State of California 

AIR RESOURCES BOARD 

STAFF REPORT: INITIAL STATEMENT OF REASONS FOR RULEMAKING

PROPOSED AMENDMENTS TO 

THE SMOG INDEX VEHICLE EMISSIONS LABEL 

This report has been reviewed by the staff of the California Air Resources Board and 

approved for publication. Approval does not signify that the contents necessarily reflect the 

views and policies of the Air Resources Board, nor does mention of trade names or 

commercial products constitute endorsement or recommendation for use. 

Date of Release: May 4, 2007

Scheduled for Consideration: June 21, 2007 

Prepared By: 

Zero Emission Vehicle Infrastructure Section 

Mobile Source Control Division 

Gerhard Achtelik, Manager 

Contributing Staff:

Craig Duehring 

Krista Eley 

Acknowledgements:

Staff appreciates the time and assistance provided by the staff of the United States 

Environmental Protection Agency, automobile manufactures and environmental groups. 

Staff also wishes to acknowledge the support and work from 

Sarah Carter, Melissa Meuser, Duc Nguyen, and Emily Smith 

with the Mobile Source Control and Operation Divisions. 

 iii

TABLE OF CONTENTS

EXECUTIVE SUMMARY ................................................................................................ 1

I. Introduction and Background............................................................................... 5

II. Need for Regulatory Amendments ....................................................................... 6

III. Environmental Justice and Public Outreach ....................................................... 7

A. Environmental Justice............................................................................. 7

B. Outreach Efforts ...................................................................................... 7

IV. Staff Proposal – Smog Score................................................................................ 9

A. Existing Requirements............................................................................ 9

B. Staff Proposal ........................................................................................ 10

V. Staff Proposal – Global Warming Score ............................................................ 13

A. Existing Consumer Information ........................................................... 13

B. Staff Proposal ........................................................................................ 13

VI. Proposed Environmental Performance Label Requirements........................... 17

VII. Economic Impacts ............................................................................................... 21

A. Background............................................................................................ 21

B. Estimated Costs..................................................................................... 21

C. Total Cost of Implementation ............................................................... 23

VIII. Estimated Environmental Benefits..................................................................... 25

IX. Issues.................................................................................................................... 26

A. Lead Time Requirements ...................................................................... 26

B. Label Size ............................................................................................... 27

X. Alternatives .......................................................................................................... 28

A. Alternative 1: Keep Existing Smog Index Label and Add a Global 

Warming Index ....................................................................................... 28

B. Alternative 2: Incorporate SmartWay Certification Mark................... 28

C. Conclusion ............................................................................................. 29

XI. References............................................................................................................ 30

Appendix A – Regulation Language........................................................................ A-1

Appendix B – Example Existing Smog Index Labels ............................................. B-1

Appendix C - Technical Analysis............................................................................. C-1

A. Smog Score.......................................................................................... C-1
 iv

B. Global Warming Score ........................................................................ C-7

C. Color Printer Economic Impact ........................................................ C-14

Appendix D - Other Vehicle Labels.......................................................................... D-1
 v

LIST OF TABLES 

Table III-1: Workshop Dates and Locations ............................................................. 8

Table IV-1: Proposed 2009 Smog Score by Certification ...................................... 11

Table V-1: Upstream Adjustment Factors for Alternative Fuels .......................... 14

Table V-2: Upstream CO2Equivalent Values for Hydrogen Internal Combustion 

Engine, Hydrogen Fuel Cell Electric, and Battery Electric Vehicles . 14

Table V-3: Statistical Distribution of California and Federal CO2 Data............... 15

Table V-4: Proposed Global Warming Scores based on CO2Equivalent Emissions 15

Table C-1: California Light-Duty Vehicle Emissions Standards for Air 

Pollutants ............................................................................................. C-1

Table C-2: U.S. EPA Light-Duty Vehicle Emissions Standards for Air 

Pollutants ............................................................................................. C-2

Table C-3: 2009 Federal and California Combined Certification Levels............ C-3

Table C-4: 2009 Federal and California Combined Certification Levels 

with PZEV Category............................................................................. C-3

Table C-5: 2009 Smog Score by Certification...................................................... C-4

Table C-6: Possible 2009 Smog Score by Straight Line Analysis...................... C-5

Table C-7: California and Federal CO2 Combined Data Distribution ................. C-8

Table C-8: California 2007 CO2 Combined Certification Data............................. C-9

Table C-9: Possible 2009 Global Warming Scores Based on CO2 Emissions .. C-9

Table C-10: Distribution of California Certifications Based on Vehicle 

Classification ..................................................................................... C-10

Table C-11: Statistical Distribution of California and Federal CO2 Data............ C-12

Table C-12: Possible 2009 Global Warming Scores Based on CO2 Emissions C-13
 vi

LIST OF FIGURES 

Figure 1: Proposed California Environmental Performance Label...................... 3

Figure IV-1: Current Smog Index Label ...................................................................... 9

Figure IV-2: Distribution of California Certification Levels by Smog Score.......... 11

Figure V-1: Distribution of Global Warming Scores............................................... 16

Figure VI-1: California Environmental Performance Label ..................................... 19

Figure VI-2: California Environmental Performance Label with Flex-Fuel ............ 19

Figure X-1: U.S. EPA SmartWay Certification Mark................................................ 28

Figure C-1: Distribution of Smog Scores Based on 2007 Model Year 

Certifications........................................................................................ C-5

Figure C-2: Distribution of Smog Scores Based on 2007 Model Year 

Certifications........................................................................................ C-6

Figure C-3: Distribution of Global Warming Scores Based on 2007 Model Year 

Certifications...................................................................................... C-10

Figure C-4: Distribution of Vehicle Classification Based on California EO 

Certifications...................................................................................... C-11

Figure C-5: Diagram of a Normal Distribution of Scores ................................... C-13

Figure C-6: Distribution of Global Warming Scores Based on 2007 Model Year 

Certifications...................................................................................... C-14
1 

EXECUTIVE SUMMARY 

California citizens purchase approximately 2 million

1

 new passenger cars, light-duty 

trucks, and medium duty passenger vehicles each year. In addition, the California fleet 

of 25 million on-road vehicles travels about 900 million miles each day. This equates to 

2,288 tons per day2 of smog precursor emissions and 0.35 million tons per day3 of 

global warming gas emissions. Even with the addition of cleaner vehicles to California’s 

vehicle population, both smog forming emissions and global warming emissions from 

motor vehicles will continue to have a major impact on California’s environment for 

years to come. 

Over the past several years there have been a number of studies using focus groups 

and market research to evaluate different types of vehicle labeling and ranking 

programs. In these studies, respondents preferred some kind of overall environmental 

score that they could have faith in and would be applicable across the country and 

across all vehicles. Respondents stated that the information needs to be presented in a 

way that consumers find simple and understandable. Unfortunately, consumers do not 

have a clear understanding of environmental factors as they relate to car choice and 

tend to assign responsibility for this issue to government or industry. However, there 

appears to be growing public awareness of environmental issues. A recent California 

Field Poll indicates the majority of Californians consider global warming a serious 

problem.4

 

Consumer awareness of a vehicle’s environmental footprint would help consumers 

make the cleanest purchasing choice possible when selecting a new vehicle. 

Ultimately, consumer decisions to buy cleaner cars could result in lower emissions than 

would be achieved from regulating vehicles alone. 

To provide vehicle emissions information to consumers, the Air Resources Board (ARB) 

has required a Smog Index Label on new vehicles since the 1998 model year (MY). 

The Smog Index Label provides consumers with an indication of the relative emissions 

performance of new light-duty vehicles for smog forming exhaust emissions of 

non-methane organic gas, oxides of nitrogen, and evaporative hydrocarbons. 

In 2005 Assembly Bill (AB) 1229 was signed into law adding Health & Safety Code 

§ 43200.1 which, among other things, requires ARB to develop a greenhouse gas index 

and label, and to review the existing Smog Index Label. Staff proposes amending the 

Smog Index Label to add a Greenhouse Gas Index, and add specific requirements to 

label information and presentation to enhance label appearance and consistency. 

These labeling requirements are prescriptive by nature and will require one label size 

 

1 California Air Resources Board: Certification Data Reported to the California Air Resources Board in 

2005

2 California Air Resources Board: 2005 Estimated Annual Average Emissions 

3

Inventory of California Greenhouse Gas Emissions and Sinks: 1990-1999, California Energy 

Commission Staff Report

4

San Jose Mercury News, “Survey finds 81% worried about global warming,” April 12, 2007.
2 

and design to be used by all affected vehicle manufacturers. Staff recommends the 

new label regulations take affect for all passenger cars, light-duty trucks, and 

medium-duty passenger vehicles manufactured on or after October 1, 2008. 

Proposed Index Requirements 

During the review staff found noticeable differences in the way the current smog index 

values are presented by different manufacturers, making it difficult for consumers to 

compare smog forming emission values from one vehicle to the next. As a result, staff 

proposes modifications to the graphics and content of the existing California Smog 

Index Label and is also proposing a new Global Warming Index to be included on the 

new label. 

The current Smog Index Label uses a relative ratio to compare actual vehicle emissions 

to an average vehicle. Staff found inconsistencies in existing label size and 

presentation of content used by manufacturers which creates confusion and 

misunderstanding by consumers. Prior market research by the United States 

Environmental Protection Agency (U.S. EPA), based on consumer focus groups, 

recommended a simple scale from 1 -10 for both Air Pollution and Greenhouse Gas 

(GHG) emissions. Staff also performed market research based on consumer focus 

groups and determined that using a simpler scale from 1-10 represents the optimal way 

to present emissions information. 

For the Smog Index, staff recommends using a simple scale from 1-10 where 1 

represents the dirtiest vehicle available and 10 the cleanest based on vehicle emission 

certification standards. This scale is consistent with the U.S. EPA scale currently used 

on their Green Vehicle Guide website. U.S. EPA found that through focus groups this 

scale was meaningful for prospective car buyers. While U.S. EPA provides these 

scores on its website, vehicle labeling using these scores is voluntary. Currently none 

of the auto manufacturers label their vehicles using U.S. EPA’s program, however some 

manufacturers reference their vehicles’ scores in product literature. 

For the global warming index, staff developed a scoring system also using a simple 

1-10 scale. The scoring system incorporates all vehicle greenhouse gases mandated 

by the ARB greenhouse gas emission standards, which take effect for 2009 model year. 

Similar to Smog scores, the U.S. EPA provides greenhouse gas scores on its website 

but does not require scores be printed on new vehicle labels. U.S. EPA’s greenhouse 

gas scores are based on different calculation methods and at this time are not aligned 

with staff’s proposed scoring system. 

Staff recommends that the scoring system be re-analyzed when 2012 MY California 

certification data becomes available. This new analysis is required because annual 

reductions in global warming emissions, as required by ARB’s greenhouse gas 

emission standards, may alter the distribution of scores over time. 
3 

Label 

In designing the new California Environmental Performance label, staff turned to market 

research specialists for help and sought out consumer-based input from focus groups to 

provide clarity and understanding of a newly designed label. The purpose of these 

focus groups was to build upon the work previously done and to obtain up-to-date 

information from California specific consumers. As a result staff designed a new label 

based on this research. The label best understood by respondents is shown in figure 1. 

Figure 1: Proposed California Environmental Performance Label 

Figure 1 shows the Global Warming score on the left and the Smog Score on the right. 

The black boxes represent the score of the labeled vehicle. A triangle below the scale 

shows the score of an average vehicle for comparison purposes. It was clear in the 

focus groups that with the word “cleanest” under the 10 and with the statement: “Protect 

the environment, choose vehicles with the higher scores” meant vehicles with more 

black boxes were cleaner vehicles. The statement at the bottom of the label describes 

the impact of motor vehicles on smog and global warming. It also points consumers to 

the ARB’s www.DriveClean.ca.gov website which is a consumer oriented website with 

information about clean cars, alternative fuel and advanced technology vehicles. 

Economic Impacts

This regulation proposes modifications to the existing Smog Index Label and adds a 

global warming score to the existing label. Based on the amount of added information 

required and the addition of the new global warming score, the size of the label must be 

increased. In addition, Health and Safety Code § 43200.1 requires use of a color other 

than black for some portion of the label. 
4 

The total annual cost to implement this regulation is estimated to be $245,000 for 

the industry as a whole. The annual cost for a typical manufacturer is estimated to 

be $8,167. This cost estimate will vary slightly by manufacturer depending on the 

actual number of assembly plants, ports of entry, printers required, and vehicles 

produced. 

Environmental Benefit 

The purpose of the label is to encourage purchasers to buy new vehicles with the lowest 

emissions. To the extent that the label accomplishes this, vehicle emissions will 

decrease. Staff has no basis upon which to quantify this effect, thus no estimates of 

cost effectiveness have been made. 

Staff Recommendation

Staff recommends the Board approves the new label. The proposed label will provide 

clarity for consumers and help them make environmentally beneficial choices. 
5 

I. Introduction and Background 

California citizens purchase approximately 2 million

5

 new passenger cars, light-duty 

trucks, and medium duty passenger vehicles each year. In addition, the California fleet 

of 25 million on-road vehicles travel about 900 million miles each day. This equates to 

2,288 tons per day6 of smog precursor emissions and 0.35 million tons per day7 of 

global warming gas emissions. Even with the addition of cleaner vehicles to California’s 

vehicle population, both smog forming emissions and global warming emissions from 

motor vehicles will continue to have a major impact on California’s environment for 

years to come. Consumer awareness of a vehicle’s environmental footprint would help 

consumers make the cleanest purchasing choice possible when selecting a new 

vehicle. Ultimately, consumer decisions could result in lower emissions than would 

result from regulated emission standard requirements alone. 

The average new car purchaser is not aware of the various smog forming pollutant 

emission requirements that apply to new vehicles and the regulatory terms used to 

describe emission levels. For example, a California certified vehicle is identified as 

being a low-emission vehicle (LEV), ultra-low-emission vehicle (ULEV), super-ultra-lowemission vehicle (SULEV), partial zero-emission vehicle (PZEV), or zero-emission 

vehicle (ZEV). Likewise, in some instances, federally certified vehicles using an 

emissions “bin” certification level from bin 1 through bin 9a can also be sold in 

California. Both the U.S. EPA’s Green Vehicle Guide website and the California’s 

DriveClean website offer emission classification identifiers to aid the consumer in 

selecting clean vehicles. However, these vehicle classifications used across multiple 

information sources can differ and overlap at times, providing additional challenges for 

the consumer to identify cleaner new vehicles. In addition to smog forming pollutants, 

cars emit greenhouse gases. Consumers are only just beginning to understand the 

greenhouse gas emissions impacts from cars and have little or no information available 

about new cars on which to base an informed purchase decision. 

In order to ensure that Californians are effectively informed as to the environmental 

impact of new vehicle purchases, Health & Safety Code § 43200.1 requires the Air 

Resources Board (ARB) to revise the existing Smog Index Label to include a Global 

Warming Index. 

 

5

 California Air Resources Board: Certification Data Reported to the California Air Resources Board in 

2005

6 California Air Resources Board: 2005 Estimated Annual Average Emissions 

7

Inventory of California Greenhouse Gas Emissions and Sinks: 1990-1999, California Energy 

Commission Staff Report 
6 

II. Need for Regulatory Amendments 

ARB requires that each new passenger car and light-duty truck offered for sale have a 

window label that includes a rating of its smog-forming emissions, called the smog 

index. On October 6, 2005, Assembly Bill 1229 was signed into law (Chapter 575, now 

Health & Safety Code § 43200.1), which directs the Air Resources Board to review and 

revise the existing Smog Index Label and to develop a Global Warming Index. A 

summary of the requirements follows. 

• No later than July 1, 2007, revise regulations relating to the smog index decal, to 

rename the existing decal and to provide specified smog forming, and global 

warming emissions information. 

• Label is required to be effective for model year 2009 and subsequent model year 

new motor vehicles. 

• Label is required for all passenger cars and light-duty trucks with a gross vehicle 

weight of 8,500 pounds and medium-duty passenger vehicles less than 10,000 

pounds. 

• Global warming index shall include emissions from vehicle operation and 

upstream emissions. 

• Label shall include projected average vehicle emissions and lowest emission 

vehicle reference points. 

• Label shall use at least one color ink in addition to black. 

• Staff shall hold at least one public workshop. 

• Staff shall seek input from automotive consumers, graphic design professionals, 

and other relevant labeling formats. 

• This bill permits the ARB to recommend to the Legislature additional sources of 

air pollution that emit significant amounts of global warming gases for which the 

disclosure of information regarding those emissions would be an effective means 

of educating the public about the sources of global warming and its impacts. 

Health & Safety Code § 43200 requires the label to be placed on the driver's side 

window or, if it cannot be so placed, to the windshield. This restrictive placement of the 

label was unintended and could have raised safety concerns. Assembly Bill 2557 was 

signed into law (Chapter 419) on September 22, 2006, permitting the label to be placed 

on a side window to the rear of the driver, or if it cannot be so placed, to the windshield. 

A review of the implementation of the existing Smog Index Label shows a lack of 

consistent label design used by auto manufacturers. Appendix B shows different 

variations of labels used by the manufacturers. Based on the requirements of Health & 

Safety Code 43200.1 and staff’s findings regarding the existing Smog Index Label, a 

proposal for a new Environmental Performance Label has been developed and is 

presented in this report. 
7 

III. Environmental Justice and Public Outreach 

The ARB is committed to ensuring that all California communities have clean, healthful 

air by addressing not only the regional smog that hangs over our cities but also the 

more localized toxic air pollution that is generated within our communities. The ARB 

works to ensure that all individuals in California, especially children and the elderly, can 

live, work and play in a healthful environment that is free from harmful exposure to air 

pollution. 

A. Environmental Justice 

On December 13, 2001, the Board approved Environmental Justice Policies and 

Actions, which formally established a framework for incorporating environmental justice 

into the ARB's programs, consistent with the directives of State law and policy8. 

“Environmental Justice” is defined as the fair treatment of people of all races, cultures, 

and incomes with respect to the development, adoption, implementation, and 

enforcement of environmental laws, regulations, and policies. These policies apply to all 

communities in California but, environmental justice issues have been raised more in 

the context of low-income and minority communities because of past land use policies 

and the accumulative impact of a concentration of emitting facilities in some 

neighborhoods. 

To achieve this goal, the ARB has established a Community Health Program and 

emphasized community health issues in our existing programs. ARB has published, 

“The Public Participation Guide to Air Quality Decision Making in California” to use as a 

basic tool and for information needed to understand and participate in air pollution policy 

planning, permitting, and regulatory decision making processes9

. The Environmental 

Justice Policies are intended to promote the fair treatment of all Californians and cover 

the full spectrum of ARB activities. Underlying these Policies is a recognition that we 

need to engage community members in a meaningful way as we carry out our activities. 

People should have the best possible information about the air they breathe and what is 

being done to reduce unhealthful air pollution in their communities. The ARB 

recognizes its obligation to work closely with all stakeholders; communities, 

environmental and public health organizations, industry, business owners, other 

agencies, and all other interested parties to successfully implement these policies. Our 

outreach efforts, described below, facilitate this objective. 

B. Outreach Efforts 

The ARB strives to involve the widest number of affected persons in the development of 

its regulations. To this end, staff held informal public workshops and meetings prior to 

publishing the notice and staff report. Information from these workshops can be found 

 

8

 Information for these programs can be found at http://www.arb.ca.gov/ch/programs/ej/ejpolicies.pdf. 

9

 Information on this program can be found at http://www.arb.ca.gov/ch/public_participation.htm. 
8 

through the Vehicle Emissions Labeling website10. For this rule, staff conducted two 

public workshops and numerous focused meetings. Notices for the workshops were 

posted to Vehicle Emissions Labeling web site and e-mailed to subscribers of ARB’s 

electronic list server. Those workshops held in Sacramento were webcast for 

individuals who could not travel to the meeting locations. Attendees of the workshops 

included representatives from auto manufacturers, environmental organizations, and 

other parties interested in vehicle emissions labeling. To generate additional public 

participation and to enhance the information flow between ARB and interested persons, 

staff made all documents, including workshop presentations, available via the Vehicle 

Emissions Labeling web site. 

Table III-1: Workshop Dates and Locations 

Date Location 

February 15, 2005 Sacramento

March 16, 2006 Sacramento

Outreach and public participation are important components of ARB’s regulatory 

development process. As part of the outreach efforts, ARB staff made extensive 

personal contacts with auto manufacturers, environmental organizations, U.S. EPA, 

other state air quality agencies and other affected parties through meetings, telephone 

calls, and electronic list-serves. These activities included holding two public workshops, 

nine focused meetings and conducting more than 50 telephone conversations. Staff 

met with a number of the same stakeholders for focused meetings throughout the 

rulemaking process to receive feedback on staff’s proposed regulatory amendments. 

Alternatives were suggested to the proposed regulation and explored by staff. 

 

10 More information on Vehicle Emissions Labeling Programs can be found at 

http://www.arb.ca.gov/msprog/labeling/labeling.htm 
9 

IV. Staff Proposal – Smog Score 

A. Existing Requirements 

The California Smog Index Label provides consumers with an indication of the relative 

contribution of new light-duty vehicles to smog formation based on exhaust nonmethane organic gas (NMOG), oxides of nitrogen (NOx), and evaporative hydrocarbon 

(HC) emissions. The current Smog Index Label uses a relative ratio to compare the 

vehicle being labeled to a base vehicle as determined by the ARB. The equation for 

this ratio is as follows: 

Where NMOG and NOx are tailpipe emissions, HC is evaporative emissions. 

This smog index ratio is then displayed graphically on a label, usually as a number less 

then 1.0, along with the smog index of an average new vehicle for the model year of the 

vehicle being sold. Figure IV-1 illustrates a typical Smog Index Label: 

Figure IV-1: Current Smog Index Label 

SMOG EMISSIONS INFORMATION

The Smog Index of this vehicle is The Smog Index of the average new vehicle is 

 0.34 0.52 

 ▼ ▼

0.0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0......3.0 

◄CLEANER MORE POLLUTING►

Note: The Smog Index (SI) indicates the relative level of smog-forming 

pollutants emitted by the vehicle. The lower the SI, the lower the vehicle's 

emissions. 

This label began appearing on new vehicles offered for sale in California in 1998 and is 

also appearing on vehicles sold in other states that have adopted California standards. 

Some vehicle manufacturers have incorporated the Smog Index information into the 

Smog 

Index =

NMOG+NOx+HC (vehicle being certified)

NMOG+NOx+HC (base vehicle)
10 

new vehicle’s Monroney label, which provides pricing information and the vehicle’s U.S. 

EPA fuel economy ratings. 

The existing smog index regulations have allowed the manufacturers to vary the size 

and graphical representation of the Smog Index over time. Today, each vehicle 

manufacturer has its own graphical representation of the scale, some similar to the one 

shown above, some showing a scale from 0.0 – 2.0, and some showing a scale from 

0.0 – 3.0. As the length of the scale increases from “0.0 – 1.0” to “0.0 – 2.0” and even 

“0.0 – 3.0,” the importance of a smog index ratio whose number is typically less than 1.0 

may diminish. Appendix B contains some example pictures of actual 2007 Smog Index 

Labels being used by various vehicle manufacturers. For this reason staff proposes 

prescriptive label requirements. 

The U.S. EPA does not require a smog index or score to be included on new cars. On 

its website, it provides a rating on a scale from 1-10 (ten being lowest emitting or 

cleanest), as part of its Green Vehicle Guide11. Separate ratings are provided for 

vehicles certified to California new vehicle emission standards. 

B. Staff Proposal 

Staff is proposing to modify the graphics and content of the label to increase consumer 

awareness and understanding of the Smog Index Label. Staff proposes using a simple 

scale of 1-10 where 1 represents the dirtiest vehicle available and 10 the cleanest. This 

is the opposite of the current scale, where 0.0 is the cleanest. Staff proposes using this 

new scale for two reasons. First, consumer focus group research indicates more 

consumers understand 10 is well performing, and 1 is poor performing. Second, the 

U.S. EPA has a popular website that uses the 1-10 scale for both smog and 

greenhouse gas ratings of new vehicles (Green Vehicle Guide10). The proposed Smog 

scores based on the 1-10 scale are shown in Table III-1. Staff has worked with U.S. 

EPA and included federal standards (bins) in the ranking system, and U.S. EPA staff 

indicates it may change its rating to be consistent with California. A more detailed 

technical analysis and discussion of the new scores can be found in Appendix C: 

Technical Analysis. 

 

11 United States Environmental Protection Agency: Green Vehicle Guide, www.epa.gov/greenvehicles
11 

Table IV-1: Proposed 2009 Smog Score by Certification 

California Emissions Certification - Federal 

Bins 

NMOG + NOx 

(g/mile) 

2009 Smog 

Score 

Zero Emission Vehicle (ZEV) or Bin 1 0.0 10 

Partial Zero Emission Vehicle (PZEV) 0.030 9 

Super Ultra Low Emission Vehicle (SULEV) or 

Bin 2 

0.030 8 

Bin 3 0.085 7 

Bin 4 0.110 6 

Ultra Low Emission Vehicle (ULEV) 0.125 5 

Low Emission Vehicle (LEV) or Bin 5 0.160 4 

Low Emission Vehicle (LEV) (option 1)* or Bin 6 

and SULEV medium duty passenger vehicles 

0.190 – 0.200 3 

Bin 7 0.240 2 

Bin 8a or 

ULEV (medium duty passenger vehicles) 

0.325 1 

* LEV (option 1) is an optional certification standard for qualifying work vehicles. 

Table III-1 lists the certification levels by their California terminology or by U.S. EPA 

“bins,” the tailpipe emission standard for NMOG and NOx and the proposed Smog 

Score. While the PZEV and SULEV – Bin 2 vehicles are certified to the same exhaust 

emission standard, PZEV certified vehicles receive a higher score due to their zero 

evaporative emissions and extended 150,000 mile emission warranty. 

Applying this Smog scale to the 2007 MY California certification data yielded the model 

based distribution of Smog scores shown on Figure IV-2. This distribution is based on 

2007 MY California certification data and may look different for the 2009 MY as vehicle 

manufacturers continue to certify to cleaner standards. 

Figure IV-2: Distribution of California Certification Levels by Smog Score 

0

20

40

60

80

100

120

140

160

180

1 2 3 4 5 6 7 8 9 10

Smog Score 

Number of Vehicle 

Certifications 
12 

Based on all 2007 MY vehicles, the average vehicle model score is closest to a 5 on the 

proposed scale, which correlates to an Ultra Low Emission Vehicle (ULEV) certification 

standard. This is a count of vehicle models however, not a sales weighted fleet 

average. In 2009, the fleet average emission standard would also be closest to the 

ULEV certification standard and receive a score of 5. Staff therefore recommends using 

the ULEV certification as the average and setting the Smog score of 5 to represent the 

average vehicle. Vehicles with a score of 1 are typically medium-duty passenger 

vehicles, such as the Ford E-250 Econoline. 

For bi-fuel, fuel flexible, and dual-fuel vehicles, vehicles capable of operating on 

gasoline and an alternate fuel like ethanol propane or natural gas, the scores displayed 

on the label will be based on only the highest emitting fuel. The label will direct 

consumers to visit ARB’s web site at www.DriveClean.ca.gov to find information on 

flexible fuel vehicles and the impact of using an alternative fuel on smog forming 

pollutant and greenhouse gas emissions. 
13 

V. Staff Proposal – Global Warming Score 

A. Existing Consumer Information 

Neither the U.S. EPA nor the ARB currently requires greenhouse gas emissions to be 

reported on a new vehicle label. U.S. EPA reports a vehicle’s CO2 emissions in its 

web-based Green Vehicle Guide. The score is based on the CO2 emissions from the 

federal test procedure, and the fuel used. Other greenhouse gases, such as nitrous 

oxides, are not included in the published score. Separate ratings for California certified 

vehicles are provided. 

B. Staff Proposal 

Staff proposes to use a global warming scoring system for labeling that is based on 

emissions data from ARB’s motor vehicle greenhouse gas emissions regulation. The 

motor vehicle greenhouse gas regulation bases compliance on four different sources of 

pollutants: (1) carbon dioxide (CO2), methane (CH4) and nitrous oxide (N2O) emissions 

resulting directly from operation of the vehicle, (2) exhaust CO2 emissions resulting from 

operating the air conditioning system (indirect air conditioning (A/C) emissions), (3) 

refrigerant emissions from the air conditioning system due to either leakage, losses 

during recharging, sudden releases due to accidents, or release from scrappage of the 

vehicle at end of life (direct A/C emissions), and (4) upstream emissions associated with 

the production of the fuel used by the vehicle. Upstream emissions are included so that 

vehicles using an alternative fuel, a fuel other than gasoline or diesel, will be given an 

appropriate score relative to the production and consumption of the fuel used. 

The greenhouse gas regulation establishes a CO2 “equivalent” value that includes all 

the various global warming gases based on their relative contribution to global warming. 

The CO2 equivalent value is as follows: 

CO2 Equivalent = CO2+296xN2O+23xCH4–A/C Direct Emissions Allowance–A/C Indirect 

Emissions Allowance 

Using this equation, and accounting for the upstream emissions factor for alternative 

fuels, ARB accounts for all global warming gasses being released into the atmosphere 

due to the operation of each vehicle. 

To maintain simplicity, the greenhouse gas regulation uses the upstream emissions for 

vehicles that use conventional fuels as a “baseline” against which to compare the 

relative upstream emissions of alternative fuel vehicles. Therefore, when certifying 

gasoline or diesel-fuel vehicles, manufacturers will report only the “direct” or “on vehicle” 

emissions. Table IV-1 lists the CO2 upstream adjustment factor for alternative fuels 

used for the greenhouse gas regulation. 
14 

Table V-1: Upstream Adjustment Factors for Alternative Fuels 

Fuel CO2Equivalent 

Adjustment Factor 

Conventional 

Gasoline (RFG) 1.00 

Compressed Natural 

Gas (CNG) 1.03 

Liquid Propane Gas 

(LPG) 0.89 

Ethanol (E85) 0.74 

The CO2Equivalentemissions will be multiplied by the CO2Equivalent Adjustment Factor for 

the alternative fuel, as shown in the Table V-1. For hydrogen internal combustion 

engine vehicles, hydrogen fuel cell electric and battery electric vehicles, the grams per 

mile average CO2Equivalent value is the sum of the upstream emissions and the A/C direct 

emissions. Therefore these vehicles will be given a constant CO2Equivalent value listed in 

Table V-2. 

Table V-2: Upstream CO2Equivalent Values for Hydrogen Internal 

Combustion Engine, Hydrogen Fuel Cell Electric, and Battery Electric 

Vehicles 

Fuel CO2Equivalent Value 

(grams/mile) 

Electricity 130 

Hydrogen – Fuel Cell 210 

Hydrogen – Internal 

Combustion Engine 

(ICE) 

290 

As required by the greenhouse gas regulation, CO2Equivalent values are reported for both 

city and highway testing cycles and than combined to represent a 55% city and 45% 

highway driving ratio. This CO2Equivalent combined value, including likely credits 

achievable from direct AC emission reductions, is the value that staff used to develop a 

global warming scoring and labeling system. 

Staff performed a statistical analysis on the CO2 data available from the model year 

2007 California Certifications. Manufacturers are not yet certifying their vehicles to the 

greenhouse gas regulation standards, and not all manufacturers currently provide ARB 

with this data. Staff requested a complete set of CO2 data from all manufacturers12 but 

 

12 Air Resources Board: February 28, 2007 letter to Steven Douglas, Director; Alliance of Automobile 

Manufacturers and February 28, 2007 letter to John Cabaniss, Director; Association of International 

Automobile Manufacturers. 
15 

received minimal feedback. Statistically, the available data was sufficient to represent 

the new vehicle fleet as a whole. To better illustrate this point, staff compared the 

California dataset to a more complete dataset from Federal certifications. As seen in 

Table V-3, the California and Federal average and standard deviation values are very 

close to being equal when not including the MDPV category. The similarity in values 

helps demonstrate that the available CO2 data is adequate to represent the entire fleet. 

Table V-3: Statistical Distribution of California and Federal CO2 Data 

CO2 combined 

(g/mile) 

California

(with MDPV data)

California

(without MDPV data)

Federal 

Minimum 130 130 133 

Maximum 874 570 662 

Average 358 355 348 

Standard Deviation 101 81 76 

Staff used the statistical average of 360 grams per mile (g/mile) CO2 and set that as 5 

on the scale. Using a standard deviation of 80 g/mile, staff developed a scoring system 

based on two standard deviations from the average to simulate a normal distribution of 

scores. The two extremes blend into the best and worst scores. Applying this principle 

to the California dataset staff developed the global warming scoring system found in 

Table V-4. 

Table V-4: Proposed Global Warming Scores based on CO2Equivalent Emissions 

Proposed Global 

Warming Score 

CO2Equivalent 

grams per mile 

10 Less than 200 

9 200-239 

8 240-279 

7 280-319 

6 320-359 

5 360-399 

4 400-439 

3 440-479 

2 480-519 

1 520 and up 

Applying this global warming scoring system to the 2007 MY California certification 

dataset yields the distribution of scores as shown in Figure-V-1 which closely resembles 

a normal distribution. 
16 

Figure V-1: Distribution of Global Warming Scores 

The spike at the low end of the scale (score of 1) represents the larger medium-duty 

passenger vehicles, such as the Ford E-250 Econoline and Expedition. Vehicles with a 

score of 10 are typically hybrid passenger cars, such as Toyota Prius and Honda Civic 

Hybrid. Average vehicles obtaining a score of 5 are typically large passenger cars and 

small light-duty trucks, such as the Ford Crown Victory, Toyota 4Runner, and Honda 

Odyssey van. 

Staff recommends using this global warming scoring system on the label required by 

Health & Safety Code 43200.1 

The greenhouse gas regulation requires vehicle manufacturers to decrease the fleet 

average CO2Equivalent emissions incrementally from 2009 to 2016 at which point the fleet 

average CO2Equivalenmt emissions remain constant. Staff looked at these incremental 

adjustments and determined that by the 2012 MY, on average, vehicles will have 

reduced the amount of CO2Equivalent emissions to the point of skewing the normal 

distribution of scores to the higher end of the scale. For example, the incremental 

change between global warming scores as proposed by this report is 40 (g/mile). 

Following the reductions required by the greenhouse gas regulation, the fleet average 

emissions will have been reduced by 84 (g/mile) by 2012. Therefore vehicles on 

average would be jumping one or more global warming scores to the next cleanest 

score and skewing the normal distribution of scores. Staff also believes this would be 

an appropriate time to evaluate the need for modifying the indices or labeling provision 

to reflect potentially increasing alternative fuels use in California. 

A more technical analysis of the global warming scoring system can be found in 

Appendix C: Technical Analysis. 

0

5

10

15

20

25

30

1 2 3 4 5 6 7 8 9 10

Global Warming Score Cleanest 

Number of Vehicle 

Certifications 
17 

VI. Proposed Environmental Performance Label Requirements 

A review of the existing Smog Index Label yielded many inconsistencies from 

manufacturer to manufacturer. As mentioned earlier in this report, the many variations 

of labels from one manufacturer to the next make it difficult for the consumer to 

compare vehicles. Appendix B shows a sampling of the many different variations of 

labels used by vehicle manufacturers. Based on this finding, staff decided to develop a 

uniform label that is easier to read and understand. To do this, staff decided to hire 

market research specialists to help. 

In March 2007, ARB staff contracted with two market research firms to conduct two 

focus groups to evaluate various components of the proposed emissions label. The 

label designs evaluated were borrowed from the U.S. EPA’s Green Vehicle Guide. The 

U.S. EPA developed its guide from performing numerous focus group tests over the 

years, and extensive market research. The purpose of our focus groups was to build 

upon the work already done by obtaining up to date information and receiving 

information from California-specific consumers. 

Two focus groups were conducted in Los Angeles, California, on March 28, 2007 to 

obtain reactions to draft labels. One group was comprised of eight people and one 

group was comprised of nine people. One criterion for selection was that participants 

must have purchased a new vehicle within calendar years 2006 or 2007. Group 

number one was comprised of smaller vehicle buyers and group number two was 

comprised of larger vehicle buyers. The reason behind this grouping was that 

consumers of similar vehicle sizes would feel more comfortable talking with each other. 

The following are some of the key findings of the vehicle emissions labeling focus 

groups13: 

• Size of label. Consumers preferred the proposed minimum emissions label size 

of 4” x 6”. The proposed minimum size was noticeable, simple and easy to read. 

The consumers felt the sample emissions label sized 1 1/4” x 4 1⁄4” placed on the 

Monroney label sized approximately 11” x 17”, was too small and that they would 

not read it. Consumers preferred the emission label to be separate and next to 

Monroney label so that one would not have to walk around to the other side of 

car to read it. Consumers also did not like the sample size 2 1⁄2” x 4” of the 

current smog index. They felt it contained too much information on too small of a 

label. 

• Color of the label border. Consumers liked the green border of the proposed 

emissions label. They felt green represents the environment, conservation and 

that color catches the eye. 

 

13 Vehicle Emissions Labeling Focus Groups Qualitative Research, April 6, 2007, prepared for the 

California Air Resources Board by ConsumerQuest, 
18 

• Global Warming Score title versus Greenhouse Gas Score title. Consumers 

strongly preferred Global Warming Score. It had more meaning and was to the 

point. 

• Cleanest versus Best as an additional indicator at end of scale. Consumers 

definitely preferred Cleanest. They felt it was more descriptive. 

• Scale representation. Consumers preferred solid black blocks over either a solid 

black bar or a gradient over the entire scale. The blocks were more definitive 

and gave another counting mechanism. Colored blocks, whether green or blue, 

were not important. From a distance consumers think more blocks would mean 

worse pollution. However, when consumers look closer they understand the 

scale with 10 being the cleanest. 

• Identification of agency or group responsible for the label. Consumers preferred 

California Environmental Protection Agency title with line over Air Resources 

Board versus just Air Resources Board. They felt it was more official looking and 

recognizable. 

• Consumers desired more information on how the scores were determined. To 

address this concern staff has added an additional statement to the bottom 

border of the proposed emissions label. 

Staff has used the information from these focus groups and other stakeholder input to 

develop the proposed design of the vehicle emissions label. These labeling 

requirements are prescriptive by nature and will require one label size and design to be 

used by all affected vehicle manufacturers. The design of the proposed vehicle 

emissions label is shown in figure VI-1. Figure VI-2 shows a flexible fuel vehicle with 

the “Alternate” fuel statement added. 
19 

Figure VI-1: California Environmental Performance Label 

Figure VI-2: California Environmental Performance Label with Flex-Fuel 

Vehicle Statement 

Figure VI-1 shows the Global Warming score on the left and the Smog Score on the 

right. The black boxes represent the score of the labeled vehicle. A triangle below the 

scale shows the score of an average vehicle for comparison purposes. It was clear in 

Alternate 

fuel 

statement 
20 

the focus groups that with the word “cleanest” under the 10 and with the statement: 

“Protect the environment, choose vehicles with the higher scores” vehicles with more 

black boxes were cleaner vehicles. The statement at the bottom of the label describes 

the impact of motor vehicles on smog and global warming. It also points consumers to 

the ARB’s www.DriveClean.ca.gov website which is a consumer oriented website with 

information about clean cars, alternative fuel and advanced technology vehicles. 
21 

VII. Economic Impacts 

A. Background 

Staff is proposing to revise the current smog index and add a global warming index as 

required by statute. The statute also requires, among other things, that the label 

contain the use of at least one color of ink other than black (at H&S § 43200.1(b)(2)(D)) 

and to seek input from consumer focus groups in determining the color, which resulted 

in the selection of the color green. 

Changes to the existing label, required by statute to include the additional global 

warming index information, necessitate an increase in the size of the label. 

Existing label sizes vary from 11⁄2 x 6 inches to 2 1⁄2 x 4 inches due to the current 

regulatory requirements for label content. Because of the amount of information 

already contained on the Smog Index Label and the fact that a new global warming 

index must be added, the size of the label must be increased to accommodate both 

indices. The findings of the consumer focus groups indicate that the new label size 

should be at least 4 x 6 inches. 

Since the statute requires using a color other than black for some portion of the 

label, the color green was chosen as it represents an environmental color to most 

consumers. Most vehicle manufacturers claim to be currently using only black ink 

printers. Adding a color to the label requires the manufacturers to either obtain preprinted color labels or replace their existing printers with color printers. Staff was 

able to analyze these costs and include them as an economic impact to the 

industry as a whole. 

B. Estimated Costs 

1. Label Size 

Part of the cost imposed on the manufacturers, based on these regulations, is 

associated with the increase in label size. Since the vehicle manufacturers are 

already required to print a Smog Index Label, staff reasoned that only minor costs 

would be incurred for setup, programming, or testing of the new label. 

The increase in label size does not appear to cause much concern for existing 

assembly line printers as these printers are already capable of printing labels up to 

6 inches wide and even Monroney labels up to 11 inches wide. The Monroney 

label is a federally mandated sticker affixed to the side window or windshield of 

every new passenger car and light-duty truck sold in the United States. The sticker 

includes consumer information such as the manufacturer's suggested retail price 

(MSRP), vehicle specifications, standard equipment and warranty details, optional 

equipment and pricing, and U.S. EPA city and highway fuel economy ratings. 
22 

Requiring a label to increase from 2.5 x 4 inches to 4 x 6 inches will add an 

estimated 0.8 cents per label based on minimum case package purchasing 

quantities of label feedstock. This cost will decrease as order quantities increase. 

Staff conservatively rounded this cost up to 1 cent per label which equates to 1 

cent per vehicle produced. 

Based on 2005 California vehicle sales data of approximately 2 million passenger 

cars, light-duty trucks, and medium-duty passenger vehicles, this would impose an 

industry wide annual operating cost increase of $20,000. Thirty vehicle 

manufacturers are currently certifying their products for sale in California. These 

manufacturers sell anywhere from 50 to 450,000 vehicles a year to California 

citizens. Based on market share, individual manufacturer costs would vary 

anywhere from $1 annually to $4,350 annually, but on average would equate to 

$667 per manufacturer per year. 

2. Label Color 

The addition of color also imposes a cost to the vehicle manufacturer. Regulating a 

specific color or colors by ARB would require the manufacturer to bear the cost of 

ordering pre-printed color labels to use as feedstock or bear the cost of replacing 

their existing black ink printers. Each solution to providing color labels is 

acceptable to staff, therefore an analysis of each solution follows. A more detailed 

and technical analysis can be found in Appendix C. 

Replace Existing Label Stock with Pre-Printed Color Label Stock 

Pre-printed color labels can be used as feedstock as long as all the information on 

the label presented in color is constant for all labels and the information being 

printed for each vehicle is in black. The new label, as recommended by staff, 

allows for this possibility. The per-label cost to go from a non-color feedstock label 

to color feedstock label is estimated to be about 5 cents per label. This equates to 

a 5 cents per vehicle cost increase. Based on 2005 California vehicle sales data of 

approximately 2 million passenger cars, light-duty trucks, and medium-duty 

passenger vehicles, this would impose a total annual operating cost increase of 

$100,000 across all manufacturers. Individual manufacturer costs would vary 

based on their actual production volume, but on average would equate to $3,333 

per manufacturer per year. 

Staff believes this option may be used for an extended period of time by small 

volume manufacturers but only for the first year or two by medium to large volume 

manufacturers. In discussions with the manufacturers, staff was given the 

impression that color labels are something the manufacturers have already been 

considering. Therefore, staff believes that manufacturers will upgrade existing 

black ink printers to color printers. 
23 

Replace Existing Black Ink Printers with Color Printers 

Staff expects manufacturers will replace existing black ink printers with color 

printers as existing printers wear out. New industrial laser-jet color printers cost 

about $6,000 each verses $5,000 for an equivalent black ink laser-jet printer. 

Therefore, staff reasoned that a manufacturer would only incur the incremental cost 

increase of $1,000 per printer. Staff reasoned that existing printers will continue to 

be used through the end of their useful lifecycle before being replaced or will be 

reutilized elsewhere in the organization. Either way, medium and large 

manufacturers will upgrade to color printers within the first three years of 

implementation. Staff estimated the range of printers required to be from as few as 

2 to as many as 52 per manufacturer, based on the number of assembly facilities 

and ports used by each manufacturer. The total number of printer replacements 

required for the industry as a whole is estimated to be 286 which equates to a total 

statewide incremental cost increase of $286,000 or about $10,000 per average 

manufacturer. 

This one time capital cost can be annualized over the 3-5 year life of a printer. 

Staff used a conservative replacement cycle of three years and a 5% real discount 

rate. Therefore the statewide 3-year annualized capital recovery cost will be 

$105,000 or about $3,500 per manufacturer. There is also an annual operational 

cost for switching from black ink cartridges to color ink cartridges. This annual cost 

was determined to be $120,000 statewide based on the estimated number of 

vehicles sold in California. This annual cost averages out to be $4,000 per 

manufacturer. Therefore the total annual cost per average manufacturer is the sum 

of the annualized one time capital cost and the annual operational cost which 

equates to $7,500. 

Cost Comparison 

The annual cost per average manufacturer ($7,500) for upgrading to color printers 

is clearly higher than the annual cost ($3,333) for ordering pre-printed color labels. 

Manufacturers sell anywhere from 50 to 450,000 vehicles a year to California 

citizens. The smaller manufacturers would be required to distribute the high capital 

and operational costs of using color printers over a relatively small number of 

production vehicles. Staff analyzed this scenario and estimated an annual cost to 

be as high as $20.00 per vehicle. The larger manufacturers can distribute these 

capital and operational costs over a much larger number of production vehicles 

bringing the annual cost to as little as 2 cents per vehicle. This is why staff 

believes larger vehicle manufacturers will choose to upgrade to color printers rather 

than use pre-printed color labels. 

C. Total Cost of Implementation 

The estimated maximum total annual cost to implement this regulation is calculated 

as the annualized capital cost to upgrade existing printers plus the annual 
24 

operating cost for increasing the label size and using color cartridges. For the 

industry as a whole this equates to $245,000 per year. The initial annualized 

capital cost for an average manufacturer to implement this regulation is estimated 

to be $3,500. The annual ongoing cost for increasing label size ($667) and using 

color cartridges ($4,000) for a typical manufacturer is estimated to be $4,667. 

Therefore the total annual cost, on average, to print the new larger color labels is 

estimated to be $8,167 ($3,500 + $4,667). This cost estimate will vary slightly by 

manufacturer depending on the actual number of assembly plants, ports of entry, 

printers required, and vehicles produced. 
25 

VIII. Estimated Environmental Benefits 

Staff expects that the proposed label will affect the purchasing choices of some 

vehicle buyers, however the degree to which this occurs is not known. If 

consumers buy vehicles with lower smog indices, smog emissions will be lower. If 

they buy vehicles with lower global warming indices, these emissions may also 

decrease. However, compliance with the current greenhouse gas emissions 

standards is based on a fleet average CO2Equivalent value by each manufacturer. 

Thus it may be possible that purchase of a cleaner vehicle will allow a 

manufacturer to produce additional vehicles with higher emissions (at presumably a 

lower cost). This would negate the effect of the label resulting in no change in 

greenhouse gas emissions. Over time however, staff expects that increased 

awareness of the benefits of purchasing a vehicle with low greenhouse gas 

emissions will result in market pressure to increase the number of models available 

with low emissions, with the result being manufacturer fleet wide emissions will be 

lower than required by regulation. The increased consumer awareness of vehicle 

greenhouse gas emissions may also encourage purchasers of other products to 

buy green. 
26 

IX. Issues 

A. Lead Time Requirements 

The vehicle manufacturers have expressed concerns with mandating a new label for all 

2009 MY vehicles. The first and foremost concern hinges around the fact that all 

vehicle manufacturers have the ability to introduce 2009 MY vehicles as early as 

January of 2008. Therefore, there is no way to label such early introduction vehicles 

with a newly regulated label if the regulation itself does not become law before these 

early vehicles are ready for market distribution. The vehicle manufacturers have also 

stated that a substantial lead time to implement a new label must be considered due to 

the time required to purchase new label stock or printers, restructure existing assembly 

procedures, and reprogram existing assembly line computer language to adapt to the 

new label format. The following summary illustrates the main concerns the vehicle 

manufactures stressed for changing or implementing a new vehicle labeling program. 

Staff solicited feedback from the vehicle manufacturers on actual implementation time 

once the regulation became law. Staff reviewed this feedback and provides the 

following overview of the implementation process and estimated processing time: 

• Label Database Set-up: Link emission scores with variable label values. (6 

months) 

• Label Design and Specification: Incorporate new design with existing labels and 

specify ink, durability, paper, etc. (1 month) 

• Label/Printer Procurement: Purchase new label feedstock and if necessary, new 

printers. (3 months) 

• Label Delivery and Implementation: Ship new label feedstock and printers to all 

assembly plants and ports and integrate new labeling process into assembly line. 

(1 month). 

Staff notes that the first process, Label Database Set-up, can be accomplished 

simultaneously with the other processes. However, the last three steps must be 

accomplished in succession. Therefore, the critical path for a new label implementation 

is estimated to be 6 months. Staff realizes that not all vehicle manufacturers operate 

identically and some variations to this process may occur during implementation, 

therefore staff recommends adding one additional month to the critical path in order to 

account for any variations. 

Based on this information, staff recommends allowing at least a 7-month lead time for 

implementation of the new label requirements once they are approved by the Office of 

Administrative Law. Staff estimates this will occur no later than February, 2008. 

Allowing for a 7-month implementation lead-time, staff recommends the new label take 

affect for all vehicles manufactured beginning October 1, 2008. 
27 

B. Label Size 

The vehicle manufacturers have also indicated concern about the proposed label size. 

They’ve stated that increasing the size of the label from what they currently produce to 

the proposed 4 x 6 inches may 1) impact the placement of the label and 2) create 

visibility problems for consumers wanting to test drive the vehicle. 

Some vehicle manufacturers place the current Smog Index Label on the vehicle as a 

separate label, sized approximately 2.5 x 4 inches, and other vehicle manufacturers 

place the current Smog Index, sized approximately 1.25 x 4.25 inches, on the Monroney 

label. A Monroney label, sized 11 x 17 inches includes the vehicle’s options, pricing, 

fuel economy information and other information. By incorporating the California Smog 

Index label onto the Monroney label the vehicle manufacturers have indicated the Smog 

Index would begin appearing in all 50 states and not just in California. Unfortunately, 

the Monroney label already contains a tremendous amount of consumer information 

and the available space for a new Environmental Performance Label is limited. Staff 

presented a sample of both current industry labels to consumer focus groups held in 

March 2007, Los Angeles, California. The focus groups felt the sample emissions 

labels were too small and that they would not notice or read it. Consumers preferred 

the emission label not be located on the Monroney label and preferred the proposed 

size of 4 x 6 inches. Staff concluded that maintaining a minimum label size of 4 x 6 

inches is required for consumer awareness and readability. 

The second issue related to a large label is the potential obstruction of driver vision for 

consumers during test drives. The primary concern is for vehicles without rear side 

windows such as two-seater sports cars and convertibles. Vehicle manufacturers 

recommended that a smaller label be authorized for use on such vehicles to limit the 

already obstructed driver vision from all other federally required labels. Staff does not 

recommend reducing the size of the label in such cases because the placement of the 

California label is not restricted to side windows only. Like the current Smog Index 

Label, the proposed 4 x 6 inch label (which is only expanding by an inch or two over the 

existing label) may also be placed on the windshield if there is no space available on the 

side windows. There is sufficient windshield area to place the label without interfering 

with the driver’s view. 
28 

X. Alternatives 

Thus far no alternative considered by the ARB has been identified that would be more 

effective in carrying out the purpose for which the action is proposed or would be as 

effective and less burdensome to affected private persons than the proposed action. 

The following alternatives were considered in reaching this conclusion. 

A. Alternative 1: Keep Existing Smog Index Label and Add a Global 

Warming Index 

One alternative would be to keep the existing Smog Index Label and expand it to add a 

global warming index. Staff felt this was not the best alternative for two reasons. First, 

the existing smog index is not well understood by consumers and focus group research 

suggests it needs revision. Second, the label does not have room for adding a new 

global warming index, and thus a second label for this index would have to be added. 

For these reasons a new, larger label is necessary.

Because this alternative requires expanding the existing label or adding a new label, 

staff assumed there is no cost difference between this alternative and the one staff is 

proposing. 

B. Alternative 2: Incorporate SmartWay Certification Mark 

U.S. EPA launched the air pollution and greenhouse gas scores on their Green Vehicle 

Guide in 2005 to provide consumers with emissions information that allows them to 

compare the environmental performance of vehicles. In January 2006, the SmartWay 

certification mark was added to the Green Vehicle Guide to highlight vehicles that are 

very good environmental performers relative to other vehicles. 

The SmartWay certification mark is achieved if a vehicle receives a minimum of a 6 on 

both the Greenhouse Gas Score and the Air Pollution Score and receives a combined 

score of 13 or higher. The SmartWay certification mark is shown in Figure X-1. 

Figure X-1: U.S. EPA SmartWay Certification Mark 

Staff reviewed the SmartWay program and included the SmartWay certification mark on 

the new label in focus group discussions. Response to SmartWay was positive and 

participants liked that the cleanest vehicles were identified using a logo. However ARB 

and U.S. EPA currently use different methods to determine global warming emissions. 

Staff recommends that the use of the SmartWay certification mark on the new label be 
29 

deferred until after the U.S. EPA’s and ARB’s methods for scoring global warming 

gases have been harmonized. 

The cost of including the SmartWay certification mark is no different than the estimated 

cost for the proposed label. Staff assumes that most manufacturers will upgrade to 

color printers therefore there would be no additional cost to print out the color 

SmartWay logo. 

C. Conclusion 

Having considered these alternatives, staff concludes that the proposed regulations are 

the best alternative because they allow staff to incorporate all previous market research 

and provide the consumers with a new Environmental Performance Label that will be 

noticed. 
30 

XI. References 

California Air Resources Board, Certification Data Reported to the California Air 

Resources Board, 2005. 

California Air Resources Board, Estimated Annual Average Emissions, 2005. 

California Air Resources Board, Letter to Steve Douglas, Director, Automobile 

Manufacturers and letter to John Cabaniss, Director, Association of International 

Automobile Manufacturers, February 28, 2007. 

California Energy Commission Staff Report, “Inventory of California Greenhouse Gas 

Emissions and Sinks,” 1990-1999. 

San Jose Mercury News, “Survey finds 81% worried about global warming,” 

April 12, 2007. 

Schwartz, Cory, “Vehicle Emissions Labeling Focus Groups Qualitative Research, 

Prepared for the California Air Resources Board, Consumer Quest, April 6, 2007. 

United States Environmental Protection Agency, www.epa.gov, “Green Vehicle Guide,” 

2007. 
A-1 

Appendix A – Regulation Language 

§ 1965. Emission Control, and Smog Index, and Environmental Performance Labels - 

1979 and Subsequent Model-Year Motor Vehicles. 

In addition to all other requirements, emission control labels are required by the 

California certification procedures contained in the “California Motor Vehicle Emission 

Control and Smog Index Label Specifications for 1978 through 2003 Model Year 

Motorcycles, Light-, Medium- And Heavy-Duty Engines And Vehicles,” adopted March 1, 

1978, as last amended September 5, 2003, which is incorporated herein by reference, 

the “California Exhaust Emission Standards and Test Procedures for 2001 and 

Subsequent Model Passenger Cars, Light-Duty trucks and Medium-Duty Vehicles,” 

incorporated by reference in §1961(d), the “California Exhaust Emission Standards and 

Test Procedures for 2004 and Subsequent Model Heavy-Duty Diesel-Engines and 

Vehicles,” incorporated by reference in §1956.8(b), the “California Interim Certification 

Procedures for 2004 and Subsequent Model Hybrid-Electric Vehicle Classes,” 

incorporated by reference in §1956.8(b) and (d), and the “California Exhaust Emission 

Standards and Test Procedures for 2004 and Subsequent Model Heavy-Duty Otto-Cycle 

Engines,” incorporated by reference in §1956.8(d). Smog index labels for passenger 

cars and light-duty trucks shall conform to the “California Smog Index Label 

Specifications for 2004 Through 2009 Model Year Passenger Cars and Light-Duty 

Trucks,” adopted September 5, 2003, as last amended {insert date}, which is 

incorporated herein by reference. Environmental Performance labels for passenger 

cars, light-duty trucks, and medium-duty passenger vehicles shall conform to the 

“California Environmental Performance Label Specifications for 2009 and Subsequent 

Model Year Passenger Cars, Light-Duty Trucks, and Medium-Duty Passenger Vehicles,”

adopted {insert date}, which are incorporated herein by reference. Motorcycles shall 

meet the requirements of Title 40 Code of Federal Regulations section 86.413-78, as last 

amended October 28, 1977, which is incorporated herein by reference. 

Note: Authority cited: Sections 39600, 39601, and 43200, and 43200.1, Health and 

Safety Code. Reference: Sections 39002, 39003, 43000, 43013, 43018.5, 43100, 

43101, 43102, 43103, 43104, 43107, and 43200, and 43200.1, Health and Safety 

Code. 

* * * * 
A-2 

State of California 

 AIR RESOURCES BOARD 

 CALIFORNIA SMOG INDEX LABEL SPECIFICATIONS 

FOR 2004 AND SUBSEQUENT THROUGH 2009 MODEL YEAR 

PASSENGER CARS AND LIGHT-DUTY TRUCKS 

Adopted: September 5, 2003 

Amended: {Insert Date} 

Note: This new document is an abbreviated version of the “California Motor Vehicle 

Emission Control and Smog Index Label Specifications” (the old Label Specifications 

document), which has been sunsetted after the 2003 model year. All of the tune-up 

label requirements in the old Label Specifications document applicable to light-, 

medium and heavy-duty vehicles and motorcycles are being incorporated into their 

respective test procedure documents effective with the 2004 model year, making a 

separate document covering the California tune-up label requirements no longer 

necessary. 

Effective with the 2004 model year, all of the smog index requirements in the old 

Label Specifications document have been moved to the new document shown here. 

Paragraph 1of this new document was previously contained in paragraph 11 of the 

old Label Specifications document; paragraphs 2, 3, and 4 were previously set forth 

in paragraphs 3.5, 3.5(c), and 3.5(d) respectively of the old Label Specifications 

document; and Appendix A in this new document is identical to Appendix A in the old 

Label Specifications document. 
A-1 

State of California 

AIR RESOURCES BOARD 

 California Smog Index Label Specifications 

1. Prohibition. The sale and registration in this state of any certified new 2004 

and subsequent through 2009 model passenger car or light-duty truck to which a smog 

index label has not been affixed in accordance with these procedures is prohibited. 

2. Requirements. A smog index label made of paper or plastic shall be securely 

affixed in a location specified in section 43200 of the Health and Safety Code. The smog 

index label shall display the smog index for the vehicle, as specified in section 3 below, and 

the fleet average smog index, which shall be referred to as “The Smog Index of the average 

new vehicle.” Every model-year, the fleet average smog index shall be updated on the 

smog index label as specified in section 4 below. The smog index label shall also include 

information to inform purchasers of the significance of the smog index. The smog index 

label shall take the form set forth in Appendix A of this document. An alternative label may 

be used if shown to yield equivalent clarity and if approved in advance by the Executive 

Officer. 

3. Smog Indices. The following smog indices shall apply to 2004 and

subsequent through 2009 model-year passenger cars and light-duty trucks 0-8500 lbs. 

GVW: 
A-2 

Enhanced 

Evap. 

2.0g/ diurnal 

+ hot soak 

test, 0.05 

g/mi – 

running loss 

test, at 

100,000 

miles 

PCs 0.5 g/ 

diurnal + hot 

soak test, 

0.05 g/mi – 

running loss 

test, at 

150,000 

miles 

LDTs < 6,000 

lbs. GVW 

0.65 g/ diurnal 

+ hot soak test, 

0.05 g/mi – 

running loss 

test, at 150,000 

miles 

LDTs 6,001-

8,500 lbs. 

GVW 

0.90 g/ diurnal 

+ hot soak test, 

0.05 g/mi - 

running loss 

test, at 150,000 

miles 

Evap. 

Exempt

LEV I 

Passenger Cars and Light-Duty Truck 1 (0-3750 lbs. LVW) 

LEV 1.00 0.92 0.93 0.94 0.80

ULEV 0.90 0.82 0.83 0.84 0.70

ZEV n/a n/a n/a n/a 0.00

Light-Duty Truck 2 (3751-5750 lbs. LVW) 

LEV 1.65 n/a 1.58 1.60 1.45

ULEV 1.51 n/a 1.44 1.45 1.30

ZEV n/a n/a n/a n/a 0.00

LEV II 

Passenger Cars; Light-Duty Truck 1 (0-3750 lbs. LVW); 

Light-Duty Truck 2 (3751 lbs. LVW – 8500 lbs. GVWR) 

LEV 0.57 0.49 0.50 (0.55)(1) 0.51 (0.57)(1) 0.36

ULEV 0.46 0.39 0.40 0.41 0.26

SULE 0.29 0.21 0.22 0.23 0.09

ZEV n/a n/a n/a n/a 0.00

 (1) The smog index in parentheses applies to the optional LEV II LEV standard. Up to 4% of 

a manufacturer’s light-duty truck 2 fleet with a maximum base payload of 2500 lbs. may be 

certified to a standard of 0.07 g/mi NOx at 50,000 miles. 

4. Fleet Average Smog Indices: The following fleet average smog indices shall 

apply to 2004 and subsequent through 2009 model-year passenger cars and light-duty 

trucks 0-8500 lbs. GVW: 

2004 2005 2006 2007 2008 2009 2010 and 

subsequent 

1.02 0.80 0.58 0.40 0.38 0.37 0.36 

5. Sunset: These specifications will sunset on September 30, 2008. All 

passenger cars and light-duty trucks manufactured on October 1, 2008 and thereafter must 

comply with the “California Environmental Performance Label Specifications” incorporated 

by reference in Title 13 California Code of Regulations § 1965.
A-3 

APPENDIX A 

SMOG EMISSIONS INFORMATION

The Smog Index of this vehicle is The Smog Index of the average new vehicle is 

 0.34 0.52 

 ▼ ▼

0.0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0......3.0 

◄CLEANER MORE POLLUTING►

Note: The Smog Index (SI) indicates the relative level of smog-forming pollutants 

emitted by the vehicle. The lower the SI, the lower the vehicle's emissions. 

 
A-4 

Note for commenters: The entire text of these proposed specifications is new. 

State of California 

 AIR RESOURCES BOARD 

 CALIFORNIA ENVIRONMENTALPERFORMANCE LABEL SPECIFICATIONS 

FOR 2009 AND SUBSEQUENT MODEL YEAR 

PASSENGER CARS, LIGHT-DUTY TRUCKS, AND MEDIUM-DUTY 

PASSENGER VEHICLES 

Adopted: {Insert Date} 

Note: These specifications shall take effect for all vehicles manufactured 

on October 1, 2008 and thereafter. On October 1, 2008, the Environmental 

Performance Label will replace the Smog Index Label; therefore vehicles 

manufactured on October 1, 2008, and thereafter will no longer require a Smog 

Index Label. Replacing the Smog Index Label with the new Environmental 

Performance Label prior to October 1, 2008, is acceptable. 
A-5 

State of California 

AIR RESOURCES BOARD 

 California Environmental Performance Label Specifications 

1. Prohibition. The sale and registration in this state of any certified new 2009 and 

subsequent model passenger car, light-duty truck, and medium-duty passenger vehicle 

manufactured on or after October 1, 2008 to which an Environmental Performance label 

has not been affixed in accordance with these procedures is prohibited. Affixing the 

Environmental Performance label to a vehicle manufactured before October 1, 2008 in 

lieu of the Smog Index Label is optional, however, each such label optionally affixed and 

not meeting all specifications herein, is prohibited. 

2. Requirements. An Environmental Performance label made of paper or plastic shall be 

securely affixed in a location specified in section 43200 of the Health and Safety Code. 

The Environmental Performance label shall display the global warming score for the 

vehicle, as specified in section 3 below. The Environmental Performance label shall 

display the smog score for the vehicle, as specified in section 4 below. The 

environmental performance label shall take the form set forth in section 7 and 

Attachment A of this document. 

3. Global Warming Score

(a) The global warming emissions value used to determine a vehicle’s score shall be 

the CO2Equivalent value as calculated according to Title 13, California Code of 

Regulations § 1961.1(a)(1)(B) and certified pursuant thereto. 

(b) The average new vehicle CO2Equivalent combined value is projected to be 360 

grams per mile and shall be assigned a score of 5. 

(c) The scores in the following table shall apply to all passenger cars and light-duty 

trucks 0-8500 pounds GVW and medium-duty passenger vehicles 8,500-10,000 

GVW: 
A-6 

Grams per mile 

CO2Equivalent combined 

Global Warming Score 

Less than 200 10 

200-239 9 

240-279 8 

280-319 7 

320-359 6 

360-399 5 

400-439 4 

440-479 3 

480-519 2 

520 and up 1 

4. Smog Score 

(a) The average new vehicle is assigned an Ultra-Low-Emission Vehicle (ULEV) 

certification and is assigned a score of 5. 

(b) The scores in the following table apply to 2009 and subsequent model-year 

passenger cars and light-duty trucks 0-8500 pounds GVW and medium-duty 

passenger vehicles 8,500-10,000 GVW: 

California Emissions Category - Federal 

Bins 

NMOG + NOx 

(g/mile) 

Smog Score 

ZEV – Bin 1 0.0 10 

PZEV 0.030 9 

SULEV – Bin 2 0.030 8 

Bin 3 0.085 7 

Bin 4 0.110 6 

ULEV 0.125 5 

LEV – Bin 5 0.160 4 

[LEV (option 1) – Bin 6] and [SULEV 

(MDPV)] 

0.190 – 0.200 3 

Bin 7 0.240 2 

ULEV (MDPV) – Bin 8a 0.325 1 

5. Bi-Fuel, Fuel-Flexible, and Dual-Fuel Vehicles. Notwithstanding Title 13, California 

Code of Regulations, Section 1961.1(a)(1)(B)(2)(a), the global warming score is based 

on exhaust mass emission tests when the vehicle is operating on gasoline. 

6. Environmental Performance Label format requirements. Detailed printing 

specifications are given in Attachment A of this part and apply to the provisions in this 

section. 
A-7 

(a) Environmental performance labels: 

(1) Must be rectangular in shape with a minimum size of 6 x 4 inches. 

(2) Must be outlined with a 1 point green line and have exactly a 0.5 inch section 

of green at the top and exactly a 1 inch section of green at the bottom. 

(b) Label information. The information on each label must meet the following 

requirements: 

(1) The color for the background as specified in Attachment A is PMS 347 C 

selected from the Pantone Matching System, solid coated swatch book. 

When printing in 4 color process the color build for the prescribed green is: 

Cyan 100 

Magenta 0 

Yellow 86 

Black 3 

(2) “Environmental Performance” is the title of the label. This title must be 

centered in the top section of green. See Attachment A for font and color 

requirements. 

(3) The phrase “Protect the environment, choose vehicles with higher scores:” 

must appear. This phrase must start exactly 2 picas 

(0.341 inches) from the left edge of label. See Attachment A for font and 

color requirements. 

(4) “Global Warming Score” is a title that must always appear over its respective 

scale. This title must start exactly 2 picas (0.341 inches) from the left edge. 

See Attachment A for font and color requirements. 

(5) The number for the Global Warming Score is variable and must appear over 

the block it represents on the global warming scale. Scores are determined 

in section 3. See Attachment A for font and color requirements. 

(6) The number 0 must appear on the left most side of the scale it is under. See 

Attachment A for font and color requirements. 

(7) “Average New Vehicle” must appear under both scales at the center point, 

which is marked by a triangle (item 15 in the style guide). See Attachment A 

for font and color requirements. 

(8) This statement must appear in the lower section of green on every label: 

“Vehicle emissions are a primary contributor to global warming and smog. 

Scores are determined by the California Air Resources Board based on this 

vehicle’s measured emissions. Please visit www.DriveClean.ca.gov for 

more information.” This statement must start exactly 2 picas (0.341 inches) 

from the left edge. The third row of text will end at the word “visit” and drop 
A-8 

down to a fourth line of text to allow room for item 17, the ARB logotype. 

See Attachment A for font and color requirements. 

(9) “higher scores:” must be bolded. See Attachment A for font and color 

requirements. 

(10) “Smog Score” must appear over its respective scale. It shall end exactly 1.5 

inches away from the right edge, and shall be flush left with its scale. See 

Attachment A for font and color requirements. 

(11) The number for the Smog Score is variable and must appear over the block 

it represents on the smog scale. Scores are determined in section 4. See 

Attachment A for font and color requirements. 

(12) Squares on the scales. Each square represents a single point on the scale. 

If a vehicle scores a 5, on a given scale, there will be five squares to 

represent that score. The first square must be flush left with the scale line 

(Attachment A item 13) and the tenth square must be flush right with item 13, 

therefore maintaining a distance of exactly 0.042 inches between squares, 

even when not all ten squares are present. See Attachment A for size and 

color requirements. 

(13) The scale line must appear on both scales and must be a consistent length. 

It must always be flush left with its respective title. See Attachment A for font 

and color requirements. 

 

(14) A number 10 must appear flush right with Attachment A item 13 of both 

scales. The number 10 represents the highest score a vehicle can get on 

each scale. See Attachment A for font and color requirements. 

(15) A triangle must appear at the center point of both scales representing where 

the average new vehicle falls on each scale. See Attachment A for font and 

color requirements. 

(16) The title “Cleanest” must appear flush right and underneath the 10 

(Attachment A item 14) on both scales. It must always be bold. See 

Attachment A for font and color requirements. 

(17) The California Environmental Protection Agency / Air Resources Board 

logotype must appear in the lower right hand corner, ending exactly 0.3 

inches from the right edge. See Attachment A for font and color 

requirements. 

(18) The Drive Clean website (www.DriveClean.ca.gov) should always appear 

in the Myriad Semi-bold within Item 8. See Appendix A for font and size 

specifications. 
A-9 

(19) This statement must appear for bi-fueled vehicles: “For bi-fuel vehicles, when 

using an alternative fuel, scores may improve. See

www.DriveClean.ca.gov”. 

(20) This statement must appear for fuel-flexible vehicles: “For flex-fuel vehicles, 

when using an alternative fuel, scores may improve. See 

www.DriveClean.ca.gov”. 

(21) This statement must appear for dual-fuel vehicles: “For dual-fuel vehicles, 

when using an alternative fuel, scores may improve. See 

www.DriveClean.ca.gov”. 

7. Severability. Each provision of this section is severable, and in the event that any 

provision of this section is held to be invalid, the remainder of these specifications 

remains in full force and effect. 
A-10 

ATTACHMENT A

ENVIRONMENTAL PERFORMANCE LABEL STYLE REQUIREMENTS 

1 Label Background 6 x 4 inches whole; top green: 6 x 0.5 inches; 

Bottom green: 6 x1 inches; green stroke: 1 point; Color: PMS 347 C 

2 font: Myriad Pro Bold; size: 25 points; color: knocked out of green 

(appears white) 

3 font: Myriad Pro Light; size: 15 points; color: Black 

4, 10 font: Myriad Pro Semi-bold; size: 14.4 points; color: PMS 347 C 

5, 11 font: Myriad Pro Semi-bold; size: 19.2 points; color: Black 

6, 14 font: Myriad Pro Light; size: 9.6 points; color: Black 

7 font: Myriad Pro Light; size/leading: 9/10.8 points; color: Black 

8 font: Myriad Pro Regular; size/leading: 11.3/13.5 points; color: knocked out of 

green (appears white) 

9 font: Myriad Pro Semi-bold; size: 15 points; color: Black 

12 size: 0.167 x 0.167 inches; color: Black; distance: 0.042 inches apart 

13 Scale Line: length: 2.05 inches; stroke: 1 point; color: Black 

15 size: 0.167 x 1.11 inches; color: Black 

16 font: Myriad Pro Semi-bold; size: 10.5 points; color: Black 

17 California Environmental Protection Agency / Air Resources Board logotype: 

Top Row: font: Myriad Pro Regular; size: 7 points (Title Case) 

Bottom Row: font Myriad Pro Regular; size: 12 points (All Caps) 

Line weight: 1 point; 

Color for all: knocked out of green (appears white)

18 www.DriveClean.ca.gov: 

Font: Myriad Pro Semi-bold 

Size: 12 points 

Color: knocked out of green (appears white) 

19 Flex-fuel phrase (variable element): font: Myriad Pro Light; size: 9 points; 

color: Black 
A-11 

Environmental Performance Label 
A-12 

California Environmental Protection Agency 

 AIR RESOURCES BOARD 

CALIFORNIA EXHAUST EMISSION STANDARDS AND TEST PROCEDURES FOR 2001 

AND SUBSEQUENT MODEL 

PASSENGER CARS, LIGHT-DUTY TRUCKS, AND MEDIUM-DUTY VEHICLES 

Adopted: August 5, 1999 

Amended: December 27, 2000 

Amended: July 30, 2002 

Amended: September 5, 2003 (corrected February 20, 2004) 

Amended: May 28, 2004 

Amended: August 4, 2005 

Amended: June 22, 2006 

Amended: [INSERT DATE OF AMENDMENT]

Amended: [INSERT DATE OF AMENDMENT]

Note: The proposed amendments to this document are shown in underline to indicate additions and 

strikeout to indicate deletions compared to the test procedures as adopted by the Board on 

June 22, 2006. Amendments to this document as adopted on March 22, 2007 as part of the 

“Rulemaking to Consider Amendments to California’s Emission Warranty Information 

Reporting and Recall Regulations and Emission Test Procedures,” are indicated by double 

underline to indicate additions and double strikeout to indicate deletions compared to the test 

procedures as amended on June 22, 2006. Existing intervening text that is not amended is 

indicated by “* * * *”. The amendments proposed here are non-substantive in that they 

impose no additional or changed requirements beyond those proposed for Section 1965, but 

are proposed here to maintain consistency. 
A-13 

NOTE: This document is incorporated by reference in sections 1960.1(k) and 1961(d), title 

13, California Code of Regulations (CCR). It contains the majority of the requirements 

necessary for certification of a passenger car, light-duty truck or medium-duty vehicle for 

sale in California, in addition to containing the exhaust emission standards and test 

procedures for these motor vehicles. However, reference is made in these test procedures 

to other ARB documents that contain additional requirements necessary to complete an 

application for certification. These other documents are designed to be used in conjunction 

with this document. They include: 

1. “California Exhaust Emission Standards and Test Procedures for 2005 and 

Subsequent Model Zero-Emission Vehicles, and 2001 and Subsequent Model Hybrid 

Electric Vehicles, in the Passenger Car, Light-Duty Truck and Medium-Duty Vehicle 

Classes” (incorporated by reference in section 1962, title 13, CCR); 

2. “California Evaporative Emission Standards and Test Procedures for 2001 and 

Subsequent Model Motor Vehicles” (incorporated by reference in section 1976(c), title 13, 

CCR); 

3. “California Refueling Emission Standards and Test Procedures for 2001 and 

Subsequent Model Motor Vehicles” (incorporated by reference in section 1978(b), title 13, 

CCR); 

4. OBD II (section 1968, et seq. title 13, CCR, as applicable); 

5. “California Smog Index Label Specifications for 2004 through 2009 Model Year 

Passenger Cars and Light-Duty Trucks” (incorporated by reference in section 1965, title 13, 

CCR); 

6. “California Environmental Performance Specifications for 2009 and 

Subsequent Model Year Passenger Cars, Light-Duty Trucks, and Medium-Duty Passenger 

Vehicles” (incorporated by reference in 1965, title 13, CCR);

67. Warranty Requirements (sections 2037 and 2038, title 13, CCR); 

78. “Specifications for Fill Pipes and Openings of Motor Vehicle Fuel Tanks” 

(incorporated by reference in section 2235, title 13, CCR); 

89. Guidelines for Certification of Federally Certified Light-Duty Motor Vehicles for 

Sale in California (incorporated by section 1960.5, title 13, CCR); and 

910. “California Non-Methane Organic Gas Test Procedures,” (incorporated by 

reference in section 1961(d), title 13, CCR). 

The section numbering conventions for this document are set forth in Part I, section A.3 on 

page A-2. 
A-14 

CALIFORNIA EXHAUST EMISSION STANDARDS AND TEST PROCEDURES 

FOR 2001 AND SUBSEQUENT MODEL 

PASSENGER CARS, LIGHT-DUTY TRUCKS AND MEDIUM-DUTY VEHICLES 

 The provisions of Subparts B, C, and S, Part 86, Title 40, Code of Federal 

Regulations, as adopted or amended on May 4, 1999 or as last amended on such other 

date set forth next to the 40 CFR Part 86 section title listed below, and to the extent they 

pertain to exhaust emission standards and test procedures, are hereby adopted as the 

“California Exhaust Emission Standards and Test Procedures for 2001 and Subsequent 

Model Passenger Cars, Light-Duty Trucks, and Medium-Duty Vehicles,” with the following 

exceptions and additions. 

PART I: GENERAL PROVISIONS FOR CERTIFICATION AND IN-USE 

VERIFICATION OF EMISSIONS 

* * * * 

C. General Requirements for Certification 

* * * * 

3. §86.1807 Vehicle Labeling 

* * * * 

3.3 California Labeling Requirements. 

3.3.1. In addition to the federal requirements set forth in §86.1807, labeling 

shall conform with the requirements specified in section 1965, title 13, CCR, and the 

“California Smog Index Label Specifications for 2004 through 2009 Model Year 

Passenger Cars and Light-Duty Trucks” and “California Environmental Performance 

Specifications for 2009 and Subsequent Model Year Passenger Cars, Light-Duty 

Trucks, and Medium-Duty Passenger Vehicles” as incorporated by reference in 

section 1965, title 13, CCR. In cases where there is conflict with the federal label 

specifications, the California requirements shall apply. 

* * * * 
A-15 

PROPOSED REGULATION ORDER 

Set forth below are the proposed amendments to title 13 of the California Code of 

Regulations. Proposed amendments are shown in underline to indicate additions and 

strikeout to indicate deletions. Amendments to §1961 that were adopted by the Board on 

March 22, 2007 as part of the “Rulemaking to Consider Amendments to California’s 

Emission Warranty Information Reporting and Recall Regulations and Emission Test 

Procedures,” but which have not yet been approved by the Office of Administrative Law are 

indicated in double underline to indicate additions and double strikeout to indicate deletions. 

The amendments proposed here are non-substantive in that they impose no additional or 

changed requirements beyond those proposed for Section 1965, but are proposed here to 

maintain consistency. 

§ 1961. Exhaust Emission Standards and Test Procedures - 2004 and Subsequent 

Model Passenger Cars, Light-Duty Trucks, and Medium-Duty Vehicles.

 Introduction. [No change.] 

 Sections (a) through (c). [No change.] 

(d) Test Procedures. The certification requirements and test procedures for 

determining compliance with the emission standards in this section are set forth in the 

“California Exhaust Emission Standards and Test Procedures for 2001 and Subsequent 

Model Passenger Cars, Light-Duty Trucks, and Medium-Duty Vehicles,” as amended June 

22, 2006 [insert date of amendment for the March 22, 2007 emission warranty rulemaking]

[insert date of amendment for this rulemaking], and the “California Non-Methane Organic 

Gas Test Procedures,” as amended July 30, 2002, which are incorporated herein by 

reference. In the case of hybrid electric vehicles and on-board fuel-fired heaters, the 

certification requirements and test procedures for determining compliance with the 

emission standards in this section are set forth in the “California Exhaust Emission 

Standards and Test Procedures for 2005 and Subsequent Model Zero-Emission Vehicles, 

and 2001 and Subsequent Model Hybrid Electric Vehicles, in the Passenger Car, LightDuty Truck and Medium-Duty Vehicle Classes,” incorporated by reference in section 1962. 

 Section (e). [No change.] 

Note: Authority cited: Sections 39500, 39600, 39601, 43013, 43018, 43101, 43104 and 43105, 

Health and Safety Code. Reference: Sections 39002, 39003, 39667, 43000, 43009.5, 43013, 43018, 

43100, 43101, 43101.5, 43102, 43104, 43105, 43106, 43204, and 43205, Health and Safety Code. 
B-1 

Appendix B – Example Existing Smog Index Labels 
B-2 
C-1 

Appendix C - Technical Analysis 

This Appendix focuses on the technical analysis ARB staff underwent to develop a new 

Smog and Global Warming scoring system for developing a new vehicle emissions label. 

This Appendix also focuses on the detailed analysis of the economic impact of replacing 

existing black and white printers with color printer to print color labels. 

 

A. Smog Score 

In developing a new Smog scoring system, staff looked at California’s LEV II regulations that 

will be in affect for all 2009 MY vehicles. Table C-1 represents the California LEV II 

emission certification limits for the 2009 MY and the current air pollution score used by the 

U.S. EPA. 

Table C-1: California Light-Duty Vehicle Emissions Standards for Air Pollutants 

California LEV II Program 

Emission Limits at Full Useful 

Life 

(120,000 miles) 

Maximum Allowed Grams per 

Mile 

Standard Model 

Year 

Vehicles 

NOx NMOG NMOG+NOx 

Current Air 

Pollution 

Score 

ZEV 2004+ PC, LDT 8500 lbs or less 0.00 0.000 0.000 10 

PZEV* 2004+ PC, LDT 8500 lbs or less 0.02 0.010 0.030 9.5 

SULEV 2004+ PC, LDT 8500 lbs or less 0.02 0.010 0.030 9 

ULEV 2004+ PC, LDT 8500 lbs or less 0.07 0.055 0.125 7 

LEV 2004+ PC, LDT 8500 lbs or less 0.07 0.090 0.160 6 

LEV option 1 2004+ PC, LDT 8500 lbs or less 0.10 0.090 0.190 5 

SULEV 2004+ MDV 8501-10,000 lbs 0.10 0.100 0.200 4 

ULEV 2004+ MDV 8501-10,000 lbs 0.20 0.143 0.343 3 

LEV 2004+ MDV 8501-10,000 lbs 0.20 0.195 0.395 2 

SULEV 2004+ MDV 10,001-14,000 lbs 0.20 0.117 0.317 3 

ULEV 2004+ MDV 10,001-14,000 lbs 0.40 0.167 0.567 2 

LEV 2004+ MDV 10,001-14,000 lbs 0.40 0.230 0.630 1 

* Vehicles certified as PZEV have a 150,000 useful life, zero evaporative emissions and a 

manufacturer 15 years/150,000 miles emissions warrantee. 

Table C-1 includes California certification limits for all vehicles up to 14,000 lbs. GVWR. 

However, AB 1229 only requires labels to be applied to vehicles up to 10,000 lbs. GVWR. 

Therefore the last three shaded rows of this table are not applicable to the labeling 

requirements. 

 

The applicable NMOG+NOx certification values range from 0.0 (g/mile) being the cleanest 

to 0.395 (g/mile) being the dirtiest. This 2009 range of certification levels is less than the 

current range used by the U.S. EPA Green Vehicle Guide for scoring air pollution; therefore, 
C-2 

a new scoring system must be developed. In keeping with the philosophy of harmonizing 

the new California scale with the U.S. EPA scale, staff took a look at the Federal certification 

levels for the 2009 model year. Table C-2 illustrates these values along with the current air 

pollution scores for each certification level. 

Table C-2: U.S. EPA Light-Duty Vehicle Emissions Standards for Air Pollutants 

Federal Tier 2 Program 

Emission Limits at Full Useful 

Life 

(100,000-120,000 miles) 

Maximum Allowed Grams per 

Mile 

Standard Model 

Year 

Vehicles 

NOx NMOG NMOG+NOx 

Current Air 

Pollution 

Score 

Bin 1 2004+ LDV, LLDT, HLDT, MDPV 0.00 0.000 0.000 10 

Bin 2 2004+ LDV, LLDT, HLDT, MDPV 0.02 0.010 0.030 9 

Bin 3 2004+ LDV, LLDT, HLDT, MDPV 0.03 0.055 0.085 8 

Bin 4 2004+ LDV, LLDT, HLDT, MDPV 0.04 0.070 0.110 7 

Bin 5 2004+ LDV, LLDT, HLDT, MDPV 0.07 0.090 0.160 6 

Bin 6 2004+ LDV, LLDT, HLDT, MDPV 0.10 0.090 0.190 5 

Bin 7 2004+ LDV, LLDT, HLDT, MDPV 0.15 0.090 0.240 4 

Bin 8a 2004+ LDV, LLDT, HLDT, MDPV 0.20 0.125 0.325 3 

Bin 8b 2004-2008 HLDT, MDPV 0.20 0.156 0.356 3 

Bin 9a 2004-2008 LDV, LLDT 0.30 0.090 0.390 2 

Bin 9b 2004-2008 LDT2 0.30 0.130 0.430 2 

Bin 9c 2004-2008 HLDT, MDPV 0.30 0.180 0.480 2 

Bin 10a 2004-2008 LDV, LLDT 0.60 0.156 0.756 1 

Bin 10b 2004-2008 HLDT, MDPV 0.60 0.230 0.830 1 

Bin 10c 2004-2008 LDT4, MDPV 0.60 0.280 0.880 1 

Bin 11 2004-2008 MDVP 0.90 0.280 1.180 0 

Again, the last eight shaded rows (Bin8b-Bin 11) in table C-2 will not apply to 2009 model 

year vehicles and the range of certification levels will be reduced to those identified in the 

non-shaded lines. 

Table C-2 represents eight certification levels for all vehicles manufactured up to 10,000 lbs. 

GVWR. The certification values for NMOG+NOx range from 0.0 (g/mile) being the cleanest 

to 0.325 (g/mile) being the dirtiest. Like the California table, this 2009 range of certification 

levels is less then the current range used by the U.S. EPA Green Vehicle Guide to score air 

pollution; therefore, a new scoring system must be developed. The best way to develop a 

new scoring system is to merge the California certification levels and the Federal 

certification levels into one table. Table C-3 represents these two certification tables 

merged together. 

It should be noted that in 2009, the applicable emission standards for California MDPVs are 

less stringent than the dirtiest federal Bin 8a standards as shown in table C-3. However, 

California regulations specify that when this occurs, the “cleaner federal vehicle” must be 

sold in California. Consequently, no 2009 MY MDPVs are expected to be certified to LEV 
C-3 

(MDPV) or ULEV (MDPV) standards in California. Therefore, only the certification levels 

identified in the non-shaded rows of Table C-3 would be applicable in the 2009 MY: 

Table C-3: 2009 Federal and California Combined Certification Levels 

Emissions Category NMOG + NOx 

(g/mile) 

ZEV – Bin 1 0.000 

PZEV – SULEV – Bin 2 0.030 

Bin 3 0.085 

Bin 4 0.110 

ULEV 0.125 

LEV – Bin 5 0.160 

LEV (option 1) – Bin 6 0.190 

SULEV (MDPV) 0.200 

Bin 7 0.240 

Bin 8a 0.325 

ULEV (MDPV) 0.343 

LEV (MDPV) 0.395 

After removing the bottom two rows, Table C-3 does provide 10 distinct certification levels 

so applying a scale from 1-10 would be simple. However, there are important differences 

between the SULEV and PZEV California certification requirements. First, the full-useful life 

for a SULEV is 120,000 miles versus 150,000 miles for a PZEV. Second, a PZEV must be 

certified to “zero” evaporative emissions standards and carry a 15 year/150,000 mile 

extended emissions warranty, which is not required for the SULEV standard. This is why 

the PZEV certification level is assigned a score of 9.5 in the current U.S. EPA air pollution 

scoring system. Staff therefore recommends that the PZEV certification level be treated as 

a distinct certification level and be assigned a score better than a vehicle certifying to 

SULEV standards. By separating the PZEV from the SULEV certification levels, the 

combined California and Federal certification table looks as shown in Table C-4. 

Table C-4: 2009 Federal and California Combined Certification Levels 

with PZEV Category 

Emissions Category NMOG + NOx 

(g/mile) 

ZEV – Bin 1 0.000 

PZEV 0.030 

SULEV – Bin 2 0.030 

Bin 3 0.085 

Bin 4 0.110 

ULEV 0.125 

LEV – Bin 5 0.160 

LEV (option 1) – Bin 6 0.190 

SULEV (MDPV) 0.200 

Bin 7 0.240 

ULEV (MDPV) – Bin 8a 0.325 
C-4 

Based on table C-4, there are 11 total certification levels so applying a simple 1-10 would 

require combining two levels or eliminating one level. One option is to find the two 

certification levels that are separated by the least amount and combine those two levels into 

one. This option makes sense if the separation is small relative to all other differences 

between certification levels or at least compared to the average separation between 

certification levels. Looking at table C-4, we see that the minimum separation between 

certification levels takes place between the LEV (option 1) – Bin 6 certification level at 0.190 

(g/mile) and the SULEV (MDPV) certification level at 0.200 (g/mile). This small difference of 

0.010 (g/mile) is relatively small compared to the average difference of 0.039 (g/mile). 

Therefore, combining these two certification levels into one would yield a Smog Score 

distribution with 10 levels as shown on Table C-5. 

Table C-5: 2009 Smog Score by Certification 

California Emissions Category – 

Federal Bins 

NMOG + NOx 

(g/mile) 

Possible 2009 

Smog Score 

ZEV – Bin 1 0.0 10 

PZEV 0.030 9 

SULEV – Bin 2 0.030 8 

Bin 3 0.085 7 

Bin 4 0.110 6 

ULEV 0.125 5 

LEV – Bin 5 0.160 4 

[LEV (option 1) – Bin 6] and 

[SULEV (MDPV)] 0.190 – 0.200 3 

Bin 7 0.240 2 

ULEV (MDPV) – Bin 8a 0.325 1 

Applying this proposed Smog scoring system to all 2007 MY California certification data 

yielded the distribution of Smog scores as shown on Figure C-1. 

The statistical average of smog-forming (NMOG + NOx) emissions calculated based on the 

emission standards to which 2007 MY vehicles certify is 0.139 (g/mile). This statistical 

average places the average vehicle available on the market today somewhere between a 

Smog score of 4 and 5. For the 2009 MY, it is expected that a statistically average vehicle 

sold in California will be a ULEV certification and will receive a score of 5. 

An alternate Smog scoring system can be developed using a straight line scale based on 

the range (dirtiest to cleanest) of emission levels and let the certification levels fall into 

whatever score they achieve. In this case the range is 0.325 – 0.0 (g/mile). Realizing that a 

Smog score of 10 must be reserved for a true zero emission vehicle, this leaves nine 

remaining Smog scores that must be divided up equally into an overall range of 0.325 

(g/mile). Therefore: 

0.325/9 = 0.036 increments/score 
C-5 

The straight line scale applied to the 2009 Certification levels and possible Smog Scores is 

shown on Table C-6. 

Figure C-1: Distribution of Smog Scores Based on 2007 Model Year Certifications 

Table C-6: Possible 2009 Smog Score by Straight Line Analysis 

California Emissions Category - 

Federal Bins 

NMOG + NOx 

(g/mile) 

Straight Line 

Scale 

Possible 2009 

Smog Score 

ZEV – Bin 1 0.000 0 10 

PZEV 0.030 0.001-0.036 9.5* 

SULEV – Bin 2 0.030 9 

 0.037-0.072 8 

Bin 3 0.085 0.073-0.108 7 

Bin 4 0.110 0.109-0.144 6 

ULEV 0.125 6 

LEV – Bin 5 0.160 0.145-0.180 5 

LEV (option 1) – Bin 6 0.190 0.181-0.216 4 

SULEV (MDPV) 0.200 4 

Bin 7 0.240 0.217-0.252 3 

 0.253-0.288 2 

ULEV (MDPV) – Bin 8a 0.325 >0.289 1 

* A Smog Score of 9.5 was given to vehicles certifying to the California PZEV standards 

based on the longer useful life, “zero” evaporative emissions requirements, and extended 

warranty for these vehicles compared to vehicles certifying to the SULEV standards. 

0

20

40

60

80

100

120

140

160

180

1 2 3 4 5 6 7 8 9 10

# Certifications

per Score

Smog Score 
C-6 

Staff looked at table C-6 and noticed two distinct issues. First, there are two instances 

where a single Smog score overlaps multiple certification levels. The Smog score of 4 

appears twice in the table as does the Smog score of 6. This overlap is due primarily to the 

small incremental difference between a few certification levels. For Example, the difference 

between the Federal Bin 4 certification level of 0.110 (g/mile) and the California ULEV 

certification level of 0.125 (g/mile) is only 0.015 (g/mile) allowing these two certification 

levels to achieve the same score of 6. The same holds true for the California LEV (option 1) 

certification level (which is also the Federal Bin 6 certification level) of 0.190 (g/mile) and the 

California SULEV (MDPV) certification level of 0.200 (g/mile). The relative difference 

between these two certification levels is only 0.010 (g/mile) allowing them both to achieve 

the same Smog score of 4. 

The second issue with this Smog score option is that some scores are not assigned to a 

certification level and would not appear on the new label. Looking at table C-6 staff noticed 

that the Smog scores of 8 and 2 are not assigned to a certification standard. This is due to 

the fact that there is a relatively large difference between certification levels where the Smog 

score of 8 and 2 do not appear. 

Applying this proposed Smog scale to the model year 2007 California certification data 

yielded the model based distribution of Smog scores as shown in Figure C-2. 

Figure C-2: Distribution of Smog Scores Based on 2007 Model Year Certifications 

In this case, the statistical average of 0.139 (g/mile) receives a score of 6 on the Smog 

scale. This average score of 6 on a scale from 1-10 did not seem appropriate as most 

consumers associate the number 5 as being the average on a scale from 1-10, 

Staff looked at the two distinct distributions of scores (figures 11.1 and 11.2) and noticed 

that they appear similar except for the simple change of smog score assignments on the 

0

20

40

60

80

100

120

140

160

180

1 3 4 5 6 7 9 9.5 10

# Certifications

per Score

Smog Score
C-7 

lower axis. Staff realizes that these distributions are for 2007 MY California certifications 

and will probably look a bit different for the 2009 MY California certifications as vehicle 

manufacturers continue to certify to higher standards. Therefore, the simplest and best way 

to assign smog scores that will allow for the continued increase of cleaner vehicles is to 

select the smog scale that is based on the certification analysis rather than the straight-line 

analysis of certification data. The certification analysis scale as shown on Table C-5 

provides a true 1-10 scoring for the entire range of certification levels and there are no 

potential for gaps (missing smog score numbers) in the scale. 

B. Global Warming Score 

In order to develop a scale for global warming emissions, the expected certification data for 

global warming emissions from each vehicle model must be known. This information is not 

required for the 2007 model year by ARB and therefore not all global warming gasses are 

available for analysis. However, staff was able to access the California certification data 

base for all 2007 Executive Order (EO) California certifications. After filtering out those 

vehicles that are not required to get an emissions label, the data contained 368 EO 

certifications. Of those certifications, 137 certifications voluntarily contained CO2 data and 

there were no certifications that contained CH4, N2O or A/C refrigerant data. The 137 

certifications that contained CO2 data represent a 37% sample. A 37% sample size is

adequate for a statistical analysis of the data as long as the sample size is random. A quick 

look at the auto manufacturers that provided CO2 data revealed that the sampling did 

appear to be random as 16 vehicle manufacturers did provide CO2 data and 14 vehicle 

manufacturers did not. 

Since some vehicle manufacturers did not voluntarily provide CO2 data, staff formally 

requested the voluntary submission of all global warming emissions – CO2, N2O, CH4, and 

A/C refrigerants – from the manufacturers in order to develop a more complete dataset. The 

response ARB received from the vehicle manufacturers was minimal. Three vehicle 

manufacturers voluntarily submitted the information as requested, one of which had already 

voluntary included CO2 data with the 2007 certification data. However, through this request, 

ARB staff was made aware of a Federal certification data spreadsheet available to the 

general public that contained CO2 information. This spreadsheet can be found at: 

www.epa.gov/otaq/cert/mpg/testcars/database/07tstcar.csv. 

Staff reviewed the Federal certification spreadsheet and found certification data for HC, CO, 

CO2, NOx, PM, as well as mile per gallon fuel economy (MPG). The Federal certification 

spreadsheet provided certification data for both city and highway testing values of these 

emissions. The Federal certification data did not provide certification data for N2O, CH4 or 

A/C refrigerants. Prior to developing a CO2Equivalent dataset for either the California or 

Federal Certification data, staff wanted to look at a direct comparison between the California 

dataset and the Federal dataset. In doing so, staff found that the information for similar 

makes and models of vehicles where very close but not identical. Therefore, a CO2

combined dataset was calculated and analyzed for both California and Federal databases 

using the 55% city and 45% highway driving ratio. 

Taking the additional global warming emission information provided by the three 

manufacturers and updating the California certification dataset; staff was able to increase 
C-8 

the sample size from 37% to 40%. With 40% of the certifications actually reporting CO2, 

staff was able to statistically evaluate the data with a 90% level of confidence that the 

sample size available would adequately represent the entire population. Table C-7 

represents the data distribution for both the California and Federal CO2 combined 

certification data. 

Table C-7: California and Federal CO2 Combined Data Distribution 

In Table C-7, the first California column represents CO2 combined data that was voluntarily 

provided by the automobile manufacturers and includes passenger cars, light-duty trucks 

and medium-duty passenger vehicles. Staff looked at the certification data available from 

the Federal database and noticed that the numbers are slightly different. This is because 

the federal database does not include data on medium-duty passenger vehicles (passenger 

vehicles from 8,500 lbs. to 10,000 lbs. GVWR). Therefore, staff developed another 

California dataset for CO2 combined certifications removing the data for all medium-duty 

passenger vehicles. The second column in Table C-7 above is the result. In comparing the 

last two columns, staff noticed that the information is extremely similar. The minimum for 

both California and Federal is almost identical. The maximum is somewhat less in California 

which indicates that California vehicles are typically cleaner. And the average for the 

Federal and California certification data is extremely close as well. Based on this 

comparison, ARB staff reasoned that although California had only 40% of the certification 

data for all 368 EOs issued, the 40% sample size was adequate to represent the entire 

population of California certified vehicles. 

Staff also tried to look at the contributions of N2O, CH4, and A/C refrigerants based on the 

limited feedback form the manufacturers to compare the CO2 combined certification values 

to the CO2Equivalent combined values. Of the three manufacturers that provided addition 

global warming emissions to ARB, only one manufacturer provided all four (CO2, N2O, CH4, 

and A/C refrigerant) emissions certification data as requested. This manufacturer, however, 

only has two California certifications on file for 2007. Another manufacturer provided only 

CO2 and CH4 emissions certification data and this manufacturer has 19 California 

certifications for 2007. The last manufacturer provided only CO2 data and staff incorporated 

this data into the California CO2 dataset. 

Because of the lack of data for N2O, CH4, and A/C refrigerants, staff decided there was not

enough information to factor these emissions into the development of a global warming 

scoring system at this time. Therefore, all analyses from this point on are predicated on the 

CO2 combined 

(g/mile) 

California

(with MDPV data)

California

(without MDPV data) Federal 

Minimum 130 130 133 

Maximum 874 570 662 

Range 744 440 529 

Average 358 355 348 
C-9 

analysis of 2007 CO2 data alone. Table C-8 represents only the California CO2 combined 

dataset and not the CO2Equivalent combined dataset. 

Table C-8: California 2007 CO2 Combined Certification Data 

CO2 Combined

(g/mile)

Minimum 130 

Maximum 874 

Range 744 

Average 358 

This distribution represents a range of CO2 emissions of 744 (g/mile) with a minimum of 130 

(g/mile) and a maximum of 874 (g/mile). Similar to the Smog scoring system, staff was able 

to develop a proposed global warming scoring system using an unbiased, straight line, 

equitable distribution of scores based on the entire range of CO2 emissions. By taking the 

range of 744 (g/mile) and equally dividing that range into 10 scores, we can determine the 

number of increments associated with each score. Since CO2 emission are not certified to 

specified individual levels, as in the case of smog forming emission, the use of a linear scale 

may be appropriate. This equates to: 

744/10 = 74 increments/score 

Table C-9 represents a possible global warming scoring system based on this analysis. 

Table C-9: Possible 2009 Global Warming Scores Based on CO2 Emissions 

Global 

Warming 

Score 

CO2 Grams 

per mile 

10 Less than 205 

9 205-279 

8 280-354 

7 355-429 

6 430-504 

5 505-579 

4 580-654 

3 655-729 

2 730-804 

1 805 and up 

Now applying these scores to the 2007 MY California certifications we can see how the 

certifications are distributed, Figure C-3 graphically illustrates this distribution. 
C-10 

In Figure C-3, staff realized that the scores are weighted more toward the high end of the 

scale. This means that the majority of the vehicles will be given scores of 7, 8, and 9. Also, 

the average global warming emissions of 358 (g/mile) receives a score of 7, which is not 

intuitive when looking at a scale from 1-10. Most consumers view the average as being in 

the middle of the scale or achieving a score of 5 on a 1-10 scale. Staff took a closer look at 

this data to see why the distribution was skewed to the high end of the scale. By breaking 

down the data set into actual vehicle classifications (i.e., passenger cars, light-duty trucks 

and medium-duty passenger vehicles), one can see the actual number of certifications in 

each class. Table C-10 illustrates the actual number of certifications by vehicle 

classification. 

Figure C-3: Distribution of Global Warming Scores Based on 2007 Model Year 

Certifications 

Table C-10: Distribution of California Certifications Based on Vehicle Classification 

Vehicle Certification 

Classification Number of Certifications Number of Certifications with Voluntary CO2 data 

Passenger Car 226 94 

Light-Duty Trucks 136 50 

Medium-Duty Passenger 

Vehicles 6 3 

Totals 368 147 

From Table C-10 staff realized that of the total 368 Executive Order Certifications on file for 

the 2007 MY, 61% are passenger cars, 37% are light-duty trucks, and only 2% are mediumduty passenger vehicles, Figure C-4 illustrates this distribution. 

0

5

10

15

20

25

30

35

40

45

50

1 2 3 4 5 6 7 8 9 10

# Certifications

per Score

Global Warming Score 

Avg. 
C-11 

PC

LDT

MDPV

Figure C-4: Distribution of Vehicle Classification Based on California EO 

Certifications. 

With 61% of all certifications being passenger cars, which typically produce less global 

warming emissions than light-duty trucks and medium-duty passenger vehicles, staff 

expected to see higher global warming scores for passenger vehicles. Therefore, with 61% 

of the certifications receiving the higher global warming scores, staff reasoned that the scale 

would be skewed to the high end. Figure C-3 justifies this scenario. ARB staff than decided 

to look at the certification data using a more statistical analysis to see how the data was 

distributed around the average of 358 (g/mile). ARB staff also wanted to perform a 

statistical analysis including standard deviations of the CO2 data that was available through 

the Federal certification database and compare these results. The federal database 

contained over 700 CO2 values which theoretically should provide a good comparison for 

the California certification data. Table C-11 represents the two statistical comparisons. 

Again, the first California column represents a statistical analysis including standard 

deviations of all CO2 data that was voluntarily provided by the automobile manufacturers 

and includes passenger cars, light-duty trucks and medium-duty passenger vehicles. In 

comparing the last two columns, one can see that the information is extremely similar. The 

average and the standard deviation for the Federal and California certification data are very 

close to being equal. The standard deviation only increases significantly when the addition 

of the MDPV data is introduced. Based on this finding, ARB staff decided to develop a 

global warming scale that represented a normal distribution of certifications. Realizing that 

the MDPV data contribution is only 2% of the entire certification dataset, staff decided to use 

a standard deviation that more closely represented the majority of certifications rather than 

the minority. 

61% 

37% 

2% 

Passenger 

Cars 

Light-Duty 

Trucks 

Medium-Duty 

Passenger 

Vehicles 
C-12 

Table C-11: Statistical Distribution of California and Federal CO2 Data 

By using the average of 360 (g/mile) and applying a standard deviation of 80 (g/mile) – the 

standard deviation we would expect to see given a fully populated data set, similar to the 

standard deviation of the Federal fully populated data set – a scale can be developed based 

on two standard deviations of the population that will account for 95% of all vehicle 

certifications. Those falling out side of the two standard deviations would be considered 

extreme and would achieve the “best” and the “worst” score. In the case of a scale from 

1-10, the “best” would be scored a 10 and the “worst” would be scored a 1 and the average 

would be scored a 5. All other scores would represent an equal division of the remaining 

range of possible CO2 emissions. This means that the remaining scores (2-9) will fall within 

two standard deviations of the average and should make up 95% of all certifications. 

Applying this principle to the dataset we would expect to see a normal distribution. Figure 

C-5 shows what a normal distribution would look like based on the number of standard 

distributions away from the average. 

Using the average of 360 (g/mile) and going out two standard deviations, 2 x 80 = 160 

(g/mile), ARB staff was able to set the extremes at 200 and 520 (g/mile). Therefore, any 

vehicle certifying to a global warming emissions level of 200 (g/mile) CO2 or less would get a 

score of 10. Likewise, any vehicle certifying to a global warming emissions level of 520 

(g/mile) CO2 or more would get a score of 1. All other scores would be given to vehicle 

certifications in the range between 520 and 200 which is 320 (g/mile). By taking the range 

of 320 (g/mile) and equally dividing that range into the remaining 8 scores (i.e., scores 2-9), 

we can determine the number of increments associated with each score. This equates to: 

320/8 = 40 increments/score 

Applying this scale to produce a global warming scoring system is illustrated in Table C-12. 

Applying this global warming score to the 2007 model California certification dataset yields 

the distribution of scores as shown in Figure C-6. Staff recognized that the scores are more 

normally distributed indicating a more precise distribution of global warming scores. The 

spike at the low end of the scale represents the addition of the medium-duty passenger 

vehicles to the certification data and should level out over time as those vehicles achieve 

reduced global warming emissions. 

CO2 combined 

(g/mile) 

California

(with MDPV)

California

(without MDPV) Federal 

Minimum 130 130 133 

Maximum 874 570 662 

Range 744 440 529 

Average 358 355 348 

Standard Deviation 101 81 76 
C-13 

Figure C-5: Diagram of a Normal Distribution of Scores 

Table C-12: Possible 2009 Global Warming Scores Based on CO2 Emissions 

Global 

Warming 

Score 

CO2 Grams 

per mile 

10 Less than 200 

9 200-239 

8 240-279 

7 280-319 

6 320-359 

5 360-399 

4 400-439 

3 440-479 

2 480-519 

1 520 and up 

Staff therefore recommends using a global warming score based on a statistical analysis of 

the global warming certification data. In the 2009 MY, per AB1493 (greenhouse gas 

regulation), vehicle certifications must include CO2Equivalent combined data from which a 

global warming score can be assigned. Staff recommends that the values depicted on 

Table C-12 be adopted for establishing the global warming scores used on the label. 

 200 360 520 
C-14 

Figure C-6: Distribution of Global Warming Scores Based on 2007 Model Year 

Certifications 

C. Color Printer Economic Impact 

This section focuses on the detailed economic impact imposed on vehicle 

manufacturers to increase the label size and upgrade to color printers. Through site 

visits and conversations with manufacturers, staff was able to identify the types of 

printers used for labeling purposes. Staff researched the replacement cost of new color 

printers and found that the average cost for an industrial laser jet color printer (e.g. HP 

9500) is $6,000. In addition, the cartridge replacement cost runs about $1,000 for all 

four cartridges, because most color printers use multiple (3 color and 1 black) 

cartridges. Each set of cartridges should print out 25,000 labels before all four may 

need replacement. Staff also researched the cost of an industrial black ink laser jet 

printer, comparable to the ones used by vehicle manufacturers today. The average 

cost of these printers is around $5,000 (e.g. HP 9000). However, the cost of a 

replacement black ink cartridge is around $270 per cartridge. Like the color cartridges, 

the black ink cartridges should print out around 25,000 - 30,000 labels before needing 

replacement. 

1. Total Statewide Costs to Comply with Regulation 

The estimated incremental cost increase of upgrading existing black ink label printers to 

color label printers is estimated to be $1,000 per printer. These label printers are only 

required at the point of final assembly. Staff estimated the total number of final 

0

5

10

15

20

25

30

1 2 3 4 5 6 7 9 10

# Certifications

per Score

Global Warming Score 

Avg. 
C-15 

assembly plants in North America to be 76. However, vehicles that are imported to the 

United States may have their labels printed and installed at the port. 

The State of California has 3 major ports of entry where vehicle manufacturers would 

most likely chose to import products. These ports are San Diego, Long Beach/Los 

Angeles, and San Francisco/Oakland. Staff did not account for ports in other states on 

the west coast or east coast because staff assumes that vehicles sold in California 

would most probably enter through one of the three major California ports for 

distribution. Discussions with the manufacturers indicated that typically, only two of the 

three major California ports are used to import vehicles into the state. Staff however, 

assumed a worst case scenario of each manufacturer using all three major ports in 

California. Smaller manufacturers building approximately 1,000 vehicles per year or 

less would most likely utilize only one, or at most, two port(s) of entry. Applying this 

scenario, staff than estimated the total number of facilities that print and apply vehicle 

labels to be 149. 

Staff also assumed that a manufacturer would have to purchase two printers for each 

assembly facility or port to print a label because one printer is typically used as an 

emergency backup. Likewise, smaller manufacturers building approximately 1,000 

vehicles per year or less would most likely utilize only one printer for labeling purposes 

because the annual production would not justify the need for a backup printer. 

Therefore, the industry wide total number of printer replacements is estimated to be 

286. At the $1000 incremental cost increase per printer, this equates to a total one time 

capital cost of $286,000 for the industry as a whole. The incremental cost increase per 

manufacturer ranged from $1,000 to $52,000 with an average cost of $9,533, or 

rounded up to $10,000. 

This cost represents a one-time capital cost to the manufacturers therefore staff applied 

a capital recovery factor to annualize these costs. Assuming the useful life of a printer 

to be 3-5 years, staff used a conservative 3-year replacement cycle and a 5% real 

discount rate to annualize the one-time capital investment. This equates to an 

annualized statewide cost to upgrade printers of $105,000 for the industry as a whole. 

The annualized cost per manufacturer ranged from $376 to $19,095 with an average 

cost of $3,500. 

Staff also assumed there is an operational cost difference between black ink and color 

printers. The differential cost between printers is assumed to be the cost difference 

between replacement cartridges in going from a black ink cartridge to color cartridges. 

The difference turns out to be approximately $730 and only occurs after 25,000 prints 

or 25,000 vehicles. Staff felt that 25,000 prints from one cartridge might be an 

optimistic value used by the cartridge manufacturer therefore staff used half this 

amount, 12,500 prints, as a replacement cycle. Applying this replacement cycle to the 

increased cost for color cartridges ($730), staff was able to calculate a per vehicle cost 

of 6 cents per vehicle. Therefore, multiplying this cost by the approximately 2 million 

annual vehicle sales equates to a $120,000 annual operating cost for the industry as a 

whole. The operating cost per manufacturer ranged from $43 to $62,200 annually, 

depending on production volume, with an average cost of $4,000. 
C-16 

The total annual cost to implement this regulation is calculated as the annualized 

capital cost to upgrade existing printers plus the annual operating cost for increasing 

the label size and using color cartridges. For the industry as a whole this equates to 

$245,000 per year or $735,000 over a 3-year period. The initial annualized capital cost 

for a typical manufacturer to implement this regulation is estimated to be $3,500. The 

annual ongoing cost for increasing label size and using color cartridges for a typical 

manufacturer is estimated to be $4,667. These cost estimates will vary slightly by 

manufacturer depending on the actual number of assembly plants, ports of entry, 

printers required, and vehicles produced. 
D-1 

Appendix D - Other Vehicle Labels 

The United States Environmental Protection Agency (U.S. EPA) in conjunction with the 

United States Department of Energy (U.S. DOE) has a comprehensive fuel economy rating 

and labeling procedure in place. These city and highway fuel economy values (in miles per 

gallon) have been the primary information source available for consumers to compare the 

fuel efficiency of vehicles they are interested in purchasing. 

Over the past several years there have been attempts to develop a label for passenger cars 

and light-duty trucks to encourage consumers to purchase more environmentally friendly 

vehicles. There have also been a number of studies using focus groups and market 

research to evaluate different types of vehicle labeling and ranking programs. Below is a 

description of some of the labels and ranking systems that have been developed and 

evaluated along with results of the market research. 

The U.S. EPA used focus groups to evaluate their SmartWay certification mark and Green 

Vehicle Guide rating system14. They found that environmental issues other than miles per 

gallon (MPG) were not key factors in the respondents’ purchasing decisions. However, 

participants were more willing to pay attention to emission labeling programs that include an 

easily understood rating system comparing vehicles. Another comment was that the label 

should compare similar vehicle classes in order to have credibility. 

Another study used focus groups to evaluate several government web sites that provided 

environmental information about vehicles15. These included the following web sites: 

• DOE and EPA web site www.fueleconomy.gov provides users with information about 

fuel economy as well as greenhouse gas emissions and criteria pollutants. 

• U.S. EPA web site www.epa.gov/greenvehicles offers similar information with the focus 

on criteria pollutants rather than fuel economy. 

• The American Council for an Energy-Efficient Economy (ACEEE) web site 

www.greencars.com, provides environmental, recycling and energy-conservation 

information. 

• The California Air Resources Board's Cleaner Car Buyer's Guide 

www.arb.ca.gov/msprog/ccbg/ccbg.htm lists California vehicles by emissions 

category. 

From the respondents, it was determined that the most useful/meaningful information 

tended to be in two areas: fuel economy and some overall rating of tailpipe emissions. 

Respondents tended to understand the issues of GHG or global warming more easily when 

such issues were correlated with familiar concepts such as fuel economy. The distinction 

between the impacts of different gases appeared to be difficult for people to understand and 

seemed somewhat unimportant since the respondents viewed all of the gases as harmful 

anyway. 

 

14 SmartWay Vehicle Qualitative Interviews - U.S. EPA by ICF Consulting and APRR August 23, 2002

15 Providing Consumers with Web-Based Information on the Environmental Effects of Automobiles. A 

Qualitative Research Report Based on Focus Groups in Knoxville, Tennessee and Los Angeles, California - 

Oak Ridge National Laboratory - June 2003
D-2 

Most respondents in this study preferred some kind of overall environmental score that (1) 

they could have faith in, (2) would be applicable across the country and across all vehicles, 

and (3) would be displayed on the new car sticker and adopted by magazines such as 

Consumer Reports. Respondents stated that the information needs to be presented in a 

way that consumers find simple and understandable. Respondents in all focus groups were 

drawn to the U.S. EPA web site's Green Vehicle Rating system, citing that designations like 

"superior" and simple 1-10 scale bar charts were easily understood. 

Europeans have been studying fuel economy labels for passenger cars16. A study by the 

Austrian Energy Agency produced a draft fuel economy label based on market research. 

This market research also found that the layout needs to be both simple and 

understandable. The study developed a draft label that offers a fuel economy comparison in 

the form of colored bars making up seven classes, well known from European appliance 

labels. From a wide variety of possible information that could be included on a car label, 

only information considered critical was included in the proposed design. With this label, 

consumers caught the core information (i.e., the fuel consumption of the car considered 

compared to others) at first glance. The consumer test found that the use of colors is very 

important for the impact of the label. This label would give vehicles an A – G rating 

depending on how their emissions compare to other vehicles. It is unlikely that 

manufacturers that receive an “F” on a number of vehicles would support this approach. 

Another study, Final Report on the Green Vehicle Market Alliance Project, published in 

March 2004, also evaluates environmental vehicle labeling17. In general, the study found 

that consumers have a good awareness of the existing fuel economy label and have some 

understanding of fuel economy insofar as it pertains to fuel consumption and driving costs, 

but they poorly link fuel economy to environmental impacts. Moreover, even when 

consumers consider vehicle environmental impacts, they tend to assign responsibility for 

addressing these issues to the government or automakers. In short, environmental factors 

were not clear to the participants and they did not understand that there were significant 

environmental differences between new vehicle models. 

 

16 Choosing cleaner cars: the role of labels and guides - Department of Transport. Lecture Fuel 

economy labeling for cars - Presentation Stefphan Fickl - Austrian Energy Agency

17 Final Report on the Green Vehicle Market Alliance Project, Prepared for Oak Ridge National Laboratory 

by John M. Decicco, Environmental Defense, March 2004