A three-year transport contract signed today will already cover the period when ETS2 is in force. 2028 may seem far off, but the system will change the economics of road transport in ways worth factoring into your planning now – especially since allowance auctions begin in 2027, a year before the system fully applies to transport.
What ETS2 is
ETS2, the new EU emissions trading system for CO2, will cover fuel combustion in road transport, buildings and small industry from 2028. Unlike the original ETS (which covers large industrial installations and the power sector), ETS2 is a fuel-based system – the cost of emissions goes straight into the price of fuel.
How this will translate into costs
According to estimates by the Italian industry federation Federtrasporti, a truck covering about 100,000 km a year will face an additional cost of around EUR 6,000 a year – this is an industry estimate based on an assumed allowance price, not an official EU calculation. The cost of emission allowances will be passed into the price of fuel and energy, so the ones actually paying will be transport companies and, as a result, their customers.
This will hit smaller transport companies especially hard, since fuel is one of their main operating costs and they have less flexibility in negotiating long-term fuel contracts.
What to include in transport contracts now
- price adjustment clauses that account for possible changes in fuel costs and road tolls,
- force majeure clauses tailored to the risk of further amendments to emissions regulations,
- flexibility in multi-year contracts, so rates are not “frozen” at pre-ETS2 levels.
Why it makes sense to talk about this as early as 2026
Companies planning transport over a longer horizon (annual agreements, framework contracts) will be negotiating terms that already cover the period when ETS2 applies. Being aware of this mechanism at the negotiation stage helps avoid an unpleasant surprise when rates are renegotiated two years from now. In June 2026, the Council of the EU and the European Parliament also agreed to strengthen the ETS2 market stability mechanism (including faster, gradual release of allowances from the reserve), so that the allowance price does not spike sharply before the system fully starts.
Frequently asked questions
Does ETS2 apply only to large transport companies?
No. It affects the whole market through the price of fuel, but it weighs relatively most on smaller companies with less bargaining power with fuel suppliers.
Is there any way to protect yourself against higher costs from ETS2?
Partly. A lower-emission fleet (newer vehicles, alternative fuels) will be relatively less affected. It is worth asking your carrier about this now if you are planning long-term cooperation.
Is ETS2 the same as the existing emissions-based road tolls (for example the CO2 surcharge in the German truck toll (Maut), in effect since December 1, 2023)?
They are separate mechanisms. Emissions-based road tolls are national and apply to specific roads and bridges, while ETS2 is a Europe-wide system built into the price of the fuel itself, regardless of the route.
Ask us about our strategy for cost changes in the coming years
We are already planning our fleet with ETS2 in mind from 2028. Let’s talk about how the system will affect the cost of your long-term transport and how to reflect that in your contract. More on the Mobility Package and the rules for carriers: “Mobility Package – regulations for carriers“. Call +48 508 546 540 or email jasek@jasek-transport.pl.
Photo: inspirestock / 123RF
