ZDK criticizes planned expansion of labeling requirements

The European Commission has proposed updating and expanding the vehicle registration system. The automotive industry is not enthusiastic about the proposal, arguing that it is hardly feasible in practice.

The the European Commission has proposed updating the directive on vehicle labelling. This aims to ensure that consumers have access to information about CO₂ emissions.₂The aim is to provide information on vehicle emissions and energy efficiency, both in showrooms and online. This will enable consumers to make informed decisions and promote more environmentally friendly, low-emission, and fuel-efficient vehicles. Currently, the labeling requirement only applies to new cars. In the future, it will also apply to used passenger cars and light commercial vehicles, as well as new light commercial vehicles.

The Central Association of the German Automotive Industry The German Association of Motor Trades and Repairs (ZDK) criticizes the proposal as impractical. "The EU Commission is overreaching by now including used cars in the regulation. This opens the floodgates for professionally operating warning letter associations, as used vehicles often deviate from their original condition and therefore there is hardly any objective fuel consumption data available for these vehicles," explains ZDK President Thomas Peckruhn.

Appeal to the Ministry of Economic Affairs

Furthermore, older used cars were registered according to the New European Driving Cycle, but now the WLTP (Worldwide Harmonised Light Duty Test Procedure) value is decisive for the labeling. This requires complicated conversions that dealers can hardly perform. In a statement to the Federal Ministry of Economics The ZDK demands that Minister Katherine Reiche (CDU) advocate for improvements to the Commission. 

Peckruhn: "The numerous changes offer consumers no added value whatsoever. For the automotive trade, the regulations pose too many risks to even consider offering older used vehicles or accepting them as trade-ins." The ZDK (German Association of Motor Trades and Repairs) appeals to the Ministry to formulate legally sound, practical, and technologically feasible regulations that do justice to the different roles and influences of manufacturers, dealers, and other market participants. Only in this way can the regulation serve both consumer interests and the competitiveness of the automotive industry.

The association has submitted an eight-point document with demands to the ministry:

1. Labeling requirement for used vehicles: The labeling requirement is limited to new passenger cars. Used vehicles often lack WLTP values, or these are inaccurate due to aging or modifications.
2. Information on battery state of health (SoH) for used BEV/PHEV vehicles: No SoH reporting requirement for used cars, but rather a restriction of the labeling requirement to new vehicles.
3. No expansion to light commercial vehicles: focus on passenger cars should be maintained; commercial vehicles have little relevance for private customers, therefore an expansion would be disproportionate.
4. Clear definitions and specifications of the implementation obligations: Detailed requirements regarding the location, form, duration and timing of the labeling (especially online/print) as well as clear definitions of key terms.
5. Product database / digital simplification (“class arrow”): Create operational readiness and clear regulations for the EU product database in parallel with its entry into force; as well as clear responsibility and liability for manufacturers; QR code option for the “class arrow”.
6. Responsibility of service providers / online platform operators: Obligations must follow the respective sphere of influence; platform operators must be held accountable; merchants can only be obligated to the extent that they have influence on the presentation.
7. Vehicle configurators: Responsibility for correct presentation and labeling lies with the operator of the configurator; clear delineation of responsibilities and specification of the term "configurator"/covered advertising materials.
8. Harmonisation of market surveillance and sanctions at EU level: Uniform EU regulations on market surveillance and sanctions to avoid partial harmonisation and distortions of competition.

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