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Members Corner
In the view of the Deutsches Verkehrsforum e.V. (DVF), the draft of the 3rd Toll Amendment Act submitted to the cabinet for decision on Wednesday leaves important questions unresolved. For example, the CO2 surcharge of €200 per tonne is close to the permissible upper limit, thereby creating incentives to shift to low-CO2 engines. At the same time, said draft does not allow alternative fuels to be taken into account in order to reduce the CO2-based toll rate.
"Given the limited supply of alternative drive systems that are ready to be put to use, especially in the heavy goods vehicle segment, and the charging infrastructure that is not yet available across the board, alternative fuels are still the only way to reduce significantly CO2 emissions in road freight transport on many routes. The HVO100 has just been approved. This important step must also be reflected in the way the toll is structured in order to create an incentive effect. Improvements are urgently needed here," demands Dr Jörg Mosolf, Chairman of the DVF Steering Committee on Freight Transport and Logistics.
"Similarly, double charging through CO2 tolls and the CO2 surcharges on fuels must be avoided," Dr Mosolf makes clear. The toll amendment should only be implemented if double charging via the Brennstoffemissionshandelsgesetz (BEHG) [Fuel Emissions Trading Act] agreed in the resolution of the coalition committee is avoided, because only in this way could distortions of competition for German transport companies due to national regulations be ruled out. "A corresponding compensation mechanism should be worked out together with the industry. It is important to make this as non-bureaucratic as possible," Dr Mosolf said.
Dr Mosolf considers the target date of 2023 December 1 for implementation to be very tight in view of the necessary contract adjustments with customers. The same holds for the envisaged date for extending the mandatory toll limit to vehicles with a total weight of over 3.5 tonnes. These would first have to be equipped with on-board units. Delays due to delivery bottlenecks as well as installation costs should be expected. The latter could become an unsustainable financial burden for some companies. "Planning and legal certainty are essential for the industry. Particularly in view of the implications of the toll amendment for the industry, proceeding with post-haste should be avoided in order to ensure both. This means that the CO2 toll should be introduced only once the weak points that are already known today have been eliminated,” Dr Mosolf explains.