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– The current Directive 1999/94/EC, which forms the basis of the German PKW-EnVKV, will be repealed; provisions on energy consumption, CO2 emission and range labeling will be introduced into Regulation (EU) 2019/631.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

The so-called “order button” and the “cancellation button” are well established features in the European and German consumer protection law. And by 2026 the „withdrawal button“ will be added!

• The “order button“ (Section 312j German Civil Code) is the oldest one of the bunch: Since 2012, online consumer contracts require an explicit acknowledgement of the payment obligation by means of an “order with obligation to pay“ button. The courts apply strict standards.

• The “cancellation button“ applies to online contracts with continuing obligations. It is a creation of the German legislature with no origin in EU law, entered into force in 2022 (Section 312k German Civil Code). An increasing number of court rulings interpret the requirements strictly.

• And the new kid on the block: the “withdrawal button“! From 19 June 2026, an electronic withdrawal function must be provided for distance contracts concluded online. The first draft of the act is available now.

Violations not only have consequences for the contractual relationship, they can also result in warnings from competitors and class actions!
Find details on the latest button in this overview.