The CO2 tax on light commercial vehicles

LNF: Which vehicles will be affected by the CO2 tax from 2020?

The light commercial vehicles affected by the CO2 tax include delivery vans and light semi-trailers that are

  • erstmals in der Schweiz in Verkehr gesetzt,
  • imported into Switzerland or
  • be produced in Switzerland
    (Article 17(1) CO2 Regulation).

Definitions: Delivery vans, light semitrailers, placing on the market

  • Delivery vans (vehicle category N1) are light motor vehicles for the transport of goods with a maximum of nine seats including driver (Article 11 paragraph 2 letter e of the Ordinance on the Technical Requirements for Road Vehicles, VTS).
  • Semi-trailer tractors (category N) are motor vehicles designed to tow semi-trailers (Article 11(2)(i) VTS).
  • Light motor vehicles are motor vehicles with a gross vehicle weight of up to 3.5 tonnes (Article 10(2) VTS).
  • Vehicles registered for the first time in Switzerland are considered to have been put into circulation for the first time.

The following vehicles are exempt from the CO2 tax
Not within the scope of the CO2 tax
Vehicles that have been registered abroad more than six months prior to registration with Swiss customs,

  • Vehicles that had previously been registered in Switzerland,
  • special purpose vehicles (as defined in Annex 2, Part A, point 5 of Directive 2007/46/EC) and
  • Vehicles with an unladen weight of over 2,585 kilograms which are measured using the measurement method for heavy motor vehicles in accordance with Regulation 595/2009/EC and which do not have emission values in accordance with Regulation 715/2007/EC.

What are “special purpose vehicles”?

What are “special purpose vehicles”? Special purpose vehicles are not subject to the CO2 tax regulations.

Special purpose vehicles shall include

  • Motor caravans: vehicles of category M designed to accommodate persons and having the following minimum equipment:
    – Table,
    – Sitting and sleeping accommodations,
    – cooking facilities and
    – Luggage accommodation facilities.
    – kugelsichere Fahrzeuge, die zum Schutz der Insassen oder Waren gepanzert sind,
  • Ambulances: Class M vehicles equipped for the transport of the sick and injured,
  • Hearse: Class M vehicles equipped for the transport of corpses,
  • Wheelchair-accessible vehicles of category M1 which, due to their special design or conversion, can accommodate persons seated in one or more wheelchairs when travelling on the road,
  • Caravans according to ISO 3833-1977, definition under,
  • Class N3 mobile cranes which are not suitable for the carriage of goods and are equipped with a crane with a permissible load moment of at least 400 kNm, and
  • other special purpose vehicles as defined in section 5 of Part A of Annex 2 to Directive 2007/46/EC (see definition at the beginning of this paragraph on “vehicles designed to perform a special function”).

Special cases: Vehicles which, at the request of the manufacturer, can be measured using the procedure for light or heavy motor vehicles.
At the request of the manufacturer, vehicles with an unladen weight between 2,585 and 2,815 kilograms may be measured according to the procedure for light motor vehicles.
Vehicles with an unladen weight between 2 355 kg and less than 2 585 kg may, at the request of the manufacturer, be measured according to the procedure for heavy motor vehicles.

Vehicle categories – Definitions in accordance with Article 12(1) VTS
Fahrzeugklasse M: Kraftfahrzeug für die Personenbeförderung

  • vehicle category M: motor vehicle intended for the carriage of passengers
  • category M2: vehicles with up to nine seats (including driver) and a guaranteed weight of up to 5 tonnes
  • category M3: vehicles with up to nine seats (including the driver) and with a guaranteed weight of more than 5 tonnes

Vehicle class N: Motor vehicle for transporting goods

  • Class N1: vehicles with a guaranteed weight of up to 3,5 tonnes
  • Class N2: vehicles with a guaranteed weight exceeding 3,5 to 12 tonnes
  • category N3: vehicles with a guaranteed weight exceeding 12 tonnes

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The CO2 target value for LNF of 147 g/km applicable from 2020 refers to the entire LNF fleet of an importer or a pool. The individual target value of a vehicle is determined taking into account the unladen weight of a vehicle: the higher the unladen weight of an LNF, the higher the vehicle-specific CO2 target value.

For the purpose of determining the CO2 target, the unladen weight of the respective vehicle is compared with the average of all LNFs newly registered within a previous calendar year (“reference unladen weight”, “standard weight”).
An LNF with “standard unladen weight” will have a CO2 target value of 147 g/km in 2020.
A heavier LNF is given a higher CO target, a vehicle with a lower unladen weight a lower CO target.

The reference unladen weight for 2018 (i.e. the average unladen weight of the new vehicle fleet in 2018) is a key parameter from which the 2020 CO2 target values are derived for the individual new vehicles (separately for LNF and passenger cars). The mathematical formula for calculating the individual target for small and large imports is contained in Annex 4a, Section 1 of the CO2 Regulation.

Important note:
The Swiss Federal Office of Energy (SFOE) will announce the LNF reference tare weight (2018) by the end of 2019. The reference unladen weight is expected to be published in an annex to the CO2 Regulation (for passenger cars so far in Annex 4a, Section 2 of the CO2 Regulation).

CO2 target value and unladen weight: special case for multi-stage vehicles
LNF can be imported into Switzerland in various production variants. It is possible to import already completed LNF vehicles or basic vehicles, which in Switzerland are equipped with certain additional equipment according to individual customer requirements.

In the case of the basic vehicles (MSV, Multi Stage Vehicles) still to be upgraded, the approval procedure differs from the procedure for vehicles that are imported in complete condition.

Articles 24 and 25 of the CO2 Regulation regulate which data on CO2 emissions and on the unladen weight are to be applied to base vehicles. Article 24 refers to type-approved vehicles with a Swiss data sheet, Article 25 to vehicles without a type-approval.

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While the achievement of CO2 targets in the European Union is determined by collecting EU-wide CO2 emission values for the individual vehicle brands (even including Norway and Iceland, which do not belong to the EU, but to the European Economic Area EEA), in Switzerland new vehicle importers are obliged to ensure that their individual CO2 targets are met.

Emissions poolImporters can join forces in order to achieve the CO2 target as a pool. Small, large and private importers are entitled to form a pool if they jointly import at least 6 new LNF vehicles per year.

Major importers: Assertion of special CO2 targets for small manufacturer vehicles
If less than 22,000 new light commercial vehicles from one manufacturer are registered each year in the European Union, these “small manufacturers” can apply to the European Commission for special CO2 targets.

Grossimporteure, die Fahrzeuge von Kleinherstellern in die Schweiz einführen, können die von der EU genehmigten CO2-Spezialziele geltend machen. Major importers must submit a notification form to the Swiss Federal Office of Energy before placing a new LNF on the market.

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In contrast to the EU, for which the target value of 147 g/km will apply without exception and uniformly to the entire LNF fleet from 2020, Switzerland is planning to introduce a CO2 tax for LNF that will be reduced in the form of phasing-in and supercredit regulations for the years 2020 to 2022.

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Die CO2-Sanktion je Gramm Zielüberschreitung pro Kilometer liegt für Personenwagen für das Jahr 2019 bei 111 CHF (siehe Artikel 29 und Anhang 5 der CO2-Verordnung).

In the European Union, a sanction amount of 95 euros per gram of exceeding the target applies to CO2 exceedances in 2019. Das Bundesamt für Energie rechnet den in der EU geltenden Euro-Betrag zum Durchschnitt aller Tageskurse CHF/EUR der zwölf Monate vor dem 30. Juni 2019 in Schweizer Franken um (Art. 29 Abs. 2 CO2-Verordnung).

The SFOE will publish the CHF amount applicable for 2020 for one gram of CO2 exceeding the target by the end of 2019.

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Each LNF importer receives the status of a small LNF importer or large LNF importer irrespective of his status as a passenger car importer.

  • In principle, LNF is a major importer if at least 6 light commercial vehicles are imported into Switzerland and placed on the market within one calendar year (Article 18 CO2 Ordinance).
  • For 2020, anyone who has placed at least six imported LNFs on the market in the first half of 2019 (cut-off date 30 June 2019) is considered an official major importer.
  • If an importer has placed a maximum of five LNFs on the market by 30 June 2019, he may nevertheless register with the SFOE as a provisional major importer for 2020. If an importer has placed a maximum of five LNFs on the market by 30 June 2019, he may nevertheless register with the SFOE as a provisional major importer for 2020.
  • Important for major importers: Even “official major importers” must formally register with the Swiss Federal Office of Energy by 31 December 2019 using the registration form in order to confirm their status as major importers and their contact details.

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  • 30. November 2019: Ende der Registrierungsperiode für Emissionspools für 2020
  • by 31 December 2019: Announcement by the Swiss Federal Office of Energy (SFOE) of the LNF reference net weight (reference year 2018) and the amount of the sanction in CHF per gram by which the CO2 targets for 2020 will be exceeded
  • 30 November 2019: End of the registration period for emission pools for 2020
  • 1 January 2020: Start of LNF inclusion in the CO2 tax regulations

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