Pkw-EnVKV: which consumption figures belong on a car dealer website

What the regulation requires

The regulation dates from 2004 and was substantially rewritten with effect from 23 February 2024. Only WLTP figures count now, and the old energy efficiency classes have been replaced by CO₂ classes A to G. The transitional periods have expired: 1 May 2024 for online advertising, 1 August 2024 for print. The most recent amendment, on 2 March 2026, left the rules for online advertising untouched.

Anyone advertising, displaying, selling, renting out or leasing a new car has to state its consumption, CO₂ emissions, energy costs, vehicle tax, possible CO₂ costs and CO₂ class. Which of these are required depends on the setting: the label on the car, the poster in the showroom, advertising, or distance selling. A dealer's own website falls under the advertising rules, which are the shortest set.

Which vehicles are covered

It applies to new passenger cars. A type-approved car counts as new if it was first registered no more than eight months ago or has covered no more than 1,000 kilometres. Pre-registered cars and demonstrators normally fall into that group.

Used cars do not have to carry these figures. A dealer who shows them anyway may only use WLTP values and has to make clear that the car is used. Figures from the old NEDC procedure may no longer be used at all.

The line between new and used is the most common point of dispute. The German motor trade association reads the definition as making anything above 1,000 kilometres a used car; on the wording, eight months since first registration is enough on its own. The question is unsettled. When in doubt, include the figures: they never do harm, leaving them out can be expensive.

What has to appear on your own website

A dealer website is advertising. It is not a point of sale, so the label itself is not required there, and without an online shop there is usually no distance selling either. Each new car needs these figures:

• The combined figure for energy consumption
• The combined figure for CO₂ emissions
• The CO₂ class, or two classes for plug-in hybrids
• For electric and plug-in vehicles also the electricity consumption and the electric range, and for plug-in hybrids the consumption with a depleted battery

A table is enough. The coloured CO₂ scale is not required on an ordinary inventory page, and neither is a particular order. The old mandatory sentence pointing to the official guide is no longer required in advertising either.

Where the figures have to appear

The figures have to be easy to read, no less prominent than the main part of the advertising message, and understandable at a glance. They have to reach the visitor at the moment they first learn anything about the engine. Since 2024 that applies even when nothing is said about the engine at all.

For a vehicle list that means: if the tile shows power, engine size or fuel type, the figures belong in the tile, not only on the vehicle page. Under the earlier version courts held that a click on a "show more" button was not enough. A mere link to a PDF is even less so.

CO₂ classes A to G

The class follows directly from the combined CO₂ emissions, with no reference to the weight of the car.

Plug-in hybrids carry two classes: one from the weighted combined figure, one from the figure with a depleted battery. The old efficiency class from A+++ to D is gone. It depended on vehicle weight and has been dropped; anyone still using it is using a label the regulation no longer recognises.

What an inventory page does not need

Energy costs, vehicle tax, the possible CO₂ costs over ten years and the vehicle identification number belong on the label and on the showroom poster, not in online advertising. The CO₂ costs are calculated from an assumed CO₂ price, the emissions per kilometre and a factor of 0.15, in three price scenarios; the ministry of economic affairs publishes the prices each year on 30 June.

Distance selling is different: if a contract can be concluded entirely through the website, the label's contents have to be shown alongside the description of the model, and displaying the completed label satisfies that. A sentence declaring distance selling to be excluded does not help if practice says otherwise.

What happens if the figures are missing

A breach is a regulatory offence, and the German energy labelling act allows fines of up to 50,000 euros. The practical risk, however, lies elsewhere.

Deutsche Umwelthilfe, an environmental association, sends warning letters to dealers over their online advertising and sues for injunctions. The federal register of association claims lists several such cases from 2025 and 2026, among them a judgment by consent from the regional court of Bochum on 30 April 2025 against a dealer whose listings lacked electricity consumption, CO₂ emissions and CO₂ class.

It is rarely the first warning letter that costs money, but what follows. Signing an undertaking with a penalty clause means every further faulty listing carries a contractual penalty, and after a judgment, a court fine. With three hundred cars in stock that stops being a one-off risk.

Where the figures come from

The authoritative source is the certificate of conformity for the individual car: field 49.1 for combustion engines, field 49.4 for plug-in hybrids. Manufacturers have to supply these figures to their dealers on request, without delay and free of charge.

The guide published by Deutsche Automobil Treuhand lists figures by model and is updated twice a year. It is a reference, not a substitute for the figures of the individual car: a different wheel and tyre combination alone changes them. Electricity consumption needs converting, as the certificate states watt-hours per kilometre while the figure to publish is kilowatt-hours per 100 kilometres.

Where the manufacturer does not yet have binding WLTP figures, the requirement falls away, and any voluntary figures have to be marked as provisional. A system or service provider that fails to deliver the figures is no defence: responsibility stays with the dealer.

How BasisCars publishes the figures

BasisCars carries the figures from your mobile.de listing across with the vehicle: combined consumption, CO₂ emissions, emission class and the remaining consumption values, including for electric and hybrid cars. The plugin shows them on the vehicle page in line with the Pkw-EnVKV and WLTP, with no second round of data entry.

All fields are stored as custom fields in WordPress, so they can also be shown in the result list or in a template of your own. What is missing from the listing cannot be invented by the plugin: if the figures are not maintained on mobile.de, they will be missing on the website too. Checking them remains your job.