The path to fully electric fleets in European logistics is complex, navigating a patchwork of regulations, unpredictable energy costs, and massive upfront capital investment. To provide strategic direction, the Berlin-based e-mobility consultancy M3E GmbH recently published the whitepaper, “Sustainability as a Competitive Advantage: Electric Mobility for Shippers and Transport Customers”, in cooperation with the freight carrier Nanno Janssen GmbH.
We spoke with Dr. Christian Milan, Founder & Managing Director of M3E. In this exclusive interview, the head of the consultancy shares his insights on how the new EU Emissions Trading System 2 (ETS 2) will fundamentally shift market competition, why depot charging remains the “low-hanging fruit,” and the biggest financial trap companies fall into when calculating Total Cost of Ownership (TCO) for e-trucks.
I. Regulatory Impact: The EU ETS 2 Transition & Tolls
Q1. The foreword states that preparing now allows companies to “actively manage costs and turn regulatory risks into competitive strengths.” Beyond the simple pass-through of cost increases, what is the single most significant structural market change the EU Emissions Trading System 2 (EU ETS 2) will enforce on shippers and logistics providers starting in, now, 2028?
Although the introduction of EU ETS 2 has been postponed by one year, the issue remains just as relevant for shippers and logistics providers. Apart from the expected yet hard-to-predict increases in fuel costs resulting from the introduction of a market-based trading system for emission certificates, the EU ETS 2 will bring a structural shift to the freight forwarding and logistics industry. Competitive dynamics will move away from pure price competition towards emission intensity and energy efficiency.
Until now, freight forwarders have primarily competed on transport price, reliability, and capacity. Under ETS 2, CO₂ intensity (g CO₂/tkm) will evolve into a strategic cost driver. Companies that operate more efficiently across their fleets—by increasingly integrating electric trucks where feasible—will gain a tangible cost advantage, as they will indirectly need to purchase fewer emission certificates. Efficiency improvements will therefore have a direct and measurable impact on pricing, rather than serving merely as an image factor.
In the future, larger freight forwarders and depot operators will be able to actively manage energy efficiency and pricing through contract design, refuelling strategies, and the use of alternative energy sources. However, smaller carriers are likely to lose flexibility and face growing margin pressure unless they develop a comprehensive long-term strategy.
Finally, when factoring in the Corporate Sustainability Reporting Directive CSRD, which mandates carbon accounting throughout the supply chain, EU ETS 2 will create new disclosure and reporting obligations. Major shippers will require shipment-level emissions data to meet their own climate commitments. As a result, CO₂ monitoring and reporting will need to be digitally integrated, expanding the industry’s information-system infrastructure.
Q2. For a manufacturer or wholesaler who does not operate their own fleet but relies solely on external carriers, what is the best first step they can take immediately to leverage EU ETS 2 for competitive advantage when negotiating future transport tenders?
Tenders should be adapted to the new market conditions, while transport companies should be made aware of the importance of electromobility through direct communication. Traditional tendering procedures are typically based on diesel-driven transport, which can put the use of electric trucks at a disadvantage.
By incorporating parameters relevant to electric mobility into the calculation basis, genuine competition between different propulsion systems becomes possible, allowing electric vehicles to emerge as the most cost-effective option. CO₂ costs can be integrated into tenders, and transport service providers can be required to disclose their energy efficiency and planned decarbonisation measures.
Finally, fixed-price agreements and long-term partnerships can enable both parties to gain a competitive edge and greater planning security.
Q3. Given the non-harmonized national CO₂ taxes across the EU (ranging from €30 to over €100 per tonne), how does this patchwork regulatory landscape complicate pan-European logistics planning for companies trying to electrify their operations?
The EU sets clear targets for decarbonisation, but the paths to achieving them vary widely. The inconsistent CO₂ taxation landscape turns what should be a unified European energy transition into a patchwork of unequal economic signals.
For logistics networks, this means that a high degree of coordination is required to balance differing total operating costs and deployment priorities. The European subsidy landscape is similarly fragmented, resulting in varying starting conditions and degrees of flexibility across member states.
In this respect, the standardisation of the emissions system is to be welcomed, even if it remains to be seen whether a market-based mechanism will bring greater volatility or stability. In our view, fleet electrification and the electrification of transport operations offer greater planning security and medium-term cost advantages. For logistics companies and their clients, there is ultimately no alternative to electromobility.
Q4. The paper highlights the legal groundwork for extending the toll exemption for e-trucks until mid-2031. For companies making large fleet investment decisions today, how crucial is the certainty of this extended toll exemption, and what immediate consequences would a delay or failure to adopt this extension nationally have on the e-truck business case?
The British HGV Road User Levy system differs from the toll systems in many European countries, where lorries have to pay up to tens of thousands of euros in tolls each year, depending on the country and mileage. In this context, the recently made decision to extend the possible toll exemption for electric trucks represents a significant cost advantage, which, together with other factors such as lower energy costs, means that electric trucks are the cost-effective option overall. In this respect, this decision plays a crucial role in the decarbonisation of freight transport in continental Europe.
II. Operational Feasibility & Infrastructure
Q5. The paper states that 87% of German truck trips are regional (under 150 km). How much “low-hanging fruit” is available for immediate, cost-effective electrification solely using depot charging, and what is the maximum reliable daily range most logistics companies can achieve without relying on public high-power charging (HPC)?
Average driving distances in Europe vary significantly from country to country, and freight forwarders and depot operators are structured accordingly. If transport companies and their clients primarily operate or commission regional routes, switching to electric trucks is not only feasible but also highly advisable.
Current electric truck models offer ranges of 500 to 600 kilometres, allowing operators to assess whether their own routes can be served with them. If the trucks can be recharged at the depot during loading and unloading, smooth electric truck operation is possible, providing cost advantages due to low-cost commercial electricity.
Q6. The whitepaper confirms that long-haul is now technically feasible. However, EAFO data (Oct 2025) shows only 143 dedicated heavy-duty public charging stations currently exist in the EU, while the AFIR mandate demands 350kW HPC every 60 km on TEN-T networks. How quickly must this infrastructure gap close for long-haul e-truck deployment to become commonplace, and what role must non-dedicated/shared-use charging stations play during this critical transition period?
The 143 heavy-duty public charging stations mentioned are exclusively available to heavy-duty vehicles. In addition, there are a further 1,369 public shared-use stations accessible to both heavy-duty and light-duty vehicles. According to EAFO data, the public e-truck charging network will thus comprise 1,512 publicly accessible charging stations across the European Union as of October 2025. The majority of these stations are located in Germany (479), followed by Sweden (278), the Netherlands (246), Denmark (158), and France (101). Of the 1,512 public charging stations, EAFO data indicates that 143 are dedicated exclusively to heavy-duty vehicles, while the remaining 1,369 are shared-use stations available to both heavy-duty and light-duty vehicles.
Expansion is ongoing, and the network is growing rapidly, as the electrification of road freight transport is currently a priority. Some transport companies, such as the freight forwarder Nanno Janssen mentioned in the white paper, are already operating e-trucks on regular long-distance routes without any issues.
Q7. The paper emphasizes that efficient depot charging infrastructure is a key enabler, even for depot operators without their own fleets. In practical terms, how can a non-logistics depot operator generate revenue or achieve cross-financing by making their charging facilities available to external partners?
We see two approaches here: on one hand, setting up charging infrastructure can make sense for depot operators without their own fleets, as it enables partnerships with transport companies that operate e-trucks. In view of rising fuel costs, this can not only provide cost advantages but also enhance public image and support increasingly important sustainability commitments, such as those required under the CSRD.
On the other hand, depot operators can make their own charging infrastructure available to external logistics providers, effectively creating semi-public charging points that extend the public e-truck charging network.
Such networks are already emerging, and with appropriate reservation software, there is no conflict with internal charging needs. A positive side effect is that this creates an additional revenue stream, which can be used to partially finance the development of the company’s own charging infrastructure.
Q8. M3E states that charging capacities between 150 and 400 kW are typically sufficient for depot charging, while Megawatt Charging (MCS) is often too expensive and puts strain on the grid. For a company starting its transition, should they invest in 150-400 kW today, or is the risk of obsolescence too high, pushing them toward adopting expensive MCS immediately?
Megawatt charging (MCS) will become increasingly relevant in the near and medium term for public charging infrastructure. From our perspective, the power ratings mentioned are fully adequate for depot charging infrastructure, and this is unlikely to change in the medium term.
Charging occurs during loading and unloading times or at night, depending on the usage patterns and route profiles of the e-trucks. Statutory rest periods must also be observed. For all these reasons, charging stations with 150 kW and 400 kW represent the optimal choice from a cost-benefit perspective.
III. TCO and Commercial Strategy
Q9. The text notes the stark contrast between the higher acquisition cost (often double) of an e-truck and its eventual lower Total Cost of Ownership (TCO). What is the most common financial misconception M3E encounters when a company begins its TCO calculation, and how do you advise clients to accurately factor in the anticipated savings from toll and energy cost mechanisms?
The most common financial misconception our consultants encounter is that companies focus too heavily on the upfront purchase price and undervalue or incorrectly model long-term operating savings. Many companies apply diesel truck cost structures to e-trucks, assuming similar energy and maintenance cost patterns.
They fail to properly account for regional or future cost dynamics—particularly toll exemptions, energy price stability, and incentives that can significantly improve e-truck economics over time. They also overlook lower brake wear, the absence of oil changes, and the reduced number of moving parts in e-trucks, often neglecting fleet data or OEM benchmarks.
Thorough planning is essential. Both the vehicle and the charging infrastructure should be optimally tailored to the company’s specific requirements.
Additionally, the potential eligibility of electric mobility projects for funding should be assessed in advance. The European funding landscape is complex and dynamic, making navigation challenging. For larger projects, it is therefore always worthwhile to consult funding experts and fleet electrification specialists beforehand to avoid costly mistakes. TCO can vary significantly from country to country.
Q10. Of the various EU special tax depreciation schemes mentioned (like Germany’s super depreciation, Austria’s IFB, or the Netherlands’ VAMIL), which is the most effective policy mechanism currently in place for reducing the upfront capital burden of e-truck acquisition, and why?
In fact, it is a combination of measures and developments that can make the purchase and operation of electric trucks more economically attractive. It is always important to closely examine the policy framework and subsidy programs in one’s own country.
Initially, a government subsidy program for the purchase of electric commercial vehicles, if available, naturally has the strongest impact. Depending on the program’s design, it can offset a significant portion of the additional purchase costs.
Other measures, such as GHG quotas, tax incentives, toll exemptions, and lower maintenance and energy costs, can further help ensure that the TCO of an electric truck is lower than that of a conventional diesel truck.
Q11. The paper mentions that reduced wear and less frequent servicing translate to lower maintenance costs. Quantitatively, what is the realistic percentage reduction M3E observes in annual maintenance costs for an average 16-tonne e-truck compared to its Euro 6 diesel counterpart, and what are the main factors driving this saving?
It is difficult to make general statements, as the figures always depend on the vehicle, its usage profile, and the country of operation, but most analyses indicate that the maintenance costs of an electric truck are around 30 percent lower.
The reasons are straightforward: compared to a combustion engine, electric motors have significantly fewer components and a less complex drivetrain. Regular oil and filter changes are entirely unnecessary for electric vehicles, as are additives such as AdBlue. Regenerative braking systems also reduce wear on the brakes.
These and other factors allow maintenance intervals for electric trucks to be slightly longer than for diesel trucks, and the reliability of electric trucks supports this.
Q12. The rising costs of diesel transport mean industry leaders must challenge price structures in tenders currently benchmarked to diesel. What specific metric or mechanism should shippers demand from their electric carrier partners to ensure they are sharing the competitive TCO-based savings, rather than simply accepting a fixed, potentially inflated, per-kilometer rate?
Shippers and transport contractors should request a detailed cost breakdown that also accounts for CO₂ savings and other sustainability measures.
We expect that market mechanisms will come into play in public tenders and when obtaining multiple quotes, ensuring an appropriate price level for electrified transport.
In this context, it should be emphasized that the savings measures mentioned make e-trucks competitive despite high acquisition costs, and in many cases even slightly more economical. However, we are still some way from a situation in which haulage companies are generating excessive profits from the use of e-trucks.
