FAQ - CO2 emission regulations for cars

To use the services on the DETEC eGovernment portal, you must log in via the federal login service eIAM (https://www.eiam.swiss/pages/eiam_en.html) to create a login. Registration is free of charge.

As certain processes are being automated and digitalised, from 1 January 2024 the type approval holder code used for CO2 enforcement regulations for large importers and emissions pools has been replaced by the UID number.

The following instructions explain the main steps required to use the services: INDUSTRY INFO No 3

A UID is required to register as a large importer or to become a member of an emissions pool. Companies receive a UID when registered with an administrative office that is linked to the UID register (e.g. commercial register, VAT register, etc.). Importers without a UID can account for vehicles individually as a small importer, assign them to a large importer or operate as a large importer via a third party (service provider with a UID).

To start this process, the necessary vehicle data must first be recorded in digital form with the Federal Roads Office (FEDRO). This can be done via the FEDRO KDI portal: Link to FEDRO website. Regardless of whether a penalty is owed or not, the vehicle must be registered on the DETEC eGovernment portal (www.uvek.egov.swiss) before certification can be requested. If no penalty is due, certification is awarded automatically. In the event that a penalty has to be paid, the importer will receive certification once payment has been received.

A user can create several organisations with their login. They can also assign a role to others in their organisation and so assign them rights to carry out certain operations on behalf of the organisation. Several organisations can be managed via one login. The administrator remains responsible for managing an organisation's user rights.

On 1 January 2024, the SFOE took over additional responsibilities from FEDRO with regard to CO2 enforcement. Processes will now be gradually digitalised via the DETEC eGovernment portal (www.uvek.egov.swiss). The following services are available on the platform:

• Request to be treated as a large importer or emissions pool
• Edit details for large importer or emissions pool
• Manage assignment powers
• Request certification

The SFOE is working on solutions to offer further processes via the DETEC eGovernment portal.

Under Art. 22a of the CO2 Ordinance, from 1 January 2024 vehicle assignments must be reported to the SFOE. From 25 March 2024 on, vehicle assignments must be notified exclusively using the digital services on the DETEC eGovernment portal. The following services are available:

• Notification of assignment: This service can be used to notify single cars.
• Notifications of assignment via Excel: With this service, large importers can assign their passenger cars by means of Excel lists. The standard template must be used.
• Analyse assignments: With this service you can conduct an analysis of your organisation's assignments. These assignments can be exported as an Excel file.

You can find additional information on each new service via the “Detailed information” link available on the DETEC eGovernment portal.

Small importers are required to report the vehicles they import to the Federal Roads Office (FEDRO) in the KDI portal. The importer receives confirmation that the vehicle has been successfully registered in the KDI portal. Vehicles must be reported in this way before an application for vehicle certification can be made to the SFOE.

Please address any questions you may have regarding recording vehicles in the KDI portal to: ivitas_supportatastra.admin.ch

To register a vehicle, small importers must obtain certification from the Swiss Federal Office of Energy (SFOE) and confirmation from the Federal Roads Office (FEDRO). Applications for certification must be submitted via the DETEC eGovernment portal (www.uvek.egov.swiss).

If a vehicle's emission level is equal to or less than the emissions target, the vehicle is automatically certified for registration. If a vehicle exceeds the emissions target, the importer is required to pay a penalty. In this case, the certificate will only be issued once the penalty has been paid. If a vehicle is not subject to the carbon emission regulations, the cantonal road traffic office does not require a certificate in order to register the vehicle.

All importers can assign vehicles to a large importer. If a small importer assigns a vehicle to a large importer, no certification is required to register the vehicle. More information on assignment: What is 'assignment of an imported passenger car'? How can a vehicle be assigned?

Large importers can register as such on the DETEC eGovernment portal (www.uvek.egov.swiss).

Importers whose fleet of new vehicles comprises 50 or more passenger cars in the year preceding the reference year are automatically registered as large importers with the Swiss Federal Office of Energy (SFOE) in the reference year (Art. 18 para. 2 CO2 Ordinance). If the fleet comprises fewer than 50 passenger cars at the end of the reference year, the importer is deemed to be a small importer and must therefore account for each vehicle individually (Art. 18 para. 4 CO2 Ordinance).

If an importer has accounted for fewer than 50 passenger cars in a new vehicle fleet in the year prior to the reference year but nonetheless wishes to be treated as a large importer in the reference year, it must register with the SFOE as a large importer via the DETEC e-Government portal. This is also a requirement for importers who were not registered with the SFOE as large importers in the year prior to the reference year and who wish to register as large importers for the reference year. An importer is treated as a large importer from the date confirmation is received from the SFOE. Any vehicles registered in the reference year before such confirmation is received must be declared separately by the importer (Art. 18 para. 3 and Art. 20 CO2 Ordinance). Therefore, the request to be registered as a large importer should ideally be submitted before the start of the reference year. Importers require a UID (business identification number) in order to be registered.

The assessment method, i.e. average emissions for 50 or more passenger cars (fleet-wide assessment for large importers) or individually for each passenger car (individual assessment for small importers), is determined in the same way for all large importers registered with the SFOE and is based solely on the number of passenger cars in the new vehicle fleet 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 carbon emission target.

All types of importers (large, small and private importers) can join together to form an emissions pool. An emissions pool has the rights and obligations of a single large importer.

Emissions pools can be registered on the DETEC eGovernment portal (www.uvek.egov.swiss) before the start of the reference year. Applications submitted in the course of the reference year can only be considered for the following year. All members of the emissions pool must have a UID (business identification number).

Like the EU, Switzerland introduced carbon emission regulations for new passenger cars in 2012. These require Swiss importers to reduce the carbon 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 CO2/km (NEDC). This value is expected to apply until the end of 2024. However, under a change in carbon emisisons 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 carbon emissions target has been adjusted from 95 grams per kilometre to 118 grams per kilometre. The higher carbon emission values calculated using the new WLTP standard reflect real-world driving behaviour more realistically.

Importers are required to meet a specific carbon emissions target for their new vehicle fleet (in the case of small 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 carbon emissions per kilometre exceed the target.

In its CO2 Act, Switzerland commits itself to reducing its carbon emissions as compared to the base year of 1990. Road traffic is responsible for a significant proportion of carbon emissions in Switzerland, and the reduction potential of passenger cars in particular is especially high. The specific carbon 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 registered for the first time are those that are registered in Switzerland for the first time. Vehicles previously registered in Switzerland are not subject to these regulations and neither are passenger cars registered abroad more than twelve months before customs clearance in Switzerland. Vehicles with a mileage of more than 5,000 kilometres at the time of import are exempt from the regulations if registered abroad more than six months previously. The length of time a vehicle has been registered abroad is not relevant at the time of customs clearance in Switzerland. Vehicles previously registered abroad can only be granted standard registration in Switzerland i.e. with a vehicle registration document. 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. The foreign registration and the mileage must be declared when registering the vehicle on the FEDRO KDI portal (see FAQ): Which requirements must be met before applying for certification?

Vehicles with initial registration 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 (NEDC) for passenger cars as of 2020. For vans and light articulated vehicles (referred to collectively as light commercial vehicles, LCVs), the target is 147 grams of CO2 per kilometre as of 2020. Under a change in carbon emission 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 carbon emission target for passenger cars was adjusted from 95 grams of CO2 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 carbon emission values calculated using the new WLTP standard reflect real-world driving behaviour more realistically.

Carbon emission regulations apply to importers of new passenger cars. A distinction is made here between small and large importers:

Large 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 importers. If the average carbon emissions of a large 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 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 importer (see also 'How do I register as a large importer?'); and
• account for 50 or more passenger cars in their fleet of new vehicles.

Private/small importers (< 50 cars)

Companies that are not registered with the SFOE for provisional treatment as a large importer or which account for fewer than 50 new cars a year from their fleet of new vehicles are classed as small 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 importers, the carbon emission target value is calculated separately for each vehicle. If the value is exceeded, the importer must pay the penalty owed before the vehicle is registered. A request for certification must be submitted to the SFOE (see FAQ: I am a small importer. How do I register a vehicle?)

Here, a distinction is made between two cases:

• If the person enjoying privileges or immunities purchases the vehicle from an importer/reseller (large or small importer), the importer must pay any penalty that may be applicable. The importer is free to add the amount of the penalty to the vehicle's 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 carbon 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 lead to the same legal consequences a second time.

Large importers (annual settlement)

The SFOE provides each large importer with a list of passenger cars assigned to their new fleet by 31 March, 30 June and 30 September of the current reference year. It also provides the target and applicable carbon 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. Early in the following year, large 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 data available from the SFOE and FEDRO. Importers are not generally required to submit any data.

Small importers (prior to registration)

Small importers are required to pay any penalty due to the SFOE before the vehicle is registered at the vehicle licensing office in their local canton.

Since 1 January 2018, the revenue collected from penalties has been allocated to the National Highways and Urban Transport Fund. It was previously allocated to the Infrastructure Fund.

For small importers, the target is calculated using the following formula for each individual passenger car:

Permissible specific emission = 118 + a × (unladen weight – Mt-2)g CO2/km

where:

A penalty is payable if a vehicle's applicable carbon emissions exceed the individual target.

The target for large importers is calculated for the entire fleet of cars registered by each large importer for the first time in the reference year using the following formula:

Permissible specific emission = 118 + a × (M_i,t – M_t-2)g CO2/km

where:

Please note: a final calculation can only be made after the end of the reference year.

A penalty becomes payable if the fleet's applicable CO2 emissions exceed the individual target.

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 carbon 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 importers, the relevant carbon emissions are calculated as a fleet-wide average, while for small importers the figure for the individual vehicle applies.

'Relevant carbon emissions' are the combined carbon emissions in accordance with the WLTP as registered in the type approval documentation. However, importers may also give proof of the relevant carbon emissions and any reduction therein by presenting a certificate of conformity (CoC).

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 carbon emission certificates are listed in the Guidelines for large importers (German).

In the following cases, relevant carbon emissions are additionally reduced:

• Natural gas vehicles (–20%; for the eligible biogenic component of the gas)
• Innovative technologies (eco-innovations recognised by the EU)

The unladen weight applicable when calculating the carbon emission 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 positions above also apply to vehicles registered with an EU certificate of conformity in electronic format.

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.

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 2024 (see calculation tool on the website)

Private import of a car in 2024:

• CO2 emissions: 130g CO2/km
• Unladen weight: 1650kg
• Reference unladen weight: 1727 kg
• The penalty amounts to CHF 95 for each gram above the target value, starting from 0.1 gram in excess of the target value.

Target = 118 + 0.0333 × (1650 – 1693) = 115.4359 g CO2/km (without rounding up or down)
Amount in excess of target = 130 – 115.4359 = 14.5 g CO2/km (rounded to the nearest tenth of a gram of CO2 per kilometre)
Penalty: 14.5 × CHF 95 = CHF 1377.50 (rounded to the nearest five centimes)

In the reference year 2024, importers and manufacturers will have to pay CHF 95 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).

Large importers

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.

Small importers

For small importers, the date of the invoice issued by the SFOE applies when any penalties due are calculated.

There is no direct bonus as such, but large importers can offset cars with carbon emissions above the fleet-specific target value against those with emissions below this value.

If a number of small importers join together to form an emissions pool, they have the same offsetting benefits as large importers.

Private and small importers may receive a bonus for an efficient vehicle by assigning it to a large importer.

For more information on this, see: What is meant by 'assignment of an imported passenger car'? How can a vehicle be assigned to another importer?

Importers of LCVs, whether large or small, may arrange for a vehicle imported by them to be assigned to a (different) large importer for calculation of the CO2 penalty. The Swiss Federal Office of Energy (SFOE) must be notified of any such assignment before the vehicle is first registered in Switzerland. Assignments arranged after initial registration in Switzerland will not be accepted. Once made, assignments cannot be revoked. Each vehicle may be assigned only once.
The vehicle assignments must be notified exclusively using the digital services on the DETEC eGovernment portal. The following services are available:

• Notification of assignment: This service can be used to notify single assignments of cars. A registered large importer can use this service to notify assignments to another large importer or to process the taking over of an assignment. In addition, assignments can be taken over from small importers, or an assignment can be notified as an intermediary between large importers. This service has no legal effect.
• Notifications of assignment via Excel: With this service, large importers can assign their cars by means of Excel lists. The standard template must be used. It is available in the service on the DETEC eGovernment portal. The portal checks the vehicles on the Excel list and informs you whether the assignment has been completed. This service has no legal effect.
• Analyse assignments: With this service you can conduct an analysis of your organisation's assignments. These assignments can be exported as an Excel file.

If you have any questions, please contact the SFOE helpdesk on the following telephone number: 058 464 54 40.