"When does the CO2 surcharge on diesel actually hit?" I hear that question a lot. On calls with freight forwarders about their freight calculation and diesel costs, since spring. The answer usually comes with it. "2028, right? ETS2 got pushed back." Both halves are only half true. ETS2 is pushed back. The surcharge is not.
ETS2 is the EU carbon market for buildings and road transport. Its legal base is Directive (EU) 2023/959. It was meant to start in early 2027. EU environment ministers agreed on a one-year delay in November 2025. The regulation appeared in the Official Journal on 18 March 2026. In force since 7 April 2026, reports IHK Karlsruhe. Full operation now starts in 2028. The Commission still plans to auction certificates from January 2027. The goal: an early price signal, ahead of the real start.
That delay only touches the EU layer. Germany has run its own scheme since 2021. The national fuel emissions trading scheme, BEHG or nEHS for short. It keeps running unchanged. It is the bridge until ETS2 arrives. For 2026, a price corridor applies. 55 to 65 euros per tonne of CO2, explains DEHSt, the German emissions authority. The price forms through weekly auctions. At the Leipzig energy exchange. The first auction in July 2026 hit the ceiling right away. 65 euros. Demand ran far ahead of supply. Bidders at the top price got only a fraction of what they asked for. Missing certificates are available from November 2026 at a fixed price. 68 euros per tonne.
For 2027, a draft law is now on the table. The third BEHG amendment, reported by the Bundestag, file 21/7869. It carries the corridor forward. 55 to 65 euros again. Without that draft, the price would have followed the open EU market. Values between 75 and 85 euros were seen as possible. Parliament and the Bundesrat still need to approve it. The first reading took place on 24 September 2026, after which the bill went to the environment committee. It has not been passed yet. The direction is clear regardless. The surcharge stays in the same range through 2027. Only the name changes later. From BEHG to ETS2.
The official emission factor for diesel sits in Annex 2 of the EBeV 2030, the German reporting regulation. 0.074 tonnes of CO2 per gigajoule. Calorific value 42.8 gigajoules per tonne. Density 0.845 tonnes per 1,000 litres. My own calculation from those figures: 42.8 times 0.845 times 0.074. Result: about 2.68 kg of CO2 per litre of diesel.
Multiplied by the price corridor, that gives the surcharge per litre:
The jump from 14.7 to 17.4 cents already happened. With the first auction in July 2026. If your diesel floater tracks a public price index, you already absorbed that jump. Fuel suppliers price the certificate cost into the pump price well before you see it. It looks different once the CO2 share needs to stand on its own. Say a customer asks for the emission value per shipment. Or the freight contract carries a separate CO2 clause. Then the number needs to be split out. That is where the real work starts.
At the forwarders we work with, the CO2 share has no column of its own. It sits inside the litre price on the fuel card statement. Invisible there. The diesel floater tracks an index, not a CO2 component. Accounting books the full litre price as fuel cost. Ask about the CO2 share, and there is no answer. Only a guess.
The data flow for this already exists, just not wired together. The fuel card gives litres per vehicle and day. Telematics gives the route and the trip. The TMS gives the customer and the freight contract. An agent pulls all three sources together. It joins on plate number and calendar day. The same pattern that holds up in toll reconciliation. Then it multiplies litres per trip by the current CO2 price. The result: a new column in the invoice. CO2 share in euros, per trip, with date and corridor value attached.
For dispatch, little changes at first. The trip runs as planned. For billing, more changes. The diesel floater gets a second, visible component. Instead of one blended index number. Price talks with customers now rest on a documented line. Instead of a gut feeling. We described the same effect in our ISO 14083 post. Just from the other direction. That piece covered the emission value per shipment. For reporting. This one covers the cost share per litre. For pricing. The data sources are almost identical. The question behind them is not.
Two things decide whether the join holds. First, the date. The fuel card statement carries a booking date. It can sit days after the actual fill-up. Same issue as with toll data. Join on booking date instead of fill date, and you land on the wrong day in the corridor. Second, vehicle mapping. Not every fuel card ties cleanly to one plate number. Some fleets share cards across vehicles. Both cases land in the log. As an open item, with a reason. Not as a silent gap in the invoice. A process that quietly miscalculates costs more. More than one that flags a card for review once a week.
What happens in 2027 depends on that draft law. It still needs to pass parliament and the Bundesrat. What happens in 2028, once ETS2 runs at full scale and the price loses its cap, is not settled yet. That is not a solid number today. Only an expectation. What is already certain: the surcharge is real. It sits in the litre price. The first auction already raised it by about 2.7 cents per litre in July 2026. Miss that number in your pricing, and you are negotiating with last year's figure.
Does your diesel floater split out the CO2 share, or does it sit hidden in the index? If the latter: send me an anonymized fuel card statement and a week of telematics data. I will show you the log of the join that builds the column. More on our logistics processes.
