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. Regardless of whether a penalty is owed or not, the vehicle must be registered on the DETEC eGovernment portal (www.uvek.egov.swiss) before attestation can be requested. If no penalty is due, attestation is awarded automatically. In the event that a penalty has to be paid, the importer will receive attestation once payment has been received.

Under Art. 22a of the CO2 Ordinance, from 1 January 2024 vehicle assignments must be notified to the SFOE.
In principle, assignments must be notified to the SFOE via the DETEC eGovernment portal. The following services are available:

• Notification of assignment: This service can be used to notify assignments of individual light commercial vehicles.
• Notifications of assignment via Excel: This service allows large importers to assign their light commercial vehicles using Excel lists. The standard template must be used.
• Analyse assignments: This service makes it possible to analyse an organisation's assignments, which can then be exported as an Excel file.

The eGovernment portal cannot currently process certain exceptional cases relating to assignments. These include the following cases:

• Vehicles with a VIN that is not 17 digits long
• Modified vehicles for which data deviating from the CoC is claimed
• Vans with emission-free drives and a gross vehicle weight of up to max. 4.25 tonnes ('Bourgeois motion' vehicles).

Until further notice, these special cases must be notified to the SFOE using a specially created form, including the documents specified in the form.

You can find further information about this on the following page: Assignment procedures

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 several responsibilities from FEDRO with regard to CO2 enforcement. Processes will 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
• Notifications of assignment
• Manage assignment powers
• Request attestation
• Feedback from large importers

To use the services on the DETEC eGovernment portal, you must first create a login via the federal login service eIAM (https://www.eiam.swiss/pages/eiam_en.html). 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 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.

Small importers are required to notify 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 notified in this way before an application for vehicle attestation can be made to the SFOE. Please email FEDRO with any questions you may have in relation to entering vehicles in the KDI portal (ivitas_support(at)astra.admin.ch).

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

If a vehicle's emission levels are equal to or less than its target, the vehicle is automatically attested for registration. If a vehicle exceeds the emissions target, the importer is required to pay a penalty. In this case, an attestation 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 an attestation 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 attestation is required to register the vehicle. Further information on assignment: 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).

Importers whose fleet of new vehicles comprises six light commercial vehicles (LCVs) 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 six LCVs 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). In this case, it must re-register with the SFOE as a large importer if it wishes to be treated provisionally as a large importer once again in the reference year. Registration takes place via the DETEC eGovernment 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 such for the reference year. An importer is treated as a large importer for the entire reference year. Importers require a UID (unique 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 determined in the same way for all large importers registered with the SFOE and is based solely on the number of LCVs 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. Members of an emissions pool are jointly and severally liable (Art. 13 para. 4 CO2 Act).

Emissions pools must be registered on the DETEC eGovernment portal 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 (unique business identification number).

In 2011, the European Parliament decided to set carbon emission targets for delivery vans and light articulated lorries (collectively known as light commercial vehicles, LCVs). Under current EU law, LCVs imported and authorised for use as such in Switzerland must have average emissions of 153.9g CO2/km or less (WLTP).

As a rule, importers are required to meet a specific CO2 emissions target for their new vehicle fleet (in the case of small or private importers, the target applies to each individual vehicle). The target is determined on the basis of the average target value, taking the unladen weight of the vehicle. If the carbon emissions per kilometre exceed the target, a penalty is levied per excess gram and vehicle.

FAQ – Who are the regulations aimed at?
FAQ – Which target values 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 the reduction potential is high for 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 paragraphs 2e and 2i of the Ordinance on the Technical Requirements for Road Vehicles (RVTRO). They apply to vehicles with a total weight of up to 3,500kg. Special-purpose vehicles (e.g. armoured vehicles, wheelchair-accessible vehicles, motor homes) are excluded from the Ordinance.

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 those 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 declaration 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 declaration 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: What requirements must be met before requesting attestation?)

Vehicles with initial registration in the Principality of Liechtenstein have the same status as vehicles registered in Switzerland.

The CO2 target values will be gradually tightened. Article 10 of the CO2 Act sets a target value of 153.9 grams of CO2 per kilometre (WLTP) for vans and light articulated vehicles (collectively known as light commercial vehicles, LCVs). For passenger cars, the target is 93.6 grams of CO2 per kilometre (WLTP). The next tightening is scheduled for 1 January 2030, when the target values for LCVs and passenger cars are expected to be reduced to 90.6 grams of CO2 per kilometre and 49.5 grams of CO2 per kilometre respectively.

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

Large importers (at least six LCVs)

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 their 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:

• have registered at least six new LCVs in the calendar year prior to the reference year, and
• are registered with the Swiss Federal Office of Energy (SFOE) as a large importer or as an emissions pool.

Private/small importers

Importers that are not registered with the SFOE as a large importer or which account for fewer than six new vehicles a year from their fleet of new vehicles are classed as small importers. This includes private individuals who import their new vehicle themselves and register it for use in Switzerland (private importers).

For small importers, the carbon emission target value is calculated separately for each vehicle. For small importers, the carbon emission target value is calculated separately for each vehicle. A request for certification must be submitted to the SFOE (see FAQ: What are the requirements for small importers to be able to authorise a vehicle for circulation?)

Light commercial vehicles can be imported into Switzerland in various stages of production. At the time of import, 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.

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 LCVs for the 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, with respect to the carbon emissions for LCVs, the initial importer or manufacturer is the responsible and entitled, and not any third party who might register the vehicle 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 (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 importer (annual settlement)

The SFOE provides each large importer with a list of light commercial vehicles 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 receives a final invoice for all light commercial 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 FEDRO before being authorised by the cantonal road traffic office.

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.

The implementing provisions for 2025 will enter into force with retroactive effect from 1 January 2025. Until then, the previous calculation formula combined with the new target values will apply to small importers. Once the Federal Council has adopted the implementing provisions, the calculation formula for 2025 will be adjusted for large importers.

In the meantime, the target for small importers should be calculated using the following formula for each individual LCV:

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

where:

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

The calculation parameters for the 2025 target for large importers ave not yet been published. The implementing provisions will come into force with retroactive effect from 1 January 2025 (likely in the second quarter of 2025). The calculation formula will be communicated as soon as possible after the Federal Council's decision. As yet, only the target value has been published; this will be 153.9 g CO2/km for LCVs in 2025.

Please note: The final calculation for large importers is only made after the end of each reference year.

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

Small manufacturers that register fewer than 22,000 LCVs in the European Union (EU) per year can apply for a special target in the EU. This must be approved by the European Commission. This arrangement also applied in Switzerland until the end of 2021. As of 2022, there are no special targets 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 meeting the EU target for that year ('de-minimis clause'). This exemption does not apply in Switzerland.

Makes of LCVs 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 153.9 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 of type-approved vehicles 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). This also describes 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 due 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 per kilometre is used. Carbon emissions measured according to the previous NEDC test method are no longer accepted.

The implementing provisions for 2025 will enter into force with retroactive effect from 1 January 2025. In the meantime, the previous calculation formula combined with the new target values will apply to small importers. Until further notice, the penalty for small importers for the year 2025 should be calculated as follows:

Example for reference year 2025 (see calculation tool on the website)

Private import of an LCV in 2025:

• CO2 emissions: 186g CO2/km
• Unladen weight: 2,139 kg
• Reference unladen weight: 2,110 kg
• Penalty: CHF 95 for each gram exceeding the target value, starting from 0.1 grams in excess of the target value (provisional amount)

Target: 153.9 + 0.096 × (2,139 – 2,110) = 156.684 g CO2/km (rounded to three decimal places)
Target missed: 186 – 156.684 = 29.3 g CO2/km (rounded up/down to nearest tenth of a gram of CO2 per kilometre)
Penalty: 29.3 × CHF 95 = CHF 2,783.50 (rounded to the nearest five centimes)

In the reference year 2025, 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 LCVs 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 the vehicle to a large importer.

For more information on this, see: What does 'assignment of an imported LCV' mean? How can a vehicle be assigned to another importer?

Importers of passenger cars, whether large or small importers, 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 once only.

The vehicle assignments must 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 notify the assignment of individual 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: This service allows large importers to assign their light commercial vehicles using Excel lists. The standard template must be used. This 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: This service makes it possible to analyse an organisation's assignments, which can then be exported as an Excel file.

The eGovernment portal cannot currently process certain exceptional cases relating to assignments. These include the following cases:

• Vehicles with a VIN that is not 17 digits long
• Modified vehicles for which data deviating from the CoC is claimed
• Vans with emission-free drives and a gross vehicle weight of up to max. 4.25 tonnes ('Bourgeois motion' vehicles).

Until further notice, these special cases must be notified to the SFOE using a specially created form, including the documents specified in the form.

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