1. What is the aim of the CO₂ fleet regulation (CO₂-Flottenregulierung)?
The European Commission obliges vehicle importers to:
reduce the average CO₂ emissions per vehicle they sell in the EU,
comply with the current fleet target (2025): an average of no more than 95 g CO₂/km across the whole fleet.
If this limit is exceeded, the importer must pay high penalties for every gram of CO₂ above the target, multiplied by the number of vehicles.
2. What if you are a small importer?
A small importer is defined as a company that imports fewer than 1,000 vehicles per year into the European Union.
In this case, you can apply to the European Commission for a derogation (Ausnahmeregelung).
What is available to you as a small importer?
| Facilitation | Explanation |
|---|---|
| Zielabweichung (target deviation) | You may request a less stringent fleet target (Flottenziel) that better matches your company size and market conditions. |
| Vereinfachter Antrag (simplified application) | You can use a simplified derogation application via the EU portal. |
| Annual validity | The derogation is granted per year. You must apply before the end of October for the following calendar year. |
3. Umweltprämie – environmental purchase incentives
If you sell new or imported low-emission vehicles (e.g. < 50 g CO₂/km),
you can offer an Umweltbonus / Umweltprämie (environmental bonus) to the buyer. The bonus is financed either:
by the state, if the vehicle is included in the BAFA list, or
by you as the importer, if the vehicle is not listed by BAFA.
Example:
You import Chinese electric cars that are not listed on the BAFA subsidy list.
The buyer does not receive a state Umweltprämie.
However, you can grant your own €2,000 discount and market it as your own Umweltprämie / eco bonus.
4. What must you do as a small importer?
Register with the KBA as an official importer
Register with the Kraftfahrt-Bundesamt (KBA) as an official vehicle importer.
Submit a CO₂ target derogation (CO₂-Ziel-Ausnahme) to the European Commission
via the EU Login Portal,
section: “Application for derogation from specific emissions targets”,
link: https://ec.europa.eu/clima/policies/transport/vehicles/cars_en
Provide the following information:
your EORI number (Economic Operators Registration and Identification),
vehicle data (type approval, CO₂ values (Typgenehmigung, CO₂-Werte)),
proof that you do not exceed 1,000 vehicles per year.
5. What happens if you do not register the derogation?
| Situation | Consequence |
|---|---|
| You import fewer than 1,000 vehicles but do not submit the derogation application | You are treated as a large manufacturer and must pay the full penalties. |
| You import vehicles emitting more than 95 g CO₂/km | A penalty of €95 for each gram of CO₂ above the target is charged, multiplied by the total number of vehicles. |
The editorial team of the website strives to provide accurate and up-to-date information based on careful research and multiple sources. However, errors or incomplete details cannot be completely ruled out, and EU regulations may change over time. Please therefore treat this article as initial guidance only, and contact the European Commission, the KBA, tax advisers or legal experts for binding and current information.
