Fuel Economy Label Proposal

October 5, 2010

1
Background

 Develop a new fuel economy label that 

helps consumers choose more efficient 

and environmentally friendly vehicles 

 Develop new labels for advanced technology 

vehicles (PHEVS and EVs) and update current label 

(conventional)

 Propose additional label information beyond MPG 

and annual fuel cost

 Propose one label that meets both NHTSA and EPA 

statutory requirements

2
Statutory Obligations

3

New Fuel Economy Label

Metrics Under Consideration

Includes Primary EPA Requirements under the 

Energy Policy and Conservation Act (EPCA)

49 USC 32908(b)

New Label Requirements

NHTSA Requirements under the Energy 

Independence and Security Act (EISA)

49 USC 32908(g)

Label affixed to all new vehicles sold in the U.S. Label to be affixed to all new vehicles sold in 

the U.S.

Fuel Economy and potentially consumption

Estimated fuel cost and potentially savings

Vehicle performance information:

1. Fuel economy

2. Greenhouse gases

3. Other emissions over the useful life of 

automobile

Greenhouse gas value and/or environmental 

emissions rating

Rating system to allow for vehicle comparison, 

including:

1. Highest fuel economy

2. Lowest GHG emissions

32908(g) also requires NHTSA to develop a consumer education campaign, and that EPA develop 

the criteria that NHTSA will use for the vehicle performance information.

EPCA also requires gas guzzler tax and other info.
Key Elements of Joint Proposal

 EPA and NHTSA Co-proposing two labels

 All Labels include the following

 Fuel economy, annual fuel cost, and fuel consumption (gal/100 mi)

 CO2 emissions (grams/mile)

 Ratings across all vehicles for: fuel economy, CO2, and other emissions 

 Fuel economy of comparable vehicles

 Reference website with additional data and tools to customize for individual 

consumer

 Smartphone interactive tool

 Advanced Technology Labels

 Range for EVs and PHEVs

 For PHEVs, show information reflecting all-electric, blended (electric + gasoline), 

and gasoline-only operation

 Propose Mpg-equivalent, instead of mpg-gasoline + kw-hr electricity

 Tailpipe only emissions – electric operation reported @ 0 grams CO2/mile

4
Proposal Supported by Market Research 

and Public Input

 Stakeholder Input

 Market Research

 Focus Groups

 2 groups per city: Atlanta, Chicago, Seattle, Houston

 3 phases in each city

 Current label and purchase process, new metrics

 Metrics for advanced technology vehicles

 Bringing it all together

 Expert Panel

 On-Line Survey

 underway

 Public Participation

 Comments

 Hearings 5
Stakeholder Input

 Comments received as part of light duty 

vehicle GHG/CAFE rule

 Support for label undergoing revisions 

 Additional metrics beyond MPG supported

 Entry of PHEVs/EVs require new metrics but must be simple 

and understandable for consumers 

 Selected metrics for label should allow for direct consumer 

comparison of conventional and advanced technology vehicles

 E.g., annual fuel cost and GHG metric

 But--no consensus on overall label approach or specific 

metrics

6
Focus Groups: Key Findings

 Create immediate first impression

 Clearly identify vehicle technology (conventional, EV, PHEV)

 Be easy and quick to read and understand

 Utilize color

 Chunk information to allow people to deal with “more information”

 Be consistent in content and design across technologies

 Allow for comparison across technologies

 Make it easy to identify the most fuel efficient and environmentally friendly 

vehicles

Participants Want:

For Conventional Vehicles

 City/Hwy MPG separately

 OK to add Consumption metric (such as Gal/100 miles)

 Annual Cost 

For EVs and PHEVs 

 Cost, MPG or MPGe information (not kw-hrs) 

 Comparison information across all technologies 

 Electric driving range & battery charging time

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Expert Panel Recommendations 

 Draft labels were not “designed;” they were negotiated

 Rejected working drafts developed by focus groups

 Consumers

 Like it simple (Fewer, bigger, better)

 Don’t act on details

 Respond to emotional appeals

 Content

 Remember reality of very short label viewing time

 Divide into ‘above the fold’ (simple) and ‘below the fold’ (details)

 Recommended Label elements 

 Use letter grade score - include explanation of elements included 

in the grade

 Use URL that incorporates a message

 Include a Smartphone interactive (QR code) 

 Use cost savings information- a strong motivator

 Include all legal requirements

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Label Methods and Assumptions

 Values for energy consumption, fuel economy, and CO2 

emissions

 Rely on the standard federal test procedures that are used today for 

fuel economy labeling

 Electric vehicles use the same procedures, except they are tested until the battery is 

empty

 Plug-in hybrids are tested under two sets of conditions: full battery and empty battery

 Values for each condition can be merged using a “utility factor,” which combines the 

two values based on the percentage of miles the vehicle is expected to spend in 

each condition

 Seeking comment on which values to present on the labels

 MPGequivalent provided for electric operation, to allow comparison across vehicles

 Conversion from kw-hrs to MPGe based on 33.7 kw-hrs/gallon

 Values for fuel cost

 Assume 15,000 annual miles, national average fuel costs for gasoline, 

diesel, and electricity

 Example labels assume $2.80/gallon, 12 cents/kw-hr—will be updated annually

 Will be updated annually based on projections from DOE

 Consistent with current approach for fuel cost values on the label

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Label 1: Overall Letter Grade

 Based on tailpipe CO2/fuel consumption

 Directly reflects environmental goal—Each grade reflects same CO2 increment

 Relatively stable system over time--grading scale will change with median vehicle

 Current fleet mix yields a bell-shaped curve

 Any vehicle type is eligible to earn any grade

 No limitations based on vehicle class, fuel type, or technology type

 Using + and – gives more information to the consumer

Rating Distributions

Based on 2010 data plus anticipated 2011 EVs and PHEVs

2 12

117

195

423

697

450

98

14 2 1

D D + C - C C + B - B B + A - A A +

Rating Distribution: Number of Models

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Letter Grade

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CO2 g/mi MPGe Sample Vehicles

A+ 0-76 117 and up Nissan Leaf (projected)

A 77-152 59-116 Chevy Volt (projected), Toyota Prius PHEV (projected)

A- 153-229 40-58 Toyota Prius, Honda Civic Hybrid, Ford Fusion Hybrid

B+ 230-305 30-39 Nissan Altima Hybrid, Ford Escape Hybrid, Honda Civic, Toyota Yaris, Toyota 

Corolla, Chevy Cobalt, VW Golf

B 306-382 24-29 Hyundai Elantra, Nissan Sentra, Ford Focus, Toyota Scion, Mazda Tribute, 

Toyota RAV4, Nissan Cube, Toyota Matrix, Toyota Camry, Chevy HHR, Honda 

Accord, Ford Fusion, Jeep Patriot, Pontiac G6, Chrysler Sebring

B- 383-458 20-23 Mazda 5, Nissan Rogue, Mitsubishi Eclipse, Toyota Avalon, BMW 328i, Chevy 

Impala, Chevy Silverado Hybrid, Hyundai Santa Fe, Mitsubishi Lancer, Porsche 

Boxster, Subaru Forester, Toyota Tacoma, Honda Odyssey, Toyota Highlander

C+ 459-535 18-19 Acura MDX, , BMW X3, Dodge Caravan, Ford Crown Vic, Cadillac CTS, Buick 

LaCrosse, Chrysler Town and Country, Ford Mustang, Honda Pilot, GMC Canyon, 

Kia Sedona, Jaguar XJ, Mitsubishi Eclipse, Toyota 4Runner, GMC Sierra, Ford 

Ranger, Toyota Sienna, Chevy Tahoe, Jeep Grand Cherokee

C 536-611 16-17 BMW 750i, Chevy Corvette, Ford Explorer, Ford F150, Toyota Tundra, Aston 

Martin DB8, Dodge Charger

C- 612-688 14-15 Chevy Express, Land Rover Range Rover, Lexus LX 570, Maserati Quattroporte, 

Nissan Titan, BMW M5

D+ 689-764 13 Ferrari Fiorano, Mercedes-Benz Maybach

D 765 and up 12 and down Ferrari Scaglietti

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Co-Proposal: Label 1

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Co-Proposal: Label 1
Co-Proposal: Label 2

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15

Alternative Label