FAQ – CO2 emission regulations for cars
Digitalisation of CO2 enforcement
To use the services on the 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2024 the type approval holder code used for CO2 enforcement regulations for large importers and emissions pools has been replaced by the UID number.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 “Fahrzeugimport” portal: Fahrzeugimport. Regardless of whether a penalty is owed or not, the vehicle must be registered on the eGovernment portal (www.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 several responsibilities from FEDRO with regard to CO2 enforcement. Processes will be gradually digitalised via the eGovernment portal (www.egov.swiss). The following services are available on the platform:
- Request to be treated as a large importer or emissions pool
- Edit details of large importer or emissions pool
- Notifications of assignments
- Analyse assignments
- Manage assignment powers
- Request attestation
- Feedback from large importers
Under Art. 22a of the CO2 Ordinance, assignments must be notified to the SFOE from 1 January 2024. Assignments must be notified to the SFOE via services on the eGovernment portal. The following services are available:
- Notifications of assignment: This service can be used to notify the assignment of individual passenger cars.
- Notifications of assignment via Excel: This service allows large importers to assign their passenger cars using Excel lists. The standard template must be used for this.
- 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. This includes 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
Procedure for vehicle importers
Small importers are required to report the vehicles they import to the Federal Roads Office (FEDRO) in the “Fahrzeugimport” portal. The importer receives confirmation that the vehicle has been successfully registered in the “Fahrzeugimport” 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 “Fahrzeugimport” portal to: hotline_import(at)astra.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 eGovernment portal (www.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 eGovernment portal (www.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).
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 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 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.
eGovernment portal service: Registration as a large importer
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 eGovernment portal (www.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 (unique business identification number).
Information about the CO2 emission regulations
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 93.6 grams CO2/km (WLTP). This version applies from 1 January 2025. From 2030, the target value will be 49.5g CO2/km (WLTP).
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). This target is determined by the unladen weight of the vehicle. Importers must 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, military vehicles used for military purposes) 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 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 FEDRO “Fahrzeugimport” portal (see FAQ: Which 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 93.6 grams of CO2 per kilometre (WLTP) for passengers cars as of 1 January 2025. For vans and light articulated vehicles (referred to collectively as light commercial vehicles, LCVs), the target is 153.9 grams of CO2 per kilometre (WLTP). The next tightening is scheduled for 1 January 2030, when the target values for passenger cars and LCVs are expected to be reduced to 49.5 and 90.6 grams of CO2 per kilometre respectively.
FAQs – carbon emission regulations for light delivery and light articulated vehicles
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 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 are registered with the Swiss Federal Office of Energy (SFOE) in the reference year for provisional treatment as a large importer (see also FAQ ‘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 (fewer than 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 attestation must be submitted to the SFOE (see FAQ: ‘I am a small importer. How do I register a vehicle?’)
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.
Calculation of penalties
For small importers, the target is calculated in 2026 using the following formula for each individual passenger car:
Permissible specific emission = 93.6 + a × (unladen weight – Mt–2)g CO2/km
where:
93.6: reference target in grams of CO2 per kilometre (based on the WLTP measurement method)
a: -0,0144 = target value line gradient
Mt-2: average unladen weight (in kilograms) of the passenger cars registered for the first time in Switzerland in the penultimate calendar year before the reference year.
For 2026, the average unladen weight for 2024 applies, namely 1,777 kilograms.A penalty is payable if a vehicle's applicable carbon emissions exceed the individual target.
The calculation formula for passenger cars in 2026 is as follows (Annex 4a No 1 & 2 CO2 Ordinance):
Individual target for the new vehicle fleet: 93.6 + a x (mi t – mt2)
where
a: Slope of the target value line: -0.0144
Mi-t: Average unladen weight of the large importer's new vehicle fleet
Mt-2: Reference unladen weight – For 2026, the average unladen weight for 2024 applies, namely 1,777 kilograms.
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 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. As of 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 93.6 grams of CO2 per kilometre.
Relevant CO2 emissions’ are the combined CO2 emissions in accordance with the WLTP measurement procedure as registered in the type approval documentation. However, importers of type-approved vehicles may also give proof of the relevant CO2 emissions and any reduction therein by presenting a certificate of conformity (CoC). In this case, the importer must provide evidence of CO2 emissions and any reductions of such emissions in the form of a 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).
If a vehicle's CO2 emissions are reduced through the use of innovative technologies (eco-innovations), this reduction can be deducted from the CO2 emissions (see the FAQ “What relief measures will apply from 2025?”).
For large importers, the relevant average CO2 emissions are calculated using the average value of the new vehicle fleet. Before this is done, the relevant CO2 emissions must be determined for each individual vehicle (see also FAQs: ‘What are the relevant CO2 emissions of vehicles?').
To determine the relevant average CO2 emissions of the new vehicle fleet, any reductions due to target market shares and the inclusion of renewable synthetic fuels must also be taken into account (see also FAQ ’How much do you have to pay?').
A calculation example for large importers is available on the SFOE website, which includes the relief through zero-emission and low-emission vehicles and the inclusion of renewable synthetic fuels:
For vehicles modified prior to initial registration in such a manner that they can no longer be registered for road use based on the CoC, the importer may choose either to submit data in accordance with the CoC or that of the modified vehicle. Should they choose the former, the importer can process CO2 legislation requirements through standard procedures (“Fahrzeugimport” portal and eGovernment portal). Should the importer wish to submit data for the modified vehicle, FEDRO and the SFOE have developed an appropriate alternative procedure. In this instance, importers must contact FEDRO or the SFOE prior to registering the vehicle on the “Fahrzeugimport” portal. When submitting data for a modified vehicle, importers must also provide evidence of CO2 emissions from an officially accredited testing centre. Alternatively, CO2 emissions may be calculated using the formulas set out in Annex 4 to the CO2 Ordinance.
This regulation does not apply to multi-stage vehicles requiring completion for registration.
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.
The penalty for small importers for the year 2026 are calculated according to the following formula:
Example for the reference year 2026 (see calculation tool on the website)
Private import of a car in 2026:
- CO2 emissions: 110g CO2/km
- Unladen weight: 1,650kg
- Reference unladen weight: 1,777kg
- The penalty amounts to CHF 95 for each gram above the target value, starting from 0.1 grams in excess of the target value.
Target = 93.6 + -0.0144 × (1650 – 1777) = 95.4288g CO2/km (without rounding up or down)
Amount in excess of target = 110 – 95.4288 = 14.57g CO2/km (rounded to the nearest hundredth of a gram of CO2 per kilometre)
Penalty: 14.57 × CHF 95 = CHF 1384.15 (rounded to the nearest five centimes)In the reference year 2026, 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).
The CO2 Ordinance provides for various relief measures for large importers who can reduce the average CO2 emissions of a new vehicle fleet or the emissions of individual vehicles. This includes the following:
- Reduction through renewable synthetic fuels: All importers have the option of reducing the average CO2 emissions of their new vehicle fleet by offsetting renewable synthetic fuels. Renewable synthetic fuels are synthetic fuels produced using renewable energy sources other than biomass. If a large importer of vehicles wishes to claim a CO2 reduction for a new car fleet through the use of renewable synthetic fuels, it must submit the corresponding application to the SFOE by 31 January following the end of the reference year. Small importers must submit the application before the vehicle is registered for the first time.
- Target market share: Large importers are granted a three-year grace period to achieve the target values. This relief measure is linked to the proportion of low-emission and zero-emission passenger cars in the new vehicle fleet and is thus intended to provide an additional incentive to put more vehicles with low CO2 emissions on the road. If the proportion of low-emission and zero-emission vehicles exceeds a certain threshold, the relevant average CO2 emissions of the new vehicle fleet will be reduced by the percentage by which the threshold has been exceeded. However, maximum reduction rates apply. The thresholds and maximum reduction rates for the years 2025 to 2027 are as follows:
- Eco-innovations: If a vehicle's CO2 emissions are reduced through the use of innovative technologies (eco-innovations), this reduction may be taken into account. Only eco-innovations recognized by the European Commission in accordance with Article 11 of Regulation (EU) 2019/631 can be considered. Furthermore, eco-innovations can only be taken into account to a limited extent, i.e. up to a maximum of 7 grams of CO2/km per vehicle (Art. 26, para. 1 of the CO2 Ordinance).
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 the vehicle to a large importer.
For more information on this, see: What does ‘assignment of an imported passenger car’ 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 only once. The vehicle assignments must be notified to the SFOE using the digital services on the eGovernment portal. The following services are available:
- Notifications of assignment: This service can be used to notify the assignment of individual passenger 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: This service allows large importers to assign their vehicles using Excel lists. The standard template must be used. This is available in the service on the 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.
Until the end of 2024, the two decisive events (notification of assignment and initial registration in Switzerland) were recorded on a daily basis. This meant that notifications of assignment made on the same day as the initial registration in Switzerland were generally accepted. Since 1 January 2025, a more precise comparison has been possible. Notifications of assignment made on the same day as initial registration in Switzerland are now only accepted if the notification was submitted before the vehicle was registered. Otherwise, the assignment is not valid.
The eGovernment portal cannot currently process certain exceptional cases relating to assignments. This includes 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.
Vehicles imported into Switzerland duty-free that are registered for use on Swiss roads are generally subject to carbon emission regulations. For duty-exempt vehicles, the deadline is calculated in the same manner as for other vehicles and corresponds to the period between the date of first registration abroad and the date of customs declaration in Switzerland.