Preliminary assessment of the fourth payment request of Romania

TollRo). The provisions set out that the unit charge, which is linked to the EURO emission norm as defined in Article 2 of Law 1. The EURO emission norm reflects the level of air pollutant emissions of a given vehicle: the lower the EURO class, the more polluting the vehicle. The unit charge is multiplied by the total kilometres driven, to determine the total charge due. Article 12(5) further provides that the categories of vehicles and level of the unit charge will be approved by order of the Ministry of Transport and Infrastructure. The respective Ministerial Order No. 1925/2025 (Evidence No. 4) approving the categories of vehicles and the level of the unit charge (Ordin pentru aprobarea categoriilor de vehicule și a nivelului tarifului unitar), was published in the Official Journal No. 940 on 10 October 2025. Article 3 provides that the Ministerial Order will enter into force on 1 July 2026, that is the date when the system will start collecting revenue, as required by the Council Implementing Decision (see also point v below). According to the annex to the Ministerial Order, the lowest unit charge (in RON/km) is applied for EURO VI vehicles, namely the least polluting ones. The

unit charge is higher for EURO V and EURO IV vehicles, and is the highest for the most polluting ones, that is vehicles falling within the EURO 0–III categories.

  ii.   Entry into force of the legal act(s) for the implementation of a new distance-based
        charging system for heavy duty vehicles (trucks) linked to (…) higher ownership taxes for
        most polluting passengers vehicles (cars/buses/ coaches). (…) and higher ownership taxes
        for most polluting passengers vehicles (cars/buses/coaches)

Law No. 239/2025 on establishing measures for the recovery and efficiency of public resources and amending and supplementing certain legislative acts (Lege privind stabilirea unor măsuri de redresare și eficientizare a resurselor publice și pentru modificarea și completarea unor acte normative, hereinafter referred to as “Law 2” (Evidence No. 3), was published in the Official Journal, No. 1160 on 15 December 2025, and entered into force on 1 January 2026 (according to the provisions of Article 4(2) of the Law No. 227/2015 approving the Fiscal Code stipulating that any amendments to the tax rates will enter into force at the beginning of next fiscal year after their approval).

Article 1(43) of Law 2 amends Article 470(2) of Law No. 207/2015 by introducing an ownership tax for passenger vehicles based on engine capacity and EURO pollution norm. For a given engine capacity, the ownership tax in RON/200 cm3 for passenger vehicles - including motorcycles, tricycles, cars, buses, coaches, minibuses – falling within EURO norm 0 to III is subject to the highest level of taxation. The ownership tax decreases progressively for vehicles complying with EURO 4, EURO 5, EURO 6 standards and is lowest for hybrid vehicles. The latter category has to pay around 20% less than the first category. The tax is calculated based on a two-dimensional matrix, with engine capacity as rows and emission standards as columns.

Moreover, Article 1(45) of Law 2 amends Article 470(3) of Law No. 207/2015 by providing that for hybrid vehicles with CO2 emission of 50 g/km or less, the tax is further reduced. The exact amount of the extra reduction - compared to the tax for hybrids with CO2 emission above 50g/km - is up to 30%, subject to a decision of the relevant local council or, in the case of Bucharest, the General Council of the Municipality of Bucharest.

Finally, Article 1(47) of Law 2 introduces a new sub-paragraph to Article 470(3) of Law No. 207/2015, providing that electric vehicles are subject to a flat ownership tax of RON 40 (approximately EUR 8), representing the lowest ownership tax applicable across all vehicle categories.

 iii.   The new charging system for vehicles shall include:

• - specific level of distance-based charges and clear criteria linked to air pollution for

charging heavy duty

34