The toll reform has been the subject of a dispute between the government and the transport and logistics industry for months, leading to blockades and demonstrations. Associations have voiced their criticism and tried to make an impact through campaigns and debates.
In the end, the German Bundestag passed the third law on the amendment of the toll system without any changes, meaning that the law comes into force as planned on 1 December 2023, and which also means that costs for CO2 emissions in the form of an additional partial toll for road freight transport will be added to the costs for infrastructure, noise and air pollution, and many trucks will also move into a higher toll category.
These are the most important changes:
– Technically permissible maximum laden mass (TPMLM) as the new basis for weight class allocation from 1 December 2023,
– The particle reduction class (PMK) will no longer apply: From 1 December 2023, vehicles with a PMK will no longer be assigned to a better emissions class. Vehicles with a 'Euro 2 + PMK 1′ emission class will be placed in emission class 2 and no longer in emission class 3. Euro 3 + PMK 2′ vehicles will be placed in toll emission class 3 and no longer in toll emission class 4.
– Toll obligation for vehicles over 3.5 tonnes TPMLM from 1 July 2024 (exception for tradesmen and similar businesses)
– Toll regulations for alternative drive systems: Toll exemption for gas-powered trucks ends on 1 January 2024, when they will be subject to the same toll rates as diesel-powered trucks.
The CO2 emission class of the vehicle is a new tariff feature
A new feature of the toll system is the CO2 emission class of the vehicle. This means that the toll rate per kilometre will also depend on how much carbon dioxide (CO2) a vehicle emits.
According to the new toll system, vehicles with internal combustion engines will be classified into CO2 emission classes 1 (applies to all vehicles built before 2019) to 5.
Change in the basis for weight class allocation
In the future, it will no longer be the permissible total weight, the gross vehicle weight (field F.2 of the vehicle registration document), that will determine the weight class, but the TPMLM, the technically permissible maximum laden mass (field F.1 of the vehicle registration document). As a result, several thousand vehicles will have to pay tolls for the first time or change their weight class.
A CO2 emission class finder is available on the Toll Collect GmbH website >> To the Toll Collect CO2 emission class finder.
“This is what happens when the state taxes twice,” says haulier association
As an important part of the economy, the German transport industry feels it is not being treated fairly by politicians. Entrepreneurs have been outspoken, warning of drastic job cuts and a massive cost avalanche in the face of a sharp rise in costs at the turn of the year. The government has also been accused of ignoring the industry.
The latest opinion comes from the European Association of International Freight Forwarders (ELVIS), which warns of financial problems and presents a market report for the third quarter.
“Companies that are unable to pass on the massive increase in toll costs on 1 December in full through to transport prices face financial losses that could threaten their very existence. The industry can only hope for a positive turnaround in the coming year,” concludes the association’s latest market report.
According to ELVIS, the situation is exacerbated by the continuing uncertain political environment. With the overall economy moving sideways, the willingness to invest remains low. The market report does not expect a significant improvement until the middle of next year.
“This hope is mainly fuelled by the looming turnaround in interest rates,” concludes Nikolja Grabowski, CEO of ELVIS AG.
However, the recent decision by the Federal Court of Justice that the Climate Change Fund does not have a legal basis could nip any positive signals in the bud.
“Ultimately, the industry will have to be satisfied if the German government does not raise the toll further during the year to make up for the shortfall in the federal budget,” the ELVIS board added.
According to the ELVIS report for the past quarter, the usual seasonal autumn upturn in the transport industry peaked in October. However, the key figures were significantly lower than in the previous year. The business climate is correspondingly subdued, which is now being further dampened by the toll increase.
Given the industry’s typically thin capital base, the focus is now on companies’ liquidity. Tolls, along with diesel costs, are one of the biggest items on a haulier’s cost base. A doubling of tolls would therefore put a considerable strain on overall solvency.
“It is particularly important to note that, due to the high value of invoices, fuel and toll providers keep a very close eye on the financial situation of their customers. If the invoice exceeds the cost limit corresponding to the credit rating, things can quickly get tight and there is a risk of cancellation,” warns Grabowski.
Against this backdrop, the association sees the following challenges for hauliers:
- to pass on the additional costs of the toll increase in full to their customers, including all kilometres travelled.
- it should be possible to prove one’s creditworthiness to creditors at short notice. For this purpose, at least the annual accounts for 2022 should be available.
- it would be advisable to cover larger outstanding amounts by commercial credit insurance or to liquidate them by means of factoring in order to increase one’s own solvency.
“The importance of solvency is often underestimated. Even transitory items can destabilise a company’s finances if they are as large as toll payments,” the ELVIS CEO points out, advising hauliers and freight forwarders to pay more attention to this issue.