Regulatory Announcement

EPA and NHTSA Propose Changes to 


the MotorVehicle Fuel Economy Label
 

The U.S. Environmental Protection Agency (EPA) and the 

National Highway Traffic Safety Administration (NHTSA) are 

redesigning the fuel economy label consumers see on the window of 

every new vehicle in dealer showrooms. The agencies are proposing 

two different label designs and are asking for input from all Americans 

on which redesigned label is the most informative to them as they 

make purchasing decisions. 

Regardless of whether EPA and DOT select one of the two labels 

proposed today or adopts a modified version following the public 

comment process, the goal of the new label will be the same: to 

provide consumers with simple, straightforward comparisons across all 

vehicles types, including electric vehicles (EV), plug-in hybrid electric 

vehicles (PHEV), and conventional gasoline and diesel vehicles. 

These proposed changes represent the most significant overhaul of 

the federal government’s fuel economy label since its inception over 

30 years ago. Beginning with model year 2012 cars and trucks, 

the redesigned label will provide American consumers with new 

information on fuel economy, energy consumption, fuel costs, and 

environmental impacts associated with their new vehicles. The 

agencies will also develop new labels for certain advanced technology 

vehicles that will soon be mass-marketed, such as plug-in hybrid 

electric vehicles (PHEVs) and electric vehicles (EVs). 

NHTSA and EPA are proposing these changes because 

	the Energy Independence and Security Act of 2007 specifically 

calls on EPA and DOT to rate available vehicles according to 

fuel economy, ghgs and smog forming pollutants. 

Office of Transportation and Air Quality 

EPA-420-F-10-048 

August 2010 
Regulatory Announcement 

 

 

 

 

 

 

 

 

 

	advanced technology vehicles, which will be widely available soon, need 

labels that tell consumers what they need to know about their fuel/energy 

use; and 

	improved information content and display can help consumers make 

more informed decisions when purchasing vehicles. 

Label Design Options and New Information 

EPA and NHTSA are co-proposing two label designs. Both labels meet legal requirements and 

rely on the same underlying data; they differ in how the data is used and presented. The agencies encourage public feedback on which label design would provide better information to help 

consumers more easily assess the energy use, costs, and emissions of different vehicles and make 

fully-informed decisions when purchasing a new vehicle. 

Label 1: This label design prominently features a letter grade (A+ to D) to communicate the 

overall fuel economy and greenhouse gas emissions, and the 5 year-fuel-cost savings compared 

to an average vehicle (see figure 1). The letter grade is technology- and fuel-neutral; that is, a 

vehicle can earn any letter grade regardless of vehicle technology or fuel type, as long as it meets 

the specified greenhouse gas/fuel economy levels. 

Label 2: This label design is more traditional and retains the current label’s focus on fuel economy and annual fuel cost projections, with a layout similar to the current label (see figure 2). 

Both options add to the content found on the current label and include the following information for gasoline and diesel vehicles: 

•	 Fuel Economy: City and highway miles per gallon (mpg) and a slider bar comparing 

vehicle’s fuel economy to that of all other vehicles 

•	 Fuel Consumption: Combined city/highway gallons per 100 miles 

•	 Greenhouse Gases: Tailpipe carbon dioxide (CO2

) emissions in grams per mile and a 

slider bar comparing the vehicle’s CO2 emissions to those of all other vehicles 

•	 Other Emissions: A slider bar comparing a vehicle’s smog-related emissions to those of 

all other vehicles 

•	 Fuel Cost: Estimated annual costs of fueling the vehicle 

•	 Comparable Fuel Economy: A comparison of the vehicle’s fuel economy to that of 

comparable vehicles 

•	 Smart phone interactive tool: A symbol that smart phones can read for additional 

consumer information (also known as a QRR

 code) 

The advanced technology vehicle labels contain additional information tailored to these technologies (see figures 3 and 4), including: 

•	 Driving Range: Identifies how many miles electric vehicles (EVs), plug-in hybrid electric 

vehicles (PHEVs), and compressed natural gas (CNG) vehicles can go before recharging 

or refueling. 

•	 Different Modes: Some vehicles, such as plug-in hybrid-electric vehicles, have different 

operating modes -- all-electric, blended, and gasoline-only. The labels provide fuel 

economy information for each distinct operating mode. 

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Regulatory Announcement 

 

 

 

•	 Energy Consumption Measurement: For EVs, the label shows energy use via both a 

miles per gallon of gasoline-equivalent (mpg-e) and kilowatt-hours per 100 miles metric; 

PHEV labels show only the mpg-e metric. Mpg-e converts kilowatt-hours of electricity 

to gallons of gasoline based on energy equivalency. 

Figure 1. Label Option 1 — Gasoline and Diesel Vehicles 

Note that the grade “B” is an example only. Gas/diesel vehicles can earn any grade, based 

on their greenhouse gas/fuel economy levels. 

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Regulatory Announcement 

Figure 2. Label Option 2 — Gasoline and Diesel Vehicles 

To view the proposed label designs for electric and plug-in electric vehicles, please visit our 

website at: www.epa.gov/fueleconomy/label.htm 

Advanced Technology Vehicles 

In the past, over 99 percent of all new vehicles have operated on petroleum fuels (e.g., gasoline, 

diesel, or a mostly-petroleum-based fuel blend) and the current fuel economy labels were designed for these gasoline and diesel vehicles. Labels for vehicles not fueled by petroleum currently are addressed on an individual basis. 

The future automotive market will most likely offer consumers vehicles that are run on alternate 

energy sources, and many of these new technologies raise new issues in terms of consumer information and vehicle labels. Electric vehicles and plug-in hybrids will soon enter the marketplace 

in significant numbers. Because these vehicles will use electricity from the grid, the familiar 

metric of miles per gallon of gasoline no longer applies. The agencies’ goal was to design simple, 

objective labels that allow consumers to easily compare all types of vehicles. The agencies are 

proposing various label options and are requesting that the public weigh in on their clarity and 

usefulness. 

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Regulatory Announcement 

 

 

 

 

 

Electric Vehicles (EVs) 

For electric vehicles (EVs), which operate solely on electricity, the agencies are proposing to 

include both kilowatt-hours per 100 miles and miles per gallon of gasoline-equivalent (electricity consumption translated into mpg). The use of kilowatt-hours would reflect the way in which 

electricity is sold, similar to the information given on a utility bill. In this case, a lower number 

is better. Miles per gallon of gasoline-equivalent converts kilowatt-hours of electricity into gallons of gasoline (based on 33.7 kilowatt-hours per gallon), and reflects the more familiar mpgtype approach for a fuel that is very different from gasoline. In this case, a higher number 

is better. 

The agencies are also proposing to show how far EVs can travel on a full battery charge. For 

EV CO2 emissions, the agencies propose to show tailpipe-only emissions, which means that EV 

label CO2 emissions will be zero, given that all of the CO2 emissions associated with EV operation occur at the power plant and other upstream sources. 

The agencies also plan to develop a web-based tool that will allow consumers to determine the total upstream CO2 emissions from electricity (production and distribution) that results from charging an EV’s battery. The agencies also ask for comments on whether to include upstream CO2 

emissions, battery charging time and driving range of EVs on the label. To view the proposed 

label designs for electric vehicles, please visit our website at: www.epa.gov/fueleconomy/label.htm 

Plug-in Hybrid Electric Vehicles (PHEVs) 

PHEVs can run on: 

1. batteries and electric motors that are plugged in to charge; 

2. a combination of both gasoline and plug-in electric operation; and 

3. gasoline only, like a conventional hybrid vehicle. 

Depending on how they are designed, PHEVs can operate in two or three of these operating 

modes. Because of these design choices, PHEVs are the most complex technology for a 

vehicle label. 

For PHEVS, the agencies propose to provide as much information as possible about each operating mode (all electric, blended, and gasoline-hybrid only). This allows consumers to tailor the 

information about each operating mode to their own driving habits. Because there are up to 

three PHEV operating modes, the agencies had to make choices on how much information to 

display on a PHEV label. 

For example, the agencies propose to display energy consumption only in terms of miles per gallon of gasoline-equivalent (mpg-e). The mpg-e converts kw-hr of electricity to gallons of gasoline based on energy equivalency (33.7 kilowatt-hours per gallon). On some of the proposed 

PHEV labels, average nationwide driving profiles are used to determine the relative electricity 

versus gasoline consumption in order to calculate a single overall value for parameters, such as 

CO2 emissions and annual fuel cost. The agencies seek comment on alternative metrics for 

PHEVs. To view the proposed label designs for plug-in electric vehicles, please visit our website 

at: www.epa.gov/fueleconomy/label.htm 

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Regulatory Announcement 

 

Other Technologies 

The labels proposed for other technologies now on the market, such as ethanol flexible fuel 

vehicles and compressed natural gas vehicles, are based on refinements to gasoline and diesel 

vehicle labels. 

Fuel Savings or Costs 

Label 1 shows the calculated fuel cost savings over a 5-year period for a specified vehicle compared to the average vehicle for that model year. (EPA will use current model year data to 

estimate the fuel economy for the subsequent model year’s average vehicle, not sales-weighted.) 

If the labeled vehicle would save the consumer money over the average vehicle, the labeled 

vehicle would state, “Over five years, this vehicle saves xxx in fuel costs compared to the average 

vehicle.” If the labeled vehicle would be more expensive to operate than the average vehicle, 

the label would state, “Over five years, you will spend xxx more in fuel costs compared to the 

average vehicle.” 

Both Label 1 and 2 show the associated annual fuel cost for the specific vehicle as required under the Energy Policy and Conservation Act. This estimated cost is based on 15,000 miles per 

year and gasoline price of $2.80 per gallon. 

Fuel Consumption Information 

While a miles per gallon estimate is required for fuel economy labels and has appeared on the 

label for several decades, the agencies have some concern that it can be potentially misleading 

for comparing fuel economy improvements, particularly when it is used in place of fuel costs. 

The following chart shows the non-linear relationship between gallons used over a given 

distance and miles per gallon. The fuel savings, in gallons, for a vehicle that gets 10 mpg versus 

a vehicle that gets 15 mpg is about 33 gallons (assuming 1000 miles). On the other hand, the 

fuel savings in gallons, for the same 5 mpg fuel economy jump, for a 30 mpg versus a 35 mpg 

vehicle is only about 5 gallons (see figure 3). 

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Regulatory Announcement 

Gallons per 1,000 Miles

Illustration of "MPG Illusion" 

150

140

130

120

110

100

90

80

70

60

50

40

30

20

10

0

0 5 10 15 20 25 30 35 40 45 50

Miles per Gallon 

33 gals 

5 gals 

Figure 3. Demonstration of the “mpg illusion.” 

This “mpg illusion” demonstrates why it may be more meaningful to express fuel efficiency in 

terms of consumption (e.g., gallons per mile or per 100 miles) rather than in terms of economy 

(miles per gallon). A consumption metric would allow for more accurate energy usage comparisons among vehicles. 

Rating for Fuel Economy and Greenhouse Gases 

The co-proposed labels show different ways to provide comparison ratings for fuel economy and 

greenhouse gases. One approach shows a rating for fuel economy and separate rating for greenhouse gases (see figure 4). This ratings system is displayed at the bottom of Labels 1 and 2 and 

uses a comparison slider bar. The bar is anchored at each end with the lowest and highest values expected for all vehicles in the model year, and uses a pointer to display the specific vehicle 

model’s location on the scale. 

The alternative approach uses a rating that combines fuel economy and greenhouse gases into a 

letter grade (see figure 4). This approach consolidates information for consumers and provides 

an easy-to-understand metric that purchasers can quickly use to compare the fuel economy and 

greenhouse gas values across all vehicles. 

Both ratings are not mutually exclusive, and a label could contain one or both. 

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Regulatory Announcement 

Letter Grade 

Rating 

(Combined 

Rating) 

CO2 Range (grams per 

mile) (Separate Rating) 

Gasoline MPG 

Equivalent (Separate 

Rating) 

A+ 0-76 117 and higher 

A 77-152 59-116 

A- 153-229 40-58 

B+ 230-305 30-39 

B 306-382 24-29 

B- 383-458 20-23 

C+ 459-535 18-19 

C 536-611 16-17 

C- 612-688 14-15 

D+ 689-764 13 

D 765-842 

and higher 

12 and lower 

Figure 4. Examples of ratings systems. 

The proposed letter grade scale would range from A+ to D, including plus and minus designations. The agencies base this rating system approach on the range of CO2

 emissions for the 

projected fleet, first determining the middle point (or median) for all model types, then generating five equal increments of CO2

 above and below this middle point. Each increment is assigned 

a grade or rating. 

For those vehicles that run on electricity, the tailpipe emissions are zero. Of course, these vehicles do cause emissions at the electric generation facility, with amounts varying greatly based 

on the source of electricity (such as coal, nuclear, natural gas, hydro, or wind). The agencies 

intend to make this information available on the web, with calculators that people can use to 

determine their upstream emissions (from the production and distribution of electricity) based 

on where they live and the vehicle they are considering. 

Most vehicle classes are expected to span multiple ratings. For example, using the letter grade 

system and MY2010 data, the agencies project the ratings distribution by vehicle class shown in 

figure 5. The majority of vehicles are expected to fall into the middle of the grade, as shown in 

figure 6. 

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Regulatory Announcement 

Figure 5. Distribution of vehicle types across the rating system 

(number of models in each category). 

Figure 6. Distribution of the current fleet across the rating system 

(number of models). 

Rating for Other Emissions 

The labels also include a rating for those pollutants that cause smog and other local air pollution. This information, listed as “Other Air Pollutants” on the labels, will be displayed using a 

slider bar with a scale of 1 (worst) to 10 (best). The scale is based on Federal Tier 2 emissions 

standards and Bin system, which incorporates specific standards for nitrogen oxide (NOx), nonmethane organic gas (NMOG), carbon monoxide (CO), particulate matter (PM), and formaldehyde (HCHO). The scale mirrors the current Air Pollution scoring system on EPA’s Green 

Vehicle Guide (www.epa.gov/greenvehicles/Aboutratings.do#aboutairpollution ). 

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Regulatory Announcement 

 

Public Participation Opportunities 

We welcome your comments on this rule. Comments will be accepted for 60 days beginning 

when this proposal is published in the Federal Register. All comments should be identified by 

Docket ID No. EPA-HQ-OAR-2009-0865 and submitted by one of the following methods: 

Internet: www.regulations.gov
 

E-mail: newlabels@epa.gov
 

Mail:
 

Environmental Protection Agency 

Air and Radiation Docket and Information Center (6102T) 

1200 Pennsylvania Avenue NW 

Washington, DC 20460 

Hand Delivery:
 

EPA West building
 

EPA Docket Center (Room 3340)
 

1301 Constitution Avenue NW
 

Washington, DC
 

You should consult the Federal Register notice for this proposal for more information about how to 

submit comments, when the comment period will close, and about where and when public hearings will be held. A copy of Federal Register notice can be found on our websites listed below. 

For More Information 

You can access the rule and related documents on EPA’s Office of Transportation and Air Quality 

(OTAQ) website at: 

www.epa.gov/fueleconomy/regulations.htm 

To view all the proposed label designs, please visit our website at: 

www.epa.gov/fueleconomy/label/label-designs.pdf 

For more information on this rule, please contact Kristin Kenausis at: 

U.S. Environmental Protection Agency 


Office of Transportation and Air Quality 


1200 Pennsylvania Ave., NW (6406J) 


Washington, DC 20460
 

(202) 343-9225 


E-mail: kenausis.kristin@epa.gov
 

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