FAQ – CO2 emission regulations for light delivery and light articulated vehicles (collectively referred to as light commercial vehicles)

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 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). 

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.

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2024 the type approval holder code used for CO2 enforcement regulations for large importers and emissions pools has been replaced by the UID number, which is used as the identification code for assigning vehicles to the corresponding large importer or emissions pool. It is therefore mandatory for large importers to have a UID.

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

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 assignments of light commercial vehicles.
• Notifications of assignment via Excel: With this service, large importers can assign their light commercial vehicles 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.

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.

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 Swiss Federal Roads Office (FEDRO). Applications for certification must be submitted via the DETEC eGovernment portal: www.uvek.egov.swiss.

If a vehicle's emission levels are 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 sells a vehicle to a large importer, no certification is required to register the vehicle. More information on the situation: What is 'assignment of an imported passenger car'? How can a vehicle be assigned?

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

Large importers who have accounted for at least six LCVs in their new vehicle fleet in the year preceding the reference year are automatically registered with the SFOE as large importers for the reference year (Art. 18 para. 2 CO2 Ordinance). If at the end of the reference year their fleet comprises fewer than six LCVs, the importer is deemed to be a small importer and must retroactively account for each vehicle separately (Art. 18 para. 4 CO2 Ordinance).

If an importer has accounted for fewer than six LCVs in its 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 their request is confirmed by the SFOE. Any vehicles registered in the reference year before such confirmation is received must be accounted for 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 six or more LCVs (fleet-wide assessment for large importers) or individually for each LCV (individual assessment for small importers), is the same for all large importers registered with the SFOE and is based solely on the number of LCVs 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 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).

In 2011, the European Parliament decided to set carbon emission targets for delivery vans and light articulated lorries (collective term: light commercial vehicles, LCVs). Under current EU law, LCVs imported and authorised for use as such in Switzerland must have average emissions of 186g CO2/km or less (according to the WLTP). This value is expected to apply until the end of 2024. On 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. The higher carbon emission values calculated using the new WLTP standard reflect real-world driving behaviour more realistically.

All importers must comply with a specific carbon emission target for new vehicle fleets. This target is usually calculated on the basis of the average target value, taking into account the unladen weight of the vehicle. If the carbon emissions per kilometre exceed this target, a penalty is levied per excess gram and vehicle.

FAQ – To whom do the regulations apply?
FAQ – Which target levels apply?

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 potential to reduce emissions is high with both passenger cars and LCVs. The specific carbon emissions from new cars in Switzerland are well above the European average.

The terms 'van' and 'light articulated vehicle' are defined in Article 11, paragraph 2a of the Ordinance on the Technical Requirements for Road Vehicles (RVTRO). They apply to vehicles with a total weight of up to 3,500kg. The Ordinance does not apply to special-purpose vehicles (e.g. armoured vehicles, wheelchair-accessible vehicles, motor homes).

In order to promote zero-emission drive systems, vehicles with a total weight of up to 4,250kg which in all other respects meet the definition of a van and whose total weight in excess of 3,500kg is due solely by the additional weight of the zero-emission drive system also fall under the scope of the carbon emission regulations for LCVs (Art. 2, let. abis, No 2).

This takes account of the fact that some alternative drive systems are heavier than fossil-fuelled ones. This applies in particular to battery-powered vehicles.

Under the CO2 Act, LCVs registered for the first time are vehicles that are registered in Switzerland for the first time. Vehicles previously registered in Switzerland are not subject to these regulations, and neither are LCVs 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 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 specifies a target value for vans and light articulated vehicles of 186g CO2/km measured using the WLTP. 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 CO2 per kilometre to 118 grams per kilometre, and that for light commercial vehicles from 147 grams per kilometre to 186 grams per kilometre. This reflects the higher and more realistic CO2 values measured using the new WLTP.

The carbon emission regulations apply to importers of new LCVs. A distinction is made here between small and large importers.

Large importers (six LCVs or more)

Companies that import at least six new vehicles a year that are registered for use in Switzerland for the first time are classed as large importers. If the average carbon emissions of a large importer’s LCV fleet exceed the importer's 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 importers in any given reference year if they:

• are registered with the Swiss Federal Office of Energy as a large importer or as an emissions pool, and
• registered at least six new LCVs in their fleet of new vehicles.

Small importers (fewer than six LCVs)

Importers that import fewer than six new vehicles a year that are registered in Switzerland for the first time are classed as small importers. This also includes persons who import their vehicle themselves from abroad and register it in Switzerland (private importers).

The carbon emission target value of vehicles imported by small importers 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: As a small importer, what do I have to do to register a vehicle?)

Light commercial vehicles can be imported into Switzerland in various stages of production. When imported into Switzerland, production may already be complete or the vehicle may be in a basic state before final fitting by a local body builder to the customer's specifications. The latter are classed as multi-stage vehicles (MSVs). Also, in the case of MSVs, the importer of the (base) vehicle is responsible for paying any charges relating to carbon emissions. The emissions of the vehicle in its completed condition when it is first registered are considered when compliance with the carbon emission target is assessed.

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.

Article 11 of the CO2 Act states that the Federal Council establishes a method for calculating an individual target value for each LCV importer or manufacturer for vehicles imported into or manufactured in Switzerland. The calculation relates to the LCVs first registered by the importer or manufacturer in the reference year (vehicle fleet). This means that the initial importer or manufacturer is the responsible and authorised entity with regard to compliance with carbon emission regulations, rather than any third party who might register the car in Switzerland at a later date. It should be noted that when the circumstances determining how the vehicle is assessed arise (i.e. import or manufacture), the corresponding legal consequences (LCV 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 Swiss Federal Office of Energy (SFOE) provides each large importer with a list of LCVs registered for the first time by 31 March, 30 June and 30 September of the current reference year. It also provides the target and relevant carbon emissions. The SFOE may request quarterly advance penalty payments if it believes there is a risk of non-payment after the end of the reference year. Early in the following year, the large importer then receives a final invoice for all vehicles 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 level for each vehicle is calculated on the basis of the following formula:

Permissible specific emission = 186 + a × (unladen weight – M_t-2) grams of CO2 per kilometre.

where:

A penalty applies if the relevant CO2 emissions of a vehicle exceed the specified individual target level.

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

Permissible specific emission = 186 + a × (M_i,t – M_t-2) grams of CO2 per kilometre.

where:

Note: a definitive calculation can only be made after expiry of the reference year.

A penalty applies if the relevant CO2 emissions of the fleet exceed the specified individual target level.

Small manufacturers that register fewer than 22,000 LCVs in the European Union (EU) in a year can apply for a special target in the EU. This must be approved by the European Commission. Switzerland adopted this regulation up to the end of 2021. Since 2022, targets are no longer adjusted for small and niche manufacturers.

Under the EU regulation, manufacturers that register fewer than 1,000 new LCVs in the European Union in a given year may retroactively be exempted from the EU target for that year ('de-minimis clause'). This exemption does not apply in Switzerland.

Makes of LCVs to which the de-minimis clause applies in the EU or which qualify for a special small or niche manufacturer target are therefore assessed in Switzerland on the basis of the average target of 186 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 provide 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), which describes in particular the procedure for multi-stage vehicles.

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)

In the case of small importers, a calculation is made for each individual vehicle on the basis of the complete vehicle before it is registered for the first time. Multi-stage vehicles and vehicles from small importers must be registered on the FEDRO KDI portal prior to registration. Any penalty is calculated on the basis of the unladen weight recorded on the KDI portal. This can be found on form 13.20A (if available) and is thus the weight of the vehicle as recorded during inspection by the cantonal motor vehicle centres (in this case, inspection takes place before the vehicle is registered on the KDI portal). It may also be provided in the form of a weight certificate for the complete vehicle. Upon request, the calculated unladen weight of the generically completed vehicle may also be given (in accordance with Annex III Part A Number 1.2.4 of Regulation (EC) No 2019/631). All relevant documentation must be submitted via the KDI portal.

Importers must provide proof of carbon emissions in accordance with the WLTP. This proof must be provided by an officially recognised inspection body. If no such proof is available, carbon emissions are calculated according to the formulae in Annex 4 No 1 of the CO2 Ordinance. If the data necessary to make the calculation are not available, a default value of 400 grams of CO2/km is taken. Carbon emissions measured according to the previous NEDC test method are no longer accepted.

Example for reference year 2024 (cf. calculation tool on the website)

Private import of a light commercial vehicle in 2024:

• CO2 emissions: 225 grams per kilometre
• Unladen weight: 2,382 kilograms
• Reference unladen weight: 2,117 kilograms
• Penalty: 95 Swiss francs for each gram exceeding the target level by 0.1 grams (provisional penalty)

Target level: 186 + 0.096 × (2,382 – 2,117) = 211.44 grams of CO2 per kilometre (rounded up/down to three decimal places)
Failure to meet target: 225 – 211.44 = 13.5 grams of CO2 per kilometre (rounded up/down to nearest tenth of a gram of CO2 per kilometre)
Penalty: 13.5 × CHF 95 = CHF 1,282.50 (rounded up/down to five cents)

Importers and manufacturers must pay CHF 95 to the federal government for each gram of CO2 per kilometre above the target value, starting from 0.1 grams 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 year (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. Large importers can offset LCVs with carbon emissions above the fleet-specific target value against those with carbon 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.

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 light commercial vehicles. 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 light commercial vehicles 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.