Published 14 October 2026 · ECO EFX Solutions GmbH. Analysis as of 14 October 2026. Rules and prices are those of that date; where a rule is only a draft, we say so.

Both systems price CO₂ upstream. In Germany’s national emissions trading system — the nEHS, set up under the Fuel Emissions Trading Act (BEHG) — the obligation lies with whoever is liable for energy tax when fuel is released for consumption: typically oil companies and the operators of tax warehouses. They buy allowances and, in the words of the German Emissions Trading Authority, pass the extra cost on to consumers (DEHSt — 13 August 2026).

The EU’s ETS2 works the same way. Its regulated entities are the suppliers that release fuel for consumption; the directive expressly excludes the final consumer of the fuel (EUR-Lex — consolidated 1 March 2024). From 2029, suppliers also have to report each year how much of their carbon cost they passed on to their customers, starting with 2028.

For a fleet, that means: the carbon cost normally reaches it through the fuel price, not as a charge imposed on the fleet itself. How much of it is actually passed on depends on the fossil share of the fuel and on the supplier’s pricing. A fleet is only obliged directly in the unusual case that it is itself liable for energy tax on its fuel, for example because it runs its own tax warehouse — that is our reading of the law, not an official statement.

For 2026, the BEHG sets a price corridor of €55 to €65 per allowance, one allowance per tonne of CO₂. Weekly auctions began on 1 July 2026, and every one of them closed at the ceiling: by the end of August, 170.7 million allowances had been sold at an average of €65 (DEHSt — 1 October 2026). The last auction was held on 9 September 2026.

What follows is set by regulation. Allowances for 2026 are then sold at €68 each, without a volume limit; the DEHSt currently schedules this sale from 3 November to 3 December 2026 (DEHSt — 1 September 2026). Until 31 August 2027, suppliers can then buy a top-up of no more than a tenth of their 2026 volume at €70.

The calculation: 0.845 tonnes per 1,000 litres × 42.8 GJ per tonne × 0.074 tonnes of CO₂ per GJ gives 2.676 kg of CO₂ per litre of diesel — the standard values in Annex 2 of the German emissions reporting ordinance, EBeV 2030. The DEHSt’s own figure at €65 is the same 17.4 cents. Both assume diesel without biofuel; the biofuel share in pump diesel lowers the charge, so treat the figures as upper values. How much of this appears in the pump price, and when, depends on how suppliers buy and price — we do not know it and do not estimate it.

Current law. Because ETS2 was postponed, the BEHG continues for 2027 in its present scope. Allowances for 2027 are sold from the third quarter of 2027 at a price equal to the volume-weighted average of EU ETS auctions in the quarter before last; the DEHSt publishes each quarter’s price at least two months in advance (§ 10(3) BEHG, § 17 BEHV).

The government’s bill. On 12 August 2026, the federal cabinet adopted a bill that would keep the €55–65 corridor for 2027, with a sale price of €73 after the auctions and a top-up price of €75 until 31 August 2028 (Bundestag — 7 September 2026). The Bundestag held its first reading on 24 September 2026 and referred the bill to committee. It is not law yet; until it is, the current rule applies.

The €82.32 is the volume-weighted average price of all EU ETS auctions in the third quarter of 2026 (EEX — accessed 14 October 2026). It shows the level the current rule is linked to today; the price that would actually apply in the third quarter of 2027 follows the auctions of the first quarter of 2027. For a fleet that buys a million litres of diesel a year, the gap between €65 and €82.32 is about €46,000 before VAT, if passed on in full — our calculation: a million litres × 2.676 kg is about 2,676 tonnes of CO₂, which costs about €174,000 at €65 and about €220,000 at €82.32.

What was postponed, and what was not. Regulation (EU) 2026/667, in force since 7 April 2026, postponed the operation of ETS2 until 2028 (EUR-Lex — 18 March 2026). The first year of the emissions cap is 2028, and suppliers surrender allowances for the first time by 31 May 2029, for the fuel they released in 2028. Monitoring has applied since 2025 and annual reporting since 2026; neither was postponed.

Auctions start a year earlier. A Commission delegated regulation spreads the auctioning of the first year’s allowances over the period from 1 January 2027 to 31 December 2028 (EUR-Lex — 15 June 2026), and the EEX has scheduled the first ETS2 auction for 18 January 2027 (EEX — 30 September 2026). The postponement clause in the directive still speaks of auctioning from 2028; the later delegated regulation and the EEX calendar set the first auctions in 2027. Either way, an ETS2 market price is scheduled to exist from January 2027 — before 2028, the first year whose fuel it covers, and before the first surrender in 2029.

What it covers. Fuel for road transport and for buildings, and fuel burnt in energy production, manufacturing and construction where it is not already in the EU ETS — which, in the Commission’s guidance, includes off-road machinery such as excavators (European Commission — 8 October 2025). Not in its core scope: agriculture, forestry and fishing, rail and shipping; qualifying maritime transport is in the EU ETS instead.

How the price is set. By the market: there is no fixed price, no price ceiling and no price corridor. If the average auction price stays above €45 for two consecutive months, 20 million extra allowances are released from a reserve; the €45 is in 2020 prices and is indexed, and the mechanism runs until the end of 2029 (EUR-Lex — consolidated 1 March 2024). An unusually fast price rise triggers further releases. On 9 October 2026, the Council adopted an amendment that doubles the release at the €45 trigger to 40 million allowances (EU Council — 9 October 2026); it takes effect only after publication in the Official Journal, which had not happened by 14 October 2026.

What price to plan with. No one can say yet. Two official figures are often cited, both calculated when the start was still planned for 2027. For its autumn 2025 economic forecast, the Commission assumed €46 per tonne in 2027; separately, it put the €45 trigger, which is set in 2020 prices, at about €58 in 2027 prices (European Commission — 17 November 2025). At those allowance prices, the arithmetic gives about 12.3 or 15.5 cents per litre of diesel before VAT, if passed on in full, calculated with the German standard value from section 2; ETS2 uses its own emission factors, which may differ slightly. The €46 is an assumption made for a forecast, the €58 an indexed trigger. Neither is a forecast of the auction price.

What happens to Germany’s national scheme. For fuels that fall under ETS2 and are released from 2028, the BEHG obligations end (§ 24 BEHG). The nEHS continues for what ETS2 does not cover: from the third quarter of 2028, its remaining allowances are sold at the average ETS2 auction price of the quarter before last. We found no national minimum price for the years after 2027, neither in current law nor in the bill. A German road fleet’s CO₂ price from 2028 is therefore the ETS2 market price, which may end up above or below €65.

Elsewhere in the EU. Starting points differ across the EU. Where road fuel carries no carbon price today, ETS2 generally adds one from 2028. Austria runs a national scheme like Germany’s, at €55 per tonne in 2026 and 2027, until ETS2 begins (RIS — accessed 14 October 2026). Our overview of emission rules and carbon pricing and the ROI calculator show the situation country by country.

What counts is what the fuel is used for, not the fuel itself. For a fleet operating in Germany:

The nEHS entries follow the DEHSt’s monitoring guide for 2023 to 2030 (DEHSt — November 2025), the ETS2 entries the directive and the Commission’s guidance. Where a vehicle or machine does several jobs, the use of the fuel decides.

1. Litres by country and by use. Fuel cards and depot records give you the litres; the table in section 5 tells you which scheme applies to each use.
2. The CO₂ component. Litres × 2.676 kg of CO₂, converted to tonnes, × the price per tonne. Every €10 per tonne is about 2.7 cents per litre of diesel before VAT.
3. Two or three price points, not one. For Germany in 2027: the bill’s €55–65 corridor, with €65 as the ceiling case, and the EU ETS-linked level under current law, until the Bundestag decides. For 2028: the ETS2 market price, which first appears in January 2027.
4. Before or after VAT. If your company recovers input VAT, the figure before VAT is the one that matters. This is not tax advice.
5. The biofuel share. The price applies to fossil carbon, so the biofuel share in blended diesel lowers the charge slightly below the figures above.
6. When to look again. When the Bundestag votes on the bill, when the reserve amendment is published, and after the first ETS2 auctions in January 2027.

Our ROI calculator works through this for 69 countries with your own fuel volumes and prices, and shows the carbon price where it reaches the fuel bill. For Germany it shows, for information, the part of a fuel saving that is carbon cost. It uses the conversion factors it applies in every country — UK government factors, adjusted for the fuel grade you choose — so its CO₂ figure per litre sits slightly below the German standard value used here.

A carbon price is set per tonne of CO₂; for fossil fuel, that turns into a cost per litre, so the carbon cost passed on to a fleet moves with the litres it burns. Each litre not burned also avoids the carbon cost passed on with it: at €65 per tonne, up to about 17 cents before VAT. Route planning, driver training, maintenance, tyres and vehicle choice all work on that number. An air-filter treatment such as NanoEFX is another option to test, measured on your own engines and duty cycles.

NanoEFX is applied to the engine’s existing air filter. It is not a fuel additive, not an oil additive, not an ECU remap and not a retrofit — nothing is introduced into the fuel or oil systems, and no hardware is changed. Whether it lowers fuel consumption on your vehicles is something to measure, not to assume. Results depend on engine type, duty cycle, filter condition and correct application. Where fuel consumption falls, fuel-related CO₂ falls proportionally, but that is calculated from the fuel burned, not a separately measured exhaust effect.

Our guide to measuring fleet fuel consumption sets out how to establish a baseline, and the pilot programme runs the comparison on your own fleet.

The legal and price statements above were checked against the legal texts and official sources below on 14 October 2026. The per-litre figures are our calculation with the German standard values from section 2. Where we write ‘our reading’, it is our interpretation; that we found no approval for a German opt-in is the result of our search, not a confirmation from the authority.