Does ETS2 impose obligations directly on carriers?

No. The obligation to surrender ETS2 allowances rests with the fuel suppliers who place fuel on the market. Carriers feel the system indirectly, through higher fuel prices, and shippers through the fuel clauses in their freight rates.

From when does ETS2 cover road transport fuels?

From 2027, under Directive (EU) 2023/959, which extends EU emissions trading with a separate system, ETS2, for fuels burned in road transport among other sectors. The system works on a cap-and-trade basis and includes a price stabilisation mechanism.

What is the CO2 component in the German truck toll?

Since December 2023 the German Maut has included a component based on CO2 emissions: vehicles are assigned to emission classes and the toll rises with the emissions. The legal basis is the amended Eurovignette Directive (EU) 2022/362. Lower-emission equipment pays a lower toll.

ETS2 and CO2: why road transport costs rise from 2027

From 2027, fuels burned in road transport will be covered by ETS2, a separate EU emissions trading system introduced by Directive (EU) 2023/959. The cost of allowances falls on fuel suppliers, who will pass it into diesel prices and, further down the chain, into freight rates. It is a system-wide cost for the whole industry, so it pays to tidy up the fuel clauses in your contracts now.

ETS2 is a new emissions trading system, separate from the existing EU ETS, covering fuels burned in road transport among other sectors. It works on a cap-and-trade basis: the total pool of allowances is capped, and the entities covered by the system have to buy and surrender them. The obligations sit with fuel suppliers, not with their customers.

Where does ETS2 come from?

For years the EU emissions trading system covered mainly power generation and heavy industry. Directive (EU) 2023/959 extends the mechanism with a new, separate system, ETS2, which covers fuels burned in road transport among other uses and applies from 2027. The logic is simple: if emissions from a chimney carry a price, emissions from an exhaust pipe get one too. The pool of allowances is capped, and a capped supply against steady fuel demand means emissions stop being a free ingredient of a transport.

Who pays on paper, and who pays in practice

The most common misunderstanding about ETS2 is that carriers will have to buy allowances. They will not. The ETS2 obligations rest with the fuel suppliers who place fuel on the market. They surrender the allowances and they will build that cost into the price of a litre, at the pump and in wholesale. The carrier pays at the filling station, and the shipper pays in the freight rate, because fuel is one of the main cost components of any haul.

We will not quote a forecast allowance price here, nor an estimate of the impact on rates, because any such number would be guesswork today. The system includes a price stabilisation mechanism designed to soften sharp spikes, but the direction is unambiguous: the cost of emissions enters the price of fuel. An honest conversation about rates from 2027 therefore starts with one sentence: this is not carrier greed, it is a systemic cost that hits every player in the market alike.

Germany has shown the direction: a CO2 component in the Maut

If you want to see the trend in practice, there is no need to wait for 2027. Since December 2023 Germany has charged its truck toll with a CO2 emissions component: vehicles are assigned to emission classes and the toll depends on how much the vehicle emits. The legal basis is the amended Eurovignette Directive (EU) 2022/362, which lets member states differentiate road charges by emissions. The polluter-pays principle is already visible in tolls, before ETS2 even touches the fuel itself.

Criterion	ETS2	CO2 component in tolls (example: Germany)
Legal basis	Directive (EU) 2023/959	Directive (EU) 2022/362 (Eurovignette)
In force from	2027	December 2023
Who settles formally	fuel suppliers	the carrier when the toll is charged
Where the cost shows up	in the fuel price	in a toll rate tied to the emission class

What to do about it as a shipper

Tidy up the fuel clauses. Since the emissions cost will enter the fuel price, the fuel clause decides how the change is shared between the parties. We explain how such a clause works and what to ask about in our article on the fuel surcharge: check the reference index, the update frequency and the threshold at which the adjustment kicks in.
Know the structure of the rate. Fuel, tolls, driver costs and overheads make up the price of a haul in different proportions; we break them down in the piece on what goes into an FTL rate. If you understand the structure, you can tell a genuine cost increase from a negotiating smokescreen.
Ask about the fleet. In Germany the emission class of the vehicle already translates into the toll. A carrier investing in newer, lower-emission equipment has lower running costs and more predictable rates on corridors with CO2-based tolls.
Do not buy promises of immunity to ETS2. No carrier can avoid a cost that enters the fuel price at the supplier. An offer claiming otherwise is moving the risk to a less visible part of the contract.

How does OTSL handle it?

We track cost regulations on the main corridors and translate them into contract language: clear fuel clauses, a transparent rate structure and carriers whose equipment fits the route. If you want to prepare a transport budget for the ETS2 years, write to us or browse our knowledge base.

Step by step

Audit contracts. Review current transport agreements to check existing fuel adjustment provisions.
Update fuel clauses. Introduce clear fuel clauses that incorporate potential emissions costs into freight rate calculations.
Calculate future budgets. Factor anticipated transport price changes into long-term financial planning.
Optimize supply routes. Minimize empty miles and optimize shipment schedules to lower overall fuel burn.
Consult your forwarder. Discuss options with your logistics provider to align supply chains with upcoming changes.

Definitions

ETS2 (Emissions Trading System 2): A separate EU emissions trading system covering fuels burned in road transport and other sectors.
EU ETS (European Union Emissions Trading System): The original EU cap-and-trade mechanism covering mainly power generation and heavy industry.
Cap-and-trade (Limit and trade mechanism): A market-based environmental system where total allowances are capped and covered entities must surrender them.
Fuel clause: A contractual provision that enables freight rates to adjust based on fluctuations in fuel prices.

The OTSL role

As a freight forwarder, OTSL assists businesses in adapting to evolving market conditions across European routes, providing efficient Road transport (FTL) services. We also support clear contracting and cost management, including proper application of Incoterms in transport to the UK.