The CO2 Ordinance provides for important changes at the beginning of 2020 that will affect major importers and general importers in particular.
Since 2012, passenger cars imported into Switzerland have been subject to a CO2 tax if certain CO2 target values are exceeded, provided that the period between registration abroad and declaration to Swiss customs does not exceed six months (the date of the customs stamp is decisive).
- From 2020, passenger cars will be subject to significantly reduced CO2 target values.
- In addition, light commercial vehicles (LNF) will also be included in the CO2 tax regulations from 2020.
A CO2 target value of 95 grams per kilometre will apply to passenger cars from 2020 (2012 to 2019: 130 g/km). This target value corresponds to a consumption of 3.6 litres of diesel or 4.1 litres of petrol for a distance of 100 kilometres.
In 2018, emissions of imported new passenger cars in Switzerland rose to a fleet average of 137.8 g/km (2017: 134.1 g/km; 2016: 133.6 g/km).
The reasons given by the Swiss Auto Importers Association for this increase in emissions are as follows
- the high and rising share of SUVs in new registrations in Switzerland (SUV share in 2018 according to the Swiss Federal Office of Energy, SFOE: 48.9 percent)
- the introduction of the new international test cycle WLTP (Worldwide Harmonized Light Vehicle Test Procedure), which is intended to ensure globally harmonized and more realistic fuel consumption and exhaust gas tests, and
- the decline in the market share of diesel vehicles to 30.2 percent (2017: 36.2 percent), an increase in registrations of passenger cars with petrol engines of around 4 percentage points. Petrol engines emit about 20 percent more CO2 than comparable diesel engines.
The CO2 emissions of the Swiss new car fleet are well above the EU average. Compared to the EU fleet, Swiss passenger cars have above-average performance indicators. No EU country has such a high market share for all-wheel drive vehicles as Switzerland.
The high emission values of the Swiss fleet of new passenger cars are attributed to the higher purchasing power of Switzerland, but also to the special topographical conditions in Switzerland.
Light commercial vehicles
The light commercial vehicles (LNF) included in the CO2 emission regulation from 2020 include delivery vans and light semi-trailers with a maximum total weight of 3.5 tonnes (Article 2 of the CO2 Regulation, Article 11(2)(e) and (i) of the Regulation on the technical requirements for road vehicles, VTS).
The CO2 target value for LNF valid from 2020 is 147 g/km. If this target value is exceeded for its fleet of light commercial vehicles, the importer must pay a CO2 penalty.
With 183.3 g/km, the Swiss LNF fleet had the highest CO2 emission value in Europe in 2018. (The EU average LNF CO2 emission in 2018 was only 158.1 g/km.) The importer association Auto-Schweiz sees a major reason for the high CO2 emissions of Swiss LNF in the performance-related heavy vehicle fee (LSVA), which is levied in this form only in Switzerland. According to Auto-Schweiz, the collection of the HVF leads to LNF transports in Switzerland being favoured over truck transports.
Major importers: The average values of a fleet are decisive
Major importers must meet the CO2 target values for the fleet average. A major importer is someone who annually
- at least 50 PW or
- at least 6 LNF
imported into Switzerland.
The Swiss Federal Office of Energy (SFOE), in cooperation with the Swiss Federal Roads Office (FEDRO), ensures that major importers meet their CO2 emission targets.
Formation of emission pools
In accordance with the rules applicable to PW, importers and manufacturers may also form LNF emission communities. A common CO2 target value applies to the entire fleet of all participants in an emissions pool. LNF and PW emission companies shall be formed independently of each other.
Special destinations for large importers: niche and small manufacturers
Niche and small manufacturers can continue to apply to the Federal Office of Energy for special destinations for PW fleets and, in future, for individual LNF fleets.
- Small manufacturers include those who produce less than 10,000 automobiles a year.
- Niche manufacturers are those who produce between 10,000 and 300,000 vehicles per year.
E-automobiles support the achievement of objectives
A higher proportion of electrically powered vehicles in new registrations would make it much easier to achieve the CO2 targets.
Newly registered vehicles that are fully or partially electrically powered are also included in the calculation of average fleet consumption. The amount of electricity consumed is calculated with a CO2 value of 0 g/km.
So far low market share of e-automobiles
In Switzerland, however, only 5,408 electric vehicles were registered in 2018. This corresponds to a market share of electric vehicles of only 1.7 percent (2017: 1.5 percent).
E-vehicles: high weighting through super credits
In order to facilitate the adjustment process, so-called “super credits” are taken into account when determining whether a new car fleet has achieved its targets: Every new vehicle imported into Switzerland that emits less than 50 g/km CO2 will be included in the new vehicle fleets of major importers and general importers with a double weighting in 2020.
Article 27(3) of the CO2 Regulation provides for a gradually reduced crediting of vehicles with low CO2 emissions:
- 2020: dips,
- 2021: 1,67-fach
- 2022: 1.33 times.
In order to avoid false incentives, a major importer can only claim Super Credits until the average CO2 emissions of its vehicle fleet have been reduced by 7.5 g/km. According to the SFOE, the observation period is from 01.01.2020 to 31.12.2022 and not per calendar year. Thus the Super Credits (improvement by 7.5 g/km) are not reset every year!
Smart use of exemption limits
Achievement of the target is also facilitated by CO2 emission limits: in 2020, new cars that are among the 15 percent of the vehicles in a new car fleet with the highest CO2 emissions will not be included in the calculation of target achievement. When calculating the CO2 target achievement in 2020, only the most efficient 85 percent of a new car fleet will be taken into account.
The proportion of vehicles with the highest CO2 emissions not included in the determination of target achievement will be gradually reduced over the years (“phasing-in” process). Article 27(2) of the CO2 Regulation provides for the inclusion of an annually increasing fleet share in the calculation of the average CO2 value (taking into account the vehicles of a fleet with the lowest CO2 emissions):
- 2020: 85 percent,
- 2021: 90 percent,
- 2021: 90 percent,
Importers’ Association: 10/20 target and demands on politicians
The Auto-Schweiz Association of Importers formulated a “10/20” target in order to give importers a point of reference on the way to achieving the CO2 targets: By 2020, 10 percent of new registrations should be for purely electric vehicles and 10 percent for plug-in hybrids.
Auto-Schweiz considers it necessary for politicians to promote electric mobility more strongly so that the CO2 targets can be met. In the opinion of the Association, the following in particular is necessary
- the expansion of tank and loading infrastructures for alternative vehicle drives,
- the harmonisation of cantonal differences in the levying of vehicle taxes, and
- the preference of models with low CO2 emissions.
Minimize CO2 tax: CO2 target values as a challenge for Swiss importers
The new CO2 limit value for light commercial vehicles and the significant reduction in the target value for passenger cars place high demands on large importers and general importers. In order to minimise the otherwise impending CO2 tax, it would appear sensible to ensure that fleet imports are as balanced as possible in terms of CO2 emissions, to increase the import of electrically powered vehicles wherever possible and to make skilful use of the exemption regulation of the CO2 Ordinance.
Processing of the CO2 levy via the CO2 Börse AG 2020
The CO2 Börse AG is anxious to be able to offer you as a large and small importer also solutions in the year 2020 for the area of the CO2 tax.
It is not yet possible at this stage to communicate the conditions and form under which settlement will be possible. We will inform you as soon as all preparations for 2020 have been completed.
CO2 Calculation and Processing Tool 2020
The changes in the CO2 tax 2020 have a direct effect on your CO2 pool calculation. In order to provide you with full transparency and simple processing, we developed the CO2 Cockpit 2020 for you:
Basic module (passenger cars / light commercial vehicles)
The basic module allows you to calculate the CO2 tax for your fleet online at any time. The calculation takes into account the CO2 Super Credits, the exemption limits and includes a forecasting function.
+ Preparation and processing of assignment forms
Optionally, the module “Creation and processing of assignment forms” can be added. You will receive an online form for entering the vehicle values, upload the documents (13.20 A and COC/TG sheet) and select the procedure (MFK or self-acceptance). The cession is automatically sent to the Astra in the case of self-acceptance or to you directly in the case of MFK.
+ Documents archive
In addition, you can save all vehicle documents in your CO2 cockpit after the assignment and retrieve them at any time.
Would you like to learn more about the CO2 Cockpit?