Small-scale importers must certify that the necessary documentation (especially Form 13.20 A and a certificate of conformity (COC)) has been submitted to the Federal Roads Office (FEDRO) and any applicable penalty has been paid. This certification is provided by means of a stamp on the inspection report (13.20 A). The application form for registering with FEDRO is available (in DE/FR/IT) from the following website:
In the case of passenger cars with no Swiss type approval (i.e. vehicles with type certificate X), importers must submit Form 13.20 A and evidence of CO2 emissions (e.g. by means of a COC) to the Federal Roads Office (FEDRO) before registering the vehicle. FEDRO will check the CO2 emissions and invoice the small-scale importer if a penalty applies or allocate the passenger car to a specific large-scale importer. The application form for registering with FEDRO is available (in DE/FR/IT) from the following website:
Importers whose fleet of new vehicles comprises 50 or more passenger cars in the year preceding the reference year are automatically registered as large-scale importers with the Swiss Federal Office of Energy (SFOE) in the reference year (Art. 18 para. 2 CO2 Ordinance). However, their status as a large-scale importer, and thus the calculation of targets and emissions for the entire fleet, is merely provisional: if the fleet comprises fewer than 50 passenger cars at the end of the reference year, the importer is deemed to be a small-scale importer and must therefore account for each vehicle individually (Art. 18 para. 4 CO2 Ordinance).
Importers whose fleet of new vehicles comprises fewer than 50 passenger cars in the year preceding the reference year must apply to the SFOE for registration as a provisional large-scale importer if they wish to be treated as a large-scale importer in the reference year (registration form). This registration requirement also applies to importers that were not registered with the SFOE as a large-scale importer in the year preceding the reference year and who now wish to register as a large-scale importer for the reference year. Importers acquire large-scale importer status on the date the SFOE approves their application. Vehicles registered in the reference year prior to approval of the application must be accounted for individually (Art. 18 para. 3 and Art. 20 CO2 Ordinance). Ideally, an application for registration or re-registration as a large-scale importer should therefore be made before the start of the respective reference year.
The assessment method, i.e. average emissions for 50 or more passenger cars (fleet-wide assessment for large-scale importers) or individually for each passenger car (individual assessment for small-scale importers), is determined in the same way for all large-scale importers registered with the SFOE and is based solely on the number of passenger cars in the fleet of new vehicles at the end of the given reference year.
An emissions pool is a group of importers that is formed for a maximum period of five years in order to jointly achieve the specified CO2 target.
All importers (whether large-scale, small-scale or private) may form an emissions pool. An emissions pool has the same rights and obligations as an individual large-scale importer.
The application to register as an emissions pool must be submitted to the Swiss Federal Office of Energy (SFOE) by the end of December in the year preceding the reference year. Applications submitted in the course of the reference year can only be considered for the following year.
Like the EU, Switzerland introduced CO2 emission regulations for new passenger cars in 2012. These require Swiss importers to reduce the CO2 emissions of vehicles that are imported for intended use as passenger cars and registered for the first time in Switzerland to an average of 95 grams per kilometre. This value is expected to apply until the end of 2024. However, under a change in CO2 regulations applicable from 1 January 2021, the former New European Driving Cycle (NEDC) values were replaced by the more realistic Worldwide Harmonised Light Vehicle Test Procedure (WLTP) values. As a result of this changeover, the CO2 target has been adjusted from 95 grams per kilometre to 118 grams per kilometre. The higher CO2 measurements calculated using the new WLTP standard reflect real-world driving behaviour more realistically.
All importers are required to meet a specific CO2 target for their new vehicle fleet (in the case of small-scale or private importers, the target applies to each individual vehicle). This target is determined by the unladen weight of the vehicle. Since 1 July 2012, importers have been required to pay a penalty if the CO2 emissions per kilometre exceed the target.
In its CO2 Act, Switzerland commits itself to reducing its CO2 emissions as compared with 1990, which serves as the base year. Road traffic is responsible for a significant proportion of CO2 emissions in Switzerland, and the reduction potential of passenger cars in particular is especially high. Specific CO2 emissions from new cars in Switzerland are well above the European average.
The term 'passenger car' is defined in Article 11, paragraph 2a of the Ordinance on the Technical Requirements for Road Vehicles (RVTRO). Special-purpose vehicles (e.g. armoured vehicles, wheelchair-accessible vehicles, motor homes) are excluded from the Ordinance.
Under the CO2 Act, passenger cars that are placed on the market in Switzerland for the first time are those that are registered for use in Switzerland for the first time. The regulations do not apply to vehicles that were previously registered in Switzerland or to passenger cars that were registered for use abroad more than six months before being declared at a customs office in Switzerland. It does not matter how long a vehicle has been registered or what its mileage is at the time of its Swiss customs clearance. Vehicles previously registered abroad will only be recognised as such if accompanied by a vehicle registration certificate showing they have been registered as standard. Vehicles registered with temporary licence plates for transit purposes or vehicles using garage licence plates do not qualify as having standard registration. Vehicles registered abroad must be registered in the name of a natural person or legal entity resident or domiciled in the country concerned.
Vehicles first placed on the market in the Principality of Liechtenstein have the same status as vehicles registered in Switzerland.
Article 10 of the CO2 Act sets a target value of 95 grams of CO2 per kilometre for passengers cars as of 2020. For vans and light articulated vehicles (referred to collectively as 'light commercial vehicles'), the target is 147 grams of CO2 per kilometre as of 2020. Under a change in CO2 regulations applicable from 1 January 2021, the former New European Driving Cycle (NEDC) values were replaced by the more realistic Worldwide Harmonised Light Vehicle Test Procedure (WLTP) values. As a result of this changeover, the CO2 target for passenger cars was adjusted from 95 grams per kilometre to 118 grams per kilometre, while the target for light commercial vehicles was adjusted from 147 grams per kilometre to 186 grams per kilometre. The higher CO2 measurements calculated using the new WLTP standard reflect real-world driving behaviour more realistically.
The transition period for the CO2 emission regulations for passenger cars expires at the end of the reference year 2022. In other words, super-credit multipliers – whereby vehicles with CO2 emissions of less than 50 grams per kilometre count more towards meeting the fleet average – will no longer be applicable as of 2023 (Art. 27 para. 3 CO2 Ordinance). The phasing-in period for passenger cars expired at the end of 2021. As of then, each passenger car in a large-scale importer's fleet is taken into account when calculating the average CO2 emissions. In the case of small-scale importers, the penalty is now collected in full.
The CO2 regulations apply to importers of new passenger cars. A distinction is made here between small- and large-scale importers:
Large-scale importers (at least 50 cars)
Companies that import at least 50 new cars a year that are registered for use in Switzerland for the first time are classified as large-scale importers. If the average CO2 emissions of a large-scale importer’s passenger car fleet exceed the individual target, the importer must pay a penalty for each vehicle registered for the first time in the calendar year concerned.
Importers are classed as large-scale in any given reference year if they:
are registered with the Swiss Federal Office of Energy (SFOE) in the reference year for provisional treatment as a large-scale importer (see also "What is the procedure for registering as a large-scale importer?"); and
account for 50 or more passenger cars from their fleet of new vehicles.
Private/small-scale importers (fewer than 50 cars)
Companies that are not registered with the SFOE for provisional treatment as a large-scale importer or which account for fewer than 50 new cars a year from their fleet of new vehicles are classed as small-scale importers. This includes private individuals who import their new car themselves and register it for use in Switzerland for the first time (private importers). For small-scale importers, the CO2 emissions target value is calculated separately for each vehicle. If the value is exceeded, they must pay the penalty owed before the vehicle is registered. For this purpose they must submit the relevant documents (in particular Form 13.20 A, the 'Application for Certification' form and the certificate of conformity (COC)) to the Federal Roads Office (FEDRO) by post.
If the person enjoying privileges or immunities purchases the vehicle from an importer/reseller (large- or small-scale importer), the importer must pay any penalty that may be applicable. The importer is free to add the amount of the penalty to the final purchase price.
If the vehicle is imported for a person who enjoys privileges or immunities (either by the individual or by an intermediary acting on their behalf), that person is deemed to be the importer. However, as they enjoy immunity from administrative jurisdiction, it is not possible to enforce any penalty that may be applicable. By way of exception therefore, no penalties are collected for vehicles imported into Switzerland on behalf of a person who enjoys privileges or immunities.
In accordance with Article 11 of the CO2 Act, the Federal Council establishes a method for calculating an individual target value for each importer or manufacturer of passenger cars for the vehicles imported into or manufactured in Switzerland. The calculation relates to the passenger cars first registered by the importer or manufacturer in the reference year (vehicle fleet). This means that, with respect to the CO2 emissions for passenger cars, the initial importer or manufacturer is responsible and entitled, and not any third party who might register the car in Switzerland at a later date. It should be noted that when the circumstances which determine how the vehicle is assessed arise (i.e. import or manufacture), the corresponding legal consequences (car belongs to the importer’s fleet) enter into effect. A repeat of these circumstances cannot give rise to the same legal consequences a second time.
The Swiss Federal Office of Energy (SFOE) provides each large-scale importer with a list of passenger cars registered for the first time by 31 March, 30 June and 30 September of the current reference year. It also provides the target and applicable CO2 emissions. The SFOE may request quarterly advance payments if it believes there is a risk of non-payment after the end of the reference year. In the spring of the following year, large-scale importers then receive a final invoice for all passenger cars registered during the reference year.
Invoices are prepared by the SFOE on the basis of the data provided by the Federal Roads Office (FEDRO). Importers are not generally required to submit any data.
Small-scale importers (prior to registration)
Small-scale importers are required to pay a penalty that may apply to FEDRO before the vehicle is registered by the driver and vehicle licensing office in their local canton.
When new CO2 regulations came into effect on 1 January 2021, the New European Driving Cycle (NEDC) values were replaced by the more realistic Worldwide Harmonised Light Vehicle Test Procedure (WLTP) values. Here is a brief overview of the most important changes:
Adjustment of previous CO2 targets to the WLTP levels
As a result of the changeover from the NEDC to the WLTP, the CO2 target value for passenger cars has been adjusted from 95 grams per kilometre to 118 grams per kilometre. The higher CO2 measurements calculated using the new WLTP standard reflect real-world driving behaviour more realistically (Art. 17b para. 2 let. a CO2 Ordinance).
Change in applicable CO2 emissions
Since 2021, the emissions used to calculate penalties are those set in the WLTP (Art. 25 CO2 Ordinance). In each case, it is the combined CO2 emissions that are relevant. The order of priority of the data sources to be used in determining the CO2 emissions remains otherwise unchanged.
Weighting of CO2-reducing factors for vehicles
Following the changeover to the WLTP standard, CO2 reductions achieved as a result of eco-innovations are given a greater weighting for a transitional period (Art. 26 para. 2).
Small manufacturers that register fewer than 10,000 new passenger cars per year in the European Union (EU) and niche manufacturers that register between 10,000 and 300,000 new passenger cars per year in the EU can apply for a special target. This must be approved by the European Commission. This arrangement also applied in Switzerland until the end of 2021. Since 2022, there are no special targets for small and niche manufacturers (implementation of parliamentary motion 20.3210 on CO2 emissions levies and fairness for niche markets).
Under the EU regulation, manufacturers that register fewer than 1,000 new passenger cars in the European Union in a given year may retroactively be exempted from meeting the EU target for that year ('de-minimis clause'). This exemption does not apply in Switzerland.
Makes of passenger cars which qualify for a special small or niche manufacturer target in the EU or to which the de-minimis clause applies are therefore assessed in Switzerland on the basis of the average target of 118 grams of CO2 per kilometre.
In the case of large-scale importers, the applicable CO2 emissions are calculated as a fleet-wide average, while for small-scale importers the figure for the individual vehicle applies.
The term 'applicable CO2 emissions' refers to the combined CO2 emissions in accordance with the WLTP that are registered in the type approval documentation. However, importers may also give proof of the applicable CO2 emissions by means of a certificate of conformity (COC). In this case, the importer must provide evidence of CO2 emissions any eventual reduction of CO2 emission in the form of a certificate of conformity.
The applicable CO2 emissions are reduced in the following cases:
Natural gas vehicles (–20%; for the eligible biogenic component of the gas)
Innovative technologies (eco-innovations recognised by the EU)
Following the changeover to the WLTP, CO2 reductions achieved as a result of eco-innovations are to be given a greater weighting for a transitional period (Art. 26 para. 2 CO2 Ordinance). The multiplication factor for the reference year 2023 has been set at 1.5.
For vehicles with an EU certificate of conformity in electronic format (e-COC), only the data contained in the e-COC can be used as a basis for calculation. Other recognised CO2 emission certificates are listed in the Guidelines for large-scale importers (in German).
The unladen weight applicable when calculating the CO2 target is the maximum unladen weight stated in the type approval. For vehicles with no type approval, the unladen weight is based on the data in the certificate of conformity (CoC): here, it is the actual mass of vehicle (heading 13.2) that is applicable (if known), otherwise it is the mass in running order (heading 13). The COC information items above also apply to vehicles registered with an EU certificate of conformity in electronic format.
For vehicles with no type approval and no certificate of conformity, a weight certificate must be submitted that has been issued by a certified weigh station. The vehicle identification number (VIN) of the car being assessed must be indicated on the weight certificate.
Example for the reference year 2023 (see calculation tool on the website)
Private import of a car in 2023:
CO2 emissions: 130g CO2/km
Unladen weight: 1650kg
Reference unladen weight: 1693kg
The penalty amounts to CHF 101 for each gram above the target value, starting from 0.1 gram in excess of the target value.
Target = 118 + 0.0333 × (1650 – 1693) = 116.5681 g CO2/km (without rounding up or down) Amount in excess of target = 130 – 116.5681 = 13.4 g CO2/km (rounded to the nearest tenth of a gram of CO2 per kilometre) Penalty: 13.4 × CHF 101 = CHF 1353.40 (rounded to the nearest five centimes)
In the reference year 2023, importers and manufacturers will have to pay CHF 101 to the federal government for each gram of CO2 per kilometre above the target value, starting from 0.1 gram in excess of the target value. The amounts are recalculated each year, taking into account the amounts applied in the European Union and the exchange rate (Art. 13 CO2 Act).
The date of registration applies when penalties are calculated. If a vehicle is registered in Switzerland for the first time between 1 January and 31 December of a given reference year, any penalties that apply must be paid for that year.
For small-scale importers, it is the date of the invoice issued by the Federal Roads Office (FEDRO) that applies when calculating penalties.
Any importer (regardless of size) of passenger cars may arrange for a vehicle imported by them to be assigned to another (large-scale) importer for the purpose of calculating the CO2 penalty. The Federal Roads Office (FEDRO) must be notified of this before the vehicles concerned are placed on the market in Switzerland for the first time. Assignments made after the vehicle has been registered in Switzerland for the first time will not be accepted. Neither is it possible to revoke an assignment. Vehicles may only be assigned once. To assign a vehicle, the importer concerned must complete the corresponding application form ('Antrag auf Bescheinigung' – 'Abtretung' section framed in red) on the FEDRO website (available in German, French and Italian).