GHG quota for electric trucks: Save twice as much with an electric fleet & PV system

Brief overview

The GHG quota enables logistics companies to electric truck, selling avoided CO₂ emissions as tradable credits. Starting in 2027, the credit factor for heavy electric trucks (N3) and electric buses will increase from 3 to 4. For this vehicle category, this means a one-third increase in revenue volume at the same market price. Combined with the full toll exemption guaranteed by law until at least mid-2031 and a proprietary PV system—or one operated via Contracting—to supply charging power, the overall profitability of an electric truck fleet can be significantly improved. Long-haul vehicles with high mileage can easily achieve annual cost savings in the five-digit range by switching from fossil fuels to solar power.  

How the GHG quota works for electric trucks

The basic principle

The GHG quota (greenhouse gas reduction quota) is a legal instrument according to §§ 37a et seq. Federal Immission Control Act (BImSchG) in conjunction with the 38th Federal Immission Control Ordinance. BImSchG is the abbreviation for the „Federal Immission Control Act“ (Gesetz zum Schutz vor schädlichen Umwelteinwirkungen durch Luftverunreinigungen, Geräusche, Erschütterungen und ähnliche Vorgänge) and BImSchV stands for the “First Ordinance for the Implementation of the Federal Immission Control Act” (Erste Verordnung zur Durchführung des Bundes-Immissionsschutzgesetzes).

Accordingly, oil companies that market fossil fuels in Germany must reduce a growing proportion of their greenhouse gas emissions each year. Under the amendment, which was passed by the Bundestag in April 2026, the following stricter quotas apply:

• 2026: 12 %
• 2027: 17,5 %
• 2028: 19,5 %
• 2029: 22,5 %
• 2030: 26,5 %
• 2035: 41 %
• 2040: 65 %

Since electric trucks do not emit CO₂ during operation, there is a calculated difference compared to a comparable fleet of fossil-fuel vehicles. This difference can be certified as a verified GHG reduction and applied to companies subject to quotas sell. The Federal Environment Agency (UBA) checks the reported amounts of electricity and issues the certificates; on this basis, fleet operators or intermediary service providers conclude contracts with the mineral oil companies.

Crediting factors – why heavy electric trucks will particularly benefit from 2027 onwards

The electricity saved is not calculated on a 1:1 basis, but rather with a Multiplier credited, which depicts the propulsion efficiency of electric vehicles:

For heavy-duty electric trucks and electric buses, the factor will be specifically raised from 3 to 4 in 2027—a regulatory lever designed to accelerate electrification in the particularly investment-intensive heavy-duty segment. However, the factor of 4 will not apply permanently. Starting in the mid-2030s, it will be gradually reduced again to make the system more technology-neutral in the long term.

• By 2035: Factor 4.0
• Starting in 2035: Factor 3.5
• From 2036: Factor 3.0
• From 2037: Factor 2.5
• From 2038: Factor 2.0
• From 2039: Factor 1.5
• From 2040: Factor 1.0

For fleet operators, this means: The Time window running with the maximum crediting factor from 2027 to 2034. Anyone who makes the transition in this phase secures the highest revenue lever per vehicle.

Flat Rate vs. Actual Charging Current: How Is the GHG Emission Volume Actually Calculated?

For electric trucks, the amount of electricity eligible for the GHG quota is not derived by default or automatically from actual kilometers driven or measured charging current. Rather, the legislator sets it flat rate your vehicle class.

The flat-rate method (standard case)

For non-public charging stations—which are the norm for depots or in the case of Depot store – Accurate data collection from private charging infrastructure is possible only with significant effort. For this reason, the UBA uses fixed annual values:

• N2 (3.5–12 t): approx. 22,600 kWh/year
• N3 (>12 t): round 33,400 kWh/year

These values apply regardless of whether a vehicle is driven 50,000 or 120,000 km per year. For the simple case, Registration Certificate Part I is generally sufficient as proof.

The metering concept route (relevant for frequent drivers)

Anyone who drives significantly more than the flat rate assumes can instead report actually measured, calibration-law-compliant kWh values – provided that a corresponding metering concept is in place at the company charging points. In the case of a 40-tonne long-distance truck with 100,000 km/year and a consumption of 90 kWh/100 km, this mathematically results in around 90,000 kWh – almost three times the flat rate.

Why this is crucial for the business case

Only if the actual amount of electricity is significantly higher than the flat rate is the additional effort for a metering concept worthwhile. For a distribution truck (N2) with moderate mileage, the flat rate can even be cheaper than the actual consumption. As Rule of thumb:

• High annual mileage + high fuel consumption per 100 km → Check metering concept
• Average usage → Flat rate is straightforward and usually sufficient

For the following example calculations, we therefore explicitly distinguish between the two approaches instead of—as is common in some circulating calculations—unkommentated calculating with the higher, metering-concept-based value.

3 Electricity Cost Scenarios for Electric Truck Charging

Electricity costs, alongside the GHG quota, are the second major lever in the business case – and here, profitability varies depending on the supply model. Three scenarios are relevant for logistics companies:

Potential Savings from PV Electricity

Even when switching to PV-Contracting, charging costs drop noticeably below the level of grid electricity—without any investment on your part, without tying up capital, and without any technical or operational risk. For logistics companies that would first like to gain experience with their own solar power supply or prefer to invest their capital in the vehicle fleet itself, this is a low-barrier entry point with immediate cost savings. For example, a 40-metric-ton electric truck with an annual consumption of 90,000 kWh (grid electricity cost: 18,000 euros) can save as much as 7,650 euros per year.

Those who take the step toward installing their own PV system can further maximize their savings potential: At the rate of 8 ct/kWh used here, the electricity costs for charging a truck amount to only about 40 % of the grid electricity price. Since logistics companies with electric truck fleets often have large warehouse or storage roof areas anyway, this generation capacity can generally be tapped without requiring additional space—and its benefits extend beyond vehicle charging, for example through additional revenue from self-consumption or feed-in tariffs generated by the rest of the operation. Especially for larger fleets with high annual mileage, this cost advantage quickly adds up to one of the most effective levers in the entire business case.

Classification for the business case

• Contracting already accounts for a good 40 % of the maximum possible electricity cost savings—without any investment and without the logistics company having to take responsibility for the roof space, structural integrity, or operations itself.
• The full benefit (€10,800 in savings for a 40-metric-ton truck) can only be achieved through in-house operation and requires that sufficient roof space be available and that the investment be economically viable.
• For fleets that already have large roof areas on their warehouses or storage facilities, both benefits are amplified: PV generation for the vehicle fleet and, where applicable, additional revenue from feeding electricity into the grid or from on-site consumption generated by the rest of the operation.

Choosing between the three models is therefore less a question of whether „PV is worth it” and more a matter of the logistics company’s available capital, risk tolerance, and roof space.

Practical examples: 12-tonne and 40-tonne electric trucks

The following sample calculations show both vehicle classes in direct comparison to the diesel counterpart – in each case for all three electricity cost scenarios and with the flat-rate approach as the base calculation, as this is the more practical entry point for most fleet operators. The assumed parameters are:

12-metric-ton electric truck (N2) – Distribution transport

50,000 km/year, actual consumption 35 kWh/100 km (17,500 kWh), GHG Flat Rate N2: 22,600 kWh/year. The credit factor for N2 will remain at 3 even after 2027—the Factor 4 increase applies only to N3/M3.

Note: For this vehicle profile, the GHG flat rate (22,600 kWh) is higher than the actual consumption (17,500 kWh) – a metering concept would reduce the GHG revenue to €13,781 here. For the 12-tonne distribution truck, the flat rate is therefore not only the simpler, but also the more economically advantageous option.

40-tonne articulated lorry (N3) – Long-distance transport

100,000 km/year, consumption 90 kWh/100 km → 90,000 kWh/year actual charging current. As a long-distance frequent driver, this value is well above the GHG flat rate (33,400 kWh/year) – the calculation is therefore based on the Measurement concept path, which represents the significantly higher and more realistic revenue for this mileage profile. From 2027, the increased crediting factor of 4 will apply.

Key Insights – How Do Electric Truck Operations and the GHG Quota Save Money?

GHG quotas remain a key lever—especially for long-distance transport

For the 40-metric-ton electric truck with the metering concept, GHG revenue will already account for 46 % of the total savings in 2026 (€70,875 out of €155,695), and as of 2027, they will account for as much as 53 % (€94,500 out of €179,320). Without the GHG quota, the business case for long-haul fleets would be significantly weaker.

Having your own PV system further improves profitability without reducing GHG revenue

Switching from grid power to on-site PV saves an additional €10,800 per year in electricity costs alone for a 40-metric-ton truck—regardless of the chosen GHG reduction pathway. For companies with available roof space, this is an additional lever on top of existing measures, not a substitute for the GHG quota.

Exemption from tolls as a major single item – and secured long-term

At €12,500 (12 metric tons) and €25,000 (40 metric tons) per year, respectively, the complete toll exemption offers a significant cost advantage. The regulation is enshrined in law until at least June 30, 2031—this provides greater planning certainty for investment decisions than any other factor in this calculation.

Starting in 2027, GHG revenue for heavy-duty electric trucks will increase by one-third

Raising the credit factor from 3 to 4 for N3/M3 increases the eligible certificate volume by exactly one-third. For a 40-metric-ton truck equipped with a measurement system, this amounts to an additional €23,625 per year—without any additional investment or increased mileage.

The choice between a flat rate and a measurement concept determines a five-figure amount

For high-mileage vehicle profiles, such as a 40-metric-ton long-haul truck, there is a difference between the flat rate and the metered rate of €44,578 (2026) and €59,438 (starting in 2027)—more than the total electricity cost savings from a private PV system. In practice, this decision deserves at least as much attention as the choice of electricity supply model.

PV + GHG Quota: The Combined Effect

The GHG quota and a PV system—whether owned or operated via Contracting—affect different aspects of the business case—and can therefore be combined without undermining each other:

• GHG quota acts on the Revenue Side: It is calculated regardless of the source of the charging current and depends solely on the vehicle class, the credit factor, and—depending on the driving profile—either a flat rate or a metered rate.
• PV electricity acts on the Cost side: It reduces ongoing charging costs, regardless of whether GHG revenue is generated and, if so, in what amount. In addition, the price of PV electricity is stable and not dependent on geopolitical crises.  

Together, these two measures result in total savings that significantly exceed what each component would achieve on its own. For a 40-metric-ton long-haul truck equipped with a monitoring system and its own PV system, the total savings starting in 2027 will be approximately €190,700 per year—compared to approximately €179,300 when using grid power. Although the PV effect currently accounts for only a small portion of the total, it can be influenced and Stable for more than 20 years.

Why Starting with Contracting Is a Good Idea

For logistics companies that want to focus their capital investment on their vehicle fleet, PV-Contracting is the best way to get started. Electricity costs drop immediately, without tying up additional capital in the solar system. CUBE CONCEPTS handles the planning, financing, and operation of the PV system on the existing warehouse or storage facility roof—the logistics company receives electricity at a price that can be calculated over the term of the contract. Another advantage is the option for the client to purchase the PV system.

For companies that already have an investment budget and are interested in realizing the full cost savings, operating the facility themselves remains the most economically attractive option—provided that the roof structure, floor plan, and internal capacity for plant operation are suitable.

Frequently Asked Questions