EU road tolls and CO2 emission classes: what the class changes

Two tractor units with the same certified CO2 figure, the same load on the same motorway, and two different toll bills. The difference need not be in the truck: it can be a classification that measures that certified figure against the rules for the reporting period in which each was first registered.

That classification is the CO2 emission class. It arrived with Directive (EU) 2022/362, which amended Directive 1999/62/EC on the charging of vehicles for the use of road infrastructures — the Eurovignette Directive. The parent directive is still the instrument in force: its EUR-Lex masthead reads In force, and the consolidated text is dated 24 December 2025, the day the most recent amendment took effect. Every provision of the directive quoted below is read from that consolidated version.

A toll is not one charge

Article 2(1)(7) defines a toll as a specified amount payable in respect of a vehicle, based on the distance travelled on a given infrastructure and on the type of vehicle, and consisting of one or more of three things: an infrastructure charge, a congestion charge, or an external-cost charge. Three separable components.

They recover different money. Article 7b ties the weighted average infrastructure charge to the construction costs and the costs of operating, maintaining and developing the infrastructure network concerned. Article 2(1)(9) makes the external-cost charge a charge for recovering the costs related to one or more of traffic-based air pollution, noise pollution and CO2 emissions. Article 7ca(3) makes one of those compulsory: from 25 March 2026 Member States shall apply an external-cost charge for traffic-based air pollution to heavy-duty vehicles on the tolled network referred to in Article 7(1) — the trans-European road network or sections of it, plus any additional sections of the national motorway network. Roads tolled under Article 7(2) — those belonging to neither — fall outside the obligation; that paragraph binds them only to Article 7(4) and (5), Article 7a and Article 7j(1), (2) and (4). Two derogations are written alongside the obligation, and a third, for concession contracts, comes at the end of this article. The two: the second subparagraph of Article 7ca(3), for sections where the charge would divert the most polluting vehicles at a cost to road safety and public health, and the second subparagraph of Article 7(4), for the tolls on bridges, tunnels and mountain passes that a Member State which imposes a user charge on its network may also impose, where the differentiation would not be technically practicable or would cause that same diversion; a Member State that uses it “shall notify the Commission of its decision”.

A user charge is the alternative, not a fourth component: Article 2(1)(16) makes it a specified amount buying the right to use the infrastructure for a period, and Article 7(4) forbids imposing both a toll and a user charge on the same category of vehicle for the same road section — except, in the very next sentence of that paragraph, that a Member State which imposes a user charge on its network may also impose tolls for the use of bridges, tunnels and mountain passes. Annex II caps it at €1,649 a year for a Euro VI vehicle with a minimum of four axles, and Article 7a(2) caps the daily rate at 2 % of the annual one — €32,98 at that ceiling, our arithmetic rather than the directive’s. From 25 March 2030, Article 7(10) stops Member States applying user charges to heavy-duty vehicles on the core trans-European transport network, with two written exits: the duly justified sections Article 7(11) allows on prior notification to the Commission, where a toll would involve disproportionate administrative, investment and operating costs compared to the expected revenue or benefits, or would lead to the diversion of traffic with negative impacts on road safety or on public health, and the combined charging system Article 7aa(2) permits notwithstanding Article 7(10) to a Member State that applied tolls on its core trans-European transport network, or on part of it, before 24 March 2022. Outside the EU, Great Britain’s HGV road user levy is likewise a charge for a period rather than for distance; see HGV road user levy.

The five classes

Article 7ga(2) requires Member States to establish five CO2 emission classes for each type of heavy-duty vehicle.

Read the third column carefully. Article 7ga(1) requires Member States to vary infrastructure charges and user charges in accordance with the article, and Article 7ga(3) measures its bands against “the charge applicable for CO2 emission class 1”. The bands bind those two charges and say nothing about an external-cost charge levied alongside them.

Class 4 is also narrower than it looks. Article 2(1)(30) defines a low-emission heavy-duty vehicle as either one meeting the definition in Article 3, point 12, of Regulation (EU) 2019/1242 — specific CO2 emissions below half the reference emissions of its vehicle sub-group — or, for a vehicle not covered by Article 2(1), points (a) to (d), of that Regulation, one whose CO2 emissions are lower than 50 % of the reference emissions of its vehicle group, other than a zero-emission vehicle. Sub-group and group are not the same denominator, and which limb applies depends on the vehicle.

Where the number comes from

Article 2(1)(28) connects the toll to a certification document: the CO2 emissions of a heavy-duty vehicle are its specific CO2 emissions given in point 2.3 of its Customer Information file under Commission Regulation (EU) 2017/2400. That is the VECTO result described in tractor unit running costs: a certified simulation output rather than a road measurement. In Germany the Customer Information File is also among the evidence Toll Collect lists for an application to change a vehicle’s CO2 class.

The threshold it is measured against is defined in Article 2(1)(37): the emission reduction trajectory for the reporting period of a year and a vehicle sub-group is the annual CO2 emissions reduction factor multiplied by the sub-group’s reference CO2 emissions, and for years after 2030 the directive fixes that factor at 0,70.

Reporting period, not calendar year — the distinction decides which trajectory a truck is measured against. Article 7ga(2) defines classes 2 and 3 by vehicles “registered for the first time in the reporting period of the year Y” and measures them against the trajectory “for the reporting period of the year Y”. Article 2(1)(36) takes the term from Article 3, point 3, of Regulation (EU) 2019/1242, where the reporting period of the year Y is the period from 1 July of the year Y to 30 June of the year Y+1. On that definition a vehicle first registered in March 2026 falls in the reporting period of 2025 and is judged against the 2025 trajectory, and thresholds step on 1 July rather than 1 January. Applying the class definitions to the formula at that fixed 0,70 factor, a vehicle first registered in a reporting period after 2030 — that is, from 1 July 2031 — needs CO2 emissions below 0,665 of its sub-group reference for class 2 and below 0,644 for class 3 — both figures our arithmetic from that formula, neither printed in the directive. On those figures 2,1 percentage points of the sub-group reference separate the two middle classes, again our arithmetic.

The timetable is written in relative terms rather than calendar dates. Article 7ga(1) applies the variation to the sub-groups covered by Article 2(1), points (a) to (d), of Regulation (EU) 2019/1242 at the latest two years after the reference CO2 emissions for those sub-groups are published in implementing acts under Article 11(1) of that Regulation. That cross-reference now points at wording the Regulation no longer carries: points (a) to (d) as adopted were four lorry and tractor configurations — 4x2 and 6x2 rigids and tractors, the 4x2 variants above 16 tonnes — and since Regulation (EU) 2024/1610 replaced Article 2(1) the scope is stated in points (a), (b) and (c) by vehicle category instead.

For groups of heavy-duty vehicles outside that original scope, classes 1, 4 and 5 apply on a matching two-year rule keyed to implementing acts under Article 7ga(7), and the fourth subparagraph of Article 7ga(1) brings in classes 2 and 3 from the entry into force of emission reduction trajectories set by a Union legislative act amending point 5.1 of Annex I to that Regulation. On our reading, that act is not hypothetical. Regulation (EU) 2024/1610 replaced Annexes I and II to Regulation (EU) 2019/1242 outright, and point 5.1 as replaced defines a trajectory for each vehicle sub-group and reporting period, taking its target years from the set {rY, 2030, 2035, 2040} for every sub-group beyond the original lorry set — the coach and Class II low-entry-bus sub-groups and the urban-bus sub-groups listed in point 4.2 among them. It entered into force twenty days after its publication in the Official Journal of 6 June 2024, and applies from 1 July 2024. The trigger for classes 2 and 3 in those groups is therefore, as we read it, an act already on the books, not a pending future one. The thresholds are another matter. Point 3.2 of that Annex sets the reporting period of 2025 as the reference period for every sub-group other than 4-UD to 10-LH (reference period 2019) and 1, 2, 3, 11, 12 and 16 (reference period 2021) — the coach, bus and urban-bus sub-groups among them — and under Article 11(1) the reference CO2 emissions for a reference period are included in the list to be published by 30 April of the year following the year in which that period ended. The reporting period of 2025 ended on 30 June 2026, so that list is due by 30 April 2027 — our arithmetic from those two provisions — and until the reference emissions those trajectories multiply are published, a class 2 or class 3 threshold cannot be computed for those groups. In Germany, Toll Collect states that for vehicles outside sub-groups 4, 5, 9 and 10 “no threshold values for CO₂ emissions have been defined so far”, so that vehicles in other groups “can currently only be classified under CO₂ emission class 1, unless they are zero-emission vehicles”.

What the German tariff actually does

Germany makes a worked example because the operator publishes the components. Toll Collect’s rate table, in force since 1 July 2024, splits the per-kilometre rate into infrastructure, air pollution, noise and CO2 shares, and BALM confirms the same four-part structure. For a Euro 6 vehicle over 18 tonnes with five or more axles the rows differ in exactly one place.

The infrastructure share does not move across the CO2 classes. Everything the CO2 class buys comes out of the CO2 component, and on that component alone the reductions are 5,1 %, 10,1 % and exactly 50,0 % — our arithmetic from the published figures. Against the whole rate they are 2,3 %, 4,6 % and 22,7 %. A fleet expecting the 30-to-50 % band of Article 7ga(3) to land on its invoice is reading the wrong charge. At 100,000 tolled German kilometres a year that is €34,800 against €26,900 — €7,900 apart, again our arithmetic.

The directive permits this shape. Article 7ga(5) lets a Member State decline to vary the infrastructure charge where an external-cost charge for CO2 emissions is levied and varied according to the reference values in Annex IIIc. For a heavy goods vehicle above 32 tonnes or with five or more axles, Annex IIIc — in the consolidated text, whose euro values were last updated in March 2025 — sets 9,3 cent for class 1 at Euro IV to VI and 4,7 cent for a low-emission vehicle, against Germany’s 15,8 and 7,9 in its table from July 2024: 1,70 and 1,68 times the Annex IIIc values, our arithmetic. Article 7cb(1) lets a Member State apply higher external-cost charges for CO2 emissions than those reference values, in a non-discriminatory manner and “limited to no more than twice the values set out in Annex IIIc”, and requires it to justify the decision and notify it to the Commission.

The class depends on the registration date, and it moves

Toll Collect assigns every vehicle to CO2 emission class 1, states that vehicles first registered before 1 July 2019 are therefore correctly classified, and says legal requirements prevent those vehicles being moved to a higher class. Reclassification is on application through its customer portal, and the suitable evidence Toll Collect lists includes the vehicle registration certificate, the manufacturer’s Customer Information File, the certificate of conformity and an individual authorisation form. For anyone buying second-hand for German toll roads that 1 July 2019 date is a hard one, and it belongs beside the checks in buying a used truck.

Movement is not one-way, and it runs on two clocks. The first is written into Article 7ga(2): a class 2 or class 3 vehicle is reassessed every six years after the date of its first registration and, where relevant, reclassified against the thresholds applicable at that time, the reclassification taking effect for a user charge at the latest on its first day of validity on or after the day of reclassification. That clock is set individually, by each vehicle’s own registration date.

The second is German practice rather than a mechanism the directive spells out. Toll Collect’s notice of 1 July 2026 announced that from that date the classification of trucks with a technically permissible maximum laden mass above 16 tonnes was changing, because the limit values used to categorise a vehicle were falling: a vehicle classified in class 3 in 2025 “may fall into class 2 or 1 in 2026”, and the changed categorisation leads to higher toll costs. The notice attributes the change to new EU regulations adopted in December 2025 without naming them; Toll Collect’s CO2-class questions and answers do: Commission Implementing Regulation (EU) 2025/2545 of 15 December 2025 “updated the reference values for vehicle (sub)groups 4, 5, 9 and 10, which will come into force on 1 July 2026”. That regulation, adopted under Article 11(2), point (a), of Regulation (EU) 2019/1242, sets adjusted reference CO2 emissions for sub-groups 4-UD to 10-LH “for the reporting period of the year 2025 and onwards”. The same Toll Collect page says the “relevant threshold value depends on the vehicle sub-group and the vehicle’s initial registration date”, and its table gives class 2 a validity of “6 years from the date of first registration, then reclassification” and class 3 “at least 6 years from the date of first registration of the truck (or the start of the first validity period), then reclassification”. Neither Toll Collect source explains how the 1 July 2026 change applies to vehicles already classified; the notice goes no further than the “may fall into class 2 or 1 in 2026” quoted above. On our reading the German change is not the six-year cycle firing: that clock runs from each vehicle’s own first registration and cannot change the classification of trucks above 16 tonnes as a group on a single date.

Zero emission, and the date that now matters

Class 5 is the only class where the directive allows more than a discount. The fifth subparagraph of Article 7ga(1) lets Member States provide reduced rates of infrastructure or user charges, or exemptions from them, for zero-emission vehicles of any vehicle group from 24 March 2022 until 30 June 2031; from 1 July 2031 such reductions “shall be limited to 75 % compared to the charge applicable to CO2 emission class 1”. Those two dates came in with Directive (EU) 2025/2459 of 26 November 2025, whose only amending article replaces 31 December 2025 with 30 June 2031 and 1 January 2026 with 1 July 2031. Any source still quoting the end of 2025 is quoting superseded wording. Those dates are not the only route for the lightest zero-emission vehicles: Article 7(9)(d) separately lets Member States provide for reduced tolls or user charges, or exemptions, for zero-emission vehicles with a technically permissible maximum laden mass up to 4,25 tonnes, with no end date in that point.

Germany moved with it. The Fourth Act amending toll regulations came into force on 1 December 2025 and extended the existing exemption for zero-emission trucks to 30 June 2031, which Toll Collect describes as the government using the full period the Eurovignette Directive permits. For a battery-electric tractor such as the eActros 600 that is an exemption from the German toll, not a reduced rate. It is also finite: as extended, it runs to 30 June 2031. Battery-electric trucks themselves, from how they are built to where they charge, are covered in electric trucks and tractor units explained.

What the directive does not decide

It does not decide whether you are charged. Article 7(1) says Member States may maintain or introduce tolls and user charges; the mandatory parts govern how a charge is structured once it exists. Nor does it reach every road at once. For infrastructure covered by concession contracts, Article 7(7) lets a Member State choose not to apply Article 7ca(3), Article 7g(1) and (2), Article 7ga and Article 7gb — the mandatory air-pollution charge, the time-of-day and Euro-class variations of the infrastructure charge, the CO2 variation for heavy-duty vehicles and the environmental-performance variation for light-duty vehicles — to tolls and user charges on those infrastructures, until the concession contract is renewed or the tolling or charging arrangement is substantially amended. Two things trigger it, not one: the contract signed before 24 March 2022, or the tenders or responses to invitations to negotiate under the negotiated procedure received in a public procurement process before that date. Article 7(8) extends the same treatment to long-term contracts between a public and a non-public entity signed before 24 March 2022 “for the execution of works and/or the management of services other than the execution of works not including the transfer of the demand risk”. Article 7ga(11) goes further again: the CO2 variation “shall not be mandatory where another Union road transport fuel carbon-pricing measure applies”.

And it does not merge the CO2 class with the Euro class. Article 7g(2) requires Member States to vary the infrastructure charge according to the Euro emission class of the vehicle, so that no infrastructure charge is more than 100 % above the same charge for equivalent vehicles meeting the strictest Euro emission standards — until the Article 7ga variation is applied, after which they may discontinue it. Article 7ga(3) provides that where the infrastructure charge or the user charge is also varied by Euro class, the CO2 reductions are measured against the charge applied to the strictest Euro emission standards.

Germany’s published table does not vary the infrastructure share by Euro class: for a vehicle over 18 tonnes with five or more axles it is 15,5 cent at every Euro step from Euro 0 to Euro 6. The second subparagraph of Article 7g(2) lets a Member State decide not to vary the infrastructure charge where, among other cases, “the toll includes an external-cost charge for air pollution”, as the German toll does; the table itself does not name the provision Germany relies on. What still varies by Euro class in the German rate is in the external-cost columns: the air-pollution component, 18,7 cent at Euro 0 against 2,3 at Euro 6 in that same axle and weight class, and, by less, the class 1 CO2 component, 16,2 cent at Euro 0 to Euro 3 against 15,8 at Euro 6. The table heads both columns proportion of toll rate for external costs. That is a different charge under a different provision: Article 7c(1) requires an external-cost charge applied to heavy-duty vehicles to be varied in accordance with Annex IIIa and to respect the reference values in Annexes IIIb and IIIc; Annex IIIb, which carries the air pollution and noise values, is banded Euro 0 to Euro VI with a further band for vehicles less polluting than Euro VI, and Annex IIIc bands its class 1 CO2 values by Euro class too. Which is why the Euro VI step and the CO2 class are two separate questions.

Which countries do charge heavy trucks, per kilometre or with the Eurovignette, and how to pay there, is set out country by country in truck tolls in Europe and the Eurovignette.