Changes to CO2 Emissions Toll in Germany

Oct 23, 2023Market Advisory

As of today, Monday, October 23, 2023, the German Government has approved the Third Act Amending Toll Law Regulations without amendments. We anticipate that a suspensive objection by the Federal Council, which is currently under deliberation, is unlikely to materialize. This legislation is set to come into effect on December 1, 2023, impacting the landscape of road freight transport significantly.

Key Points of the Toll Law Amendment

The Toll Law Amendment includes these key changes:

  • CO2 Emissions Tariff (Effective December 1, 2023): The new toll law will introduce a CO2 differentiation in the truck toll system. This means that the toll rate per kilometer will depend on the amount of carbon dioxide (CO2) emitted by the vehicle. The CO2 emission class will be based on an EU-wide regulation. This shift is expected to result in toll fees increasing by up to 83%, affecting road freight transport costs substantially.
  • Change in Weight Class Allocation (Effective December 1, 2023): The permissible total weight (GVW) will no longer be the basis for allocating vehicles to weight classes. Instead, the technically permissible total mass (TPMLM) will determine a vehicle’s weight class. This change may result in vehicles falling into higher weight classes and being subject to increased toll charges. Toll customers should verify their vehicles’ weight class information in the customer portal and make necessary adjustments.
  • Particulate Reduction Class Changes (Effective December 1, 2023): Vehicles with a particulate reduction class will no longer be assigned to better emission classes. This means that vehicles with toll emission classes “Euro 2 + PRC 1”will now be categorized under toll emission class 2, while “Euro 3 + PRC 2” vehicles will fall into toll emission class 3.
  • Over-3.5-Tonne Toll Requirement (Effective July 1, 2024): The toll requirement for vehicles with a technically permissible maximum laden mass (TPMLM) exceeding 3.5 tonnes will be introduced on July 1, 2024. Vehicle combinations will only be subject to tolls if the TPMLM of the towing vehicle exceeds 3.5 tonnes.
  • Toll Regulations for Alternative Drives: Trucks equipped with CNG/LNG drive systems in Euro emission class 6 will become subject to tolls in January 2024. However, emission-free vehicles such as electric vehicles, hydrogen vehicles, and vehicles with a hydrogen fuel cell will remain toll-exempt until the end of 2025. Starting on January 1, 2026, they will be required to pay 25% of the partial toll rate for infrastructure costs, in addition to partial toll rates for air and noise pollution.

Please note that the changes in the toll law are part of a broader legislative package that includes the Act on the Acceleration of Approval for Transport Infrastructure, which will impact the expansion of the federal rail network and route expansion projects. This comprehensive legislation aims to address the challenges of noise and air pollution, as well as CO2 emissions while promoting infrastructure development.

Industry Impacts

The impending Truck Highway Toll increase, with a potential 83% rise based on the CO2 emission class of the truck, will significantly affect transport costs. While modern trucks with lower CO2 emissions may experience a more manageable increase of 10-20%, older trucks with higher CO2 emissions could face the full 83% hike. Moreover, the proposed CO2 tax of EUR 200 per 1,000 kg CO2 will compound the impact on pricing. The exact cost implications remain challenging to pinpoint, as each truck has a unique CO2 footprint. 

It is essential to prepare for these upcoming changes to ensure compliance with the new toll regulations. Rest assured, the TOC Logistics team is here to assist you in adapting to these regulatory changes and ensuring a smooth transition for your operations. We are committed to closely monitoring this issue and will promptly update you once we have more information. If you have any further questions or concerns, please do not hesitate to contact us. Our team is ready to assist you in navigating these changes effectively, providing expert guidance on adapting to the evolving regulatory landscape and optimizing your transportation strategies.


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