by Florian König, maut1.de - 16 November 2023
In its 2021 coalition agreement, the red-green-yellow coalition government has pledged to accelerate the switch to climate-neutral drive systems, especially in freight transport, and to link the lorry toll introduced in 2005 to CO2 emissions in future. This is intended to ensure greater climate protection in freight transport, which is currently responsible for a third of total CO2 emissions in the transport sector. The Bundestag and Bundesrat have already approved the pending amendment to the law.
Goods vehicles weighing 3.5 tonnes or more in Germany will be subject to tolls
A toll reform will soon come into force in Germany, which will include a toll obligation for all vehicles weighing more than 3.5 tonnes that are used to transport goods. The toll will then come into force on 1 July 2024.
What is the legal basis for the change in toll charges?
The background to the new adjustment to the calculation of toll rates are both updated EU requirements and the so-called "infrastructure cost report" from the Federal Ministry for Digital and Transport Affairs. According to the so-called "Eurovignette Directive", the HGV toll must in future also be based on the costs of building, operating, maintaining and expanding transport routes. The new regulation of toll charges therefore primarily serves to cover the costs of the increasing financing requirements of the transport infrastructure.
To whom does the "new toll" apply and on which routes does it apply?
The commercial vehicle toll was introduced in 2005 as a distance-based road user charge on all federal motorways in Germany. In accordance with Section 1 of the Federal Trunk Road Toll Act, all motor vehicles and vehicle combinations with a gross vehicle weight of 7.5 tonnes or more from Germany and abroad are currently subject to the toll. The toll charges are levied as soon as the vehicle enters a federal trunk road and apply to both federal roads and motorways as well as the adjacent service stations and rest areas.
Does the "new toll" also apply to motorhomes weighing over 3.5 tonnes?
The new HGV toll law may have an impact on certain motorhomes over 3.5 tonnes. Below we take a closer look at which vehicles this affects and what campers should do:
- Motorhomes in general remain toll-free
- Validity of the toll obligation from 3.5 tonnes: from 1 July 2024
- A small number of "lorry-based" vehicles are affected
- Option: Aktualisierung der Zulassung als Wohnmobil statt Lkw
In detail: "pure" motorhomes over 3.5 tonnes remain toll-free
There are currently around 160,000 motorhomes with a total weight of over 3.5 and up to 7.5 tonnes registered in Germany, some of which could be confronted with the toll obligation from July due to their special type of body - particularly those based on lorries or buses.
However, most of these motorhomes are already clearly recognisable as motorhomes by the structure of the installed toll control systems or random checks and therefore remain toll-free without any bureaucratic effort toll-free.
According to information from the Federal Office of Logistics and Mobility (BALM), the new toll obligation for vehicles weighing 3.5 tonnes or more will continue to apply to all vehicles (motorhomes or campers) that
- are permanently and fixed equipped with living facilities (e.g. toilet/shower, living room/beds or cooking facilities),
- are used exclusively for the carriage of passengers and not for the transport of goods, or
- have subsequently been permanently converted into a motorhome (e.g. lorry with box body).
For all differently constructed motorhomes, e.g. with a specific area for loading (transport of horses/cows or a garage in the rear for small vehicles) or trailers for transport, the available "living area" (with permanently installed toilet/shower, living room/beds or cooking facilities) must be at least 50 % of the total usable area of the vehicle and may only be used for private journeys.
Possible problems when converting a lorry or bus into a motorhome
Although it is not yet possible to estimate in detail how many camping vehicles will actually be affected by the new lorry toll, it is likely to be a very small proportion.
For motorhome owners, however, it should be noted that there are some motorhomes based on lorries or buses that have been converted and built by themselves and are not clearly recognisable as motorhomes at first glance, even if they are registered as M1 SA ("vehicle for passenger transport special body motorhome").
In addition, some of these converted motorhomes are currently still on the road with a lorry registration, as self-builders use lorries or Unimogs with a box body as a motorhome, for example, or have mounted a caravan without wheels on the loading area of a lorry and use this combination as a "mobile home".
Last but not least, it is also not obvious whether a motorhome weighs just under or already over 3.5 tonnes (depending, for example, on whether it can be subsequently loaded or unloaded).
Possible solution option: Change registration to motorhome instead of lorry/bus
What options do owners of camper vans based on lorries or buses that are not clearly "recognisable" as camper vans or that are still registered as lorries have to avoid potential toll problems from July 2024?
As the most practicable solution, the BALM recommends, among other things, the carrying of appropriate vehicle documents for inspections and registration as "other motor caravan".
For older vehicles based on trucks or buses, which are also to be used more frequently on motorways and main roads, it is worth calculating the costs for a change of registration as an "M1 SA motorhome" compared to the previous registration as a "truck", as, together with the new CO2 tax, there will also be significantly higher travel costs per route.
In principle, there is of course the possibility that any truck weighing 3.5 tonnes or more but less than 7.5 tonnes gross weight will remain exempt from the new toll obligation, provided it is used exclusively as a motorhome. However, it is the owner's responsibility to provide the toll operator Toll Collect GmbH with this not entirely effortless proof…
Voluntary registration for "unclear" vehicles as motorhomes expected to be possible from 2024
If, in future, uncertainties arise during the monitoring of toll charges as to whether a vehicle is actually to be categorised as a motorhome, the owner will be sent a hearing form. This will then give them the opportunity to prove the status of their vehicle.
It should also be possible to register your own vehicle as a motorhome with toll operator Toll Collect on a voluntary basis before the deadline. According to BALM, this should make it possible to avoid "unnecessary rejections, checks and subsequent collection notices as far as possible".
Für diese Registrierung für Fahrzeuge als Wohnmobil muss im Registrierungsantrag eine Kopie des Fahrzeugscheins, Fotos und Aufbauskizzen des Wohnmobils mit Angaben der Größenverhältnisse von Wohn- und Ladebereich sowie Informationen zur Nutzung des Wohnmobils beigefügt werden. Die Gültigkeitsdauer dieser Registrierung beträgt allerdings höchstens zwei Jahre und kann nach Ablauf wieder verlängert werden.
From the beginning of 2024, vehicles weighing more than 3.5 tonnes, which may have problems proving their "motorhome" status, can be registered as motorhomes in the Toll Collect service portal.
A statement by maut1 on the increase in the HGV toll in Germany on 1 December 2023 (criticism of the date, alternatives for haulage companies, infrastructure problems, options for haulage companies, rail as an alternative) can be found in the RFO media library.
CONCLUSION
For all motorhomes weighing more than 3.5 tonnes or for all vehicles based on trucks or buses weighing more than 3.5 tonnes that are used more than 50% as motorhomes, there is still no obligation to pay tolls in Germany, provided they are not used for commercial goods transport.
For motorhome travellers, however, depending on the selected country of travel, different toll charges are due on foreign routes, which can often only be settled via a route-based ticket or a toll box approved for the country.
For Italy, France, Spain and Portugal as well as Austria (large motorhomes) and Croatia (excluding Istria, small motorhomes), you can find out more at maut1.de.
