Advertisers in the automotive sector who display, offer for sale or lease, or advertise new passenger cars are required, under certain conditions, to include information on fuel consumption, CO2 emissions and electricity consumption of the advertised vehicles in their advertising materials.
The efficiency labelling requirements subject to the German Ordinance on Efficiency Labelling of New Passenger Cars (Pkw-EnVKV), which in part are unfortunately slightly imprecise, have presented car manufacturers, car dealers and legal practitioners with enormous challenges for years. The replacement of the New European Driving Cycle (NEDC) test procedure, which was previously used to determine the fuel consumption and emission values of new passenger cars, by the WLTP test procedure adds further difficulties, since the German legislator has unfortunately been lagging behind for years with the corresponding legislative process. Even at present, it is not yet foreseeable when the German legislator will pass the amendments to the Passenger Car Energy Consumption Labelling Ordinance (Pkw-EnVKV), which is urgently awaited by advertisers.
The following Q&A on the labelling requirements for the Pkw-EnVKV is therefore intended to provide advertisers in the automotive industry with a quick and easy-to-understand overview of the relevant requirements pursuant to the Pkw-EnVKV. The individual Q&As will be updated on an ongoing basis and supplemented with further important points. So please check out for updates to these Q&A.
If you are interested in individual support, our team of experts around our partner Roman Brtka will be happy to assist you at any time.
READ THE FULL Q&A HERE (10 page PDF).
For further information, please contact:
Roman Brtka, Partner, Bird & Bird
roman.brtka@twobirds.com
