A new truck in the road toll system: class one by default

A CO2 component has been part of the German road toll calculation since 2023. Vehicles are assigned to one of five CO2 emission classes, and the gap between the classes is wider than most people expect.

For a Euro VI tractor unit over 18 t with five or more axles the rates are: class one — 34.8 ct/km, class two — 34.0, class three — 33.2, class four — 26.9. For a four-axle combination in class one — 32.4 ct/km. For lighter vehicles from 3.5 to 7.49 t — 15.1 ct/km.

The gap between class one and class three is 1.6 ct/km. For a vehicle running 8,000 km a month in Germany that is €128 a month, or about €1,540 a year. The gap to class four is 7.9 ct/km, which is €632 a month.

The default value is class one

Here is the essential point, the one that costs the most money: if a vehicle is not assigned to a specific class, class one applies. Not an average, not “according to the Euro standard”, but the least favourable class.

That means a new vehicle entering the system is charged at the highest rate until somebody assigns it to another class. The system is not making an error — it is applying the default value.

Reclassification does not happen by itself

The system does not reclassify a vehicle on its own. It has no data for it: the first registration date and the technical figures do not reach it automatically. Reclassification is initiated by the owner of the vehicle, by filing the data.

Second: only vehicles first registered on or after 1 July 2019 can be reclassified. Vehicles registered earlier stay in class one regardless of their technical figures. Which means not every invoice showing class one is an error — the registration date has to be checked before a claim is submitted.

Third, and the one most often missed: registration is done separately in each country. A vehicle reclassified in the German system stays in class one in the Austrian system until it is reclassified there as well. Companies operating in several countries usually have their main market in order and the rest not.

Where it breaks down in practice

Reclassification is not difficult. It is simply not assigned to anyone.

The process of acquiring a new vehicle includes registration, the technical inspection, insurance, the tachograph, the digital cards. Reclassifying the CO2 class in the road toll system is usually not on that list — not out of negligence, but because it is not necessary for the vehicle to go out on the road. The vehicle will run and the toll will be paid. Only at class one.

So the typical picture in a fleet audit is not “all vehicles in class one” but “the older vehicles are sorted, the ones bought last year and this year are not”. The error does not arise at a single moment — it accumulates with every change in the fleet.

The thresholds were tightened on 1 July 2026

The thresholds for class assignment are not fixed: they are tied to the emission reduction trajectory, and the reporting period runs from 1 July to 30 June. So on 1 July 2026 the thresholds tightened not because of a new act but because of the ordinary step along the trajectory. Some vehicles previously assigned to class three moved to class two, which means a higher rate.

This is not an error and there is nothing to dispute here. But it has a practical consequence: a class determined earlier does not necessarily match the current thresholds, so the assessment has to be made against the version in force at the time. And a higher invoice should not be checked as if it were an error — a check in which there is nothing costs time.

One thing is worth knowing about the future: the European Commission proposal that reached a provisional agreement between the Council and Parliament on 30 June 2026 would relax the thresholds, not tighten them. It has not yet been adopted or published, so it is not included in calculations — but the direction is the opposite of what is often assumed.

What to check

If you want to check your own fleet without any outside service, three things are needed:

1. Road toll invoices with the rate stated for each vehicle. If the rate is not stated on the invoice, it can be worked out by dividing the charge by the kilometres — but only on sections in the same country.

2. The first registration date of each vehicle. On or after 1 July 2019, or earlier.

3. A list of the countries in which the vehicle is charged, and a list of the countries in which it has been reclassified. The difference between those two lists is where the money goes most quietly.

The third point is the one worth checking even if everything else looks in order.

On the time limit

In Germany a refund of overpaid road toll can be requested until the end of the third calendar year following the year of payment. The application goes to BALM (Bundesamt für Logistik und Mobilität), and a €20 administration fee is charged for each registration number. That fee is charged regardless of the amount refunded, so for vehicles with low mileage an application may not be economically worthwhile — worth working out before filing.

Reclassification going forward has no time limit, but every month without it is a month at class one.