TCO Climate-Friendly Commercial Vehicles #3: Regulatory Framework

Different regulatory measures must be taken into account for the respective drive technologies:

• CO₂ price according to the Fuel Emission Trading Act (BEHG): Surcharge on diesel prices
• CO₂-differentiated truck toll: Exemption for zero-emission vehicles
• Revenue from THG quota trading in favour of climate-friendly vehicles and the associated infrastructure
• Funding for the additional investment costs of climate-friendly vehicles

The regulatory impacts are considered on the basis of the average values determined in the TCO cost analysis for the three drive types in 2030.

In the worst case from the point of view of climate-friendly vehicles (scenario “Worst Case”), there will be no further increase in the price of diesel and no preferential treatment of or additional income for zero-emission vehicles. The “Status Quo” scenario uses the currently applicable regulations and prices for the individual measures.

Influence of regulation for the year 2030

Individual assumptions for the four regulatory measures can also be set using the controllers on the right-hand side of the dashboard.

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CO₂ price according to the Fuel Emission Trading Act

The Fuel Emission Trading Act (BEHG) creates the basis for pricing fossil greenhouse gas emissions from the transport and heating sectors that are not covered by EU emissions trading. The aim is to contribute to achieving national climate protection targets. In the law, which has been in force since 2021, the national price for CO₂ emissions is fixed with an increasing trend until 2025. From 2026, the CO₂ price will be regulated via a national emissions trading system (nEHS), in which the price depends on the supply and demand of CO₂ certificates. The price must be paid when the fossil fuels are placed on the market. The companies pass the price on to the end consumers, so that the CO₂ pricing – in the case of the transport sector – is directly noticeable at the petrol station with higher diesel prices.

Currently (as of November 2024), the national CO₂ price is €45/t CO₂ (equivalent to approximately €0.14/l diesel). It will rise to €55/t CO₂ in 2025. For 2026, a price corridor of €55 to €65/t is specified. It is unclear how prices will develop in the subsequent nEHS. However, it can be assumed that the CO₂ price for the transport sector will rise significantly. The forecasts of different studies vary greatly. Within the framework of the Kopernikus project Ariadne, a range of 210 – 405 €/t CO₂ is forecast for 2030, for example.

Revenue from THG quota trading

The quota for the reduction of greenhouse gas emissions – in short: THG quota – is a market-based climate protection instrument that is intended to help achieve European and national climate protection targets in the transport sector. This is accompanied by a THG quota trading system that offers the option of transferring the obligation to meet the quota to third parties. Anyone who owns a climate-friendly vehicle or offers refuelling and charging infrastructure for these may be able to participate in quota trading and thus generate income.

The income generated from THG quota trading can have a significant impact on the TCO of commercial vehicles. On the one hand, electricity and hydrogen costs at public charging and refuelling infrastructure can be reduced if the operators pass on the proceeds from THG quota trading to the end users. On the other hand, BEV vehicle owners can receive a THG premium for a flat amount of energy from their vehicles.

At the current THG quota prices of around €100/t CO2 on the market, the TCO for BEV can be reduced by around €0.04/km. It is assumed that 50% of the quota revenues at refuelling and charging infrastructure are passed on to the end users through reduced electricity and hydrogen prices. With an H2 mix of 50% green and 50% grey hydrogen at public refuelling infrastructure, savings of around €0.04/km are also possible for FCEV.

CO₂-differentiated truck toll

With the differentiation of toll rates according to the pollutant and CO₂ emissions of the vehicles, the toll regulations offer an incentive to use climate-friendly vehicles. For so-called emission-free heavy commercial vehicles, the Federal Trunk Road Toll Act provides for a toll exemption until the end of 2025 in order to support the market ramp-up of these vehicles. Emission-free vehicles with a technically permissible maximum laden mass (tzGm) of up to 4.25 t are even permanently exempt. From 2026, emission-free vehicles will be subject to a toll sub-rate for infrastructure reduced by 75%, in addition to the respective toll sub-rates for air pollution and noise pollution. The toll sub-rate for CO₂ emissions is zero and therefore does not apply.

Climate-friendly commercial vehicles have a clear advantage over diesel trucks: In the example shown of the SZM and 90% toll routes, the TCO is reduced by €0.20/km with a reduced toll rate (regulation applicable from 2026) or by €0.24/km with a full toll exemption (currently valid).

Funding for additional investment costs

Vehicles with climate-friendly drives are often still significantly more expensive to purchase than conventional vehicles. In order to reduce the additional expenditure on purchase and to contribute to market activation or the market ramp-up for commercial vehicles with climate-friendly drives, some federal states – and until recently the federal government – have published calls for funding.

Depending on the funding guideline, up to 80% of the additional investment costs compared to a comparable vehicle with a diesel engine were eligible for funding.

The impact is greatest with high additional investment costs, as is still the case in 2024. As the investment costs approach those of comparable diesel vehicles, as in 2030, the impact of the funding also decreases sharply.