FAQ – CO2 emission regulations for Heavy-duty vehicles
Remark: The content of these FAQs may be subject to change, depending on the Federal Council's decision on the revision of the CO2 Ordinance. This decision is expected at the beginning of the second quarter of 2025. The latest published status refers to the consultation draft, which can be accessed via the following link ('Vernehmlassungsvorlage-2' in German): https://fedlex.data.admin.ch/eli/dl/proj/2024/57/cons_1
Procedure for vehicle importers
What are emissions pools?
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 emission target.
All types of HDV importers (large-scale, small-scale and private importers) can join together to form an emissions pool. An emissions pool has the rights and obligations of a single large-scale importer.
Emissions pools can be registered on the DETEC eGovernment portal up to 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.
Who is obliged to register on the DETEC eGovernment portal?
All importers of HDVs must register on the DETEC eGovernment portal (www.uvek.egov.swiss) as a large-scale importer – including importers who only register one vehicle per year.
As an importer, how do I know whether my vehicle falls under the provisions on CO2 emissions before I register it?
The relevant source (for multi-stage vehicles) is the certificate of conformity (CoC) data for the base vehicle. The fully assembled vehicle or its condition when it is first registered in Switzerland is not relevant.
In Article 17cbis of the revised CO2 Ordinance, lorries and articulated vehicles with an axle configuration of 6x2 or with an axle configuration of 4x2 and a total weight of more than 16 tonnes are generally considered to be heavy-duty vehicles.
Vehicles produced before July 2019 are exempt, as are working vehicles according to their condition as base vehicles. Military vehicles used for military purposes, i.e. for combat troops, are also exempt.
What obligations do importers have before registration?
In order to be able to enforce the provisions on CO2 emissions for heavy-duty vehicles, the Swiss Federal Office of Energy (SFOE) must be able to allocate the vehicles subject to the provisions to their respective importers. If a vehicle is registered with type approval (TA) or, in future, with an electronic CoC, the importer can be identified from the registration process. In all other cases, importers are obliged to notify the SFOE of the vehicles they import. The SFOE then confirms to the importer that the vehicle has been successfully registered. This notification is a prerequisite for registering the vehicle with the driver and vehicle licensing office for vehicle inspection.
Where do I register as a large-scale importer?
Importers must register on the DETEC eGovernment portal (www.uvek.egov.swiss) as a large-scale importer.
Importers whose new vehicle fleet comprises two or more heavy-duty vehicles (HDVs) in the year preceding the reference year are automatically re-registered provisionally as large-scale importers with the SFOE in the reference year (Art. 18 para. 2 CO2 Ordinance).
If an importer's new vehicle fleet comprised fewer than two HDVs in the year before the reference year, it must re-register with the SFOE as a large-scale importer. Registration takes place via the DETEC eGovernment portal. This is also a requirement for importers who were not registered with the SFOE as large-scale importers in the year prior to the reference year and who wish to register as such for the reference year. A large-scale importer is considered to be such for the whole year from the date on which the SFOE approves its application to be registered as a large-scale importer. Ideally, the application to be registered or re-registered as a large-scale importer should be submitted before the start of the reference year. Importers require a UID (Unique Business Identification Number) in order to be registered.
If an importer's fleet comprises fewer than two HDVs at the end of the reference year, the importer is considered a small-scale importer and must therefore register each vehicle separately (Art. 18 para. 4 CO2 Ordinance).
Using digital enforcement services
What are the requirements for using the services on the DETEC eGovernment portal?
To use the services on the DETEC eGovernment portal, you must first create a login via the federal login service eIAM (www.eiam.swiss/pages/eiam_de.html). Registration is free of charge.
Can one user manage several large-scale importers on the 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. It is therefore possible to manage several organisations with one login. The administrator remains responsible for managing an organisation's user rights.
How are assignments processed?
In accordance with Article 22a, assignments must and can only be notified to the SFOE using the digital services on the DETEC eGovernment portal. The following services are available:
- Notification of assignment: This service can be used to report the assignment of individual vehicles.
- Notifications of assignment via Excel: This service allows large-scale importers to assign their vehicles using Excel lists. The standard template must be used to do this.
- Analyse assignments: This service makes it possible to analyse an organisation's assignments, which can then be exported as an Excel file.
Further information can be found on the following page in German: Umsetzung Abtretungen ab dem 25. März 2024
Key information about provisions on CO2 emissions
What does 'assigning' an imported HDV mean? How can a vehicle be assigned to another importer?
All importers of passenger cars, whether they are large-scale or small-scale importers, have the option of assigning a vehicle they have imported to another large-scale importer for the purpose of calculating the CO2 penalty. Notification of an assignment must be given to the SFOE 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 once only.
Notification of vehicle assignments must be given to the SFOE using the digital services on the DETEC eGovernment portal. The following services are available:
- Notification of assignment: This service can be used to report assignments of individual vans and light articulated vehicles. A registered large-scale importer can use this service to notify another large-scale importer of an assignment or to process the taking over of an assignment. In addition, assignments can be taken over from small-scale importers, or an assignment can be notified as an intermediary between large-scale importers. This service has no legal effect.
- Notifications of assignment via Excel: With this service, large-scale importers can assign their vans and light articulated vehicles using Excel lists. The standard template must be used to do this. This can be carried out using the digital services on the DETEC eGovernment portal. The portal confirms to the importer that the assignment has been completed. This service has no legal effect.
- Analyse assignments: This service is used to conduct an analysis of an organisation's assignments, which can then be exported as an Excel file.
Who are the provisions aimed at?
The provisions on CO2 emissions apply to all importers of new HDVs. A distinction is made between large-scale and small-scale importers when calculating compliance with targets and penalties.
Which vehicles are considered HDVs?
In Article 17cbis of the revised CO2 Ordinance, lorries and articulated vehicles with an axle configuration of 6x2 or an axle configuration of 4x2 and a total weight of more than 16 tonnes are considered to be HDVs.
The categorisation of multi-stage vehicles is dependent on their condition as a base vehicle, and not the fully assembled vehicle or their condition when first registered in Switzerland.
Which vehicles are excluded from the scope of the provisions?
As a rule, vehicles produced before July 2019 are excluded.
Vocational vehicles are also excluded. The categorisation of multi-stage vehicles is dependent on their condition as a base vehicle, and not the fully assembled vehicle or the condition when first registered in Switzerland. Military vehicles used for military purposes, i.e. for carrying combat troops, are also exempt.
What counts as first or initial registration? Do the regulations apply to second-hand vehicles?
Under the CO2 Act, HDVs registered for the first time are vehicles that are registered for the first time in Switzerland. Vehicles that were previously registered in Switzerland are not subject to these provisions. Also excluded are:
- HDVs registered abroad more than twelve months before customs clearance in Switzerland
- HDVs with a mileage of more than 5,000 kilometres at the time of import if they were 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. Where vehicles were previously registered abroad, only standard registration, i.e. with a vehicle registration document, is recognised in Switzerland. 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 initially registered in the Principality of Liechtenstein have the same status as vehicles registered in Switzerland.
What date is used to calculate penalties? What is the reference year?
The reference year is the calendar year for which compliance with the target is checked. The date on which a vehicle was first registered in Switzerland determines the reference year.
When is the penalty due?
Large-scale importers receive a final invoice by the middle of the following year for all vehicles registered for the first time during the reference year.
What happens to the revenue from the penalties collected?
The revenue from the penalties is allocated to the National Highways and Urban Transport Fund.
Calculating penalties
What date is used to calculate penalties?
The date of first registration in Switzerland is used to calculate penalties.
What does 'assigning' an imported passenger car mean? How can a vehicle be assigned to another importer?
All importers of passenger cars, whether they are large-scale or small-scale importers, may arrange for a vehicle imported by them to be assigned to a (different) large-scale importer for calculating the CO2 penalty. The SFOE must be notified of these assignments before the vehicle is first registered in Switzerland. Assignments arranged after the first registration in Switzerland are not recognised. Assignments cannot be revoked and each vehicle may be assigned once only. Notification of vehicle assignments must be given to the SFOE through the digital services on the DETEC eGovernment portal. The following services are available:
- Notifications of assignment: This service can be used to report the assignment of individual passenger cars. A registered large-scale importer can use this service to notify another large-scale importer of an assignment or to process the taking over of an assignment. In addition, assignments can be taken over from small-scale importers, or an assignment can be reported as an intermediary between large-scale importers. This service has no legal effect.
- Notifications of assignment via Excel: This service allows large-scale importers to assign their vehicles using Excel lists. The standard template must be used to do so. This is available in the digital services 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, which can then be exported as an Excel file.
What are the relevant CO2 emissions?
The emissions determined in the VECTO simulation procedure are decisive. This procedure is part of the overall European approval process and is also mandatory for new vehicles in Switzerland.
The relevant target value is the CO2 emissions figure in grams per tonne-kilometre. For individual vehicles, this is indicated on the CoC (Section 49.5) or the Customer Information Sheet (Section 2.3).
What is a vehicle subgroup?
In the VECTO simulation tool, vehicles are categorised into groups and subgroups. There are currently nine subgroups subject to CO2 target values.
The subgroup for individual vehicles is shown on the CoC (Section 49.7) and the group on the Customer Information Sheet (Section 1.1.5). This essentially shows the scope of the target value rule according to the axle configuration.
How is the individual CO2 emission target calculated?
The target is a weighted average of the EU baseline values per subgroup (Implementing Decision 2021/781). The shares of the importer's fleet made up by each subgroup in the respective year are decisive; these shares determine which individual target is set for the importer. In addition, the vehicles are weighted differently for each subgroup using payload and mileage weighting factors. The calculation is regulated in Annex 4a of the CO2 Ordinance.
How are the average CO2 emissions of a new car fleet calculated?
The average fleet emissions are calculated as a weighted average of the emissions from the vehicles in the importer's fleet. The shares of the importer's fleet made up by each subgroup in the respective year are decisive. In addition, the vehicles are weighted differently for each subgroup using payload and mileage weighting factors. The calculation is regulated in Annex 4a of the CO2 Ordinance.
How is the penalty calculated?
If the average CO2 emissions exceed the individual target, an amount of CHF 4,250 is payable per gram of excess multiplied by the number of vehicles in the fleet.
