Small importers require a certificate confirming that the necessary documentation (Form 13.20 A, Certificate of Conformity) has been submitted to FEDRO and any applicable penalty has been paid. Confirmation takes the form of a stamp on the verification report (13.20 A). The application form for registration with FEDRO can be obtained by clicking on the following link:
In the case of cars without a Swiss type approval (i.e. vehicles with type certificate "X"), importers have to submit Form 13.20 A and a CO2 emissions certificate (e.g. COC) to FEDRO before registering the vehicle. FEDRO will check the CO2 emissions and if a penalty applies it will issue an invoice (small importer) or allocate the vehicle to a specific large-scale importer. The application form for registering with FEDRO is available from the following website:
If an importer registers at least 50 new cars in a given year, the company is automatically classified as a large-scale importer in the next reference year. Here, all cars are considered which are subject to the provisions of the CO2 Ordinance and can be allocated to the GI account of the importer concerned on the basis of the type approval or attestation by FEDRO.
If a large-scale importer does not register the required 50 cars within a given reference year, the company nonetheless has to submit a calculation of the average value of the fleet, but will be classified as a small importer in the following year. The importer concerned may, however, apply for classification again as a provisional large-scale importer.
Provisional large-scale importer
All entities that are not automatically classified as large-scale importers (see above) can register with the SFOE as a provisional large-scale importer by completing the corresponding application form. Registration as a provisional large-scale importer may be submitted at any time. If an importer submits the application form for classification as a large-scale importer during the year for the current reference year, only those vehicles in that importer’s fleet are included in the calculation that are subject to the provisions of the CO2 Ordinance and were registered after the approval of the application by the SFOE. Cars that were registered prior to the approval of the application by the SFOE will be included individually in the calculation by FEDRO.
In the event that, at the end of a reference year, fewer than 50 cars (in accordance with the emission regulations specified in the CO2 Ordinance) have been allocated to the account of a provisional large-scale importer, in its capacity as a small importer the importer is required to subsequently submit a calculation for each car registered during the reference year.
Provisional large-scale importers who register the specified minimum number of vehicles, regardless of when they registered with the SFOE, will automatically be classified as large-scale importers in the following year and therefore do not need to submit an application for classification as a provisional large-scale importer (see above).
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 (large-scale, small and private) may form an emissions pool.
An emissions pool has the same rights and obligations as an individual large-scale importer. When the emissions pool estimates the provisional status, as a small importer in the reference year it has to submit data for each individual vehicle if the members of the pool have jointly put less than 50 new cars into circulation in Switzerland (Article 19, paragraph 3).
The application form for emissions pools must be submitted to the SFOE by the end of November in the year prior to 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 regulations oblige Swiss importers to reduce the level of CO2 emissions from cars imported for the approved purpose and registered for the first time in Switzerland to an average of 95 grams per kilometre. This target is to provisionally apply until the end of 2024. However, within the scope of the enforcement of the CO2 regulations the previously applicable New European Driving Cycle (NEDC) was replaced by the more realistic Worldwide Harmonised Light Vehicle Test Procedure (WLTP) with effect from 1 January 2021. As a result of this changeover, the CO2 target of 95 grams per kilometre was adjusted to 118 grams per kilometre. Thus the higher and more realistic CO2 measurements in accordance with the WLTP have been taken into account.
All importers are required to meet a specific CO2 target for their new vehicle fleet (or in the case of small or private importers, the vehicle-specific target). This target is influenced by the vehicle mass. With effect from 1 July 2012 a penalty applies if the CO2 emissions per kilometre exceed the specified target.
In its new CO2 Act, Switzerland undertakes a commitment to reduce its CO2 emissions versus the level in the reference year (1990). In Switzerland, road traffic is responsible for a significant proportion of CO2 emissions, and therefore the reduction potential is particularly high in the area of passenger cars. Here the level of specific CO2 emissions from new cars is well above the European average.
The term "car" (or "passenger car") is defined in accordance with Article 11, paragraph 2a of the Ordinance on Technical Requirements for Road Vehicles. Special-purpose vehicles (e.g. armoured vehicles, vehicles with approved space for transporting wheelchairs, mobile homes) are excluded from the Ordinance.
In accordance with the CO2 Act, the term “initial registration” refers to the registration of cars that have been approved for the first time for use in Switzerland. The regulations do not apply to vehicles that were previously registered in Switzerland, nor to cars that have been approved abroad more than six months before their customs declaration in Switzerland. The duration of the registration and the distance travelled by a vehicle at the time of its Swiss customs clearance are of no relevance. In the case of vehicles previously registered abroad, only a standard registration with accompanying certificate is acceptable. Here, for example, the registration of vehicles for transfer licence plates or the use of vehicles with garage licence plates are not classified as standard registration. Registration abroad must be made in the name of a natural person or legal entity with residence or domicile in the country concerned.
Vehicles registered in the Principality of Liechtenstein have the same status as vehicles registered in Switzerland.
Article 10 of the CO2 Act states that from 2020, the target for cars is 95 grams of CO2 per kilometre, and for vans and light articulated vehicles (collective term: light commercial vehicles) the target is 147 grams of CO2 per kilometre. Within the scope of the enforcement of the CO2 regulations the previously applicable New European Driving Cycle (NEDC) was replaced by the more realistic Worldwide Harmonised Light Vehicle Test Procedure (WLTP) with effect from 1 January 2021. As a result of this changeover the CO2 target for 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. Thus the higher and more realistic CO2 measurements in accordance with the WLTP have been taken into account.
With the adjustment of the target to 95 grams of CO2 per kilometre in 2020 and 118 grams per kilometre with effect from 2021 (in accordance with the WLTP), there is a transition period until the end of 2022. Under Article 27 of the CO2 Ordinance, super credits are to be used as an introductory relief measure. In the reference years (2020-2022), the CO2 emissions from vehicles with emissions of less than 50 grams of CO2 per kilometre are considered until an accumulated reduction in the average CO2 emissions for the new car fleet of 7.5 grams of CO2 per kilometre is reached. In 2022, the weighting factor for these vehicles is 1.33.
Following the changeover to the WLTP the total eligible grams per kilometre are to be adjusted to 9.3 grams per kilometre over a period of three years. This corresponds to the restriction to 7.5 grams per kilometre that was previously applicable under the NEDC method (Article 27, paragraphs 3 and 4, CO2 Ordinance). Thus after 2020 the still applicable effect based on the multiple calculation will be converted for 2021 and 2022 with a factor of 1.24 on the basis of the WLTP.
The CO2 regulations apply to importers of new cars. Here a distinction is made 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 are classified as large-scale importers. If the average CO2 emissions of a large-scale importer’s passenger car fleet exceed the individually specified target, the importer has to pay a penalty for each vehicle initially registered in the calendar year concerned.
Importers are classified as large-scale importers in a reference year if:
In the calendar year prior to the reference year they have registered at least 50 new passenger cars (here the determining criterion is registration in accordance with a type approval holder code)
They are registered with the Swiss Federal Office of Energy (SFOE) as a provisional large-scale importer or as an emissions pool. Registration has to be made using the appropriate form.
Private/small importers (less than 50 cars)
Companies that import fewer than 50 new cars a year which are registered for use in Switzerland are classified as small importers. This includes private individuals who import their new car themselves and register it for use in Switzerland (private importers).
For small importers, the target is specified separately for each car. In the event that the target is exceeded, they have to pay the corresponding penalty before the vehicle is registered. For this purpose they have to submit the relevant documents (in particular Form 13.20 A, "Application for Certification" and the Certificate of Conformity COC) to the Swiss Federal Roads Office (FEDRO) by post.
Here a distinction has to be made between two cases:
If the person who is entitled to privileges or immunities purchases the vehicle from an importer/reseller (large-scale or small importer), the importer has to pay any penalty that may be applicable. The importer is at liberty to add the amount of the penalty to the final purchase price.
If the vehicle is imported on behalf of a person who is entitled to privileges or immunities (either by the person himself/herself or by an intermediary acting on his/her behalf), the person concerned is classified as the importer. Since the latter enjoys immunity from administrative jurisdiction, it is not possible to enforce any penalty that may be applicable. By way of exception, an exemption from payment of a penalty therefore applies for the import of a vehicle into Switzerland on behalf of a person who is entitled to privileges or immunities.
In accordance with Article 11 of the Federal CO2 Act, for each importer or manufacturer the Federal Council specifies a calculation method for an individual target for cars imported into or manufactured in Switzerland. The calculation is based on the cars of the importer or manufacturer (vehicle fleet) initially put into circulation in the respective year. This means that, with respect to the CO2 emissions for cars, it is the initial importer or manufacturer who is responsible and entitled, and not a third party who may register the car in Switzerland at a later date. Here it should be noted that when the action that is of relevance to the allocation of the car actually takes place (import or manufacture), the corresponding legal consequences (cars belong to the importer’s fleet) enter into effect. A repeat of this action cannot trigger the same legal consequences a second time.
Each quarter, the SFOE provides large-scale importers with a list of cars initially registered up to 31 March, 30 June and 30 September respectively of the current reference year, together with the corresponding target and the relevant CO2 emissions. If the SFOE is of the opinion that the payment of a penalty after expiry of the reference year could be at risk, it may request quarterly downpayments. In the spring of the following year, large-scale importers will then receive a definitive invoice for all passenger cars registered during the reference year.
Invoices will be prepared by the SFOE based on the data provided by the Swiss Federal Roads Office (FEDRO). It is not necessary for importers to submit data.
Small importers (prior to registration)
Small importers are required to pay FEDRO any penalty that may be applicable before the vehicle is registered by the cantonal road traffic authority.
Within the scope of the enforcement of the CO2 regulations the previously applicable New European Driving Cycle (NEDC) was replaced by the more realistic Worldwide Harmonised Light Vehicle Test Procedure (WLTP) with effect from 1 January 2021. 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 for cars has been adjusted from 95 grams per kilometre to 118 grams per kilometre. This takes account of the higher and more realistic CO2 levels in accordance with the new WLTP measurement method (Article 17, paragraph 2a).
Change in applicable CO2 emissions
Since 2021, the WLTP method must be used for the calculation of penalties (Article 245). In each case it is the combined CO2 emissions that are of relevance. The cascade of the data sources to be used for calculating the CO2 emissions remains unchanged.
Weighting of CO2-reducing factors for vehicles
Following the changeover to the WLTP method, CO2 reductions achieved through ecological innovations will be transitionally more highly weighted. For further information, see: “What are relevant CO2 emissions?”
Small manufacturers that register fewer than 10,000 passenger cars per year in the EU, and niche manufacturers that register between 10,000 and 300,000 passenger cars per year in the EU can apply for a special target, which must be approved by the European Commission. Until the end of 2021, these special targets also applied to Switzerland. From 2022 onwards, no more special targets are planned for small and niche manufacturers (implementation of Motion 20.3210 filed by Müller on CO2 emissions levies and fairness for niche markets).
According to a special EU regulation (“de-minimis clause”), manufacturers who register fewer than 1,000 passenger cars in the European Union in one year may retroactively be exempt from meeting the EU target for that year. The de-minimis clause was deliberately not introduced in Switzerland.
Passenger cars manufactured by brands that in the EU qualify for a special target for small or niche brands or for whom the de-minimis clause applies are therefore subject to calculation based on the average target of 118 grams of CO2 per kilometre.
In the case of large-scale importers the relevant CO2 emissions are calculated as a fleet average, while for small importers it is the figure for the individual vehicle that is relevant.
The term "relevant CO2 emissions" refers to the combined CO2 emissions in accordance with the WLTP measurement method that are registered in the type approval. However, importers may also certify the relevant CO2 emissions using a Certificate of Conformity (COC). In this case the importer must provide evidence of the reduction in the form of a Certificate of Conformity. For vehicles with an Electronic Certificate of Conformity (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 Article 24 of the Ordinance on the Reduction of CO2 Emissions. In the following cases the level of relevant CO2 emissions is reduced:
Gas-fuelled vehicles (–20 percent for the proportion of biogas)
Innovative technologies (ecological innovations recognised by the EU)
Following the changeover to the WLTP method, the CO2 emissions are transitionally more highly weighted though ecological innovations (Article 26, paragraph 2). The multiplication factors for reference years 2022 to 2023 have been specified as follows:
b. In reference year 2022: 1.7 c. In reference year 2023: 1.5
The unladen weight that is applicable for the calculation of the CO2 target level is the weight cited in the type approval. For vehicles without type approval, the unladen weight is based on the data in the Certificate of Conformity: here it is the actual mass of the vehicle (position 13.2) that is applicable (if known), otherwise it is the mass in running order (position 13). The abovementioned COC positions also apply to vehicles being registered with an Electronic Certificate of Conformity.
For vehicles without type approval, without a Certificate of Conformity and for which the CO2 emissions are calculated in accordance with Appendix 4 of the CO2 Ordinance, a weight certificate has to be submitted that has been issued by a calibrated weighing machine. The vehicle identification number (VIN) of the car to be tested has to be indicated on the weight certificate.
Example for the reference year 2022 (see calculation tool on the website)
Private import of a car in 2022:
CO2 emissions: 130 grams of CO2 per kilometre
Unladen weight: 1,650 kilograms
Reference unladen weight: 1,674 kilograms
The amount of the penalty is 104 Swiss francs for each gram, starting from 0.1 gram in excess of the target.
Target = 118 + 0.0333 × (1,650 – 1,674) = 117.2008 grams of CO2 per kilometre (without rounding up or down) Unmet target = 130 – 117.2008 = 12.7 grams of CO2 per kilometre (rounded to the nearest tenth of a gram of CO2 per kilometre) Penalty: 12.7 × CHF 104 = CHF 1320.80 (rounded to the nearest five cents)
In reference year 2022, importers and manufacturers will have to pay 104 Swiss francs to the federal government for each gram of CO2 per kilometre, starting from 0.1 gram in excess of the target. The penalty amounts will be redefined for each year. The amounts applicable in the European Union and the exchange rate will be taken into account (Article 13, CO2 Act).
For the calculation of penalties it is the date of registration that is of relevance. If a vehicle is initially registered in Switzerland between 1 January and 31 December of a given reference year, it is included in the calculation for that year.
For small importers it is the date of the invoice issued by the Swiss Federal Roads Office (FEDRO) that is of relevance for the calculation of penalties.
Any importer (regardless of size) of passenger cars has the option of assigning an imported vehicle to another importer for the purpose of calculation of the CO2 penalty. Each assignment has to be reported to the Federal Roads Office (FEDRO) prior to the initial registration of the vehicle in Switzerland. An assignment made after the initial registration of the vehicle in Switzerland will not be accepted. A vehicle can only be assigned once. To assign a vehicle, the importer concerned is required to use the corresponding application form ("Antrag auf Bescheinigung" – "Abtretung" section framed in red) on the FEDRO website (available in German, French and Italian).