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April 5, 2026

Automotive Advertising 2026: Electric, Diesel, Hybrid

“Zero Emission” — caution from 2026: Under Section 5 UWG and the EmpCo Directive (EU 2024/825), advertising with “Zero Emission” for electric vehicles without reference to supply chain emissions (battery production) is misleading.

Electric vehicles: “Locally emission-free” permissible, “Zero Tailpipe Emissions” permissible, “Zero Emission” generally misleading (battery supply chain), “Climate neutral vehicle” per-se prohibited under EmpCo.

Hybrid vehicles: “Hybrid with an electric range of 50 km (WLTP)” permissible, “Environmentally friendly hybrid” generic, “CO₂ reduction of 23 % compared to the previous combustion engine model” permissible with methodology.

Combustion engines with E-fuels: “Compatible with synthetic E-fuel” permissible as a technical statement, “Climate-friendly diesel” prohibited under Section 5 UWG and the EmpCo Directive (EU 2024/825), “CO₂ reduction through RED-II-compliant E-fuels” permissible with percentage indication.

LCA — the key: According to EmpCo, the system boundary (Scope 1-3) must be stated with every CO₂ statement. Manufacturers should provide LCA compliant with ISO 14067.

WLTP vs. real: WLTP values must be supplemented with a reference to real deviations (typically +20-30 %).

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