The Pkw-EnVKV (Pkw-Energieverbrauchskennzeichnungsverordnung) is the German regulation behind the labeling duty for new passenger cars, the Kennzeichnungspflicht: how dealers show fuel or electricity consumption, CO2 emissions, the CO2 class and running costs on a label at the car, on a poster in the showroom and in every ad, including your website and listing portals. The current label with CO2 classes A to G has applied since February 2024, and the regulation was last amended on March 2, 2026. This guide, written in English for dealers in Germany, explains what applies as of October 2026.
It summarizes the regulation text and the guidance on the dena platform alternativ-mobil.info, which publishes on behalf of the federal economics ministry (BMWE). It is not legal advice. For your own case, the regulation and your lawyer or trade association have the final word.
Which cars fall under it
The duty applies to new passenger cars of class M1. A car is new if it has not yet been sold for any purpose other than resale or delivery. The regulation presumes this when, at the moment you display, offer or advertise the car, first registration is no more than eight months ago or the odometer shows 1,000 km or less (either one is enough).
That has practical consequences:
- Day registrations and demonstrators can count as new cars, according to the dena FAQ, and then need the full information.
- A car can stop being new while it stands on your lot, because the check is made when you offer or advertise it.
- Used cars are not covered. You may label them voluntarily, but only with WLTP values, and the label must say clearly that it is for a used car.
- New cars for which the manufacturer has no binding WLTP values yet are exempt. A voluntary label for them must carry the word "(vorläufig)", meaning preliminary.
Vans (N1), motorcycles and motorhomes are not passenger cars under the Pkw-EnVKV.
What you have to show, by channel
| Where | What is required |
|---|---|
| The car at your premises | The Pkw label in A4 at the car or directly next to it, also allowed on a screen. According to the dena FAQ, a QR code or a link cannot replace the label. |
| Your showroom | A poster (Aushang) covering the models offered at this location, updated at least every six months, or every three months if shown on a screen. |
| On request | The guide (Leitfaden) to fuel consumption and CO2 emissions of new cars. |
| Ads, print and online | Combined energy consumption, combined CO2 emissions and the CO2 class. Plug-in hybrids: weighted combined values and both CO2 classes, one of them "with a discharged battery." |
| Selling online (Fernabsatz) | If the car can be bought or leased online, all label details as well. Showing the matching label template counts. |
For online ads, including your own website, listing portals, social media and video platforms, the values must reach the viewer at the moment engine details such as power, displacement or acceleration are first shown. The CO2 class should appear in at least the same font size as those details. If an ad shows no engine details at all, the values still have to be given.
The CO2 classes
The class depends on the combined CO2 emissions in the certificate of conformity of that individual car:
| Class | CO2 g/km |
|---|---|
| A | 0 |
| B | 1 to 95 |
| C | 96 to 115 |
| D | 116 to 135 |
| E | 136 to 155 |
| F | 156 to 175 |
| G | 176 and more |
Plug-in hybrids show two classes: one for the weighted combined value and one with a discharged battery.
Running costs on the label
The label shows annual energy costs for 15,000 km, possible CO2 costs over the next ten years and the annual vehicle tax. The BMWE updates the reference prices every year on June 30, and dealers must use them for all labels from October 1 at the latest.
The BMWE publishes the new lists every year on June 30: reference prices for petrol, diesel and household charging electricity (the averages of the previous year) and three CO2 price paths for the next ten years (low, medium, high). Take the values from the current lists on the BMWE website before you print labels; this guide does not repeat them, because they change every year.
Worked example (method only). The prices below are round example values, not the official reference prices. A new petrol car with combined consumption of 6.0 l/100 km and 136 g/km CO2, with a petrol price of 1.70 EUR per liter and a medium CO2 price of 140 EUR per tonne:
- Energy costs per year: 1.70 x 6.0 x 150 = 1,530.00 EUR
- CO2 costs over ten years: 136 x 0.15 x 140 = 2,856.00 EUR (medium); repeat with the low and high CO2 prices from the list
- CO2 class: E (136 g/km)
The factor 150 stands for 15,000 km a year in liters per 100 km, and 0.15 for 150,000 km over ten years converted from grams to tonnes.
Two 2026 changes to remember. Since January 1, 2026, the tax footnote for battery electric and fuel cell cars has new dates: the exemption applies to first registrations from May 18, 2011 to December 31, 2030, for ten years, at most until December 31, 2035. The dena FAQ says there is no transition period. And the regulation was amended on March 2, 2026 (Federal Law Gazette 2026 I No. 55, published March 5), so use the label templates in its current annex.
Fines and warning letters
Breaches are administrative offenses under section 15 of the Energy Consumption Labeling Act (EnVKG) and can be fined up to 50,000 EUR. The market surveillance authorities of the federal states enforce it. According to the dena FAQ, wrong or missing details can also lead to warning letters (Abmahnungen), for example over an online ad without the CO2 class.
A checklist for your stock
- Flag every car that is "new" by the eight-month or 1,000 km rule, including day registrations and demonstrators, and recheck while it is in stock.
- Take the values from the certificate of conformity of that exact car. A different wheel and tire combination can change them.
- Check that your data source delivers all values, including the four phase values (city, suburban, rural, highway) the label needs.
- Use the current reference prices from October 1 each year.
- Put the label at the car or on a screen next to it, never just a QR code.
- Check every online channel: your website, each portal, social posts. The values must be visible where the engine details appear.
- Keep the poster and the guide ready at each location.
FAQ
Does the Pkw-EnVKV Kennzeichnungspflicht apply to used cars?
No. Used cars can be labeled voluntarily, only with WLTP values and clearly marked as used. A car registered no more than eight months ago or with no more than 1,000 km can still count as new.
Is a QR code at the car enough?
No. According to the dena FAQ, a QR code or a link to another website cannot currently replace the label.
Do I need the label on mobile.de or other portals?
The A4 label belongs at the point of sale. A portal listing counts as online advertising, so it must carry the consumption, CO2 and CO2 class information, visible together with the engine details. If the car can be bought online, the full label details are needed too.
Where do I get the values?
Mostly from the certificate of conformity (CoC) of the car. According to the dena FAQ, manufacturers must give dealers the details on request, promptly and free of charge. The dena site also has a free tool to fill in and print a label.
When do the new prices apply?
The BMWE publishes them on June 30. They apply to cars offered from then on, and to all labels from October 1 at the latest.
If you manage your stock and your website listings in Vehicle Hub, the dealer app in KIMISUITE, keep the CoC values with each car, so every listing carries them next to the engine details. Check the label itself against the official templates.
