Executive summary

From a consumer perspective, the ongoing review of the Car Labelling Directive provides a timely opportunity to strengthen the EU framework for consumer information on passenger cars. The current Directive no longer fully reflects market developments, in particular the growing diversity of powertrains and the increasing importance of electric vehicles.

From a consumer perspective, access to clear, reliable and comparable information remains a key condition for making informed choices. The revised framework should therefore aim to further improve transparency and usability, while ensuring that information is presented in a way that is both meaningful and accessible in practice. This is particularly important in a context where consumers are expected to navigate increasingly complex technology choices, cost considerations and different patterns of vehicle usage.

In this context, the revision could contribute to a transition that is not only environmentally effective, but also affordable and socially fair, supporting informed choice for all consumers, including those relying on the second-hand market. The Directive can play an important role in this respect by helping consumers better understand the economic and practical implications of their choices, while supporting transparency, accessibility and confidence in the transition to cleaner mobility.

Vehicle labelling and consumer information

Clear and comparable information is essential to enable consumers to navigate an increasingly complex vehicle market. The revision of the Directive provides an opportunity to strengthen the consistency and clarity of the information presented across different vehicle types.

To support consumer confidence, any future labelling framework should be accompanied by appropriate enforcement and market surveillance measures, ensuring that information obligations remain both credible and effective in practice.

In particular, the framework could evolve to better reflect energy efficiency and, where sufficiently robust methodologies become available, lifecycle or well-to-wheel emissions. Such developments could support improved transparency and comparability between technologies, while maintaining a balanced and technology-neutral approach.

Energy efficiency and BEV labelling

FIA Region I notes that the current framework does not fully reflect differences in the energy efficiency of battery electric vehicles, despite the existence of significant variations in their electricity consumption. In this respect, the introduction of a dedicated label for BEVs, based on energy consumption expressed in kWh/100 km and structured through efficiency classes, could be considered as a useful approach to improve transparency for consumers.

Such an approach could help provide clearer information on running costs and encourage the uptake of more energy-efficient models. At the same time, any move towards a common CO₂-based label across all powertrains should be carefully considered and would depend on the availability of harmonised and robust methodologies, in order to ensure credible and comparable results.

Reflecting various driving conditions

Improving the relevance of the label for consumers requires better alignment with real-world vehicle usage. As energy consumption varies depending on driving conditions, providing additional information on consumption across different driving cycles could help support a more accurate understanding of vehicle performance and costs.

If presented in a clear and accessible format, such information could enhance the usefulness of the label and contribute to more informed consumer decision-making.

Representation of plug-in hybrid vehicles

FIA Region I notes that the current representation of plug-in hybrid vehicles may not always provide a complete picture of their practical performance. In this context, it could be beneficial to further explore ways of improving transparency, for example by presenting both combined CO₂ emissions and emissions with the battery discharged, alongside relevant information on electricity and fuel consumption.

Such an approach could help consumers better understand the operational characteristics of these vehicles and support more informed purchasing decisions.

Scope and second-hand vehicles

From a consumer perspective, extending the scope of the Directive to the second-hand market deserves further consideration, particularly in light of its importance for affordability and access to mobility. Approaches such as requiring professional dealers to provide comparable information for used vehicles could help strengthen consumer confidence and ensure continuity of information across the vehicle lifecycle.

In this context, and taking into account the durability and lifetime compliance requirements introduced under Euro 7, mandatory labelling for used vehicles could be considered in particular for used Euro 7 passenger cars. For these vehicles, manufacturer-provided type-approval values and lifetime compliance obligations could provide a sufficiently robust and comparable basis for consumer information. Such labelling should be understood as model-based information enabling consumers to compare vehicles, rather than as a certification of the actual emissions or consumption performance of an individual used vehicle.

More broadly, consideration could also be given to how consumer information for older used vehicles can be improved, while ensuring that the data made available remains sufficiently reliable, comparable and meaningful for consumers.

At the same time, it would appear appropriate to explicitly exempt private sales from such obligations, in order to avoid disproportionate burdens and to ensure legal clarity. A clear and consistent framework in this area would support a more inclusive approach to consumer information, reflecting the realities of the wider vehicle market.

State of health of batteries

Battery state of health is a relevant consideration for consumers, particularly in the context of the second-hand electric vehicle market. However, FIA Region I notes that current methodologies are not standardised and may not yet provide fully reliable or comparable results across manufacturers.

In this context, it may be premature to include such values in the label. Priority could instead be given to the development of a harmonised and robust methodology within the type approval framework, so that any future information provided to consumers is both credible and comparable.

Product database and digitalisation

A comprehensive EU-wide product database could usefully complement the physical label and improve access to information for consumers. Provided that it is regularly updated and based on reliable data, such a tool could facilitate comparison across vehicles and technologies.

In particular, the integration of real-world consumption data, such as OBFCM data where sufficiently robust, could enhance the relevance of the information available to consumers. Digital tools should however remain user-friendly and closely linked to the point of sale, ensuring that they effectively support consumer understanding.

Conclusion

The review of the Car Labelling Directive represents an important opportunity to strengthen consumer empowerment in the transition to cleaner mobility. A balanced and effective framework would be expected to provide clear and reliable information, better reflect real-world usage, and remain accessible for all consumers.

Ensuring that the transition is transparent, affordable and socially fair will be essential to maintaining consumer trust and supporting informed choices across both new and second-hand markets. In this regard, the Directive can play an important role in helping consumers compare vehicles more easily, understand the practical and financial implications of different technologies, and engage with the transition on the basis of clear and trustworthy information. FIA Region I stands ready to continue engaging constructively with EU institutions as this work progresses.