Who really pays the CO2 toll for trucks in 2027?
CO2 toll trucks 2027: German law makes the haulier the toll debtor, and the shipper pays only if the contract passes the cost on.
Logifie Team
Logistics Technology Experts
The haulier owes the CO2 toll for trucks in 2027. German law names the owner, keeper, driver or registered holder as toll debtor, not the shipper. The shipper pays only if the contract passes the cost on through the rate or a toll clause, and ETS2, the separate fuel carbon price, starts only in 2028 .
Who legally pays the CO2 toll for trucks in 2027?
The toll debtor is the party operating the truck. Section 2(1) of the German Federal Trunk Road Toll Act ( BFStrMG , read 2026-11-07) lists the owner or keeper, the person who decides on the use of the vehicle, the driver and the person to whom the vehicle is registered. Several debtors are jointly and severally liable, and the toll creditor is the Federal Government. A shipper does not appear on that list.
The CO2 part is a large share of the bill. On the Toll Collect tariff page (rates valid since 2024-07-01, read 2026-11-07), a Euro VI truck over 18 t with 5 or more axles in CO2 class 1 pays 34.8 ct/km, of which 15.8 ct/km is the CO2 component, about 45%. No 2027 rate change or indexation was found on that date.
| Germany CO2 class (Euro VI, over 18 t, 5+ axles) | Toll per km since 2024-07-01 |
|---|---|
| Class 1 | 34.8 ct/km |
| Class 2 | 34.0 ct/km |
| Class 3 | 33.2 ct/km |
| Class 4 | 26.9 ct/km |
Other countries index their rates. In the Netherlands, a diesel Euro 6 truck over 32,000 kg pays 20.6 eurocent/km in 2027 after 2.6% indexation, according to RDW (2026-08-20). To compare countries, check the 2027 EU truck toll changes .
Can a haulier pass the CO2 toll on to the shipper?
Yes, but only through the contract. No legal obligation to pass the toll on to shippers was found, so any pass-through rests on the rate, a surcharge or a clause the parties agreed.
Both sides stated a position in 2023, when the German CO2 component was new. On 2023-11-03, eurotransport.de reported that BGL chief Dirk Engelhardt said every shipper must pay the CO2 toll. The same report says Mercedes-Benz, in a letter to its forwarding partners, declined to take over the toll increase in full for at least some lines, while Daimler Truck said its truck division would pay the toll.
The German forwarders' association DSLV, writing about an earlier court ruling on the truck toll, states that under a fixed all-in price the toll is part of the total remuneration, while a separately itemised toll surcharge is treated differently ( DSLV ). A contract can therefore show the toll as its own invoice line or link it to the published operator rate, in the same way an index-linked fuel surcharge works; learn how to build a fuel surcharge formula . Exact clause text needs legal advice, because none of the sources above gives a model clause.
Frequently asked questions
Who pays the CO2 toll, the haulier or the shipper?
The haulier pays the toll operator, because German law makes the owner, keeper, driver or registered holder the toll debtor. The shipper carries the cost only when the contract passes it on.
Is the CO2 toll the same as the ETS2 carbon price?
No. The CO2 toll is a road charge that varies with a truck's CO2 class, while ETS2 is a carbon price on fuel that starts in 2028. In 2027 only the toll applies to trucks in Germany.
Is a shipper liable to the toll operator in Germany?
No. The toll debtors under section 2(1) BFStrMG are the owner or keeper, the person deciding on the vehicle's use, the driver and the registered holder. A shipper is involved only through the transport contract.
Does an all-in freight price include the truck toll?
DSLV states that under a fixed all-in price the toll is part of the total remuneration, in a note on an earlier toll court ruling rather than the CO2 toll itself. An itemised toll surcharge is treated differently, so the invoice structure matters.
