At the end of 2025, the European Union institutions agreed to postpone the start of the new Emissions Trading System ETS2 by one year, and this decision was finally confirmed in March 2026. The system covering road transport fuels will fully come into effect in 2028. This gave carriers more time, but did not eliminate either the future CO₂ price or the need to prepare for it.
Allowances will have to be purchased and submitted not by carriers, but by ETS2 regulated entities, usually fuel suppliers responsible for excise duty; costs will likely be reflected in the price. Using an illustrative price of 45 EUR per ton of CO₂, the ETS2 component would amount to about 11 cents per liter of diesel excluding VAT. For a fleet of one hundred trucks, this could mean about 400 thousand EUR per year. So what should be done by 2028 to ensure the new cost item does not become an unexpected blow to the margin?
Delayed start, but not preparation
ETS2 will be separate from the current EU Emissions Trading System (ETS), which covers electricity and heat production, energy-intensive industry, aviation, and maritime transport. It will operate at the start of the supply chain: emissions from fuels released for use will be accounted for not by transport companies, but usually by ETS2 regulated entities responsible for excise duty. They must monitor emissions from 2025 and submit annual reports by April 30 of the following year. Allowance auctions will begin in 2027. Allowances for CO₂ emitted in 2028 must be submitted by May 31, 2029.
Artūras Michejenko, head of the leading B2B payments and solutions platform for road transport in the Baltics, DKV Mobility, emphasizes that the additional year should be seen not as a pause but as preparation time.
“The delay is only beneficial if the company turns it into concrete work. If until the first auctions it only monitors the overall fuel price, the results may catch the company unprepared. It is already necessary to know how many liters are consumed on each route and how different CO₂ price scenarios would reduce the margin,” says A. Michejenko.
Early auctions will provide the first real price signal, but by themselves will not mean a mandatory ETS2 surcharge on fuels as early as 2027. Carriers themselves will not need to buy or return ETS2 allowances. Whether and how costs are passed on will depend on the supplier’s pricing and invoicing model. However, a large part of the costs of purchasing, administering, and managing the risk of allowances incurred by suppliers will likely be included in the fuel price. As the allowance price changes in the market, the CO₂-related diesel price component may fluctuate, but its size and timing will depend on the specific supplier’s pricing and contractual terms.
11 cents – just a reference point
45 EUR per ton of CO₂ is not a strictly set ETS2 price cap, although this amount is often understood as such. It is the threshold of the price stabilization mechanism set at 2020 prices and indexed for inflation. According to current rules, if the average ETS2 allowance auction price exceeds this threshold for two consecutive months, 20 million additional allowances are released from the market stability reserve. In June 2026, the EU Council and European Parliament preliminarily agreed to double the number of allowances released at once to 40 million, but the change still needs to be finally adopted.
“Basing the budget solely on the assumption that a ton of CO₂ will cost 45 EUR would be overly optimistic. Carriers should calculate a baseline and at least two less favorable scenarios, for example, 75 and 100 EUR per ton. Then it will be clear on which routes the planned margin remains and where pricing or the business model needs to be changed,” explains A. Michejenko.
Additional supply should dampen price spikes, but it does not guarantee that the market price will not exceed this threshold. It will be determined by allowance demand, fuel consumption, and the overall pace of emission reduction. Therefore, 11 cents per liter should be considered as one of the planning scenarios, not as a diesel price forecast for 2028.
The difference is best illustrated by a simple example. It is assumed that burning one liter of B7 diesel emits about 2.47 kg of fossil CO₂; the actual coefficient depends on the fuel composition and certified biogenic content. If 100 trucks travel 120,000 kilometers per year, with average consumption of 30 liters per 100 kilometers, the entire fleet would need 3.6 million liters of diesel. At a price of 45 EUR per ton, the ETS2 component would amount to about 400 thousand EUR excluding VAT. If the price rises to 75 EUR, it would be about 667 thousand EUR, not including possible supplier administration and risk management costs.
Additional years must turn into data
“First, you need to organize the data and see where the fuel is actually consumed. Only then can you assess how the final result would change with a different route, less empty mileage, more economical driving, or alternative fuels,” says A. Michejenko.
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Reliable modeling requires more than just the total annual fuel budget. Actual data on fuel consumption by vehicle, fuel type, country, route, and client are needed. Data collected from 2025 to 2027 can become a reference base showing not only the sensitivity of the entire fleet but also of a specific trip to the CO₂ price.
For example, on a 1,500-kilometer trip, a truck with average consumption of 30 liters per 100 kilometers would use about 450 liters of diesel. Applying a CO₂ price of 45 EUR per ton, the ETS2 component for such a trip would be about 50 EUR, and at 75 EUR price – about 83 EUR. For a single order, the difference may seem small, but on regular routes it quickly adds up over a year.
“DKV Analytics” provides data on fleet expenses, fuel consumption, and other performance indicators in one place. The “Premium” version allows applying advanced filters and exporting data. It integrates “DKV Carbon Monitor,” which calculates the CO₂e amount for fuel refueling and charging operations registered via DKV Mobility and separately shows emissions from energy production and supply (WTT), vehicle use (TTW), and total (WTW). The carrier must model the ETS2 cost scenario themselves: multiply the actual amount of each fuel type by the applicable fossil CO₂ emission factor and the chosen allowance price, and assign the result to a specific route or client. The overall WTW CO₂e indicator is not a direct basis for ETS2 cost calculation.
CO₂ price – into budgets and contracts
In the 2027 budget, future ETS2-related costs should be planned as a separate scenario or reserve, and in 2028 as a separate variable cost component, rather than including them in the overall fuel price increase percentage. Once auctions begin, calculations can be updated based on the actual allowance price. Until then, companies can determine how many liters correspond to different clients and routes, what size reserve is needed, and from what threshold an order becomes unprofitable.
“If a fixed-rate contract valid until 2029 is signed in 2027 without a clause for tariff recalculation due to ETS2 or legislative changes, the future CO₂ price risk may fall on the carrier. A clear recalculation formula is also beneficial for the client: it shows where the price change comes from and helps avoid rushed negotiations once the system starts operating,” notes A. Michejenko.
More attention should be paid to long-term contracts valid in 2028 and beyond. They can predefine which allowance price source and emission factor will be used to adjust the tariff, how often it will be reviewed, and whether the tariff will decrease as the allowance price falls, just as it increases. If the current fuel surcharge is already linked to a price index that later reflects ETS2 costs, the formula must be checked to ensure the same component is not counted twice.
HVO – one of the measures, but not a universal answer
One alternative to consider is HVO fuel, produced from renewable raw materials and usable instead of conventional diesel. If the biogenic fuel content is properly certified and meets EU sustainability and greenhouse gas reduction criteria, a zero emission factor may be applied to it in ETS2 accounting. However, a zero emission factor cannot be automatically applied to every liter of HVO: ETS2 accounting depends on fuel origin, sustainability evidence, and blend composition, and practical use requires approval from the specific truck manufacturer.
The economic benefit of HVO should be assessed based on the price difference between it and conventional diesel, availability on the chosen route, and the real life cycle CO₂e reduction. Elsewhere, better trip planning, less empty mileage, or a few percent reduction in fuel consumption will bring more benefit. It is important to compare not a single measure but the entire transport cost.
“There will be no one solution for all routes. In some places, reducing empty mileage will be most cost-effective, elsewhere – trying HVO or renegotiating the price formula. It is important that by 2028 each measure is verified with its own numbers, not just general market forecasts,” summarizes A. Michejenko.
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