September 8, 2010

Environmental Protection Agency 

Fuel Economy Label

Final Report

Topics 

Background.........................................................................3

Steps Involved.....................................................................5

Critical Themes...................................................................9

Keep it Simple.....................................................................10

Provide Ability to Compare Vehicles.......................................15

Role of the Label in Purchase Process has Changed.................22

Label Designs for Public Comment......................................25

Appendix A – Detailed Research Methodology.......................31

Final Report 1
2 EPA Fuel Economy Label Redesign
Background

The Environmental Protection Agency (EPA) and the National 

Highway Traffic Safety Administration (NHTSA) are conducting 

a joint process to redesign the fuel economy label that is posted 

on the window sticker of all new cars and light-duty trucks 

sold in the U.S. These changes are proposed to impact vehicles 

beginning with model year 2012. The redesigned label will provide 

information to help American consumers choose more efficient 

and environmentally friendly vehicles. The changes are needed to 

respond to the Energy Independence and Security Act (EISA) of 

2007, introduction of advanced technology vehicles such as plugin hybrid electric vehicles and electric vehicles, and changes in how 

vehicles are purchased by Americans. 

A thoughtful and thorough process is underway to ensure the 

public is provided the best possible tool to help inform a decision 

that impacts their lives, their community and their environment. 

Both the research process and the design process are continuums 

involving many staff in multiple agencies and hundreds of research 

participants. Even though research participants were provided 

several options to review throughout this process, literally 

hundreds of options were created, modified, and discarded prior 

to ever reaching the research participants. Designs were influenced 

and directed by staff and managers from each agency involved in 

the review process, as well as dictated by statutory requirements. 

This report presents the key findings from the label redesign 

research process that informed the resulting label designs proposed 

for public comment. This report is intended to provide the 

reader with a top line summary of significant findings from the 

multifaceted information gathering process described in the next 

section. Detailed information is provided in the reports generated 

following each research phase. 

Final Report 3
4 EPA Fuel Economy Label Redesign
Steps Involved

To help inform the redesign of the fuel economy label and increase the 

value of and preference for more fuel efficient vehicles, EPA engaged 

PRR Inc. to work with them in the development and implementation 

of several information gathering tasks. The following tasks were 

included and, as can be seen in Figure 1, each task informed the next 

task ultimately resulting in the redesigned labels.

• Literature review

• Focus groups (including pre-focus group online 

surveys with participants)

• Expert panel

• Internet survey of new vehicle buyers and intenders

See Appendix A for a more detailed description of these research 

methodologies and their limitations. 

Literature Review

PRR assembled and reviewed eighty articles. The primary focus of 

the review was to understand how consumers decide which vehicles 

to purchase and the factors that influence their decisions. 

Final Report 5
Focus Groups

Focus group participants completed an online survey before they 

took part in the discussions. The purpose of the pre-group online 

survey was to obtain information regarding their vehicle purchase 

process, the role of fuel economy in their purchase decision, how 

they used the current fuel economy label, and motivators and 

barriers to purchasing advanced technology vehicles. By gathering 

this information before the focus groups we were able to use the 

focus group time most efficiently.

Three phases of focus groups were conducted to acquire the desired 

information. The three phases and their in-depth discussions 

addressed the following issues:

• Phase I – Use of the current fuel economy label, as well as 

metrics and design of the label for conventional internal 

combustion engine vehicles.

• Phase II – Understandability of and preference for metrics 

on advanced technology vehicle labels.

• Phase III – Assessment of full label designs for conventional 

and advanced technology vehicles in regard to both content 

and look.

6 EPA Fuel Economy Label Redesign
Expert Panel

A group of individuals with demonstrated experience in changing 

social norms was recruited to participate in a daylong consultation. 

Panel members came from a variety of fields in advertising, national 

educational campaigns and product introduction. Feedback received 

from this group was critical because of their unique history of creating 

dramatic shifts in social change and influencing product preference 

over short periods of time. In addition to providing feedback on 

prototype label designs as constructed following the three phases of 

focus groups, panelists were asked to provide guidance on increasing 

the value of and preference for more efficient vehicles. Counsel 

provided by the Expert Panel was significant and compelling because 

of the exceptional credentials of each panel member, the conviction 

of their recommendations and the strong consensus of the group. 

The very purpose of assembling this group was to receive comments 

and recommendations from an independent group of exceptional 

individuals and bring an outside perspective. 

Final Report 7
Internet Survey of New Vehicle Buyers and Intenders

While the focus groups and expert panel were used to develop 

new label designs, the internet survey will be used to examine 

how understandable the new label designs are, and whether the 

proposed new labels will improve consumers’ knowledge about 

more efficient vehicles. The survey is scheduled to begin sometime 

in September 2010 and will ask these types of questions for both 

conventional and advanced technology vehicle labels. 

8 EPA Fuel Economy Label Redesign
Critical Themes

Developing an effective label – one that conveys the required and 

desired information to consumers so that they can understand 

and use it to make decisions – involves some inherent subjectivity. 

By this we mean that it involves the careful interpretation of the 

research results since some results are contradictory, as well as the 

fact that what is understandable and useful for one consumer may 

be confusing or unhelpful to another. Furthermore, research results 

must be assessed in regard to which results are more important 

than others relative to the ultimate goal of the label. Finally, the 

label metrics and designs are also ‘negotiated’ so as to meet the 

specific requirements of the various federal agencies involved.

In looking at all of the research results through the filters mentioned 

above we found that three key themes emerged which guided the 

label metrics used and the designs of the labels themselves. These 

three critical themes are:

1. Keep it simple – Without exception, consumers and experts 

stressed simplicity of content and design.

2. Provide the ability to compare vehicles – Consumers cast 

a wide net when selecting a vehicle and want the ability to 

easily compare the features and benefits of multiple vehicles.

3. The role of the label in the purchase process has changed – 

With the rise of internet and social media services, a 

significant and growing portion of the buying process is 

now happening before buyers even visit a lot. 

Final Report 9
Consumers currently receive an 

estimated 3,000 to 5,000 

marketing messages each day. It 

has been said that “Data is like 

food. A good meal is served in 

reasonably-sized portions from 

several food groups. It leaves you 

satisfied but not stuffed. Likewise 

with information, we're best

served when we can partake of 

reasonable, useful portions, 

exercising discretion in what data 

we digest and how often we seek 

it out.” This is true in the vehicle 

purchasing process as well. 

Keep It Simple 

Without exception, consumers and experts stressed extreme 

simplicity for both content and design.

Many factors such as the aesthetics of the vehicle, reliability, safety, 

price, and fuel economy can influence a consumer decision. In 

addition, and addressed in greater detail later in this document, 

the buying process is an ever evolving continuum that includes 

consumer reliance on multiple sources to acquire information and 

make their purchasing decision. The fuel economy label is just one 

piece in this continuum and should be considered in that context. 

Throughout each phase of the focus group process, and even more 

pronounced with the expert panel, was the cry for simplicity. When 

asked to select understandable designs participants described 

their selections as simple, straight forward, and concise. The least 

understandable designs were described as confusing, distracting, 

and complicated. In essence, participants preferred designs that 

they thought of as informative and that presented the information 

in a simple format.

The desire for simplicity became evident immediately, especially 

when focus group and expert panel participants were shown the 

existing Monroney label as a reminder of the space available for 

fuel economy information as well as the context in which this 

information is provided. 

Phase 1 focus group participants were provided four approaches to 

represent individual metrics outside of the context of a full label. They 

were asked to indicate which approach was most understandable. 

Even in this sterile environment of looking at a single metric without 

other information competing for their attention, simplicity was the 

primary reason individuals gave for selecting their choice as most 

understandable. Statements used included:

• Easy. Nothing difficult to understand

• Could see it right away

“What you put on the sticker 

needs to be simple, basic, 

because it’s going to scare a lot 

of people away from the car if 

there are too many figures.” 

– Chicago Male

“It took me some time to figure 

it out [3B]. If I have to take the 

time, I won’t figure it out.” 

– Houston Female 

http://www.nytimes.com/2007/01/15/

business/media/15everywhere.html

10 EPA Fuel Economy Label Redesign
Simplicity was again reinforced when participants were asked 

why they specifically rejected other options. Comments included 

statements such as:

• Cluttered and too busy

• Not reader friendly – there’s too much stuff

• I get nervous when there’s a lot of information

• This takes too much time and effort to figure it out

“Familiarity” was another significant theme that emerged related 

to simplicity. Throughout the research process participants raised 

the desirability and usefulness of having information provided in 

a “familiar” manner. The term “familiar” was used by participants 

when explaining their preferred choices across metrics for fuel 

economy, fuel consumption and environmental impacts. 

When focus group participants were provided various metrics 

intended to help them compare one vehicle to another they again 

used the terms “simple” and “familiar” to describe why they selected 

a specific metric approach over the others. This was after viewing 

rating scales represented numerically, with stars and with leaves (in 

the case of environmental impacts), as well as slider scales similar 

to the bar that exists on the current fuel economy label.

In Phase 2 focus groups (where they were presented with a variety 

of metrics that could potentially be included on labels for advanced 

technology vehicles) and Phase 3 focus groups (where they were 

presented with full labels), participants were overwhelmed with 

the amount of information and therefore favored designs that 

emphasized some values/metrics with larger font sizes and more 

prominence (so they knew what to look at and what to compare).

The two strongest recommendations provided by the Expert Panel 

echoed these comments as well—keep it simple and present it in a 

way that is familiar.

Final Report 11
The Expert Panel was provided label designs for review that were 

the most current at the time. (See samples below). They understood 

that these designs reflected legal requirements, directives of staff 

from multiple agencies and feedback from focus group participants. 

Their initial response summarized the feelings of the group: “This 

label is the result of negotiation, not design.”

Expert Panel members recognized that focus group participants 

had requested specific information and in some cases wanted it 

provided in great detail (such as wanting city and highway miles per 

gallon estimates for both electric and gas use on dual fuel vehicles). 

However, they rejected the need for this information to be provided 

in detail and in full on the label. 

12 EPA Fuel Economy Label Redesign
The guiding principles they used to support their recommendations 

were that consumers don’t act on details, so information must be 

kept simple without the use of jargon, and that purchasing a car is 

an emotional decision so communications must appeal to emotions.

The Expert Panel then offered specific recommendations regarding 

design and content that, given their experience, would effectively 

engage the public. They referenced other successful labels when 

strongly recommending that the top portion, and the greatest 

amount of space on the label, contain only one element – a “grade.” 

They suggested combining as many of the desired and required 

metrics as possible into a single grading scale (A, A-, B+, B, etc.). 

The rationale is that in a simple and familiar way, this design 

provides useful comparative information to the consumer who 

may only glance at it, while also providing the necessary details to 

those who want more in-depth information.

To help demonstrate the benefits of one vehicle over another they 

also suggested prominently displaying “savings” (over five years to 

express a larger and more realistic impact) rather than “cost.” They 

went on to suggest that a website, similarly reflecting the desire 

for simplicity, could be created to provide additional detailed 

information for those who desired it. It was suggested that an 

easily remembered URL (such as “itsimple.com”) be provided to 

help reinforce the educational messages and be easy to remember. 

Recognizing the current and quickly evolving level of information 

available using mobile devices such as Smart Phones, the Expert 

Panel echoed the recommendations of each focus group phase, to 

include a QR type scan code which would provide the consumer 

with multiple functions such as storing specific vehicle information, 

seeking additional information, and the ability to undertake sideby-side vehicle comparisons.

In the space under the grade they suggested placing the URL, 

which would inform the consumer that additional information was 

available and easily accessible while providing a natural design 

element. The remaining space below the grade and the URL could 

be used for any remaining information required by law.

Final Report 13
For the Expert Panel it came down to these points:

• It is difficult for consumers to sway from routine

• It is critical to use only a few messages that are relevant 

and empower individuals to understand how their choices 

will make a difference

• Messages must address “What’s in it for me?” and how 

making this decision will improve “my” life 

• Keep it simple; we all yearn for simplicity 

• Consumers don’t act on details 

• Remember the reality of very short label viewing time - 

roll ratings and metrics up into a single score 

• Instead of focusing on costs, use savings information - 

a very strong consumer motivator

• Develop a website to be launched in conjunction with 

the new label

Expert Panel recommendations provided clarity and refinement, as 

well as specific tactical suggestions consistent with the findings of the 

literature review, pre-focus group online surveys, and focus groups. 

The implications of these recommendations for the label design are 

significant and might seem at first glance to contradict the focus 

group findings. However, there is consistency in striving to provide 

the ability to compare within and across vehicle technologies in a 

simple way. 

14 EPA Fuel Economy Label Redesign
“There was a time when 

compact car meant something, 

but now there’s sub-compact, 

mid-sized compact; everyone 

has different categories for the 

same thing. You’re really talking 

about a small, mid-sized or 

luxury car.” – Seattle Male

Provide Ability to Compare Vehicles

Consumers cast a wide net when selecting a vehicle and want the 

ability to easily compare the features and benefits of multiple vehicles.

Consumers shop within and across vehicle classes

Consumers cast a fairly wide net when selecting a vehicle, possibly 

wider than they consciously realize and report. When asked in the 

focus groups and in the pre-group online surveys if they had a specific 

vehicle in mind when they started shopping, the vast majority said 

yes. However, more than three-fifths (63%) of respondents to the 

pre-group online survey reported that they seriously considered 

more than one vehicle class, with about a third of these considering 

both cars and trucks.1 It is also important to note that participants 

thought of vehicle classes in fairly broad terms that are not necessarily 

parallel to those used by EPA. Class or type of vehicle is considered 

in terms such as SUVs, sedans, mini-vans, etc. This is probably why, 

when focus group participants were given the choice of having the 

comparison information on the label be displayed as ‘within class’, 

‘among all classes’, or both, that most preferred both. 

The fact that consumers shop across multiple vehicle classes 

throughout the buying process indicates that the label has the 

potential to influence consumers to choose vehicles that are more 

fuel efficient. As a trusted source of fuel economy information 

(according to 72% of pre-focus group online survey respondents), 

the EPA is in a strong position to use the redesigned fuel economy 

labels and its planned educational campaigns to aid consumers in 

selecting more fuel-efficient vehicles. 

Consumers want the ability to easily compare

across multiple vehicles

Based on the above, it is no surprise that throughout the focus groups, 

participants consistently and strongly indicated the need to be able to 

compare across vehicles. As reflected earlier in this document, they also 

demanded simplicity. But, what factors allow them to compare in the 

simplest way? The literature review made clear that the top four factors 

that buyers report as influencing their vehicle choice include reliability, 

safety, price, and fuel economy (in that order). In addition, one can’t 

discount the importance of vehicle aesthetics. Put simply – the most 

reliable, safe, affordable, and fuel efficient vehicle will not be purchased 

if doesn’t also, as one focus group participant said, “Speak to me!” 

1 It should be noted that 

participants used the terms 

‘vehicle class’ and ‘vehicle 

type’ interchangeably and how 

they grouped vehicles by type 

or class varied and did not 

necessarily match the distinct 

EPA vehicle classes.

Final Report 15
It is worth restating that the buying process is a continuum 

that includes consumer reliance on multiple sources to acquire 

information and make their purchasing decision. The fuel economy 

label is just one piece in this continuum and should be considered 

in that context. To be effective it needs to provide relevant 

information, be understood in a very short amount of time, be 

compelling enough to generate the desired impact, and be presented 

in such a way that it draws the attention and interest of the buyer in 

the stressful, cluttered and confusing car lot environment. 

Comparisons across vehicles can be made using a variety of metrics. 

The following three metrics were selected for further research 

exploration. Each is discussed in greater detail in this section:

• Fuel economy/fuel consumption 

• Fuel costs

• Environmental impacts

In Phases 1 and 3, focus group participants were shown rating scales 

including numerical, iconic (such as five star systems), and slider 

scales similar to the bar that exists on the current fuel economy label 

for within-class comparisons. Participants were split into two camps: 

those that preferred the analytic detail of the absolute slider scales, 

and those that prefer the simplicity of a star-type rating scale. 

A major challenge to providing a useful comparison tool is the 

complexity of advanced technology vehicles. If consumers first 

encounter advanced technology vehicles on the dealer’s lot, and are 

not predisposed to buy one, a label that effectively conveys the 

benefits of such vehicles would be helpful in informing consumers 

and could potentially influence them to purchase such vehicles. 

Three advanced technologies were covered in the Phase 2 and Phase 

3 pre-group online surveys, and were a particular focus of the Phase 

2 focus groups. These advanced technology vehicles included:

• Electric Vehicles (EV)

• Extended Range Electric Vehicles (EREV)

• Plug-in Hybrid Electric Vehicles (PHEV)

“I wasn’t sure about the 

information it’s measuring, 

but the stars make sense.” 

–Seattle Male 

“I liked that it identified the 

worst case scenario, you know 

where the 347 falls in relation 

to the scale.” – Houston Male 

16 EPA Fuel Economy Label Redesign
When considering the implications of this research, it is important 

to remember that research participants had their first exposure to 

two of these technologies (EREV and PHEV) during the research 

process. In the ‘real’ shopping experience manufacturers, news 

organizations, websites, and a host of other resources will all be 

active in increasing awareness, understanding and preference for 

these emerging technologies.

The combination of confusion over new technology and a 

proclivity for people to want any information offered, makes it 

easy to understand why, even in spite of their call for ‘simplicity’ 

in label designs, Phase 2 focus group participants sought as much 

detailed information as possible. 

As such, the overwhelmed participants indicated a thirst for 

more information. This however, did not mean that they would 

necessarily use all the information sought in comparing vehicles, 

but somehow having it provided them with a greater sense of 

control. Nonetheless, when asked what the two most important 

metrics were for comparison purposes they chose consumption 

and cost. This was further supported by the fact that 60% of pregroup online survey respondents rated fuel economy a ‘9’ or above 

on a 10-point importance scale. On another survey question, 40% 

indicated that ‘gas mileage/fuel economy’ was the second most 

common factor they used to compare across the vehicles they were 

considering (second only to ‘size/seating capacity/cargo capacity’). 

As important as fuel consumption and fuel costs are to consumers, 

their unfamiliarity and discomfort with advanced technology 

vehicles caused focus group participants to insist that labels for 

vehicles with electric power include both range (the distance a 

vehicle could travel on one charge) and charging time information. 

For that reason, even though we believe such information will be 

provided by other sources (such as manufacturers) or in other 

mediums (such as websites), both range and charge time appear 

on two of the three label designs for vehicles using electric power.

Currently consumers compare across vehicles using city and 

highway MPG figures. When participants were probed in the 

Phase 3 focus groups about why they liked certain label designs, 

the familiarity of city and highway values was often cited. The 

lack of this information was also cited for not liking those labels 

“It’s not really like any other 

car, its miles per charge, not 

MPG, it’s a complete paradigm 

shift. This range is probably 

important, how far you go on 

a charge. There isn’t room 

for error; it has to be awfully 

accurate.” – Chicago Male 

“What happens if I’m driving 

somewhere and I only have a 

limited time to recharge? How 

long will it take to recharge is 

important.” – Chicago Male 

“I usually look at city and 

highway, and then compare to 

other vehicles in class.” 

– Seattle Female 

Final Report 17
that did not include it. This was further supported by results of 

the pre-group online surveys where ‘highway MPG’, ‘city MPG’ 

and ‘combined fuel economy compared to other vehicles’ were 

rated by survey respondents as the top three most helpful pieces of 

information on the current fuel economy label. Consequently, the 

redesigned labels include city and highway breakouts. 

Finally, the Expert Panel (without knowledge that the agencies 

had already planned to introduce QR codes on the fuel economy 

label due in part to the enthusiasm for such an approach evidenced 

in the focus groups) recommended that the agencies include this 

technology and perhaps launch it by hosting a competition to 

create a Smart Phone application (App) that would directly provide 

users with additional vehicle information and expand consumers’ 

ability to compare vehicles.

Fuel economy and fuel consumption

As discussed above, MPG information (in many cases to the 

exclusion of all other label information) is currently used for 

comparison purposes. Interestingly, participants admit that this 

might be because they have been trained to do so since they first 

started buying vehicles because it is by far the most prominent 

information displayed on the current label.

However, MPG is not linear and can therefore be misleading. When 

people compare vehicles with different MPG values they are apt to 

incorrectly estimate the fuel savings of one vehicle over another. For 

example, switching from a 15 MPG vehicle to a 20 MPG vehicle 

will save more fuel than switching from a 30 MPG vehicle to a 35 

MPG vehicle (see MPG Illusion2). Consequently, we introduced the 

option to use ‘gallons per 100 miles’ in the Phase 1 focus groups as 

a more useful metric for fuel consumption.

The reaction from focus group participants to ‘gallons per 100 

miles’ was immediate, clear and intense – they did not understand 

it and they did not like it. However, once they understood the 

concept, many participants saw the value of the information, but 

still did not want to see it at the cost of losing the familiar MPG 

information. Consumers like and are attached to MPG. It became 

clear that if ‘gallons per 100 miles’ was to make it to the label, it 

would need to be through a slow transition process, occurring over 

time and in conjunction with retaining the MPG information in a 

more prominent position.

“I’m used to MPG. Using 

gallons per 100 miles is like 

teaching us the metric system.” 

– Chicago Female

2 MPG Illusion 

http://www.efficient-mileage.com/

mpg-illusion.html.

18 EPA Fuel Economy Label Redesign
Advanced technology vehicles further complicate this issue with the 

need to express the consumption of electricity rather than gallons 

of any petroleum based fuel. In the Phase 2 focus groups, it became 

clear that participants did not understand the concept of a kilowatt 

hour as a measure of electric energy use in spite of the fact that they 

all receive monthly electric bills using this metric.

For electric-only vehicles, focus group participants favored an 

MPG equivalent, ‘MPGe.’ This was in spite of the fact that they 

did not understand, nor did they feel the need to understand how 

an MPGe metric was calculated. This again suggests that the desire 

for simplicity and familiarity outweighs the desire for accurate 

information. 

As the complexity of the technology increased, so too did the 

complexity and number of metrics that consumers’ desired. Given 

the options presented to them, focus group participants wanted an 

MPGe that combined the MPGe of electric operation and the MPG 

of gas operation in any vehicle that could operate in more than one 

mode of operation, such as an EREV or PHEV. In general, the more 

they were shown, the more they wanted. However, in order to stay 

true to consumers’ greater desire for label simplicity, a decision 

was made to use the following fuel economy and fuel consumption 

metrics on the redesigned labels:

• MPG (city and highway, and combined)

• MPGe (city and highway, and combined)

• Gallons per 100 miles

• kW-hrs per 100 miles3

Fuel costs

Focus group participants reported (on the pre-group online survey, 

as well as in the group discussions) that after the use of city MPG 

and highway MPG, they turned to annual fuel costs when comparing 

vehicles. The use of annual fuel cost is not surprising given that cost 

is a major decision point for individuals and a metric (dollars) they 

easily understand. It should be noted that research took place during 

a period of record unemployment and immediately following one of 

the worst economic crises faced by this country. 

“I think by the time these cars get 

out we’ll be more used to this, 

but this (kW-hr) doesn’t mean 

anything to me right now. Keep it 

simple.” – Charlotte Male 

“To me, this 2.9 miles per kW-hr, 

if I’m comparing it to a gasoline 

car, that doesn’t help me, where 

as the 98 MPGe, my brain knows 

MPG.” – Houston Female 

3 It should be noted that the ‘kWhrs per 100 miles’ metric was 

more confusing to focus group 

participants compared to a ‘miles 

per kW-hr’ metric since the 

former metric results in a lower 

number being better (that is, 

fewer kW-hrs is more efficient). 

This issue of ‘the lower the 

number the better’ is confusing 

because consumers think in 

terms of higher being better, as in 

MPG. The same can be said of 

‘gallons per 100 miles’, but when 

kW-hrs are involved the issue 

becomes even more confusing. 

However, in order to have an 

electricity consumption measure 

that would be equivalent to 

‘gallons per 100 miles’, it was 

decided to stick with ‘kW-hrs per 

100 miles’.

Final Report 19
However, participants made it clear that annual fuel cost is a metric 

surrounded by skepticism because they question the assumptions 

upon which the cost figure is based. The current label clearly states 

that the cost figure assumes 15,000 annual miles at $2.80 a gallon. 

And yet, many focus group participants could not get beyond the fact 

that – “I don’t drive 15,000 miles a year and gas costs a lot more than 

$2.80 where I live.” In other words, participants really struggled with 

the idea that the annual cost figure needs to be based on some set of 

assumptions and that, regardless of which assumptions were chosen, 

it could still be used to compare one vehicle to another. Consequently, 

at least in regard to use of the current label, this skepticism drove 

consumers to rely even more on city and highway MPG. 

The exact same skepticism was expressed for electricity costs, 

impacting metrics used for advanced technology vehicles – “Where 

I live electricity costs a lot more than 12 cents a kilowatt hour.” 

The implication of this for the redesigned label is that consumers 

will continue to look for metrics with which they are familiar and 

which they trust, even if they do not understand the details. 

In spite of the skepticism, in the Phase 2 focus groups, where 

participants were asked to create labels from scratch, most groups 

placed a cost value on the label. When probed about expressions 

of a cost value, many participants expressed interest in cost per 

mile figures, monthly figures and annual cost figures. Monthly 

figures were appealing since that is how they are used to seeing 

electricity costs (on their monthly electricity bill) and it is also how 

they budget their money (i.e., monthly). However, in Phase 3, when 

presented with labels that displayed both a monthly cost and an 

annual cost, participants suggested that the monthly cost value 

could be dropped, since they could do the math (divide by 12). 

Advanced technology vehicle labels are even more complex in that some 

run on both gasoline and electricity, or on a blend of both fuels. Most 

participants in the Phase 2 focus groups preferred to see costs separated 

by fuel type. However, when presented with full label designs during 

the Phase 3 focus groups, many saw the utility of a fuel cost figure that 

merged all fuels. Such a dollar figure could easily be compared across 

vehicles, across different vehicle technologies, and even to a PHEV 

(which runs at times on a blend of gasoline and electricity). As a result 

of the research, two of the designs presented here for public comment 

show fuel costs expressed in annual dollars with all fuels combined, 

while the third design presents separate costs by fuel type. 

“The economy is important. 

If you looked at this two years 

ago, it would be a lot more 

accurate. But a year ago, gas 

was closer to $4. I thought 

this on the lot, at $2.80- a 

gallon, the information wasn’t 

accurate.” – Seattle Female 

“If you’re doing your budget, you 

need to know how much more 

your electric bill is and how 

much less your gas bill is.” 

– Charlotte Female 

20 EPA Fuel Economy Label Redesign
Understanding that cost is a significant influencer for vehicle 

purchasers and that demonstrating the benefits of more efficient 

vehicles is critical to the EPA, the Expert Panel suggested expressing 

financial information in terms of ‘savings’ and expressing it over a 

five year period in order to demonstrate a larger and more realistic 

impact. It was also thought that the introduction of the five year 

savings information would help consumers in overcoming the 

effects of the MPG Illusion. This use of a ‘savings’ metric made 

particular sense since focus group participants reported on the pregroup online surveys that the most compelling factor for purchasing 

fuel efficient vehicles was ‘to save money.’ 

The second most compelling factor for purchasing a fuel efficient 

vehicle was because such vehicles are ‘better for the environment,’ 

which brings us to the third major metric category on the redesigned 

labels which can be used to compare vehicles: environmental impact. 

Environmental impact

Most of the research included in the literature review and echoed 

in the focus groups indicated that consumers place much less 

importance on the environmental impact of vehicles, compared to 

other factors such as safety, price and fuel economy. Nonetheless, 

consumers are not opposed to, and some may welcome, an eco-label 

on their vehicle, although they say that it is unlikely to impact their 

purchase decision. Most focus group participants indicated that if 

such information was not on the label they were not likely to seek it 

out elsewhere. However, when presented with whole label designs in 

Phase 3 many participants indicated that the environmental metric 

should be on the label to accommodate those who were interested. 

Participants were shown multiple options for the presentation of 

environmental information; some separated CO2 from other pollutants, 

while some combined all pollutants; some used relative rating scales, 

while others showed actual grams of CO2. Rating scales examined 

included those based on relative values, such as a “5 leaf” rating 

system, as well as a linear scale that had the vehicle’s absolute CO2

value identified on a scale also showing the highest and lowest emitting 

vehicles available. As with all other information, the participants 

indicated that environmental information must be simple in order for 

consumers to pay any attention to it. An overall environmental rating 

was favorably received because as participants stated– “I don’t need to 

know the science behind the rating,” and “I trust the EPA to know how 

to come up with these ratings.” 

“I care about the environment, 

but when it comes to money, 

I have to put my pocket book 

first. The environment isn’t 

going to pay my bills.” 

– Charlotte Female 

Final Report 21
The Expert Panel suggested that environmental metrics be included 

as part of the overall rating or as a stand-alone rating in a less 

prominent position for those consumers interested in more detailed 

environmental information. Consequently, the label designs include 

CO2 grams (separate from other pollutants), as well as absolute 

and relative scales of environmental impact. 

Additionally, such a ‘rating’ could include the use of an 

environmental certification such as the SmartWayTM logo that 

appeared on label designs shown to focus groups. Although none 

of the participants recognized and knew what the SmartWayTM 

logo meant, they assumed that it was an EPA designation similar 

to the Energy StarTM rating found on electric appliances. However, 

while some participants indicated the logo may confer credibility 

to an environmentally friendly vehicle, it was obvious that for an 

environmental metric to have influence, it would either need to be 

incorporated into an overall rating system, or consumers would 

need to be educated as to why environmental ratings should be 

more important to them. 

Role of the Label in the 

Purchase Process Has Changed

With the rise of internet and social media services, a significant and 

growing portion of the buying process is now happening before buyers 

even visit a lot. 

The Vehicle Buying Cycle

The vehicle buying cycle is that period of time between consumers’ 

first contemplation of purchasing a new vehicle and when they actually 

purchase the vehicle. The vehicle buying cycle is a seven step process: 

awareness, familiarity, opinion/imagery, consideration, one make/model 

intention, shopping, and purchase. 

Unlike in the past, consumers increasingly seek out fuel economy 

information prior to, and beyond, simply viewing the fuel economy 

label on vehicles during dealership visits. They are taking advantage 

of the many opportunities available to become informed about 

the benefits they are seeking, which can include fuel economy 

and environmental impact. Two-thirds of the respondents to the 

pre-focus group online surveys reported they had researched fuel 

economy prior to buying their vehicle. Of these, about half (52%) 

“I don’t need to know the actual 

grams per mile, I just need to 

know how it compares with 

other cars [i.e. the 1-10 scale].” 

– Houston Male 

22 EPA Fuel Economy Label Redesign
reported that they started researching vehicle information about 

one to three months prior to final purchase. Consequently, the 

length of the vehicle buying cycle is contracting as consumers 

obtain more information sooner. 

The literature review, as well as the results of the pre-focus group 

online surveys, demonstrated a significant portion of the buying 

process takes place prior to consumers visiting a dealership. 

What this means for the fuel economy label is that through their 

own information gathering, many consumers now rely less on 

the fuel economy label as a source of initial fuel economy, fuel 

consumption, fuel cost, and environmental impact information. 

Rather, the label is more likely to be used to confirm what they have 

already learned. By the time the consumer enters the dealership to 

test drive a vehicle s/he is closer to a final purchasing decision than 

was true in the past. This might suggest that the label now has less 

influence over purchase decisions. However, if properly designed, 

the label has the potential to expand consumers’ vehicle options in 

the direction of more fuel efficient vehicles. The label can do this by 

providing useful comparison metrics in a usable format.

Sources of Information

For many consumers, purchasing a big-ticket item like a vehicle 

happens only occasionally and tends to be related to other major 

changes in their lives. This increases the anxiety level of the 

consumer and increases the need for good information to drive the 

decision process.4 Traditionally, information has come from vehicle 

manufacturers and dealers, word of mouth, personal experience, 

and family and friends, but much has changed with the advent of 

the Internet and the ability of consumers to search for information 

on specific types of vehicles and brands. Pre-focus group online 

survey respondents reported gathering fuel economy information 

from manufacturer websites, Consumer Reports, Edmunds, auto 

dealers, vehicle search websites, automobile magazines, others with 

similar vehicles, government websites, television advertisements, and 

the fuel economy label itself. However, for some buyers, viewing the 

label is simply too late in the purchase process to greatly influence 

their decision. Therefore, to be effective it becomes increasingly 

important for EPA to be where the consumer is, with the information 

they are seeking, delivered in a format that is relevant, and using the 

mediums they prefer throughout the buying cycle.

The Internet has emerged as one of the most important sources of 

“I used the label more to 

confirm, I already had an idea 

when shopping for cars.” 

– Charlotte Female

“I already know this information 

before I go to the dealer.” 

– Seattle Female 

4 Center for Advancing Health. 

(2009). Consumer Reports: Car 

Buying Guide. A Case Report for 

Getting Tools Used. Retrieved from 

http://www.cfah.org/activities/

Getting_Tools_Used/consumer.pdf

Final Report 23
information for consumers interested in purchasing a vehicle. For 

example, traffic on the DOE and EPA website www.fueleconomy.gov

increased from 400,000 user sessions in 1999 to more than 

30 million in 2008.5 Nearly half of consumers visit a vehicle 

manufacturer’s website6 in search of product and price information. 

Consequently, information on the redesigned fuel economy label 

that is intended to inform consumers about a vehicle’s performance 

in regard to several metrics (such as fuel economy, consumption, 

cost, and environmental impact) should also be available online in 

the same format as it appears on the label so that consumers can 

easily recognize it and use it when they visit auto dealerships. The 

Internet also provides the opportunity for consumers to purchase 

vehicles online (annual growth rate of 14.6% in the United States 

over the past five years, although this still represents a small 

percentage of total car sales), which is very attractive to consumers 

who do not want to negotiate with vehicle dealerships. 

Our research also validated the increasing importance third party 

reviews of vehicles and social networks play in informing the vehicle 

purchase process. The Expert Panel strongly recommended that 

outreach activities include crowdsourcing, the use of Smart Phone 

applications, creation of tools for car dealers, and collaboration 

with other organizations. 

Consequently, influencing consumer purchase decisions increasingly 

needs to occur prior to consumers visiting dealer showrooms, and 

to highlight the value of educational tools beyond the label to 

provide consumers with information on a vehicle’s fuel economy, 

fuel consumption, fuel costs, and environmental impact. EPA will 

need to be a content provider and use the fuel economy label, the 

web, emerging technologies such as QR codes and Smart Phones, 

and social networks – including third party trusted advocates – to 

get information out to the consumers.

“I would use the label to verify 

what I looked at online.” 

– Seattle Male 

5 Greene, D.L., Gibson, R., and 

Hopson, J., “Reducing Oil Use 

and CO2 Emissions by Informing 

Consumers’ Fuel Economy 

Decisions: The Role for Clean 

Cities,” prepared by Oak Ridge 

National Laboratory, Oak Ridge, 

TN, August 2009, p.1. Available at 

http://www1.eere.energy.gov/

cleancities/pdfs/fuel_economy_

strat_paper.pdf

6 Capgemini. (2009a). Cars Online 

09/10: Understanding Consumer 

Buying Behavior in a Volatile 

Market. Retrieved from 

http://www.capgemini.com/

services-and-solutions/byindustry/automotive/carsonline/

24 EPA Fuel Economy Label Redesign
Label Designs for 

Public Comment

EPA Fuel Label Options August 23, 2010

Label 1 – Conventional (Gas) – B grade

in fuel costs 

compared to the 

average vehicle.

$ saves 1,900

B

Gasoline Vehicle

Gallons/

100 Miles

MPG

City

MPG

Highway

CO2 g/mile 

(tailpipe only)

Annual 

fuel cost

3.8 22 32 347 $1,617

10

Worst 103

Best 850

Worst 0

Best 1Worst 10Best

Combined MPGe CO2 g/mile Other Air Pollutants

• Fuel economy for all SUVs ranges from 12 to 32 MPG. 

• Annual fuel cost based on 15,000 miles per year at $2.80 per gallon. 

26 347 6

Smartphone

The above grade reflects fuel 

economy and greenhouse gases. 

Grading system ranges from A+ to D.

website.here

Visit website.here to calculate estimates 

personalized for your driving, and to 

download the Fuel Economy Guide (also 

available at dealers).

Fuel Economy and 

Environmental Comparison

EPA

DOT

Over five years, this vehicle

EPA Fuel Label Options August 23, 2010

• Fuel economy for all midsize cars ranges from 12 to 103 MPGequivalent. 

MPGequivalent: 33.7 kW-hrs = 1 gallon gasoline energy.

• Annual fuel cost based on 15,000 miles per year at 12 cents per kW-hr.

Range 

(miles)

kW-hrs/

100 Miles

MPGe

City

MPGe

Highway

CO2 g/mile 

(tailpipe only)

Annual 

fuel cost

99 34 102 94 0 $618

Electric Vehicle

A

Label 1 – Electric

$ saves 6,900 in fuel costs 

compared to the 

average vehicle.

10

Worst 103

Best 1Worst 10Best

Combined MPGe CO2 g/mile Other Air Pollutants

98 0 10

website.here

850

Worst 0

Best

Smartphone

The above grade reflects fuel 

economy and greenhouse gases. 

Grading system ranges from A+ to D.

website.here

Visit website.here to calculate estimates 

personalized for your driving, and to 

download the Fuel Economy Guide (also 

available at dealers).

Fuel Economy and 

Environmental Comparison

EPA

DOT

Over five years, this vehicle

EPA Fuel Label Options August 23, 2

Label 1 – PHEV

A

• Fuel economy for all midsize station wagons ranges from 18 to 75 

MPGequivalent. MPGequivalent: 33.7 kW-hrs = 1 gallon gasoline energy.

• Annual fuel cost based on 15,000 miles per year at $2.80 per gallon 

and 12 cents per kW-hr.

Dual Fuel Vehicle: Plug-in Hybrid Electric

Blended Electric+Gas 

(first 50 miles only) Gas Only Blended & Gas Only Combined

eGallons/

100 Miles

Combined 

MPGe

Gallons/

100 Miles

Combined 

MPG

CO2 g/mile

(tailpipe only)

Annual 

fuel cost

1.5 65 2.7 38 137 $855

$ saves 5,700 in fuel costs 

compared to the 

average vehicle.

10

Worst 103

Best 1Worst 10Best

Combined MPGe CO2 g/mile Other Air Pollutants

53 137 8

website.here

850

Worst 0

Best

Smartphone

The above grade reflects fuel 

economy and greenhouse gases. 

Grading system ranges from A+ to D.

website.here

Visit website.here to calculate estimates 

personalized for your driving, and to 

download the Fuel Economy Guide (also 

available at dealers).

Fuel Economy and 

Environmental Comparison

EPA

DOT

Over five years, this vehicle

Label Version 1

Final Report 25
EPA Fuel Label Options August 23, 2010

Label 1 – Conventional (Gas) – C grade

C

Gasoline Vehicle

Gallons/

100 Miles

MPG

City

MPG

Highway

CO2 g/mile 

(tailpipe only)

Annual 

fuel cost

6.2 14 18 572 $2,625

• Fuel economy for all SUVs ranges from 12 to 32 MPG. 

• Annual fuel cost based on 15,000 miles per year at $2.80 per gallon. 

Over five years, you will

$ spend 3,100 more in fuel costs 

compared to the 

average vehicle.

10

Worst 103

Best 1Worst 10Best

Combined MPGe CO2 g/mile Other Air Pollutants

16 572 5

website.here

850

Worst 0

Best

Smartphone

The above grade reflects fuel 

economy and greenhouse gases. 

Grading system ranges from A+ to D.

website.here

Visit website.here to calculate estimates 

personalized for your driving, and to 

download the Fuel Economy Guide (also 

available at dealers).

Fuel Economy and 

Environmental Comparison

EPA

DOT

EPA Fuel Label Options August 23, 2010

Label 1 – Conventional (Gas) – D grade

D

Gasoline Vehicle

Gallons/

100 Miles

MPG

City

MPG

Highway

CO2 g/mile 

(tailpipe only)

Annual 

fuel cost

9.1 10 13 797 $3,818

• Fuel economy for all midsize cars ranges from 12 to 103 MPGequivalent. 

• Annual fuel cost based on 15,000 miles per year at $2.80 per gallon. 

Over five years, you will

10

Worst 103

Best 1Worst 10Best

Combined MPGe CO2 g/mile Other Air Pollutants

11 797 4

website.here

$ spend 9,100 more in fuel costs 

compared to the 

average vehicle.

850

Worst 0

Best

Smartphone

The above grade reflects fuel 

economy and greenhouse gases. 

Grading system ranges from A+ to D.

website.here

Visit website.here to calculate estimates 

personalized for your driving, and to 

download the Fuel Economy Guide (also 

available at dealers).

Fuel Economy and 

Environmental Comparison

EPA

DOT

EPA Fuel Label Options August 23, 2010

A

Dual Fuel Vehicle: Plug-in Hybrid Electric

All-Electric 

Range

eGallons/

100 Miles

MPGe

City

MPGe

Highway

CO2 g/mile 

(tailpipe only)

Annual 

fuel cost

Blended Electric+Gas (first 50 miles only) 11 1.5 66 64 90 $737

Gas Only – 2.7 36 40 236 $1,105

$ saves 5,700 in fuel costs 

compared to the 

average vehicle.

10

Worst 103

Best 1Worst 10Best

Combined MPGe CO2 g/mile Other Air Pollutants

53 137 8

Over five years, this vehicle

website.here

• Fuel economy for all midsize station wagons ranges from 18 to 75 

MPGequivalent. MPGequivalent: 33.7 kW-hrs = 1 gallon gasoline energy.

• Annual fuel cost based on 15,000 miles per year at $2.80 per gallon 

and 12 cents per kW-hr.

850

Worst 0

Best

Label 1 – PHEV – 2nd option

Smartphone

The above grade reflects fuel 

economy and greenhouse gases. 

Grading system ranges from A+ to D.

website.here

Visit website.here to calculate estimates 

personalized for your driving, and to 

download the Fuel Economy Guide (also 

available at dealers).

Fuel Economy and 

Environmental Comparison

EPA

DOT

26 EPA Fuel Economy Label Redesign
EPA Fuel Label Options August 23, 2010

• Fuel economy for all midsize cars ranges from 12 to 103 MPGequivalent. 

MPGequivalent: 121.5 cubic feet CNG = 1 gallon of gasoline energy.

• Annual fuel cost based on 15,000 miles per year at $1.45 per gasoline 

gallon equivalent .

Range 

(miles)

eGallons/

100 Miles

MPGe

City

MPGe

Highway

CO2 g/mile 

(tailpipe only)

Annual 

fuel cost

170 3.6 24 36 220 $777

Compressed Natural Gas Vehicle

A

Label 1 – CNG

$ saves 6,100 in fuel costs 

compared to the 

average vehicle.

10

Worst 103

Best 1Worst 10Best

Combined MPGe CO2 g/mile Other Air Pollutants

28 220 9

website.here

CNG

850

Worst 0

Best

Over five years, this vehicle

Smartphone

The above grade reflects fuel 

economy and greenhouse gases. 

Grading system ranges from A+ to D.

website.here

Visit website.here to calculate estimates 

personalized for your driving, and to 

download the Fuel Economy Guide (also 

available at dealers).

Fuel Economy and 

Environmental Comparison

EPA

DOT

EPA Fuel Label Options August 23, 2010

Label 1 – Dual Fuel

B

in fuel costs 

compared to the 

average vehicle.

$ saves 1,600

Dual Fuel (Gas & E85) Vehicle

Gallons/

100 Miles

Gasoline 

MPG City

Gasoline MPG

Highway

CO2 g/mile 

(tailpipe only)

Annual 

fuel cost

4.0 22 30 355 $1,680

10

Worst 103

Best 1Worst 10Best

Combined MPGe CO2 g/mile Other Air Pollutants

• Fuel economy for all midsize cars ranges from 12 to 103 MPGequivalent.

• Ratings are based on gasoline and do not reflect performance and 

ratings using E-85.

• Annual fuel cost based on 15,000 miles per year at $2.80 per gallon. 

• See the Fuel Economy Guide for more information.

25 850 355 7 Worst 0

Best

Over five years, this vehicle

Smartphone

The above grade reflects fuel 

economy and greenhouse gases. 

Grading system ranges from A+ to D.

website.here

Visit website.here to calculate estimates 

personalized for your driving, and to 

download the Fuel Economy Guide (also 

available at dealers).

Fuel Economy and 

Environmental Comparison

EPA

DOT

Final Report 27
EPA Fuel Label Options August 23, 2010

How This Vehicle Compares Environment Among all vehicles and within SUVs

Worst 10 Best MPGe 103

MPGe

combined city/hwy

26 MPG

3.8 gallons used every 100 miles

city highway

22 32

Annual Fuel Cost

$1,617

Gasoline Vehicle Fuel Economy and 

Environmental Comparisons

Greenhouse 

Gases

(CO2 g/mile, tailpipe only)

Other Air 

Pollutants

0

Best 850 347 Worst

10

Best 1 6 Worst

26

SUVs

Your actual mileage and costs will vary with fuel cost, driving conditions, and how you drive and 

maintain your vehicle. Cost estimates are based on 15,000 miles per year at $2.80 per gallon. 

MPGequivalent: 33.7 kW-hrs = 1 gallon gasoline energy.

Visit www.fueleconomy.gov to calculate estimates 

personalized for your driving, and to download the 

Fuel Economy Guide (also available at dealers).

Smartphone 

Interactive

Scan code for more 

information about this 

vehicle or to compare 

it with others.

Label 2 – Conventional (Gas)

EPA

DOT

EPA Fuel Label Options August 23, 2010

Electric Vehicle

on a fully charged battery, vehicle can travel about...

0 10 20 30 40 50 60 70 80 90 99 99 miles

Charge & Range Charge time 

12 hours

Full Battery

combined city/hwy

98 MPGequivalent Annual Electric Cost

city highway

102 94

34 kW-hrs per 100 miles

$618

Your actual mileage and costs will vary with electricity cost, temperature, driving conditions, and how 

you drive and maintain your vehicle. Cost estimates are based on 15,000 miles per year at 12 cents per 

kW-hr. MPGequivalent: 33.7 kW-hrs = 1 gallon gasoline energy.

Smartphone 

Interactive

Scan code for more 

information about this 

vehicle or to compare 

it with others.

How This Vehicle Compares Environment Among all vehicles and within midsize cars

Greenhouse 

Gases

(CO2 g/mile, tailpipe only)

Other Air 

Pollutants

0

Best 850

Worst

10

Best

10

0

1

Worst

Worst 10 Best MPGe

103

MPGe

98

midsize cars

Label 2 – Electric

Fuel Economy and 

Environmental Comparisons

Visit www.fueleconomy.gov to calculate estimates 

personalized for your driving, and to download the 

Fuel Economy Guide (also available at dealers).

EPA

DOT

EPA Fuel Label Options August 23, 2010

Charge & Range Charge time 

4 hours

Full Battery

0

When electricity is used up, vehicle runs on gas.

Gas Only

38combined city/hwy

MPG

When battery is fully charged, first 50 miles only.

Electric + Gas

65combined city/hwy

MPGequivalent

cost per year if 

always run in 

Electric + Gas mode

cost per year if 

always run in 

Gas Only mode

+

1.5 gallon gas 

equivalent 

per 100 miles 2.7 gallons per 

100 miles

miles 10 20 30 40 50 60 70 80 90

Blended Electric + Gas Range (battery) Extended Range (gas)

504

$737 $1,105

Your actual mileage and costs will vary with fuel cost, temperature, driving conditions, and how you 

drive and maintain your vehicle. Cost estimates are based on 15,000 miles per year at $2.80 per gallon 

and 12 cents per kW-hr. MPGequivalent: 33.7 kW-hrs = 1 gallon gasoline energy.

Smartphone 

Interactive

Scan code for more 

information about this 

vehicle or to compare 

it with others.

Dual Fuel Vehicle: 

Gasoline-Electricity

How This Vehicle Compares Environment

Worst 10 Best MPGe 103

MPGe

Greenhouse 

Gases

(CO2 g/mile, tailpipe only)

Other Air 

Pollutants

0

Best 850

Worst

10

Best 1 8 Worst

53

137 Among all vehicles and within midsize station wagons 

midsize station wagons 

Label 2 – PHEV

Fuel Economy and 

Environmental Comparisons

Visit www.fueleconomy.gov to calculate estimates 

personalized for your driving, and to download the 

Fuel Economy Guide (also available at dealers).

EPA

DOT

Label Version 2

28 EPA Fuel Economy Label Redesign
EPA Fuel Label Options August 23, 2010

Charge & Range Charge time 

4 hours

Full Battery

0

When electricity is used up, vehicle runs on gas.

Gas Only

38combined city/hwy

MPG

When battery is fully charged, first 30 miles only.

All Electric

98combined city/hwy

34 kW-hrs per 

100 miles 2.7 gallons per 

100 miles

miles 10 20 30 40 30 60 70 80 90

All Electric Range (battery) Extended Range (gas)

504

MPGequivalent

Your actual mileage and costs will vary with fuel cost, temperature, driving conditions, and how you 

drive and maintain your vehicle. Cost estimates are based on 15,000 miles per year at $2.80 per gallon 

and 12 cents per kW-hr. MPGequivalent: 33.7 kW-hrs = 1 gallon gasoline energy.

Smartphone 

Interactive

Scan code for more 

information about this 

vehicle or to compare 

it with others.

Dual Fuel Vehicle: 

Gasoline-Electricity

cost per year if 

always run in 

All Electric

$618 cost per year if 

always run in 

Gas Only mode

$1,105

How This Vehicle Compares Environment Among all vehicles and within midsize cars

Worst 10 Best MPGe 103

MPGe Other Air 

Pollutants

0

Best 850

Worst

10

Best 1 8 Worst

56

111

midsize cars

Greenhouse 

Gases

(CO2 g/mile, tailpipe only)

Label 2 – EREV

Fuel Economy and 

Environmental Comparisons

Visit www.fueleconomy.gov to calculate estimates 

personalized for your driving, and to download the 

Fuel Economy Guide (also available at dealers).

EPA

DOT

EPA Fuel Label Options August 23, 2010

How This Vehicle Compares Environment Among all vehicles and within SUVs

Worst 10 Best MPGe 103

MPGe

combined city/hwy

28 MPGequivalent

3.6equivalent gallons per 100 miles

city highway

24 36

Annual Fuel Cost

$777

Compressed Natural Gas Vehicle

Other Air 

Pollutants

0

Best 850 220 Worst

10

Best 1 9 Worst

28

SUVs

Your actual mileage and costs will vary with fuel cost, driving conditions, and how you drive and 

maintain your vehicle. Cost estimates based on 15,000 miles per year at $1.45 per gasoline gallon 

equivalent. MPGequivalent: 121.5 cubic feet CNG = 1 gallon of gasoline energy.

Smartphone 

Interactive

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information about this 

vehicle or to compare 

it with others.

CNG

Greenhouse 

Gases

(CO2 g/mile, tailpipe only)

Label 2 – CNG

Fuel Economy and 

Environmental Comparisons

Visit www.fueleconomy.gov to calculate estimates 

personalized for your driving, and to download the 

Fuel Economy Guide (also available at dealers).

EPA

DOT

EPA Fuel Label Options August 23, 2010

Label 2 – Dual Fuel

How This Vehicle Compares Environment Among all vehicles and within midsize cars

Worst 10 Best MPGe 103

MPGe

combined city/hwy

25 MPG

4.0 gallons of gasoline used 

every 100 miles

city highway

GASOLINE

22 30

Annual Fuel Cost

$1,680

Other Air 

Pollutants

0

Best 850 355 Worst

10

Best 1 7 Worst

25

Your actual mileage and costs will vary with fuel cost, driving conditions, and how you drive 

and maintain your vehicle. Cost estimates based on 15,000 miles per year at $2.80 per gallon.

Ratings are based on gasoline and do not reflect performance and ratings using E-85. 

See the Fuel Economy Guide for more information.

Smartphone 

Interactive

Scan code for more 

information about this 

vehicle or to compare 

it with others.

Dual Fuel Vehicle: 

Gasoline-Ethanol (E85)

midsize cars

Greenhouse 

Gases

(CO2 g/mile, tailpipe only)

Fuel Economy and 

Environmental Comparisons

Visit www.fueleconomy.gov to calculate estimates 

personalized for your driving, and to download the 

Fuel Economy Guide (also available at dealers).

EPA

DOT

Final Report 29
EPA Fuel Label Options August 23, 2010

Gasoline Vehicle

347

3 out of 5 (5 is best)

Other Air Pollutants

Visit www.fueleconomy.gov

• Calculate personalized driving estimates

• Download the Fuel Economy Guide 

(also available at dealers)

CO2 grams/mile

(tailpipe only)

Environment Rating

(among all vehicles)

Fuel Economy Consumption

Fuel Economy & Greenhouse Gas Rating

Smartphone 

Interactive

Scan code for more 

information about this 

vehicle or to compare 

it with others.

Your actual mileage and costs will vary with fuel cost, driving conditions, and how you 

drive and maintain your vehicle. Cost estimates are based on 15,000 miles per year at 

$2.80 per gallon.

MPG 26combined annual fuel cost

$1,617 city highway

22 32

3.8 gallons used 

every 100 miles

(among all vehicles)

Fuel economy for all SUVs ranges from 12 to 32 MPG.

SUVs

Worst 1 2 3 4 5 7 8 9 10 Best

6

Label 3 – Conventional (Gas)

Fuel Economy and 

Environmental Comparisons

EPA

DOT

EPA Fuel Label Options August 23, 2010

Electric Vehicle

5 out of 5 (5 is best)

Other Air Pollutants

Visit www.fueleconomy.gov

• Calculate personalized driving estimates

• Download the Fuel Economy Guide 

(also available at dealers)

Your actual mileage and costs will vary with electricity cost, temperature, driving conditions, 

and how you drive and maintain your vehicle. Cost estimates are based on 15,000 miles per 

year at 12 cents per kW-hr. MPGequivalent: 33.7 kW-hrs = 1 gallon gasoline energy.

0 CO2

grams/mile

(tailpipe only)

Environment Rating

(among all vehicles)

Smartphone 

Interactive

Scan code for more 

information about this 

vehicle or to compare 

it with others.

Charge & Range

Full charge in Vehicle can travel about

99 miles 12 hours

Fuel Economy Consumption

34 kW-hrs per 

100 miles

MPGequivalent

combined

98102 94 city highway

$618 annual fuel cost

Fuel Economy & Greenhouse Gas Rating

(among all vehicles)

Fuel economy for all midsize cars ranges from 12 to 103 MPGequivalent.

midsize cars

Worst 1 2 3 4 5 6 7 8 9 Best

10

Label 3 – Electric

Fuel Economy and 

Environmental Comparisons

EPA

DOT

EPA Fuel Label Options August 23, 2010

Dual Fuel Vehicle: Plug-in Hybrid Electric

Smartphone 

Interactive

Scan code for more 

information about this 

vehicle or to compare 

it with others.

Visit www.fueleconomy.gov

• Calculate personalized driving estimates

• Download the Fuel Economy Guide 

(also available at dealers)

Annual Fuel Cost

Gas Only

(when battery is empty)

1.5 2.7 gallons 

per 100 mi.

gallon gas 

equivalent 

per 100 miles

Charge takes Range

4 hours 50 miles before 

switching to Gas Mode

Electric only: first 11 miles

Blended Electric+Gas

(when fully charged)

MPGequivalent 65 MPG 38

Blended and 

Gas Only combined

$855

Fuel Economy & Greenhouse Gas Rating

(among all vehicles)

Fuel economy for all midsize station wagons ranges from 

18 to 75 MPGequivalent. This vehicle gets 53 MPGequivalent.

midsize station wagons

Worst 1 2 3 4 5 6 7 8 10 Best

9

Your actual mileage and costs will vary with fuel cost, temperature, driving conditions, and how 

you drive and maintain your vehicle. Cost estimates are based on 15,000 miles per year at $2.80 

per gallon and 12 cents per kW-hr. MPGequivalent: 33.7 kW-hrs = 1 gallon gasoline energy.

Label 3 – PHEV

4 out of 5 (5 is best)

Other Air Pollutants

137 CO2

grams/mile

(tailpipe only)

Environment Rating

(among all vehicles)

Fuel Economy and 

Environmental Comparisons

EPA

DOT

EPA Fuel Label Options August 23, 2010

Dual Fuel Vehicle: Plug-in Hybrid Electric

Smartphone 

Interactive

Scan code for more 

information about this 

vehicle or to compare 

it with others.

Your actual mileage and costs will vary with fuel cost, temperature, driving conditions, and how 

you drive and maintain your vehicle. Cost estimates are based on 15,000 miles per year at $2.80 

per gallon and 12 cents per kW-hr. MPGequivalent: 33.7 kW-hrs = 1 gallon gasoline energy.

Visit www.fueleconomy.gov

• Calculate personalized driving estimates

• Download the Fuel Economy Guide 

(also available at dealers)

Annual Fuel Cost

Gas Only

(when battery is empty)

2.7 gallons 

per 100 mi.

Charge takes Range

4 hours 30 miles before 

switching to Gas Mode

All Electric

(when fully charged)

MPGequivalent 98 MPG 38

All Electric and 

Gas Only combined

$847

Fuel Economy & Greenhouse Gas Rating

(among all vehicles)

Fuel economy for all mid-sized cars ranges from 12 to 103 MPGequivalent. 

This vehicle gets 56 MPGequivalent.

34 kW-hrs 

per 100 mi.

midsize cars

Worst 1 2 3 4 5 6 7 8 10 Best

9

4 out of 5 (5 is best)

Other Air Pollutants

111 CO2

grams/mile

(tailpipe only)

Environment Rating

(among all vehicles)

Label 3 – EREV

Fuel Economy and 

Environmental Comparisons

EPA

DOT

Label Version 3

30 EPA Fuel Economy Label Redesign
Appendix A – Detailed 

Research Methodology 

The Environmental Protection Agency (EPA) and the National 

Highway Traffic Safety Administration (NHTSA) embarked on a 

comprehensive and innovative research program beginning in the fall 

of 2009. The research helped inform the development of the new labels 

being proposed and included a review of available literature, three 

phases of consumer focus groups (including pre-group online surveys), 

and a day-long consultation with an expert panel of individuals 

who have introduced new products or have spearheaded national 

educational campaigns. In addition, an online survey of vehicle buyers 

and intenders is planned to take place in September of 2010.

Such a multi-method approach has many benefits, perhaps the 

most important of which is that the limitations of one method can 

be potentially compensated for by the methodological strengths of 

another. For example, while focus groups are the preferred method 

to obtain in-depth reactions to potential label metrics and designs 

and to generate new ideas, they are not meant to be representative 

of new vehicle buyers nationwide in general. The focus groups for 

this research were held in four specific locations and the type of 

individuals who agree to participate in a focus group may be unique 

in some ways. In addition, group dynamics can influence the resulting 

discussion in ways that are not present during individual interviews.

Pre-group online surveys compensated for some of these limitations by 

gathering information from participants before they were influenced 

by the group discussion. Another technique we used during the groups 

themselves was to have participants record on paper their individual 

answers to discussion topics before opening the issue up to group 

discussion. Having conducted thirty-two focus groups, it was also 

beneficial to have another group, the Expert Panel, not involved with the 

project come in with a fresh set of eyes to provide another perspective. 

Final Report 31
To address the issue of the lack of representativeness of focus 

group participants, we plan to supplement the research process 

with a much broader sample of new vehicle buyers and prospective 

new vehicle buyers (“intenders”) through a large sample online 

survey. This approach also has its limitations since such surveys 

do not allow for in-depth probing. Furthermore, the samples are 

self-selected to be contacted by email and there is no guarantee that 

those who choose to complete the survey are representative even of 

this self-selected group. 

Literature Review 

We began the research process with a review of existing literature on 

the vehicle buying process, information sources used by consumers 

as they shop for vehicles, the factors (such as price, fuel economy, 

and safety, as well as demographics and psychographics) that 

influence consumer vehicle purchasing decisions, and the impact of 

the increasing availability of “greener” vehicles. This allowed us to 

establish a foundation upon which subsequent research tasks were 

based and supplement (instead of repeat) existing research. A total 

of eighty studies/articles were reviewed and the sources spanned 

a broad range of books, articles, papers, and secondary research 

reports. Data presented were primarily taken from business, 

marketing, and academic journals and magazines; websites; 

newspapers; conference proceedings; and published government 

guidelines, standards, and documents. The literature review report 

provides a summary of the reviewed information. 

Pre-Focus Group Online Surveys

The next research step involved gaining initial insights from 

individuals who would be participating in the focus groups. The 

online surveys had several objectives including validation of some 

key findings from the literature review (especially in regard to the 

vehicle purchase process and factors that influence the vehicle buying 

process). Using an online survey tool provided the opportunity to also 

acquire some information without the impact of peer influence in the 

focus groups. It also exposed participants to discussion topics raised 

later in the focus groups (such as the MPG Illusion and descriptions 

of advanced technology vehicles) to allow more time for discussion 

of priority topics when the focus groups met face-to-face. 

32 EPA Fuel Economy Label Redesign
A main purpose of the survey was to obtain additional information 

regarding participants’ vehicle purchase process, the role of fuel 

economy in their purchase decision, how they used the current 

fuel economy label, and motivators and barriers to purchasing 

advanced technology vehicles. The survey questions were developed 

by PRR, with input from the EPA, NHTSA and OMB (Office of 

Management and Budget). 

Those recruited were sent a link to the pre-group online survey 

approximately one week in advance of the scheduled focus groups. 

They were instructed to complete the online survey at least two 

days prior to their group. Follow-up reminder calls were made to 

those who had not completed the survey in the specified timeframe. 

A total of 404 of those recruited completed the online survey. It 

should be noted that the results of these surveys are not intended 

to be representative of any larger group of new vehicle buyers 

and reflect only the experience of the focus group participants 

themselves. Nonetheless, these results provided important insights 

when used in conjunction with the other research tasks connected 

with this overall project.

Focus Groups

When our research process was at the point of requiring in-depth 

consumer feedback on design possibilities the agencies determined that 

focus groups would be ideal to gather in-depth, qualitative feedback 

about fuel economy labeling, potential new label information, and 

ways of displaying the information. Focus groups are the optimum 

approach to use when the task calls for qualitative, in-depth insight 

into a consumer’s understanding of fuel economy labels. Focus groups 

allowed us to probe around why some label designs were more 

understandable, how different label designs would be used in the 

vehicle purchase process, and which label metrics were most important 

to consumers. The focus group discussions also provided insights into 

how a label design may help consumers choose more fuel efficient 

vehicles. The focus groups were not intended to provide quantitative 

results, but were instead designed to help EPA and NHTSA discern 

the subtleties of consumer understanding and preference as it relates 

to the label and the best way to provide numerous and sometimes 

complicated pieces of information. 

Final Report 33
A total of thirty-two focus groups (256 participants) were conducted 

in three phases between February 25th and May 27th, 2010 in the 

cities of Seattle, Chicago, Houston and Charlotte. The three phases 

were designed to address the following issues:

• Phase I (8 focus groups) – Use of the current fuel economy 

label, as well as metrics and design of the label for 

conventional internal combustion engine vehicles.

• Phase II (8 focus groups) – Understandability of and preference 

for metrics for advanced technology vehicle labels.

• Phase III (16 focus groups) – Assessment of full label 

designs for conventional and advanced technology vehicles 

in regard to content and look.7

Thus, overall, focus groups were used to obtain a qualitative 

understanding of consumers’ comprehension and reactions to fuel 

economy label information. 

Participants were recruited from panels developed and maintained 

by the focus group facility used in each city. All the groups consisted 

of eight participants (with the exception of one group that had 

7 participants, two that had 6 participants, and one that had 5 

participants). Participants were screened for having purchased a 

new vehicle (not a used or pre-owned vehicle; not a motorcycle; 

and not a ‘Cash for Clunkers’ purchase) in the last 12 months and 

being the sole or primary decision maker with regard to this new 

vehicle purchase. To ensure a good cross-section of participants, 

each focus group included a mix of participants based on the 

following variables: type of new vehicle, price range of new vehicle, 

distance they typically travelled daily in this new vehicle, if they 

had seriously considered an advanced technology vehicle before 

purchasing their vehicle, and a variety of demographic variables. 

In each city, separate male and female groups were conducted in 

English and each group lasted two hours. A moderator guide was 

used to structure the focus group discussions. 

7 There were as many as fifteen 

approaches presented to the 

agencies and they selected 

three to present to focus 

groups. Developing the labels 

was iterative and PRR strived 

to incorporate all statutory 

requirements, findings from 

Phase 1 and Phase 2 focus 

groups, and agency perspectives 

and overarching guidelines. 

34 EPA Fuel Economy Label Redesign
Expert Panel

Following the focus group research, we assembled an expert panel 

for a one day consultation and asked them to give us feedback 

on the draft label designs the focus groups had helped create and 

to assist us in identifying opportunities and strategies to increase 

consumer preference for energy efficient and environmentally 

friendly vehicles. The experts came from a variety of fields in 

advertising and product development and were chosen because 

they have led successful national efforts to introduce new products 

or had spearheaded national educational campaigns. Feedback 

received from this elite group was desirable because of their unique 

history and experience of creating dramatic social change and 

influencing product preference over short periods of time.

An initial list of products and social changes that met the criteria of 

being dramatic, impacting a significant percentage of the population, 

having demonstrated staying power and having happened quickly 

was generated and prioritized. Individuals who were in roles critical 

to the success of these efforts were then identified and invited to 

participate in the Expert Panel. The panel was limited to no more 

than 10 participants in order to ensure full participation. 

Nine expert panelists eventually participated in the six hour 

discussion. The group was convened on Wednesday, June 9, 2010 

at EPA headquarters located in Washington DC. In advance of 

the discussion, participants were provided a draft agenda, a brief 

overview of the project, and initial research and focus group findings. 

Panelists were asked to come prepared to discuss how they would 

recommend that the EPA increase the value of, and preference for 

more efficient vehicles, as well as identify opportunities to increase 

the priority of energy efficiency in the vehicle purchase process, and 

finally to provide feedback on fuel economy label design drafts.

Final Report 35
Online Survey of New Vehicle Buyers 

and Intenders

The online survey of vehicle buyers and intenders is meant to 

examine how understandable the new label designs are, and 

whether the proposed new labels will improve consumers’ 

knowledge about more efficient vehicles. This survey will use two 

samples: self-selected new vehicle purchasers, and people who 

expressed an intention to purchase a new vehicle by requesting a 

price quote from a dealer8 within the past 12 months (excluding 

the ‘Cash for Clunkers’ 2009 period). Each sample will be divided 

into three separate groups and see surveys identical in every way 

except for the label design, each of the groups will see only one of 

the label designs. 

The survey tests respondents’ understanding of the labels by 

showing each respondent a series of label pairs. In each pair, all 

vehicle characteristics are held constant except the information on 

the vehicle label. For instance, the fuel economy of the vehicles may 

differ, or one may be for a conventional vehicle and one an electric 

vehicle. Respondents are then asked to identify which vehicle is 

better to use for trips of specified distances.9 The key question is 

whether the different label designs produce statistically significant 

different results. If one label produces more correct responses than 

other labels, then it can be considered more understandable. If the 

labels do not produce statistically different results, then the labels 

can be considered equivalently understandable.

To test the potential influence of the labels on vehicle purchases, 

respondents will see pairs of labels for vehicles with all vehicle 

attributes constant except those varied on the label, such as the 

technologies of the vehicles, their efficiencies, and their energy 

costs. Instead of using the label to identify the better vehicle for 

a trip distance scenario, the respondents are asked which of these 

vehicles they would prefer to buy, based on their individual driving 

patterns. Because the survey asks respondents about their typical 

daily driving distances, it is possible to see whether respondents 

chose the vehicle better suited for their habits. The key variable is 

whether the responses differ for different label designs. 

8 Sources of respondents were 

databases owned by Autobytel, 

http://www.autobytel.com 

(for those intending to buy 

new vehicles), and Focus USA 

(for those who purchased 

a vehicle in the last year), 

http://www.focus-usa-1.com.

9 Respondents are asked which 

was better, rather than which 

was more fuel-efficient or 

less costly, so as to leave the 

respondents with the choice 

of what information on the 

label to use for the comparison. 

A later question asks which 

information they used in their 

response. While this somewhat 

ambiguous approach may reduce 

the absolute number of correct 

answers to the questions, the goal 

is to test the relative effects of the 

labels, not the absolute effects.

36 EPA Fuel Economy Label Redesign

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