to more specific guidelines on reporting emissions, as the CSRD is implemented.