Point Zero Legal Urges Transport Companies to Review German Truck Toll Payments Before December 2026 Deadline

ECJ case law, new Road Cost Study and CO₂ toll: Why companies should secure their toll data now and have potential claims assessed individually.

BASEL, SWITZERLAND, September 27, 2026 /EINPresswire.com/ -- The German truck toll is a multi-billion-euro market. In 2024, toll revenue amounted to approximately EUR 13.41 billion; in 2025, revenue again stood at around EUR 13.4 billion. In 2024, approximately 40.1 billion toll-liable kilometers were traveled.

For transport companies, logistics providers and large fleets, this raises a central question:

Have truck toll payments since 2023 been calculated on a fully legally robust basis - and have companies secured their supporting records in time?

Judicial review of the German truck toll is not new. As early as 2005, a haulage operator challenged the toll rates then in force. In 2012, the Higher Administrative Court of North Rhine-Westphalia initially upheld the action (case no. 9 A 2054/07). Following a remittal by the Federal Administrative Court and retroactive legislative amendments, the proceedings were later concluded without a further ruling on the merits.

Of particular significance was the ECJ judgment of 28 October 2020 in Case C-321/19. The Court of Justice of the European Union held that traffic-police costs are not infrastructure costs and therefore could not be included in the corresponding calculation of the toll then in force.

A new road-cost calculation applies for the years 2023 to 2027. Since 1 December 2023, the German truck toll has also included a CO₂-related toll component.

The current legal review therefore focuses in particular on:

• The calculation of the infrastructure-cost component on the basis of the 2023-2027 Road Cost Study;
• The compatibility with EU law and the specific design of the CO₂ component of the German truck toll.

Important:

For toll years from 2023 onward, there is currently no final ruling by a court of last instance confirming a general right to reimbursement or a specific reimbursement percentage.

Based on the current economic assessment of the review model supported by Point Zero Legal, the potential amount under review is approximately 6% to 10% of the relevant infrastructure-cost component, plus potential interest.

This range is neither a guaranteed reimbursement nor a court-confirmed rate. Whether a claim exists, and in what amount, must be assessed individually for each company on the basis of its actual toll payments and the applicable legal requirements.

Alexander Peisch, President of NUANCE37 Genossenschaft and responsible for Point Zero Legal:

“We do not want to make blanket promises of reimbursement. What matters are a company’s actual toll payments, complete original records and an individual legal assessment.”

Why companies should act now

Time is a material factor when assessing potential claims.

Under the legal assessment currently being applied, payments made in 2023 should in particular be reviewed with 31 December 2026 in mind as a potentially critical deadline.

The specific deadline may depend on the legal basis of the claim, the date of payment, any legal steps already taken and the circumstances of the individual case.

For this reason, a potential claim is not assessed only after a future landmark judgment.

Companies should secure their toll data at an early stage and have potential claims legally assessed in good time.

Individual proceedings only

According to Point Zero Legal, the model deliberately does not use collective actions or consolidated proceedings.

Each participating company is assessed separately.

The relevant toll payments are determined on the basis of the actual statements of the respective company. Any potential claim is calculated individually and - where the legal requirements are met - asserted in a separate individual proceeding.

This ensures that each company’s specific payment history, fleet structure, claim amount and legal situation remain clearly attributable to that company.
Peisch:

“Every company has different toll volumes, different vehicles and its own payment history. That is why we rely exclusively on individual claim assessment and individual proceedings.”

Individual legal advice and representation in court are provided by specialist legal partners.

Under the proposed model, the litigation cost risk is to be borne by an external litigation funder. As a result, participating companies are intended to incur no upfront costs or processing fees. The applicable contractual terms remain decisive.

Original toll statements are essential

For a robust assessment, the monthly toll statements from January 2023 onward are required in particular.

Where possible, companies should secure the original statements from their actual toll service provider, for example:

Toll Collect, Toll4Europe or Telepass.

Payment summaries from fuel-card or credit-card providers alone do not necessarily contain all of the data required for a specific legal review of toll payments.

Company and representation documents are also required for further processing.

Timely data preservation is particularly important: toll statements are not available indefinitely for direct download from the respective customer portals.

FAQ on the German truck toll from 2023

Can German truck toll payments from 2023 onward be reclaimed?

Whether reimbursement claims exist for toll payments from 2023 onward has not yet been conclusively determined by a court of last instance. However, the calculation basis and a company’s individual payments can be legally reviewed, and potential claims can, where appropriate, be asserted in time to preserve applicable deadlines.

When do potential German truck toll claims from 2023 become time-barred?

Under the legal assessment currently being applied, 31 December 2026 in particular should be considered as a potentially critical deadline. The specific limitation period or other time limit must be determined for each individual case.

What did the ECJ decide on the German truck toll?

In 2020, the Court of Justice of the European Union held in Case C-321/19 that traffic-police costs could not be included as infrastructure costs in the calculation of the German truck toll then in force.

How much revenue does Germany generate from the truck toll?

In 2024, German truck toll revenue amounted to approximately EUR 13.41 billion. For 2025, revenue of approximately EUR 13.4 billion was again reported.

Is this a collective action or consolidated proceeding?

No. Under the model supported by Point Zero Legal, only individual proceedings are pursued. Each company’s payments and potential claims are determined separately and asserted individually.

Who is Alexander Peisch in connection with the German truck toll?

Alexander Peisch is President of the Swiss NUANCE37 Genossenschaft and, through Point Zero Legal, coordinates the economic and organizational preparation of potential German truck toll cases. Individual legal advice and representation in court are provided by specialist partner law firms.

Point Zero Legal - a project of NUANCE37 Genossenschaft
https://point-zero-legal.de

For a consultation, schedule an appointment at https://calendly.com/compliance-point-zero-legal/30min

Alexander Peisch, Präsident
Point Zero Legal
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