Emission Factors Gap Analysis: CLEVER project

Wednesday, March 26th, 2025

Understanding the CLEVER Gap Analysis 

The CLEVER project Gap Analysis marks a significant step towards harmonising emission factor (EF) methodologies. Through extensive engagement with the Expert Forum, including surveys and discussions, key inconsistencies in emission factor development, classification and transparency were identified. 

A major focus is on defining boundaries to ensure accurate enough reporting and simpler methodology. The project prioritises the attributional approach, aligning with the CountEmissions EU regulation to prevent misleading negative emission factors and creating a stable and science-based framework independent of policies promoting particular fuels of technologies. Additionally, CLEVER emphasises transparent documentation, fostering trust and consistency in emissions data. 

Moving forward, CLEVER will refine its methodology, classification and reporting framework, addressing challenges such as waste allocation, multi-output systems and non-GHG influencers. The project aims to develop a standardised approach for emission factor calculation, ensuring clarity, comparability and regulatory alignment across energy carriers. 

Key Gaps and Concerns in emission Factors 

The Gap Analysis identifies major challenges in EF development, calculation, application and information collation. Key issues include: 

  • Fragmentation and inconsistencies due to multiple institutions developing EFs independently. 
  • Data accuracy and availability concerns, particularly for emerging energy carriers. 
  • Lack of centralised databases for harmonised data collation. 
  • Sector and region-specific data gaps, including land-use considerations and black carbon emissions. 
  • Regulatory inconsistencies, causing challenges in cross-comparison and application. 
  • Transparency issues, which have eroded trust in emission factor methodologies. 

Conclusions and the Way Forward 

The findings from the Gap Analysis confirm that addressing EF inconsistencies requires a modular approach to accommodate different regulatory requirements while ensuring methodological transparency. The CLEVER methodology will focus on: 

  • Attributional modelling to provide average GHG emission factors for all relevant fuel pathways. 
  • Consistent system boundaries covering the full energy carrier life cycle, from production to usage. 
  • Alignment with existing regulations while bridging gaps in EF availability. 
  • Clear documentation and transparency, ensuring methodological choices are well justified. 
  • Stakeholder collaboration, particularly with regulators and certification bodies, to drive EF standardisation. 

Next Steps for the CLEVER Project 

The CLEVER project now transitions to its next phase, which focuses on defining methodological approaches, fuel pathways and data inputs to develop robust emission factors. Critical next steps include: 

  • Establishing a comprehensive European EF database that also supports global applications. 
  • Addressing waste allocation, multi-output systems, carbon removals and non-GHG influencers such as black carbon. 
  • Conducting outreach and training for regulators, certification bodies and industry stakeholders to ensure the effective adoption of harmonised EFs. 
  • Implementing practical use cases to demonstrate the importance of accurate EF calculations in emission reporting and regulatory compliance. 

The CLEVER project recognises that achieving widespread EF harmonisation requires global stakeholder engagement and long-term involvement beyond the project’s formal timeline. By addressing technical gaps, fostering transparency and creating a structured EF framework, CLEVER is paving the way for more reliable and standardised emission reporting in the transport sector. 

For more information on CLEVER’s ongoing work, follow our updates on methodological development and stakeholder engagement. 

Access the full report through the CLEVER repository: CLEVER Repository | Knowledge Platform & ALICE members Intranet



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