Changes to labeling in advertising of vehicles on the horizon

As part of the EU’s “Automotive Package”, the EU Commission published a proposal for a new Regulation on 16 December 2025 which, among others, concerns vehicle labeling. So far, the proposal is only available in English; the full text can be found here.

These are our initial observations:

– The current Directive 1999/94/EC, which forms the basis of the German PKW-EnVKV, will be repealed; provisions on energy consumption, CO2 emission and range labeling will be introduced into Regulation (EU) 2019/631. This is indented to bring about EU-wide standardization.

– The proposed provisions are less comprehensive and less differentiated than those in the current PKW-EnVKV. E.g., no distinction is made between new and used vehicles.

– Any promotional material related to the sale or lease of individual vehicles needs to show a vehicle label; this is not the case at present.

– The new standard label will be less comprehensive than the current energy label required by the PKW-EnVKV; it is more reminiscent of the tire label.

– As an alternative to displaying the standard vehicle label, it will also be possible to use a simplified label on the internet, which contains color coding and indicates the CO2 class. That generally requires that the simplified label guides the user to the product database containing the relevant information.

– Enforcement and legal consequences of violations will be left to the EU Member States.

The legislative process is still in its early stages and adjustments are sure to be made.

You can find the new labels here.