Buying a used truck: what to check before you commit

Some of what a used truck will cost, and some of the work it may legally do, is settled by its papers and the dates on them rather than by its condition. This guide takes them in turn — the German CO2 toll class, the tachograph, the roadworthiness file, the plated weights and the documents that should change hands — and says why to ask which Euro VI step the truck holds.

The first registration date and the German toll

Since 1 December 2023 the German truck toll has charged by CO2 emission class. There are five classes, and the lower the CO2 emissions, the higher and better the class. Toll Collect assigns every vehicle to class 1 by default and states plainly that vehicles first registered before 1 July 2019 are therefore correctly classified and, due to legal requirements, cannot be assigned to a higher CO2 emission class.

For a used buyer that is a legal ceiling, not a paperwork gap. A truck registered in June 2019 stays in class 1, the most expensive CO2 class, however clean it actually is. The legal frame behind the classes — the five classes, the discount bands, and the six-yearly reassessment and threshold changes that can move a class 2 or class 3 truck back down — is set out in EU road tolls and CO2 classes.

Toll Collect’s rate table, in force since 1 July 2024, puts a Euro 6 vehicle over 18 tonnes with five or more axles at 34.8 cents per kilometre in CO2 class 1, 34.0 in class 2, 33.2 in class 3 and 26.9 in class 4.

For a truck first registered on or after 1 July 2019, an application for a less expensive class can be made, only through Toll Collect’s customer portal and with evidence. Whether the class changes depends on the truck’s documented CO2 emissions: Toll Collect defines class 2 as vehicles of a vehicle subgroup whose CO2 emission levels “at classification time t are more than 5 per cent below the reference value of the reporting period of t applicable to this vehicle subgroup”, class 3 as more than 8 per cent below that reference value and class 4 as more than 50 per cent below the applicable reference value, and states that “the relevant threshold value depends on the vehicle sub-group and the vehicle’s initial registration date”. It also states that threshold values have so far been defined only for vehicle sub-groups 4, 5, 9 and 10, so a truck outside them can currently be classified only in class 1 unless it is a zero-emission vehicle, and that a vehicle entered as a commercial service vehicle in field 1.1.9 of the CIF or field 49.3 of the CoC “currently always falls into CO2 emission class 1” or, if it has a zero-emission drive, into class 5. The suitable evidence Toll Collect lists includes the vehicle registration certificate, the manufacturer’s customer information file (CIF), the certificate of conformity (CoC) and an individual authorisation form. Without evidence, the truck stays in class 1.

The Euro VI steps, A to E and E+

Table 1 of Appendix 9 to Annex I of Regulation (EU) No 582/2011 lists the Euro VI steps by character and gives each its own dates. As Regulation (EU) 2019/1939 replaced it, the table ran from A to E; Regulation (EU) 2026/361 has since replaced the step E row and added E+. Step D applied to new types from 1 September 2018 and to all vehicles from 1 September 2019; step E followed from 1 January 2021 for new types and 1 January 2022 for all vehicles, and the table gives 28 May 2029 as its last date of registration — all three step E dates subject to the transitional measures in Article 17a of Regulation (EU) No 582/2011.

Regulation (EU) 2026/361 added E+ so that vehicles fitted with on-board fuel and energy consumption monitoring devices can be identified. The table gives E+ no date for new types; its date for all vehicles is 1 July 2027, for vehicles falling within the scope of Implementing Regulation (EU) 2025/2161, the Commission’s rules for those devices on certain heavy-duty vehicles, and its last date of registration is also 28 May 2029. In that table E and E+ are the only steps marked for cold start and particle number, and the 2019 regulation records why the cold start was brought in: emissions in the period after a cold engine start had not been assessed in either the type-approval demonstration test or the in-service conformity test.

Ask which step the truck holds, because makers do not all say. MAN states Euro 6e for the D30 engine it fits to the TGX, while DAF’s specification sheet for the XG+ 450 FT 4x2 tractor states only Euro 6 — so a sheet that says Euro 6 does not answer the question.

Which of the mandatory driver assistance systems the truck was obliged to carry is a separate question: it turns on the approval of the type the vehicle was built to and on the date it was registered, not on its model year, and on four calendars rather than one.

Looking forward, Euro 7 (Regulation (EU) 2024/1257) entered into force on 28 May 2024. It applies to new types of goods vehicles in categories N2 and N3 from 29 May 2028 and to new vehicles in those categories from 29 May 2029; for new N2 and N3 vehicles built by small-volume manufacturers, the registration prohibition in Article 10(10) takes effect from 1 July 2031.

The tachograph generation decides cross-border work

The Commission’s questions and answers on the tachograph provisions of the Mobility Package put the dates of Regulation (EU) No 165/2014 on the calendar. Vehicles registered for the first time from 21 August 2023 must be equipped with smart tachograph version 2. Older vehicles operating in a member state other than the one they are registered in had to be retrofitted: those with analogue or non-smart digital units by 31 December 2024 at the latest, those with smart tachograph version 1 by 18 August 2025 at the latest. Light commercial vehicles with a maximum permissible mass between 2.5 and 3.5 tonnes engaged in international transport or cabotage have had to carry version 2 since 1 July 2026, under Regulation (EC) No 561/2006, and by August 2028, the Commission says, all drivers will have to have a version 2 driver card.

What each generation records, and which vehicles the retrofit duty reaches, is set out in the smart tachograph explained. Both retrofit deadlines have passed, so a truck bought for work in a member state other than the one it is registered in, on carriage that falls under Regulation (EC) No 561/2006, needs a version 2 unit before that work starts: the Commission’s guidance is that the tachograph must be replaced before the start of the journey. A truck kept on purely domestic work is outside the retrofit duty, which the Commission applies only in as much as a vehicle operates in member states other than its own, and not to one that merely transits another member state on a domestic job. Until a vehicle carries version 2, its driver has to enter each border crossing by hand, an obligation whose main objective, the Commission says, is to facilitate enforcement of the rules on cabotage and posted drivers; a version 2 unit records the crossings automatically.

While you are there, ask when the tachograph was last inspected. Article 23 of Regulation (EU) No 165/2014 requires regular inspection by approved workshops, carried out “at least every two years”, checking among other things that the installation plaque is affixed and that all seals are intact and effective. The workshop draws up an inspection report “in cases where irregularities in the functioning of the tachograph had to be remedied”; such reports are retained “for a minimum period of two years”, and member states decide whether they “are to be retained or sent to the competent authority during that period”.

Read the roadworthiness file as a mileage record

Article 5(1) of Directive 2014/45/EU has vehicles tested “at least within the following intervals”, and for goods vehicles in categories N2 and N3, and trailers in O3 and O4, the interval is “one year after the date on which the vehicle was first registered, and thereafter annually”; under Article 5(3) member states or competent authorities “may establish a reasonable period during which the roadworthiness test is to be carried out, not exceeding the intervals laid down in paragraph 1”. The certificate records the odometer reading at the time of the test, if available, and Article 8(6) requires the information from the previous test to be made available to inspectors “for the purposes of checking the odometer, where an odometer is normally fitted”, as soon as it is available electronically; manipulating an odometer to reduce or misrepresent a vehicle’s distance record is to be punishable. Where the purchase includes trailers, their braking approval and what to read off a used trailer are covered in trailer brakes and EBS.

That makes the file a mileage record as well as a record of passes. On an annual interval, two consecutive certificates two years apart leave a year the file does not account for — our reading, not the Directive’s words — and that is a question for the seller. A buyer holding consecutive certificates can make the comparison Article 8(6) gives the inspector, and a reading lower than the one on the certificate before it needs an explanation. Where the truck will be written down by kilometres run under German tax rules, each year’s distance has to be proved, and the rule and its million-kilometre basis are set out in truck depreciation and book value.

Buying across a border, Article 8(3), “without prejudice to Article 5”, requires the member state of re-registration to recognise a roadworthiness certificate issued by another member state as if it had issued it itself, provided the certificate is still valid against the re-registering state’s own test intervals; “in cases of doubt”, the re-registering member state “may verify the validity of the roadworthiness certificate before recognising it”. A change of owner does not by itself end a valid certificate either — Article 8(4) has member states recognise it as a matter of principle — although Article 5(4) lets a member state call the vehicle in early when the holder of the registration certificate changes. What each grade on the certificate means, and how deficiencies graded the same way at a roadside inspection feed the operator’s risk rating, is set out in roadworthiness tests and roadside checks.

Plated weights and component ratings

On the Volvo FH Volvo gives the I-Shift gearbox and the rear axle each their own GCW approval, and the plate can be lower than either: Volvo’s GB data sheet for the FH 6×4 tractor plates it at 44 tonnes GCW while giving some of its I-Shift gearboxes a GCW of 60 or 100 tonnes. On the Scania S-series the weights Scania’s specifications give follow the rear axle, but they are not a plated rating: they are what each type of rear axle gear can handle, stated as gross vehicle and train weight — up to 78 tonnes for a single driven single-reduction axle and up to 210 tonnes for a tandem hub-reduction group, while for its R756 rear axle Scania states “up to 53 tonnes GTW”. Read the plate, then read the gearbox designation and the rear axle type.

Where the make is a recent arrival in Europe, the approval rules, and what some of those makers have published about approval, workshops and parts, quoted from their own documents, are set out in new truck brands entering Europe.

The document list

Before money moves, have these in hand: the registration certificate, its VIN checked against the manufacturer’s statutory plate and against the VIN marked on the chassis, frame or similar structure, both of which Implementing Regulation (EU) 2021/535 requires of vehicles type-approved to it from 6 July 2022, as Regulation (EU) No 19/2011, since repealed, did of vehicles type-approved to it before that date; the consecutive roadworthiness certificates with their odometer readings; the CoC or the manufacturer’s customer information file for the CO2 class; the date of the last tachograph inspection; the ADR certificate of approval if the work needs one, read against its own expiry date; the ATP certificate where the truck will carry perishable foodstuffs internationally, whose six-year and three-year clocks are explained in refrigerated transport and temperature records; and the EN 12642 XL certificate and body plate where the vehicle is sold as XL-rated, because the roadside inspection table set out in load securing qualifies its grading of the strength of the front wall, board walls and rear wall with “certificate or label if applicable”. One document does not come with the truck: certified true copies of the Community licence are issued to the licence holder, one for each vehicle at its disposal, and what it takes to hold one is set out in the road transport operator licence.