COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission Commission report under Article 12(3) of Regulation (EU) 2019/631 on the evolution of the real-world CO2 emissions gap for passenger cars and light commercial vehicles and containing the anonymised and aggregated real-world datasets referred to in Article 12 of Commission Implementing Regulation (EU) 2021/392
Date: 2024-03-18
Institutions: Directorate-General for Climate Action, European Commission
Subjects: data collection, energy consumption, environmental monitoring, greenhouse gas, light-duty vehicle, motor car, motor fuel, motor vehicle pollution, pollution control measures, reduction of gas emissions

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 18.3.2024  SWD(2024) 59 final  COMMISSION STAFF WORKING DOCUMENT   Accompanying the document Report from the Commission Commission report under Article 12(3) of Regulation (EU) 2019/631 on the evolution of the real-world CO2 emissions gap for passenger cars and light commercial vehicles and containing the anonymised and aggregated real-world datasets referred to in Article 12 of Commission Implementing Regulation (EU) 2021/392       {COM(2024) 122 final}  
 
 
TABLE OF CONTENTS 

GLOSSARY ............................................................................................................ 3 

1. 

Introduction ..................................................................................................... 4 

2.  Data sources .................................................................................................... 7 

3.  Data processing ............................................................................................... 9 

3.1.  Basic quality checks on submission ...................................................... 9 

3.2.  Linking with the 2021 WLTP data ...................................................... 10 

3.3.  Unmatched vehicles ............................................................................. 11 

3.4. 

Inconsistencies in fuel type/mode ....................................................... 12 

3.4.1.  Vehicles out of scope ............................................................. 12 

3.4.2. 

Inconsistencies  in  reported  fuel  types,  fuel  modes  or  OVC-
HEV specific parameters ....................................................... 12 

3.5.  Vehicles with low mileage .................................................................. 13 

3.6.  Removing remaining outliers from the real-world data set ................. 16 

3.6.1. 

Implausibly high distance driven ........................................... 17 

3.6.2.  Very low or high fuel consumption (ICEVs/NOVC-HEVs) . 18 

3.6.3.  OVC-HEV parameter outliers ............................................... 19 

3.7.  Flex-fuel ethanol vehicles (E85) ......................................................... 19 

3.8.  Missing WLTP emission values .......................................................... 20 

3.9.  Overview of data processing steps ...................................................... 20 

4.  Final 2021 real-world dataset ........................................................................ 21 

5.  Calculation of average real-world fuel consumption and CO2 emission values 
and comparison with the WLTP values ........................................................ 23 

5.1.  Calculation of real-world fuel consumption (l/100 km) for each vehicle
 ............................................................................................................. 24 

5.2.  Calculation  of  the  real-world  CO2  emissions  (g  CO2/km)  for  each 
vehicle .................................................................................................. 24 

5.3.  Calculation  of  the  average  real-world  and  WLTP  fuel  consumption 
(l/100 km) for each manufacturer, split by powertrain/fuel type of the 
vehicles ................................................................................................ 24 

5.4.  Calculation of the average real-world and WLTP CO2 emissions (g/km) 
for each manufacturer, split by powertrain/fuel type .......................... 25 

5.5.  Comparison between real-world data and WLTP data and calculation of 
the “gap” .............................................................................................. 25 

5.6.  Calculation of WLTP fuel consumption values .................................. 26 

6.  Results ........................................................................................................... 27 

 
 
6.1.  Fleet-level assessment ......................................................................... 27 

6.1.1.  Representativeness  of  the  vehicles  in  the  final  real-world 
dataset compared to the 2021 new vehicle fleet .................... 27 

6.1.2.  Comparison for M1 vehicles ................................................. 30 

6.1.2.1.  Fuel Consumption ................................................. 30 

6.1.2.2.  CO2 emissions ....................................................... 32 

6.1.2.3.  Vehicle mass .......................................................... 35 

6.1.3.  N1 vehicles: Fuel Consumption and CO2 emissions ............. 37 

6.2.  Manufacturer-level assessment ........................................................... 38 

6.2.1.  Coverage of the vehicle manufacturers 2021 fleet in the final 
real-world dataset .................................................................. 38 

6.2.2.  CO2 emissions and fuel consumption gap ............................. 41 

6.2.2.1. 

ICEVs and NOVC-HEVs ....................................... 41 

6.2.2.2.  OVC-HEVs............................................................ 42 

6.3.  Country-level assessment .................................................................... 43 

6.3.1.1. 

ICEVs and NOVC-HEVs ...................................... 43 

6.3.1.2.  OVC-HEVs............................................................ 45 

ANNEX A 

LIST OF MANUFACTURERS ............................................ 47 

ANNEX B 

CONVERSION 
FUEL 
CONSUMPTION TO CO2 EMISSIONS AND FROM WLTP 
CO2 EMISSIONS TO FUEL CONSUMPTION ................... 49 

REAL-WORLD 

FROM 

ANNEX C 

ELECTRIC  ENERGY  CONSUMPTION  AND  UTILITY 
FACTOR (PLUG-IN HYBRID ELECTRIC VEHICLES) ... 51 

1.  Real-world and CoC electric energy consumption values ............................ 51 

2.  Utility factor (%) ........................................................................................... 53 

2.1.  Calculation methodologies .................................................................. 53 

2.2.  Calculation methodology results ......................................................... 55 

ANNEX D 

AGGREGATED DATA PER MANUFACTURER ............. 57 

1.  M1 vehicles ................................................................................................... 57 

1.1.  Manufacturers reporting over 20% of registered vehicles .................. 59 

1.2.  Manufacturers reporting 10-20% of registered vehicles ..................... 64 

1.3.  Manufacturers reporting 5-10% of registered vehicles ....................... 67 

1.1.  Manufacturers reporting 1-5% of registered vehicles ......................... 76 

1.1.  Manufacturers reporting < 1% of registered vehicles ......................... 93 

2.  N1 vehicles .................................................................................................. 102 

2 

 
Glossary 

ABBREVIATION  DEFINITION 
CD 

‘Charge depleting operation’, meaning, for OVC-HEVs, the state of 
vehicle operation when the Rechargeable Electric Energy Storage 
System (REESS) state of charge (SOC) is higher than the charge 
sustaining target SOC value and the intent of the vehicle control system 
is to deplete the SOC from a higher level down to the charge sustaining 
target SOC value. 
'Driver-selectable charge increasing operation’, meaning, for OVC-
HEVs, the operation condition in which the driver has selected a mode 
of operation, with the intention to increase the REESS state-of-charge. 
‘Certificate of Conformity’. 
‘Charge Sustaining operation’, meaning, for OVC-HEVs, the state of 
vehicle operation when the REESS SOC may fluctuate but the intent of 
the vehicle control system is to maintain, on average, t he current state of 
charge. 
A mixture of petrol and ethanol up to an 85 per cent ethanol blend. Flex 
fuel ethanol vehicles can run on petrol, or E85. 
Fuel consumption. 
Fuel Cell Electric Vehicle, meaning a vehicle equipped with a 
powertrain containing exclusively fuel cell(s) and electric machine(s) as 
a propulsion energy converter. 
Internal Combustion Engine Vehicle. 
‘New European Driving Cycle’, a driving cycle designed to determine 
the emission levels of car engines and fuel economy of light duty 
vehicles. 
‘Natural Gas Vehicles’, an alternative fuel vehicle that uses compressed 
natural gas or liquefied natural gas. 
‘Not-Off-Vehicle Charging Hybrid Electric Vehicle’, meaning a hybrid 
electric vehicle that cannot be charged from an external source. 
‘On-Board Diagnostics’ system on the vehicle. 
‘On-Board Fuel and/or energy Consumption Monitoring’ devices, 
meaning any element of design, either software and/or hardware, which 
senses and uses vehicle, engine, fuel and/or electric energy parameters to 
determine and make available this information, and store the lifetime 
values on board the vehicle. 
‘Over-the-air’ transmission or direct data transfer from vehicles. 
‘Off-Vehicle Charging Hybrid Electric Vehicle’, also known as plug-in 
hybrid electric vehicle, meaning a hybrid electric vehicle that can be 
charged from an external source. 
‘Pure electric vehicle’, also known as Battery Electric Vehicle (BEV). 
‘Periodic Technical Inspection’. 
‘Rechargeable Electric Energy Storage System’, is a battery or other 
system that provides electric energy for propulsion of vehicles. 
‘State Of Charge’ of the REEESS 
‘Vehicle Identification Number’. 
‘Worldwide harmonised Light vehicles Test Procedures’. 

3 

CI 

CoC 
CS 

E85 

FC 
FCEV 

ICEV 
NEDC 

NGVs 

NOVC-HEV 

OBD 
OBFCM 

OTA 
OVC-HEV 

PEV 
PTI 
REESS 

SOC 
VIN 
WLTP 

 
 
1. 

INTRODUCTION 

Road transport is responsible for about one fifth of the European Union’s (EU) greenhouse 
gas emissions. Within  road transport  emissions,  light-duty  vehicles (passenger cars  and 
light commercial vehicles) are responsible for around 70% of the total (1).  

In order to  achieve the objective of a climate-neutral  EU by 2050, the European Green 
Deal states that a 90% reduction in greenhouse gas emissions from transport compared to 
1990 levels will be needed (2). Regulation (EU) 2019/631 setting out the CO2 standards 
for  new  passenger  cars  and  light  commercial  vehicles  (3)  is  one  of  the  key  policy 
instruments to achieve this goal. It sets EU fleet-wide and manufacturer-specific targets 
for  the  average  CO2  emissions  of  new  passenger  cars  (M1  vehicles)  and  new  light 
commercial vehicles (N1 vehicles, i.e. vans) first registered in the EU. The effectiveness 
of the Regulation in reducing CO2 emissions, as well as the robustness of the CO2 emission 
monitoring  system,  depends  on  how  well  those  official  test  values  represent  the  ‘real-
world’ emissions of vehicles out on the road. This representativeness is therefore important 
for the environmental integrity, transparency and reliability of the monitoring system, and 
therefore also for consumers’ trust. 

The official CO2 emission and fuel consumption values of a car or a van, as indicated on 
its  certificate  of  conformity  (‘CoC’),  are  based  on  the  type-approval  values  determined 
through  the  Worldwide  harmonised  Light  vehicles  Test  Procedure  (‘WLTP’)  set  out  in 
Regulation (EU) 2017/1151 (4) and in UN Regulation No 154 (5). Since 2017, the WLTP 
has replaced the New European Driving Cycle (NEDC) procedure (6), as the NEDC was 
found  to  be  no  longer  adequately  reflecting  the  emissions  of  vehicles  used  on  the  road 
(‘real-world’ emissions).  

In the case of plug-in hybrid electric vehicles, the CO2 emissions and fuel consumption 
values determined through the WLTP are weighted by a utility factor to reflect the share 

(1)   Data  viewer  on  greenhouse  gas  emissions  and  removals,  sent  by  countries  to  UNFCCC  and  the  EU 
Greenhouse  Gas  Monitoring  Mechanism  (EU  Member  States)  (https://www.eea.europa.eu/data-and-
maps/data/data-viewers/greenhouse-gases-viewer) 

(2)  Communication from the Commission to the European Parliament, the European Council, the Council, 
the European Economic and Social Committee and the Committee of the Regions - The European Green 
Deal (COM(2019) 640 final). 

(3)  Regulation (EU) 2019/631 of the European Parliament and of the Council of 17 April 2019 setting CO2 
emission  performance  standards  for  new  passenger  cars  and  for  new  light  commercial  vehicles,  and 
repealing Regulations (EC) No 443/2009 and (EU) No 510/2011 (OJ L 111, 25.4.2019, p. 13). 

(4)  Commission Regulation (EU) 2017/1151 of 1 June 2017 supplementing Regulation (EC) No 715/2007 
of  the  European  Parliament  and  of  the  Council  on  type-approval  of  motor  vehicles  with  respect  to 
emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on access to vehicle 
repair and maintenance information, amending Directive 2007/46/EC of the European Parliament and 
of  the  Council,  Commission  Regulation  (EC)  No  692/2008  and  Commission  Regulation  (EU)  No 
1230/2012 and repealing Commission Regulation (EC) No 692/2008 (OJ L 175, 7.7.2017, p. 1). 

(5)  UN  Regulation  No  154  –  Uniform  provisions  concerning  the  approval  of  light  duty  passenger  and 
commercial  vehicles  with  regards  to  criteria  emissions,  emissions  of  carbon  dioxide  and  fuel 
consumption  and/or  the  measurement  of  electric  energy  consumption  and  electric  range  (WLTP) 
[2021/2039] (OJ L 423, 26.11.2021, p. 1). 

(6)  Commission Regulation (EC) No 692/2008 of 18 July 2008 implementing and amending Regulation 
(EC) No 715/2007 of the European Parliament and of the Council on type-approval of motor vehicles 
with respect to emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on 
access to vehicle repair and maintenance information (OJ L 199, 28.7.2008, p. 1). 

4 

 
 
of electric driving of the vehicle. Various studies (7) found that the utility factor as set out 
in Regulation (EU) 2017/1151 does not accurately reflect the current average real-world 
use and CO2 emissions of those vehicles. Therefore, the Commission introduced changes 
to the calculation of the utility factor to bring it closer to real-world conditions (8), which 
will apply from 2025 onwards. 

Under  Article  7  of  Regulation  (EU)  2019/631,  Member  States  are  obliged  to  annually 
report to the Commission the official CO2 emission values (hereafter referred to as ‘WLTP 
data’) for all cars and vans newly registered in their territory in the preceding calendar year. 
Based  on  those  data,  the  Commission  calculates  the  average  CO2  emissions  of  each 
manufacturer and assesses whether it complies with its CO2 emission targets, as set out 
under that Regulation.  

Article 4a of Regulation (EU) 2017/1151 requires the following new M1 and N1 vehicles, 
which are registered as of 1 January 2021 (9), to be equipped with on-board fuel and energy 
consumption monitoring devices (‘OBFCM devices’) (10): 

(1)  Pure  Internal  Combustion  Engine  vehicles  (ICEVs)  and  Not-Off-Vehicle 
Charging Hybrid Electric vehicles (NOVC-HEVs) powered exclusively by mineral 
diesel, biodiesel, petrol, ethanol or any combination of these fuels, and  

(2)  Off-Vehicle  Charging  Hybrid  Electric  Vehicles  (OVC-HEVs)  powered  by 
electricity and any of the fuels mentioned in point (1).  

Article 12 of Regulation (EU) 2019/631 requires the Commission to assess the real-world 
representativeness of the WLTP values using data from the OBFCM devices (‘real-world 
data’).  To  this  end,  the  Commission  should  process  the  reported  data  and  publish 
anonymised and aggregated datasets, inter alia per manufacturer. By comparing the real-
world data with the corresponding WLTP data, the Commission should monitor the size 
of the gap between the two values, with the aim of preventing this gap from growing, as 
that would undermine the effectiveness of the CO2 emission standards in reducing vehicle 
CO2 emissions. The Commission also should assess how these data may be used to ensure 

(7)  ICCT, Real-world usage of plug-in hybrid electric vehicles: Fuel consumption, electric driving, and CO2 
emissions, 2020, (International Council on Clean Transportation: https://theicct.org/publications/phev-
real-world-usage-sept2020). 

Plötz, P. and Jöhrens, J., Realistic Test Cycle Utility Factors for Plug-in Hybrid Electric Vehicles in 
Europe. Karlsruhe: Fraunhofer Institute for Systems and Innovation Research ISI, 2021. 

Ktistakis,  M.A.,  Tansini,  A.,  Laverde  Marín,  A.,  Suarez  Corujo,  J.,  Komnos,  D.,  Fontaras,  G., 
Understanding  the  fuel  consumption  of  plug-in  hybrid  electric  vehicles:  a  real-world  case  study,  in: 
Conference  on  Thermo-and  Fluid  Dynamics  of  Clean  Propulsion  Powerplants.  Presented  at  the 
THIESEL 2022, Editorial Universitat Politècnica de València, Valencia, Spain, 2022. 

Tansini,  A.,  Pavlovic,  J.,  Fontaras,  G.,  Quantifying  the  real-world  CO2  emissions  and  energy 
consumption  of  modern  plug-in  hybrid  vehicles,  Journal  of  Cleaner  Production,  Volume  362,  2022, 
132191, ISSN 0959-6526, https://doi.org/10.1016/j.jclepro.2022.132191. 

(8)  Commission Regulation (EU) 2023/443 of 8 February 2023 amending Regulation (EU) 2017/1151 as 
regards the emission type approval procedures for light passenger and commercial vehicles (OJ L 66, 
2.3.2023, p. 1–237). 

(9)  For N1 class II and III vehicles, this obligation started from 1 January 2022. 

(10)  The ICEVs and NOVC-HEVs will henceforth be referred to by their fuel type (‘petrol, ‘diesel’, ‘E85’ 
or ‘other fuels’), while the OVC-HEVs will also be referred to as ‘plug-in hybrid electric vehicles’. 

5 

 
 
 
that the WLTP values remain representative of the real-world situation over time for each 
manufacturer.  

The procedures for collecting and reporting the data read out from the OBFCM devices by 
Member  States  and  vehicle  manufacturers  are  set  out  in  Commission  Implementing 
Regulation (EU) 2021/392 (11). It requires vehicle manufacturers from 2022 onwards, and 
Member  States  from  2024  onwards,  to  report  to  the  Commission  by  1  April  of  each 
calendar  year  for  each  vehicle  for  which  OBFCM  data  was  collected  the  vehicle 
identification number (VIN) and the following ‘lifetime’ information from the OBFCM 
device recorded in the preceding year: 

•  Total fuel consumed (litres) – fueltot 

•  Total distance travelled (km) – dtot  

For plug-in hybrid electric vehicles, in addition: 

•  Distance  travelled  in  charge  depleting  (‘CD’)  operation  with  engine  off  (km)  – 

dCD,Eng,off 

•  Distance travelled in CD operation with engine running (km) – dCD,Eng on 

•  Distance travelled in driver-selectable charge increasing (‘CI’) operation (km) – 

dCI 

•   Fuel consumed in CD operation (litres) – fuelCD 

•  Fuel consumed in driver-selectable CI operation (litres) – fuelCI 

•  Total grid energy into the battery (kWh) – gridtot  

This real-world data should then be linked to the corresponding WLTP data reported for 
the calendar year when the new vehicles were first registered. This allows the Commission 
to publish each year anonymised and aggregated datasets for cars and vans, split according 
to their powertrain and fuel type, which include the following data per manufacturer: 

•  The average real-world fuel consumption (l/100km); 

•  The average real-world electric energy consumption (kWh/100km) (OVC-HEVs 

only); 

•  The average real-world CO2 emissions calculated on the basis of fuel consumption 

data (gCO2/km); 

(11)  Commission Implementing Regulation (EU) 2021/392 of 4 March 2021 on the monitoring and reporting 
of  data  relating  to  CO2  emissions  from  passenger  cars  and  light  commercial  vehicles  pursuant  to 
Regulation (EU) 2019/631 of the European Parliament and of the Council and repealing Commission 
Implementing  Regulations  (EU)  No  1014/2010,  (EU)  No  293/2012,  (EU)  2017/1152  and  (EU) 
2017/1153 (OJ L 77, 5.3.2021, p. 8). 

6 

 
 
•  The  gap  between  the  average  real-world  fuel  consumption  (l/100km)  and  CO2 
emissions (gCO2/km) and the corresponding average WLTP fuel consumption and 
CO2 emissions; 

•  The  gap  between  the  average  real-world  electric  energy  consumption  and  the 
corresponding average WLTP electric energy consumption (kWh/100km) (OVC-
HEVs only).  

This Staff Working Document accompanies the Report from the Commission (12), which 
fulfils the obligations of the Commission under Article 12(3) of Regulation (EU) 2019/631 
and Article 12 of Implementing Regulation (EU) 2021/392. This Staff Working Document 
sets  out  the  methodology  used  for  processing  and  analysing  the  real-world  data  and 
contains  more  detailed  results,  including  the  anonymised  and  aggregated  datasets  per 
manufacturer in accordance with Article 12 of Implementing Regulation (EU) 2021/392. 

It is based on data collected by vehicle manufacturers throughout 2021 and reported by 
them  in  the  course  of  2022  to  the  European  Environment  Agency  (EEA),  as  set  out  in 
Article 9 of Regulation (EU) 2021/392. These real-world data were assessed against the 
2021  WLTP  dataset  underlying  Commission  Decision  (EU)  2023/1623 (13)  on  the  CO2 
emission performance of manufacturers of passenger cars and light commercial vehicles 
for calendar year 2021, considering only those which had to be equipped with OBFCM 
devices. 

2.  DATA SOURCES 

Over time, the real-world data reported should come from two primary sources: vehicle 
manufacturers (Article 9 of Implementing Regulation (EU) 2021/392) and Member States 
(Article 10 of that Regulation). In both cases, during the collection, vehicle owners have 
the possibility to refuse making this data available. 

Manufacturers are required to collect real-world data either via over-the-air (‘OTA’) data 
transmission or through their authorised dealers or repairers when vehicles are brought in 
for service or repairs and data is read out from the on-board diagnostics (‘OBD’) interface. 
As  of  1  April  2023,  vehicle  manufacturers  will  also  have  to  report  the  reasons  for  not 
reporting real-world data and the number of vehicles affected. This could be due to vehicle 
owners  refusing  to  give  access  to  the  data,  technical  failures  in  the  read-out,  or  other 
reasons. 

Member  States  will  rely  on  their  designated  bodies  and  establishments  for  periodical 
technical inspections (‘PTI’) to collect real-world data through a read-out from the OBD 
during roadworthiness tests as required under Directive 2014/45/EU (14). The collection of 

(12)  COM(2024) 122 

(13)  Commission Implementing Decision (EU) 2023/1623 of 3 August 2023 specifying the values relating 
to the performance of manufacturers and pools of manufacturers of new passenger cars and new light 
commercial  vehicles  for  the  calendar  year  2021  and  the  values  to  be  used  for  the  calculation  of  the 
specific emission targets from 2025 onwards, pursuant to Regulation (EU) 2019/631 of the European 
Parliament  and  of  the  Council  and  correcting  Implementing  Decision  (EU)  2022/2087  (OJ  L  111, 
25.4.2019, p. 13.). 

(14)  Directive  2014/45/EU  of  the  European  Parliament  and  of  the  Council  of  3  April  2014  on  periodic 
roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC (OJ L 127, 
29.4.2014, p. 51). 

7 

 
 
real-world data by Member States is only required since 20 May 2023, i.e. the deadline 
under  Directive  2014/45/EU for  the  PTI  facilities  to  be  equipped  with  the  necessary 
devices, such as scan tools. While Member States had the option to submit data voluntarily 
in 2022, none of them did.  

This Staff Working Document covers the data collected from vehicles first registered in 
2021 and reported in 2022 and is based on real-world data collected and reported by vehicle 
manufacturers only. 

For identifying the manufacturers falling under the real-world data reporting obligations, 
the Commission, supported by the European Environment Agency (EEA), relied on the 
information  collected  under  Article  7  of  Regulation  (EU)  2019/631.  The  following 
manufacturers were considered not to be required to report real-world data in 2022: 

–  manufacturers  having  in  2021  only  pure  electric  vehicles  (‘PEVs’)  newly 
registered, as such vehicles are not required to be equipped with OBFCM devices; 

–  manufacturers having in 2021 only N1 vehicles of class II & III registered, as for 
such vehicles the obligation to be fitted with OBFCM devices only applied from 1 
January 2022; 

–  small-volume  manufacturers  as  defined  in  Article  4(32)  of  Regulation  (EU) 

2017/1151. 

As  a  result,  51  individual  manufacturers  (of  M1  and/or  N1  vehicles)  were  expected  to 
report real-world data for their new vehicles registered in 2021. 

In the course of 2022, the Commission received real-world data from 45 out of those 51 
manufacturers and from one other manufacturer who reported data on a voluntary basis. 
Those  manufacturers  who  did  not  report  real-world  data  were  contacted.  Two  of  these 
manufacturers communicated that they were not in a position to identify which vehicles 
were registered in 2021, and as a result they would report the 2021 collected data in 2023. 
Two other manufacturers created an account in the reporting system but did not report any 
vehicles. 

Real-world data was received for 988 292 vehicles out of a total of 9 821 479 vehicles (i.e. 
10.1%) first registered in the EU, Iceland or Norway in 2021 (15).  

The complete list of manufacturers and the number of vehicles reported per manufacturer 
are provided in Annex A. 

3.  DATA PROCESSING  

The raw real-world  data received in  2022 was  processed into an aggregated dataset  for 
further calculations through the following main steps:  

(1) 

Basic quality checks on the submissions 

(2) 

Linking unique real-world submissions with the 2021 WLTP data  

(15)  The total number of new vehicles referred to here do not include pure electric vehicles, fuel cell electric 

vehicles, and natural gas vehicles. 

8 

 
 
(3) 

Removing unmatched data 

(4) 

Removing inconsistencies between reported real-world and WLTP fuel types 
and fuel modes 

(5) 

Removing vehicles with low mileage 

(6) 

Removing remaining outliers from the real-world data set 

(7) 

Removing incomplete WLTP data and discrepancies 

(8) 

Calculating real-world CO2 values and WLTP fuel consumption values 

(9) 

Aggregating at manufacturer level 

In general, a conservative data processing approach was taken, removing data for which 
the  analysis  revealed  possible  doubts  over  the  accuracy  or  consistency.  With  this,  high 
robustness was aimed for, while keeping a number of data points as statistically significant 
as possible. The trade-offs between data quality and quantity are explained in the following 
sections for each of the processing steps.  

Manufacturers  were  requested  to  report  the  real-world  data  for  all  vehicles  they  had 
collected  data  from,  including  apparently  implausible  or  extreme  values.  While  most 
manufacturers  responded  positively  to  this  request,  it  cannot  be  excluded  that  some 
manufacturers  had  removed  vehicles  or  data  points  prior  to  the  reporting,  which  might 
explain  certain  differences  observed  between  manufacturers  in  terms  of  the  share  of 
vehicles removed in the data processing steps. 

The detailed steps taken during the data processing procedure and the outcome of each of 
these steps as regards the composition of the 2021 real-world dataset are outlined in the 
following sections.  

The approach taken may be revisited in the coming years depending on the data received. 
Additional steps may be required once Member States start reporting real-world data. 

3.1.  Basic quality checks on submission 

Manufacturers  reported  their  data  on  the  EEA  reporting  platform  Reportnet  3.  The 
reporting  platform  includes  automatic  basic  checks  of  the  submitted  data  so  that  data 
reported complies with minimum standards. This ensures that mandatory parameters are 
filled in and that the values entered correspond to the expected parameter type (16). 

Following these basic quality checks, which led to the removal of 61 duplicates, the real-
world data covered 988 231 vehicles.  

3.2.  Linking with the 2021 WLTP data 

In order to compare the real-world data received with the WLTP data for the same set of 
new vehicles registered in 2021, the two data sets were linked using the common Vehicle 

(16)  It was found that one manufacturer had the wrong delimiter for the distance, and this has been corrected. 
For  another  manufacturer,  the  wrong  variable  was  inserted  for  electric  energy  consumption.  These 
vehicles have not been considered for the electric energy related calculations.  

9 

 
 
Identification Number (VIN). In that way, for each vehicle in the real-world dataset, the 
following parameters taken from the WLTP data could be identified: 

•  Country where the vehicle was first registered; 

•  Date of first registration; 

•  Manufacturer name; 

•  Vehicle type identifiers: interpolation family identifier, type approval number, 

type, variant, version, make and commercial name;  

•  Vehicle category (M1 or N1, as registered); 

•  Mass in running order, fuel type, fuel mode, engine capacity and engine power; 

•  WLTP CO2 emissions, fuel consumption, and electric energy consumption. 

Through  linking  the  two  datasets,  out  of  the  988 231  unique  vehicles  in  the  real-world 
dataset, 916 216 M1 and 12 301 N1 vehicles (17) could be matched with the 2021 WLTP 
dataset. This represents 10.6% of the 2021 M1 first registrations (8 635 178) and 1.0% of 
the 2021 N1 first registrations (1 185 544) (18). For 59 714 vehicles reported as part of the 
real-world dataset, no match could be found in the 2021 WLTP dataset, mainly due to the 
majority  of  these  vehicles  being  first  registered  in  either  2020  or  2022, as  described  in 
Section 3.3.  

The number of vehicles in this initial real-world dataset, split per fuel type as reported in 
the WLTP data (‘Ft’), is shown in Table 1.  

Table 1: Number of vehicles in the initial real-world dataset as compared to the total 
2021 registrations, per WLTP fuel type 

M1 vehicles 

N1 vehicles 

Total 2021 
first 
registrations 

Initial real-
world dataset 
(% of 2021 
first 
registrations) 

Total 2021 
first 
registrations 

Initial real-
world dataset 
(% of 2021 
first 
registrations) 

5 495 708 

2 229 388 

6 026 

391 329  
(7.1%) 

301 995 
(13.5%) 

2 084  
(34.6%) 

44 475 

1 139 405 

159 

1 891  
(4.3%) 

10 053  
(0.9%) 

0  
(0%) 

Petrol 

Diesel 

E85 

(17) The vehicle category referred to in this report is the one under which the vehicles have been registered 

according to the 2021 WLTP data. 

(18)  See note 15, page 8. 

10 

 
 
 
Other fuels (19) 

- 

Petrol/Electric 

848 251 

Diesel/Electric 

55 805 

Total  

8 635 178 

697  
(0.1%) 

191 197 
(22.5%) 

28 914  
(51.8%) 

916 216 
(10.6%) 

- 

1 501 

4 

1 243 873 

30  
(0.1%) 

326  
(21.7%) 

1  
(25.0%) 

12 301 
(1.0%) 

There is a very low quantity of N1 vehicles reported. This is primarily due to the fact that 
in  2021  the  obligation  for  new  N1  vehicles  to  be  equipped  with  OBFCM  devices  only 
applied for N1 class I vehicles. For N1 class II and III vehicles, this requirement started to 
apply  only  from  2022 onwards.  Therefore, it is  expected that N1  vehicle  coverage  will 
improve substantially in the next years. 

Linking with the WLTP data showed that the N1 real-world dataset included data for 1 020 
Class I vehicles (3.8% of 2021 registrations), but also for 4 598 Class II (1.0%) and 6 683 
Class III vehicles (0.9%). Overall, N1 vehicle data was only reported for 1.0% of new N1 
vehicles registered in 2021.  

In view of this,  further  data processing  and analysis  will focus mainly on M1 vehicles, 
while also providing results for N1 vehicles for each step. 

3.3.  Unmatched vehicles 

For 59 714 vehicles reported as part of the real-world data set, the VIN could not be found 
in the 2021 WLTP data. These vehicles are therefore not included in the further analysis 
as the comparison with the 2021 WLTP data is not possible.  

Looking into the reasons for the mismatch, apart from likely typing errors in the VINs, 
which are not easily verifiable for each individual case, it was found that the majority of 
the vehicles concerned were actually first registered in 2020 (18 129 vehicles) or in 2022 
(15 264 vehicles). The vehicles first registered in 2020 will not be taken into consideration 
for calculating the real-world gap as they were not yet required to be fitted with OBFCM 
devices. Where relevant, the vehicles first registered in 2022 will be taken into account in 
the following year when the 2022 WLTP data becomes available. 

3.4. 

Inconsistencies in fuel type/mode  

3.4.1.  Vehicles out of scope  

For each of the records of the real-world dataset, the fuel type reported in the WLTP data 
was checked to identify vehicles which were not required to be equipped with an OBFCM 
device (9). Vehicles with reported fuel types ‘LPG’ (451 M1), ‘NG-BIOMETHANE’ (244 

(19) Fuel types other than those specified under Article 4a of Regulation (EU) 2017/1151. These vehicles are 
out of scope and will be removed in Section 3.4.1. The total number of first registrations of such vehicles 
in 2021 is therefore not presented in this table (and not included in the overall total shown). 

11 

 
 
 
M1 and 30 N1) or ‘ELECTRIC’ (1 M1) were excluded from the dataset for further analysis, 
as well as 1 M1 vehicle for which the fuel type was not reported.  

Together, these excluded vehicles represent only 0.1% (697) of M1 vehicles and 0.2% (30) 
of N1 vehicles in the dataset. After this step, 915 519 M1 vehicles and 12 271 N1 vehicles 
remained in the dataset. 

3.4.2.  Inconsistencies  in  reported  fuel  types,  fuel  modes  or  OVC-HEV 

specific parameters 

To allow the analysis for plug-in hybrid electric vehicles and other vehicles separately, the 
dataset was screened to ensure a correct assignment of the vehicles  to one of these two 
groups.  

In  the  WLTP  data,  both  the  vehicle  fuel  type  and  its  fuel  mode  could  be  used  for  this 
purpose. As regards fuel mode, pure ICEVs should be reported as ‘M’ (monofuel), NOVC-
HEVs as ‘H’, OVC-HEVs as ‘P’ and ‘E85’ as ‘F’ (flex-fuel). The relevant fuel types for 
ICEVs and NOVC-HEVs are ‘Petrol’, ‘Diesel’ or ‘E85’. For OVC-HEVs, these are either 
‘Petrol/Electric’ or ‘Diesel/Electric’.  

In  the  real-world  dataset,  OVC-HEVs  can  be  identified  on  the  basis  of  the  additional 
parameters that have to be reported, related to their electric driving. Vehicles in the real-
world dataset for which the specific OVC-HEV parameters were reported, are classified as 
‘OVC-HEV’, all others as ‘ICEV/NOVC-HEV’.  

Table 2 summarizes the findings of this matching exercise for M1 vehicles. To ensure a 
high  internal  consistency  of  the  data  used  for  the  calculations,  the  50 995  M1  vehicles 
(5.6%) with inconsistencies in the reported fuel type/fuel mode were removed from the 
real-world dataset.  

For the 864 524 other M1 vehicles (94.4% of the 915,519 M1 vehicles remaining after the 
previous  step)  remaining  in  the  dataset  after  this  step  no  such  inconsistencies  were 
observed. 

Table 2: Inconsistencies between the vehicle type according to the real-world data and 
fuel type or fuel mode reported in the WLTP data (M1 vehicles only) 

Vehicle type according 
to the real-world data 

WLTP fuel type 

WLTP fuel mode 

Number of 
vehicles 

ICEV/NOVC-HEV  

Petrol/Electric 

ICEV/NOVC-HEV  

Diesel/Electric 

OVC-HEV 

OVC-HEV 

OVC-HEV 

ICEV/NOVC-HEV 

Total number of 
inconsistencies 

Petrol 

Petrol 

Diesel 

Petrol 

12 

P 

P 

M 

H 

M 

B 

45 278 

7 

285 

5 230 

5 

190 

50 995  
(5.6%) 

 
  
  
 
The  main  inconsistency  found  concerns  45 285  vehicles  classified  as  ‘ICEV/NOVC-
HEV’on the basis of the real-world  data  (OVC-HEV specific parameters not reported), 
which were marked as ‘P’ (OVC-HEV) in the WLTP data. This represents over 20% of 
the OVC-HEVs in the dataset. For the majority of these vehicles (89%), the manufacturer 
is Volvo. A reason for the missing OVC-HEV specific parameters in the real-world data 
of those vehicles may be their low mileage, due to which they either were not at all driven 
in electric mode during the first stages of their use, or not long enough for the parameters 
to be registered.  

Applying the low-mileage filter of 500 km (see Section 3.5) to those 45 285 vehicles would 
anyway have left only 3 242 of them in the dataset. After also applying the other filters, 
the remainder of those vehicles would have had an impact of less than 1% on the average 
fuel consumption of OVC-HEVs. Therefore, removing them entirely from the calculations 
improves the consistency of the dataset without overly influencing the outcome. 

For  5 520  vehicles,  mostly  manufactured  by  Renault  (95%),  the  opposite  situation 
occurred. While one or more of the OVC-HEV specific parameters were reported in the 
real-world dataset, they had been marked as ICEVs or NOVC-HEVs in the WLTP data. 
Taking all other filters into account, removing these vehicles also had an impact of less 
than 1% on the average fuel consumption of petrol/diesel vehicles.  

For N1 vehicles, 163 records (1.3% of 12 271 N1 vehicles) had to be removed as no OVC-
HEV specific parameters were reported as part of the real-world data, while they had been 
marked as ‘P’ (OVC-HEV) in the WLTP data. This left 12 108 N1 vehicles in the dataset. 

3.5.  Vehicles with low mileage  

As shown in Figure 1, the remaining M1 vehicles in the real-world dataset show a wide 
range of driven distances. Many vehicles had a very low mileage at the time of recording 
their real-world data: 124 299 vehicles (14.4%) had driven less than 10 km and nearly a 
quarter  of  the  vehicles  (24.8%)  had  driven  less  than  100  km.  On  the  other  side  of  the 
spectrum,  10%  of  the  vehicles  had  driven  more  than  20 000  km.  Such  divergence  was 
expected  in  the  first  year  of  data  collection  when  all  the  vehicles  monitored  have  been 
newly registered across the past year. 

Figure 1: Distribution by total lifetime distance travelled of M1 vehicles in the real-world 
dataset 

13 

 
 
 
However, as can be seen from Figure 2, which is showing the relation between the fuel 
consumption (l/100km) and the total distance driven (km), including vehicles with a very 
low distance driven (< 100 km) into the further calculations and analysis would introduce 
a huge number of extremely high fuel consumption values (l/100 km).  

Based  on  the  feedback  received  from  manufacturers,  several  possible  reasons  for  the 
presence  of  those  outliers  could  be  identified.  In  the  case  of  some  manufacturers,  real-
world data was already read-out immediately after manufacturing, when vehicles may be 
operated  in  unrepresentative  ways.  For  example,  for  vehicles  undertaking  technical 
operations in logistics hubs, operated in idle mode during the production processes, or used 
for test drives or parking operations prior to being sold or registered, the recorded mileage 
could be (close to) zero, while the fuel consumption may already be relatively significant, 
resulting in extremely high calculated fuel consumption values in l/100 km. 

Following  these  findings,  several  manufacturers  have  indicated  that  they  have  changed 
their data collection process and will no longer read out OBFCM data before the vehicle 
is registered. 

However, there are also indications that OBFCM devices were reset right before the data 
was  read  out,  as  many  manufacturers  have  a  peak  of  registrations  at  0  km  mileage. 
Regulation (EU) 2017/1151 allows for the values of the lifetime counters to be reset only 
for those vehicles where the memory type of the engine control unit is unable to preserve 
data  when  not  powered  by  electricity.  In  this  case,  or  when  the  engine  control  unit  is 
replaced, all values may be reset simultaneously, thereby preventing the introduction of a 
bias. This provision only applies for vehicles first registered in 2021, and values must be 
preserved for new vehicle types approved as of January 2022, and new vehicles as of 2023. 

In this first dataset, all of these vehicles with a low mileage reported should be filtered out 
to perform the analysis based on representative values. 

Figure  2: Total  lifetime  distance  driven  (km)  and  real-world  fuel  consumption  (l/100 
km)  (only  vehicles  with  up  to  3 000  km  driven  and  with  finite  calculated  fuel 
consumption are shown)  

14 

 
 
 
Therefore, as a first step, the 214 496 vehicles (24.8%) with a lifetime distance driven of 
less than 100 km were removed from the dataset, leaving 650 028 vehicles.  

As  a  next  step,  vehicles  with  a  distance  driven  in  the  range  100-3 000  km (20)  were 
considered in more detail. Table 3 shows the changes in number of vehicles retained and 
their average fuel consumption when applying a low-mileage filter of 300, 500, 1 000 or 
3 000 km. This shows that a more significant share of vehicles would be disregarded at 
higher mileage filters with a limited impact in terms of the 2021 registrations-wide average 
fuel consumption and CO2 emissions. 

Table 3: Influence of different low-mileage filters on the number of M1 vehicles (with a 
lifetime mileage over 100 km) retained and their average fuel consumption (21) 

Low-mileage filter applied 

< 300 km 

< 500 km 

< 1 000 km  < 3 000 km 

Number of vehicles excluded (> 
100 km) 

% of vehicles excluded 

Average fuel consumption of the 
additionally excluded vehicles 
(l/100km) 

Average fuel consumption of the 
remaining vehicles (l/100km) 

11 057 

21 753 

47 434 

145 727 

1.7 

9.20 

3.4 

8.63 

7.3 

8.03 

22.4 

7.62 

7.14 

7.13 

7.11 

7.05 

Figure  3  shows  that  most  fuel  consumption  outliers  occur  for  vehicles  with  a  mileage 
below 300 km, while fuel consumption values up to 40 l/100km continue to exist even past 
3 000  km.  It  should  also  be  kept  in  mind  that  the  situation  differs  between  individual 
manufacturers  depending  on  the  mileage  distribution  of  their  reported  2021  newly 
registered vehicle fleet. 

(20) 3 000 km being the minimum mileage for vehicles to be granted WLTP emission type-approval. 

(21)  Values in the table do not include the 214 496 vehicles with < 100 km lifetime driven distance. 

15 

 
 
 
Figure 3: Total lifetime distance driven and respective fuel consumption of M1 vehicles 
in the real-world dataset (only vehicles with a mileage from 100 to 3 500 km are shown) 

To  strike  a  balance  between  removing  all  significant  mileage-based  outliers  and 
maintaining  the  largest  possible  data  set,  also  taking  into  account  the  variations  across 
manufacturers, it was decided to also exclude vehicles with a lifetime mileage from 100 to 
500 km. This leads to the removal of a further 21 753 (3.4%) vehicles.  

Overall, applying the low-mileage filter of 500 km removed 236 279 M1 vehicles (27.3% 
of the 864 524 vehicles remaining after the previous step), leaving 628 245 M1 vehicles in 
the real-world dataset.  

Applying  the same filter for N1 vehicles  removes  5 307 vehicles (43.8% of the 12 108 
vehicles remaining after the previous step), leaving 6 801 N1 vehicles in the dataset.  

It  is  expected  that  the  average  distance  driven  by  vehicles  will  increase  over  time,  and 
thereby  the  low-mileage  filter  will  have  a  less  significant  impact  on  the  number  of 
registrations in following years. 

3.6.  Removing remaining outliers from the real-world data set  

As  a  next  step,  the  real-world  dataset  was  screened  further  for  outliers,  which  may  be 
indicative of erroneous data collection or transmission and would disproportionately affect 
the calculated average values and distort the comparison between real-world and WLTP 
data. 

For this, the main focus was on the total fuel consumption and the total distance as these 
parameters  directly  affect  the  average  real-world  fuel  consumption  and  CO2  emissions. 
Three outlier cases were identified: 

(1) 

implausibly high distance driven; 

(2) 

very low fuel consumption (for ICEVs/NOVC-HEVs); 

(3) 

extreme values of OVC-HEV specific parameters. 

These three cases are described in the following Sections. 

16 

 
 
The first two cases are visualised in Figure 4, which shows the fuel consumption (l/100km) 
of petrol and diesel vehicles plotted against their total lifetime distance driven (km) (both 
on a logarithmic scale).  

Figure 4: Distribution of the real-world fuel consumption (l/100km) against the lifetime 
distance driven (km) (M1 ICEVs/NOVC-HEVs)  

2 

1 

3.6.1.  Implausibly high distance driven 

Extremely high mileages recorded can be a sign of a defective OBFCM device. Based on 
the data summarised in Table 4, a threshold of 300 000 km was chosen to filter out such 
outliers. This removed 12 M1 vehicles (including 1 OVC-HEV) and 3 N1 vehicles from 
the dataset, leaving 628 233 M1 and 6 798 N1 vehicles. Two of the four manufacturers of 
the M1 vehicles concerned had reported that the OBFCM devices in these vehicles were 
indeed found to be defunct. 

Table  4:  High  distance  thresholds  and  average  fuel  consumption  per  threshold  (M1 
vehicles) 

Distance driven (1000 km) 

≥ 100 

≥ 200 

≥ 300 

≥ 400 

≥ 500  ≥ 1000 

Number of vehicles 

Average fuel consumption 
(l/100km) 

128 

4.92 

25 

12 

10 

8 

4 

2.12 

0.52 

0.30 

0.34 

0.06 

In subsequent years, as vehicles will have driven higher mileages, this filter may have to 
be  reconsidered  to  reflect  the  plausible  driving  distances,  also  considering  differences 
between M1 and N1 vehicles. 

17 

 
 
 
3.6.2.  Very low or high fuel consumption (ICEVs/NOVC-HEVs) 

Where  either  the  total  fuel  consumption  (l)  or  total  distance  driven  (km)  has  not  been 
recorded correctly by the OBFCM device, the calculated fuel consumption (l/100km) may 
be far higher or lower than theoretically possible.  

The low fuel consumption filter was not applied for OVC-HEVs, as those vehicles may 
have a very low fuel consumption when primarily driving electrically.  

Figure 5 shows that it is unlikely for ICEVs/NOVC-HEVs to have a fuel consumption of 
less  than  2.5  l/100km.  Applying  this  threshold  removes  1 665  M1  vehicles  (0.27%), 
leaving  626 568  M1  vehicles  in  the  dataset.  For  N1  vehicles,  this  removes  19  vehicles 
(0.28%), leaving 6 779 N1 vehicles in the dataset (22).  

Figure 5: Distribution of fuel consumption of M1 ICEVs/NOVC-HEVs 

A small number of vehicles were found to have an unlikely high fuel consumption recorded 
by the OBFCM device. Apart from the cases where the vehicle had driven a short distance, 
which were already filtered out (see Section 3.5), such high fuel consumption may occur 
when there is a fault in the recording, causing either the fuel consumption or total lifetime 
distance to be incorrect. The vehicles with a fuel consumption of more than 30 l/100km 
are  predominantly  luxury  SUVs  and  sports  cars  from  9  different  manufacturers.  As  it 
cannot be concluded in these cases that there was an error in the recording of the data, these 
vehicles are not filtered out from the dataset. 

3.6.3.  OVC-HEV parameter outliers 

For OVC-HEV, the values reported for the distance and fuel consumption in the separate 
phases – charge-depleting (CD) and charge-increasing (CI) phases – were compared with 
the  total  lifetime  values  reported  to  check  for  inconsistencies.  These  variables  are  not 
subject to any accuracy testing under Regulation (EU) 2017/1151, and therefore may be 

(22)  The percentage of exclusions in this section always are relative to the number of vehicles remaining in 

the previous step, as a step-wise exclusion approach has been followed. 

18 

 
 
 
less reliable. However, in principle it should not be the case that the values covering only 
part of the lifetime operation are greater than the total lifetime values.  

The consistency checks compared the total lifetime fuel consumption (ftot) and the total 
distance driven (dtot) against the CD and CI phase values as well as against the sum of the 
CD  and  CI  phase  values.  It  has  been  considered  that  for  OBFCM  devices  correctly 
recording all parameters, the following should be true: 

𝑑𝑡𝑜𝑡 ≥ 𝑑𝐶𝐷,𝐸𝑛𝑔 𝑜𝑛 + 𝑑𝐶𝐷,𝐸𝑛𝑔 𝑜𝑓𝑓 + 𝑑𝐶𝐼 

𝑓𝑡𝑜𝑡 ≥ 𝑓𝑢𝑒𝑙𝐶𝐷 + 𝑓𝑢𝑒𝑙𝐶𝐼 

These checks revealed inconsistencies for 4 871 M1 OVC-HEV regarding distances driven 
and for 4 244 M1 OVC-HEV regarding reported fuel consumption values. By far most of 
the issues identified were related to the values reported for the CI phase. As some vehicles 
had  both  issues  occurring,  a  total  of  7 834  M1  vehicles  (1.25%  of  remaining  M1, 
corresponding to 6.0% of remaining OVC-HEVs) were concerned and removed from the 
dataset, leaving 618 734 M1 vehicles in the dataset. 

Furthermore, some manufacturers indicated that an energy overflow could cause an error 
in  the  OBFCM  device,  leading  to  the  recording  of  extremely  high  values  for  the  grid 
energy.  Only  one  such  extreme  outlier  (>  100 000  kWh)  could  be  identified  in  the 
remaining dataset and was removed, thus leaving 618 733 M1 vehicles in the dataset. 

For N1 vehicles, given the very small share of OVC-HEV in the 2021 registered fleet, the 
abovementioned issues are minor (5 vehicles removed, 6 774 remaining). 

3.7. 

Flex-fuel ethanol vehicles (E85) 

New flex-fuel vehicles, powered by ethanol (E85), or a combination of ethanol and other 
fuels, must be equipped with OBFCM devices under Regulation (EU) 2017/1151 and as 
such real-world data must be reported under Regulation (EU) 2021/392. However, for the 
WLTP data monitoring, only the CO2 emission values in petrol mode have to be reported 
for these vehicles, with fuel mode “F” and fuel type “E85”. 

E85 is less energy dense than petrol (E10), meaning that more fuel has to be consumed to 
provide the same amount of energy to propel the vehicle. This results in a higher amount 
of fuel consumed per km under the same conditions by E85 flex-fuel vehicles as compared 
to petrol vehicles. In terms of CO2 emissions, this higher fuel consumption is compensated 
by the lower carbon content of E85. To confidently compare the real-world CO2 emissions 
of these vehicles with their reported WLTP (petrol-based) CO2 emission values, it would 
be necessary to know the ethanol content of the fuel used when they were driven. However, 
from  the  real-world  dataset  it  is  not  possible  to  find  out  the  quantity  or  share  of  E85 
consumed by the flex-fuel vehicles on the road. 

On  average,  the  1 534  E85  vehicles  in  the  remaining  dataset  consumed  11.9  l/100  km, 
which is 50% more than the average for the 274 453 petrol vehicles (7.9 l/100 km). The 
average  (petrol-based)  WLTP  emissions  of  the  E85  vehicles  are  188.3  g/km.  When 
assuming  that  these  vehicles  are  driven  solely  on  E10,  their  average  real-world  CO2 
emissions would be 270.1 g/km, which means  a gap of 43.5% (81.8 g CO2/km). When 
considering them as purely using E85, their average real-world CO2 emissions would be 
196.1 g/km, so the gap is only 4.2% (7.8 g CO2/km). Even if one could be confident that 
only  E85  was  used,  the  ethanol  content  of  this  fuel  in  the  EU  varies  seasonally  and 

19 

 
geographically  between  50-85%  and  this  variation  by  itself  introduces  a  significant 
uncertainty into the gap calculations.  

Therefore, it was decided to remove the 1 534 flex-fuel vehicles from the further analysis 
(0.2% of the 618 733 vehicles remaining in the previous step). This leaves 617 199 M1 
vehicles in the dataset. 

3.8.  Missing WLTP emission values 

After  the  previous  data  filtering  steps,  5 M1  and  107  N1  vehicles  for  which  no  WLTP 
emission values were available remained in the real-world dataset.  

After removing these vehicles, 617 194 M1 and 6 667 N1 vehicles vehicles remained.  

With this, the real-world dataset was considered final. 

3.9.  Overview of data processing steps 

The abovementioned data processing steps are summarized in Table 5 and Figure 6. This 
underscores the  impact  of the low  mileage driven by many vehicles,  the importance of 
accurate  reporting  of  WLTP  fuel  modes/types  by  Member  States,  and  of  the  correct 
functioning of the OBFCM devices and reading out of the OBFCM data by manufacturers.  

It  is  expected  that  over  time  vehicles  are  driven  more  so  that  the  low-mileage  filter  in 
subsequent reporting years should have a smaller impact on the real-world data. 

Table 5: Overview of vehicles removed and retained during each data processing step 

Step 

Unmatched 
vehicles 

Inconsistencies 
scope 

Inconsistencies 
fuel mode/type 

Vehicles 
removed 

M1 
vehicles 
removed 

M1 
vehicles 
retained 

N1 vehicles 
removed 

N1 vehicles 
retained 

59 714 

916 216 

12 301 

727 

697 

915 519 

30 

12 271 

51 158 

50 995 

864 524 

163 

12 108 

Low-mileage 

241 586 

236 279 

628 245 

5 307 

Outliers (high 
distance) 

Outliers (low 
FC) 

Outliers (OVC-
HEV) 

E85 

WLTP missing 

15 

12 

628 233 

1 684 

1 665 

626 568 

7 840 

7 835 

618 733 

1 534 

112 

1 534 

617 199 

3 

19 

5 

0 

6 801 

6 798 

6 779 

6 774 

6 774 

6 667 

5 

617 194 

107 

20 

 
 
 
 
Figure 6: Overview of all data processing steps (M1 and N1 vehicles) 

4.  FINAL 2021 REAL-WORLD DATASET 

Starting  from  a  total  of  988 231  unique  vehicles,  for  which  real-world  data  had  been 
reported, of which 916 216 M1 vehicles and 12 301 N1 vehicles could be matched with 
the 2021 WLTP data, the processing led to a final dataset including 617 194 M1 vehicles 
and 6 667 N1 vehicles. Only this final dataset will be considered for the calculation of the 
average fuel/energy consumption and CO2 emissions and the gap between the real-world 
and the WLTP figures. 

Table 6 shows that in 2021 real-world data was collected for 9.8% of diesel passenger cars, 
5.0%  of  petrol  passenger  cars,  44.6%  of  diesel  plug-in  hybrid  electric  vehicles (23)  and 
11.7% of petrol plug-in hybrid electric vehicles, which were first registered in that year. 
The final real-world dataset covers 7.2% of the 2021 first registered M1 vehicles. 

(23)  This higher coverage results from Mercedes-Benz AG, who is the main supplier of diesel plug-in hybrid 

vehicles in 2021, providing good coverage of these vehicles. 

21 

 
 
 
 
 
 
Table 6: Overview of the data processing for M1 vehicles by fuel type (24) 

Powertrain/ 
fuel type 

2021 registrations 

Reported real-world 
dataset (before 
processing) 

Final real-world dataset 
(after processing) 

Vehicle 
registrations 
per fuel 
type 

Number 
of 
vehicles  

Share of 
total 2021 
registrations  

Number 
of 
vehicles  

Percentage 
retained  

Share of 
total 2021 
registrations

Petrol 

Diesel 

5 495 708 

391 329 

7.1% 

274 451 

70.1% 

2 229 388 

301 995 

Petrol/Electric 

848 251 

191 197 

Diesel/Electric 

55 805 

28 914 

13.5% 

22.5% 

51.8% 

219 003 

72.5% 

98 847 

24 893 

51.7% 

86.1% 

TOTAL  

8 629 152 

 913 435 

10.6% 

617 194 

67.4% 

5.0% 

9.8% 

11.7% 

44.6% 

7.2% 

As shown in Table 7, real-world data for N1 vehicles is much more limited. The final real-
world  dataset  covers  less  than  0.6%  of  the  2021  registered  N1  vehicles.  This  can  be 
explained by the fact that N1 Class II and III vehicles, which represent the vast majority 
of N1 vehicles, were not yet required to have OBFCM devices in 2021. As such, the real-
world dataset for N1 vehicles cannot be considered representative of the 2021 EU fleet.  

Table 7: Overview of data processing for N1 vehicles by fuel type (25) 

Powertrain/ 
fuel type 

2021 registrations 

Reported (before 
processing) 

After processing 

Vehicle 
registrations 
per fuel type 

Number 
of 
vehicles  

Share of 
total 2021 
registrations  

Number 
of 
vehicles  

Percentage 
retained  

Share of 
total 2021 
registrations

Petrol 

Diesel 

44 475 

1 891 

1 139 405 

10 053 

Petrol/Electric 

1 501 

Diesel/Electric 

4 

326 

1 

TOTAL 

1 185 385 

12 271 

4.3% 

0.9% 

21.7% 

25.0% 

1.0% 

988 

5 593 

86 

0 

52.3% 

55.6% 

25.8% 

0% 

6 667 

54.2% 

2.2% 

0.5% 

5.7% 

0% 

0.6% 

(24)  Total M1 registrations excluding those excluded from the analysis, i.e. pure electric vehicles (PEVs), 
fuel cell electric vehicles (FCEVs), E85 vehicles and natural gas vehicles (NGVs) (leaving a total of 
8 629 152 vehicles in-scope). 

(25)  Total N1 registrations excluding pure electric vehicles (PEVs), fuel cell electric vehicles (FCEVs), and 

natural gas vehicles (NGVs) (leaving a total of 1 185 385 vehicles in-scope). 

22 

 
  
 
 
  
 
5.  CALCULATION OF AVERAGE REAL-WORLD FUEL CONSUMPTION AND CO2 EMISSION 

VALUES AND COMPARISON WITH THE WLTP VALUES 

Article 12 of Implementing Regulation (EU) 2021/392 requires the Commission to publish 
each year the anonymised and aggregated real-world datasets per manufacturer, split by 
vehicle category and type of powertrain, and including: 

•  the average CO2 emissions; 

•  the average fuel consumption; 

•  the average electric energy consumption (for OVC-HEVs only). 

Calculating the average electric energy consumption for OVC-HEV and the comparison 
with the WLTP values raised particular issues, due to which  these average values have not 
been  computed  per  manufacturer.  These  calculations  and  the  associated  issues  will  are 
presented separately in Annex C, together with considerations regarding the utility factor.  

The  calculation  of  the  other  average  values  involves  the  following  steps,  based  on  the 
reported total fuel consumption (l) and total distance travelled (km): 

(1) 

(2) 

(3) 

(4) 

(5) 

calculation of real-world fuel consumption (l/100 km) for each vehicle; 

calculation of the real-world CO2 emissions (g/km) for each vehicle; 

calculation of the average real-world and WLTP fuel consumption (l/100 km) per 
manufacturer, split by powertrain/fuel type of the vehicles; 

calculation  of  the  average  real-world  and  WLTP  CO2  emissions  (g/km)  per 
manufacturer, split by powertrain/fuel type of the vehicles; 

comparison between the average real-world values and the average WLTP values: 
calculation  of  the  “gap”  per  manufacturer,  split  by  powertrain/fuel  type  of  the 
vehicles. 

For  the  fuel  consumption  and  CO2  emissions,  two  different  averages  are  calculated,  as 
follows: 

(a) arithmetic average: 

This  average  gives  equal  weight  to  each  vehicle  in  the  dataset,  independently  of  the 
distance driven. It is calculated as the sum across all vehicles of the fuel consumption (l/100 
km) or CO2 emissions (g/km), divided by the number of vehicles concerned.  

(b) km-weighted average: 

This average takes into account the distance driven by the vehicles as reported in the real-
world dataset. This should give a better picture of the impact of the real-world gap in terms 
of the total additional emissions it causes. However, the calculation is more sensitive to 
bias in the real-world vehicle sample in terms of their distance driven.  

The calculations are set out in more detail in the next sub-sections and the results of the 
calculations are provided in Section 6. 

23 

 
5.1.  Calculation of real-world fuel consumption (l/100 km) for each vehicle 

Each vehicle’s fuel consumption (FC) in l/100 km is calculated as follows: 

𝐹𝐶  =

𝑓𝑢𝑒𝑙𝑡𝑜𝑡
𝑑𝑡𝑜𝑡

× 100

(1) 

where  fueltot (l) is  the total amount of fuel consumed and  dtot (km) is  the total  distance 
travelled. Both of these values are readily available per vehicle as part of the reported data.  

5.2.  Calculation of the real-world CO2 emissions (g CO2/km) for each vehicle 

The real-world CO2 emissions (g CO2/km) of the vehicles are not reported as such but, 
assuming complete combustion and ignoring other gases, they are directly proportional to 
the fuel consumption and can be calculated as follows: 

𝐶𝑂2   = 𝐹𝐶  × 𝐸𝐹

(2) 

The  emission  factor  EF  depends  on  the  properties  of  the  fuel  used  by  the  vehicle.  To 
compare  the  real-world  emissions  with  the  WLTP  emissions,  the  EF  has  been  set  in 
accordance with the reference fuel (26) that was used for the emission testing, as detailed 
in Annex B:  

–  for petrol-fuelled vehicles:   EF = 22.78 (100 g CO2/l) 

–  for diesel-fuelled vehicles:   EF = 26.31 (100 g CO2/l) 

5.3.  Calculation  of  the  average  real-world  and  WLTP  fuel  consumption 
(l/100 km)  for  each  manufacturer,  split  by  powertrain/fuel  type  of  the 
vehicles 

For each manufacturer, the average real-world and WLTP fuel consumption of its M1 and 
N1 vehicles is calculated, split according to the following powertrain/fuel types: 

•  ICEV and NOVC-HEV – petrol 

•  ICEV and NOVC-HEV – diesel 

•  OVC-HEV – petrol 

•  OVC-HEV – diesel 

Both an arithmetic average and a km-weighted average value is calculated. 

The arithmetic average fuel consumption (FCaverage) in l/100 km is calculated by dividing 
the sum of individual vehicle fuel consumptions (see Equation 1) by the number of vehicles 
for the powertrain/fuel type considered (n):  

𝐹𝐶𝑎𝑣𝑒𝑟𝑎𝑔𝑒 =

𝑛
∑ 𝐹𝐶
𝑖=1
𝑛

(3) 

(26)  In reality, the market fuel density may vary depending on the region, country, and ambient temperature, 

therefore this emission factor is a source of uncertainty in the calculation. 

24 

 
 
The  km-weighted  average  fuel  consumption  (FCkm-weighted)  in  l/100  km  is  calculated  by 
dividing the sum of the total amount of fuel consumed by all vehicles (l) by the sum of the 
total lifetime distance travelled by those vehicles (km) and multiplied by 100: 

𝐹𝐶𝑘𝑚−𝑤𝑒𝑖𝑔ℎ𝑡𝑒𝑑 =

𝑛
∑ 𝑓𝑢𝑒𝑙𝑡𝑜𝑡
𝑖=1
𝑛
∑ 𝑑𝑡𝑜𝑡
𝑖=1

×  100

(4) 

These km-weighted values is only calculated as an aggregated value, and not available for 
individual vehicles. 

5.4.  Calculation of the average real-world and WLTP CO2 emissions (g/km) for 

each manufacturer, split by powertrain/fuel type 

Similarly,  as  for  the  fuel  consumption,  for  each  manufacturer,  the  arithmetic  and  km-
weighted  averages  of  the  real-world  and  WLTP  CO2  emissions  of  its  vehicles  are 
calculated, split according to the abovementioned powertrain/fuel types. 

The arithmetic average CO2 emissions are calculated by taking the sum of the individual 
vehicle CO2 emissions (see Equation 2) in the given split, and dividing this by the number 
of vehicles of that same group: 

𝐶𝑂2𝑎𝑣𝑒𝑟𝑎𝑔𝑒  =

𝑛
∑ 𝐶𝑂
𝑖=1
𝑛

2

(5) 

The km-weighted average CO2 emissions (CO2 km-weighted) are  calculated by taking the sum 
across all vehicles of the products of their CO2 emissions (g CO2/km) multiplied by their 
total  lifetime  distance  travelled  (km)  and  dividing  this  by  the  sum  of  the  total  lifetime 
distances (km) of all vehicles, multiplied by 100. These values are therefore only available 
as an aggregated value, and not available per vehicle. 

𝐶𝑂2𝑘𝑚−𝑤𝑒𝑖𝑔ℎ𝑡𝑒𝑑 = ∑ (

𝑛

𝑖=1

𝐶𝑂2 ×   𝑑𝑡𝑜𝑡
𝑛
∑ 𝑑𝑡𝑜𝑡
𝑖=1

) × 100

(6) 

5.5.  Comparison between real-world data and WLTP data and calculation of the 

“gap” 

The  data  linkage  between  the  real-world  and  WLTP  data  through  the  VINs  allows 
comparing  the  average  real-world  performance  of  the  vehicles  in  terms  of  fuel 
consumption and CO2 emissions and their performance as determined through the WLTP. 
The excess fuel consumption and CO2 emissions on the road as compared to the WLTP 
values are referred to as the real-world “gap”. 

The gap can be quantified in several ways. It may be calculated either as the average of all 
individual vehicle gaps or as the difference between the average real-world values and the 
average WLTP values (27).  

As required under Article 12 of Regulation (EU) 2021/392, the second approach has been 
used for this analysis. 

(27)  The  averages  can  be  calculated  at  different  aggregation  levels,  e.g.  at  fleet-wide  level, manufacturer 

level, manufacturer/powertrain type level, country level, etc. 

25 

 
 
The gap can be expressed either in absolute or relative (percentage) terms, as the difference 
between the average real-world and WLTP values: 

𝐺𝑎𝑝 (absolute) = (real-world value)  −  (WLTP value)

𝐺𝑎𝑝 (%) =

(real-world value)  −  (WLTP value)
(WLTP value)

× 100

(7) 

(8) 

5.6.  Calculation of WLTP fuel consumption values 

For the 2021 data, an issue arose as regards the calculation of the fuel consumption gap. 
Member States were required to report the WLTP fuel consumption as part of the annual 
monitoring exercise for vehicle registrations only as of 2022. In 2021, as reporting of this 
parameter was only optional, the value is missing for a quarter of the records in the final 
2021 real-world dataset and a significant number of outliers were identified amongst the 
reported data.  

Instead of the reported WLTP fuel consumption values, one could use the reported WLTP 
CO2  emission  values  and  convert  them  into  their  equivalent  WLTP  fuel  consumption 
values. For this, fixed conversion factors can be applied based on the characteristics of the 
reference fuels used during type-approval in accordance with Regulation (EU) 2017/1151. 
These factors are summarised in Table 8 and explained in more detail in Annex B. 

Table 8: Factors used for converting WLTP CO2 emission values into petrol (E10) and 
diesel (B7) WLTP fuel consumption values based on the reference fuels characteristics 

Fuel type 

Conversion factor (

 𝒍/𝟏𝟎𝟎𝒌𝒎

𝒈𝑪𝑶𝟐/𝒌𝒎

) 

Petrol (E10) 

Diesel (B7) 

0.0439 

0.0380 

For this year, it was decided to use those calculated values for all vehicles to determine the 
fuel consumption gap. This approach allows filling in the missing data as well as correcting 
the many outliers. This approach explains why the CO2 gap and the fuel consumption gap 
are the same within the same powertrain/fuel types. 

It should be noted that this approach does not take into consideration the characteristics of 
the market fuels used and how those vary across  countries or seasons. Therefore, using 
reference fuels based conversion factors for all vehicles introduces an uncertainty in the 
calculations, in particular for countries where the fuel density deviates strongly from the 
average. On a fleet-wide level, as explained in Annex B, this uncertainty is limited.  

26 

 
 
 
 
 
 
 
6.  RESULTS  

The analysis is based on the final real-world dataset, which includes 617 194 M1 vehicles 
and 6 667 N1 vehicles.  

In the next sections, the representativeness of the final real-world dataset with respect to 
the  EU  2021  registrations  is  assessed,  followed  by  a  calculation  of  the  average  fuel 
consumption,  average  CO2  emissions,  and  the  gap  between  the  real-world  and  WLTP 
average values, both at the level of the 2021 new vehicle fleet and for each manufacturer 
separately. In addition, an analysis at country-level is provided. 

6.1. 

Fleet-level assessment  

6.1.1.  Representativeness  of  the  vehicles  in  the  final  real-world  dataset 

compared to the 2021 new vehicle fleet 

The representativeness of the vehicles in the final real-world dataset depends on how well 
the  dataset  reflects  those  vehicles  newly  registered  in  2021.  This  relates  both  to  the 
coverage of the various manufacturers and models in the fleet, as well as the characteristics 
of those vehicles in the real-world dataset compared to the overall 2021 new vehicle fleet. 

The data collected in this first year presents a number of limitations in terms of coverage, 
representativeness  and  quality.  Nevertheless,  while  this  first  data  is  not  yet  broad  or 
representative enough to draw firm conclusions or identify trends, it does provide valuable 
preliminary insights for car emissions. 

The final real-world dataset represents 7.2% of the 2021 first registrations for M1 vehicles. 
By definition, vehicles reported in the first year had been on the road for less than one year. 
Thereby, except for manufacturers making extensive use of over-the-air transmission, data 
was only collected from the limited number of vehicles brought in for service or repairs. 

As discussed in the manufacturer-level assessment in Section 6.2, some manufacturers only 
provided limited data while others had a far better representation. Therefore, the reported 
vehicles  may  not  be  fully  representative  at  a  fleet-wide  level,  as  there  is  insufficient 
coverage of certain manufacturers. Further efforts will be required to significantly improve 
the fleet coverage in the coming year, to ensure representative data from all manufacturers. 

For  N1  vehicles,  the  final  dataset  contains  data  for  only  0.6%  of  newly  registered  N1 
vehicles. This very low reporting of N1 vehicles is primarily due to the fact that in 2021 
the obligation for new N1 vehicles to be applied with OBFCM devices only applied for N1 
class I vehicles. For N1 class II and III vehicles (with a mass greater than 1 305 kg), which 
make up the majority of N1 vehicles, this  requirement only  started to  apply  from  2022 
onwards. Therefore, it is expected that N1 coverage will improve substantially in the next 
years.  

In order to assess the representativeness of the characteristics of the vehicle sample covered 
by the final real-world dataset as compared to the entire 2021 new vehicle fleet (28) (per 
powertrain/fuel  type),  their  average  WLTP  CO2  emissions  and  mass  are  compared,  as 
shown in Table 9. For this comparison, only those vehicles that should be equipped with 

(28)  New vehicles first registered in the EU, Norway or Iceland in 2021. 

27 

 
 
OBFCM are considered, which means that pure electric vehicles, fuel cell electric vehicles 
and gas-fuelled vehicles have been left out from the analysis (29). 

Table  9:  Representativeness  of  the  real-world  dataset  compared  to  the  vehicles  first 
registered in 2021 (M1 vehicles) (30) based on the average WLTP data per fuel type 

Powertrain
/ fuel type 

Average WLTP CO2 
emissions (gCO2/km) 

Average mass in running order 
(kg) 

Share of 2021 
registrations per 
powertrain/ fuel type 

real-
world 
dataset 

145.0 

153.0 

148.5 

2021 first 
registrations 

real-world 
dataset 

2021 first 
registrations 

134.8 

144.7 

137.7 

1 404 

1 747 

1 554 

1 317 

1 627 

1 407 

5.0% 

9.8% 

6.4% 

40.3 

37.7 

1 955 

1 899 

11.7% 

37.2 

37.2 

2 281 

2 291 

44.6% 

39.6 

37.7 

2 021 

1 923 

13.7% 

126.9 

127.2 

1 651 

1 461 

7.2% 

Petrol 

Diesel 

Petrol + 
Diesel 

Plug-in 
hybrid 
(petrol) 

Plug-in 
hybrid 
(diesel) 

Plug-in 
hybrid 
(all) 

All 
vehicles 

This comparison shows that the average WLTP CO2 emissions of all M1 vehicles in the 
real-world dataset are similar to those of the 2021 registrations. However, their average 
mass in running order is nearly 200 kg higher, which indicates that heavier vehicles are 
somewhat  overrepresented  in  the real-world  data. The  fact  that this does  not  lead to  an 
equivalent increase in average CO2 emissions is explained by the far higher share of plug-
in hybrid vehicles in the real-world dataset (20%) compared to the share of plug-in hybrid 
vehicles in the 2021 registrations (9%). 

In view of the higher share of diesel vehicles in the real-world dataset (9.8% of the 2021 
registrations of diesel vehicles) compared to the share of petrol vehicles in that dataset (5% 
of the 2021 registrations of petrol vehicles), as was shown in Table 9, these two groups of 
vehicles should be looked at separately. This is also the case for plug-in hybrid electric 
vehicles,  as  diesel  plug-in  hybrids  (44.6%  of  the  2021  registrations)  are  far  better 
represented in the dataset than petrol plug-in hybrids (11.7% of the 2021 registrations). 

(29) E85 vehicles were also excluded based on high uncertainty as described in Section 3.7.  

(30)  Excluding E85 vehicles, PEVs, FCEVs and gas-fuelled vehicles. 

28 

 
 
 
 
For all vehicle types in the real-world data, except for diesel plug-in hybrid vehicles (31), 
the average WLTP emissions are 6-8% higher and mass around 7% higher than for the 
average  2021  registrations.  While  during  the  WLTP  the  vehicle  mass  is  taken  into 
consideration, the higher mass of the real-world dataset could introduce some bias in the 
comparison between the final real-world data and respective WLTP values, as the relative 
and absolute gaps may differ per weight category.  

In the 2021 N1 real-world dataset, there are only 6 581 petrol/diesel vans and 86 petrol 
plug-in hybrid vehicles.  This represents less than 1% of the 2021 N1 registrations. The 
analysis undertaken is therefore limited and will focus on the conventional vans.  

Looking at the representativeness of these vans in Table 10, the mass in running order of 
the vans in the real-world dataset is 4% lower and these vans have 15% lower emissions 
than the average 2021 newly registered fleet of vans. This indicates that some bias may be 
introduced in the N1 real-world dataset, and relates to the vans not being representative of 
the entire N1 new registered fleet in 2021. Based on this, in the first year only preliminary 
insights can be attained from analysing the N1 vehicles. 

Table 10: Comparison between the real-world  dataset  and the  2021 registrations  (N1 
vehicles) (32) based on the average WLTP data per fuel type 

Powertrain/fuel 
type 

Average WLTP CO2 
emissions (gCO2/km) 

Average mass in 
running order (kg) 

Share of 2021 
registrations per 
powertrain/fuel 
type 

real-
world 
dataset 

137.5 

178.8 

Petrol 

Diesel 

Petrol + Diesel 

172.6 

Plug-in hybrid 
(petrol) 

41.4 

2021 
registrations 

153.1 

202.1 

200.1 

55.5 

real-
world 
dataset 

1 203 

1 916 

1 809 

1 845 

2021 
registrations 

1 272 

1 905 

1 881 

2 081 

All vehicles 

170.9 

200.0 

1 809 

1 881 

2.2% 

0.5% 

0.6% 

5.7% 

0.6% 

6.1.2.  Comparison for M1 vehicles 

6.1.2.1.Fuel Consumption 

Table 11 provides a comparison between the average real-world fuel consumption and the 
average WLTP fuel consumption, calculated as set out in Section 5. Both the arithmetic 
average and km-weighted average values are shown. 

(31)  All diesel plug-in hybrid vehicles in the real-world were reported by Mercedes-Benz AG, and contribute 
45%  of  the  new  diesel  plug-in  hybrid  registrations,  as  such  these  are  representative  of  the  2021 
registrations, but do not provide information on manufacturer variability. 

(32)  As N1 Class II and III vehicles were present, the comparison is performed based on N1 Class I, II and 

III vehicles which will be required to have OBFCM devices 

29 

 
 
 
Table 11:  Average real-world  and WLTP fuel  consumption (FC) (33)  and  % gap (M1 
vehicles) 

real-world 
FC 
(l/100km) 

WLTP FC 
(l/100km) 

gap 
(%) 

real-world 
FC 
(l/100km) 

WLTP FC 
(l/100km) 

gap 
(%) 

arithmetic average 

km-weighted average 

7.89 

6.88 

7.44 

5.97 

6.38 

5.82 

6.13 

1.76 

23.7 

18.1 

21.4 

238 

7.90 

6.69 

7.16 

6.37 

6.56 

5.73 

6.05 

1.81 

20.4 

16.7 

18.3 

251 

5.83 

1.41 

312 

5.94 

1.42 

318 

5.94 

1.69 

251 

6.25 

1.71 

266 

Petrol 

Diesel 

Petrol + Diesel 

Petrol plug-in 
hybrid 

Diesel plug-in 
hybrid 

All plug-in 
hybrid 

In the first year, the average fuel consumption gap was found to be 23.7% (1.51 l/100km) 
for petrol vehicles and 18.1% (1.06 l/100km) for diesel vehicles. For plug-in hybrid electric 
vehicles the gap is much higher: 238% (4.21 l/100km) for petrol OVC-HEV and 312% 
(4.42  l/100km)  for  diesel  OVC-HEV.  The  significance  of  these  gaps,  and  difference 
between ICEV/NOVC-HEVs and OVC-HEVs, will be reflected on with regards to their 
CO2 emissions in the following section. 

The km-weighted average fuel consumption gap is lower than the arithmetic average gap 
for petrol and diesel vehicles. For petrol vehicles, this gap appears to be reduced as the 
average  km-weighted  WLTP  value  is  higher,  while  the  real-world  fuel  consumption 
remains the same. For diesel vehicles, both the km-weighted WLTP and real-world values 
are lower.  

For both petrol and diesel plug-in hybrid electric vehicles, the km-weighted average fuel 
consumption  gap  is  slightly  higher  than  the  arithmetic  average  gap.  This  indicates  that 
overall  OVC-HEV  with  a  higher  mileage  driven  have  a  higher  real-world  fuel 
consumption. This confirms what could be expected: that higher mileage is associated with 
an increased use of the internal combustion engine. 

The  distribution  of  the  real-world  and  WLTP  fuel  consumption  across  the  M1  fleet  is 
shown in Figure 7 for petrol and diesel vehicles, and in Figure 8 for petrol and diesel plug-
in hybrid electric vehicles. 

(33)  WLTP fuel consumption calculated from the WLTP CO2 emissions. 

30 

 
 
 
 
 
Figure  7: Distribution  of  real-world  (blue)  and  WLTP  (orange)  fuel  consumption 
(l/100km) for petrol (left) and diesel (right) M1 vehicles 

Figure  8: Distribution  of  real-world  (blue)  and  WLTP  (orange)  fuel  consumption 
(l/100km) for petrol (left) and diesel (right) plug-in hybrid electric M1 vehicles 

The distribution of the absolute fuel consumption gap per M1 vehicle (l/100 km) can be 
seen in Figure 9. This shows that the gap values for petrol and diesel vehicles fall within 
a far smaller range than those for plug-in hybrid electric vehicles. This also shows that only 
a very limited number of petrol plug-in hybrid electric vehicles (2%) have lower real-world 
emissions  than  under  WLTP,  while  the  majority  have  far  higher  emission  gaps.  This 
indicates that, when vehicles are driven primarily electrically, it is possible to achieve the 
emission reductions under WLTP. 

31 

 
 
 
Figure 9: Distribution of the absolute fuel consumption gap (l/100km) for M1 vehicles 

6.1.2.2.CO2 emissions 

Table 12 provides a comparison between the average real-world CO2 emissions, calculated 
as set out in Section 5, and the WLTP CO2 emissions. Both the arithmetic average and km-
weighted average values are shown.  

Table 12: Average real-world and WLTP CO2 emissions (gCO2/km) and CO2 emissions 
gap (M1 vehicles) 

real-world  
CO2 
emissions 
(g/km) 

WLTP  
CO2 
emissions 
(g/km) 

gap 
(%) 

real-world 
CO2 
emissions 
(g/km) 

WLTP 
CO2 
emissions 
(g/km) 

gap 
(%) 

arithmetic average 

km-weighted average 

179.8 

181.0 

180.3 

135.9 

145.3 

153.2 

148.8 

23.7 

18.1 

21.2 

40.2 

238.1 

179.9 

176.0 

177.5 

145.0 

149.5 

150.7 

150.2 

20.4 

16.7 

18.1 

41.4 

250.5 

153.3 

37.2 

312.1 

156.4 

37.4 

317.8 

139.4 

39.6 

252.1 

148.1 

40.3 

267.3 

Petrol 

Diesel 

Petrol + Diesel 

Petrol plug-in 
hybrid 

Diesel plug-in 
hybrid 

Plug-in 
hybrids 

This shows that the average real-world gap is 23.7% (34.5 g CO2/km) for new petrol cars 
and 18.1% (27.8 g CO2/km) for new diesel cars first registered in 2021, giving a combined 
average gap for ICEV/NOVC-HEV of 21.2% (31.6 g CO2/km) for the vehicles covered by 
the real-world dataset. 

32 

 
 
 
 
 
The km-weighted average gaps are somewhat lower: 20.4%  (30.4 g CO2/km) for petrol 
cars and 16.7% (25.3 g CO2/km) for diesel cars.  

This observed gap for 2021 registrations indicates that the switch from the old NEDC (New 
European Driving Cycle) to the new WLTP testing procedure has about  halved the gap 
between the real-world emissions and those measured through laboratory testing. By 2017, 
the gap between real-world CO2 emissions and CO2 emissions measured under the NEDC 
type-approval  procedure  had  grown  to  around  40% (34).  This  rising  gap  motivated  the 
switch from NEDC to WLTP, and the requirement to fit vehicles with OBFCM devices.  

For  the  Impact  Assessments (35) underpinning  the  revision  of  the  CO2  emission 
performance standards for cars and vans, the Commission assumed that the WLTP CO2 
emissions of combustion engine cars were on average 21% higher than those calculated 
with  the  NEDC,  which  was  later  confirmed  by  a  JRC  study (36).  This  ratio  implies  an 
emissions gap of about 16% between the real-world emissions and the WLTP ones. For 
the year 2021, the gap observed is compatible with the 2021 gap assumed for the Impact 
Assessment underlying the CO2 standards. Such a gap was anticipated as there are different 
factors affecting real-world emissions which cannot all be fully replicated in a laboratory 
test.  

The observed gap also means that the real-world fuel consumption experienced by drivers 
remains  on  average  1-1.5  l/100km  higher,  and  CO2  emissions  are  on  average  25-35  g 
CO2/km higher than what is indicated on the official documents.  

The distribution of the WLTP CO2 emissions and the real-world CO2 emissions of the M1 
real-world vehicles after data processing are depicted in  Figure 10 for petrol and diesel 
vehicles, and in Figure 11 for plug-in hybrid petrol and diesel vehicles.  

(34)  Pavlovic,  J.,  Clairotte,  M.,  Anagnostopoulos,  K.,  Arcidiacono,  V.,  Fontaras,  G.  and  Ciuffo,  B., 
Characterisation  of  real-world  CO2  variability  and  implications  for  future  policy  instruments,  EUR 
28734 EN, Publications Office of the European Union, Luxembourg, 2017, ISBN 978-92-79-72096-3, 
doi:10.2760/839690, JRC107796. 

(35)  SWD(2017)650 final and SWD(2021)613 final. 

(36) Chatzipanagi, A., Pavlovic, J., Ktistakis, M., Komnos, D. and Fontaras, G., Evolution of European light-
duty  vehicle  CO2  emissions  based  on  recent  certification  datasets,  Transportation  Research  Part  D-
Transport and Environment, ISSN 1361-9209, 107, 2022, p. 103287, JRC127295. 

33 

 
 
Figure  10: Distribution  of  real-world  CO2  emissions  (blue)  and  WLTP  emissions 
(orange) for petrol (left) and diesel (right) M1 vehicles 

For the new plug-in hybrid electric cars (OVC-HEVs) registered in 2021, the average real-
world CO2 emissions were on average 3.5 times (100 g CO2/km) higher than their WLTP 
CO2 emissions (39.5 g CO2/km). The emissions of new plug-in hybrid electric cars (139.5 
g  CO2/km)  were  on  average  only  23%  lower  than  for  petrol  and  diesel  vehicles  (180.3 
gCO2/km).  

For those vehicles, the calculation of their WLTP fuel  consumption and CO2 emissions 
takes into account a Utility Factor. In the WLTP, the determination of the Utility Factor, 
which is a measure of the expected proportion of electrified distance driven compared to 
total distance and used for calculating the CO2 emissions of OVC-HEVs, is based on the 
following assumptions: 1) the vehicle starts the travel day with a fully charged battery, 2) 
OVC-HEVs are charged once per day on the days driven, at the end of the last trip, 3) 
additional intra-day charging and vehicles not being charged at the end of the day offset 
each other, 4) specific travel patterns and vehicle use is made depending on the electric 
range (37).  

On the road, the CO2 emissions of those vehicles will depend to a great extent on the real 
share of distance driven electrically, which in turn depends on the actual recharging and 
use patterns.  

Therefore, the gap observed now makes it clear that the OVC-HEV currently on the road 
are not being used in accordance with those assumptions under WLTP, as they are charged 
and driven in electric mode much less than how they were expected to be used, which leads 
to a significant underestimation of the CO2 emissions by the WLTP. This confirms findings 
from previous studies (38), following which the Commission has taken action and amended 
(39) the Utility Factor calculation, which will apply in two consecutive steps, from 2025 

(37)  Seshadri  S.  R.,  Gil  T.,  Plug-in  hybrid  electric  vehicle  observed  utility  factor:  Why  the  observed 
International  Journal  of  Sustainable 
from  expectations, 

electrification  performance  differ 
Transportation, Volume 16, Issue 2, 2022. 

(38)  ICCT (2020): Real-world usage of plug-in hybrid electric vehicles: Fuel consumption, electric driving, 
Transportation: 

and 
https://theicct.org/publications/phev-real-world-usage-sept2020). 

(International 

emissions, 

Council 

Clean 

CO2 

on 

(39)  Commission Regulation (EU) 2023/443 of 8 February 2023 amending Regulation (EU) 2017/1151 as 
regards the emission type approval procedures for light passenger and commercial vehicles (Text with 
EEA relevance), C/2023/843, OJ L 66, 2.3.2023, p. 1–237.  

34 

 
 
 
and  2027  onwards.  Furthermore,  by  the  end  of  2024  and  based  on  the  real-world  data 
collected by then, the Commission will review the factor for the second step.  

Figure 11 shows the distribution of the real-world and WLTP CO2 emissions for plug-in 
hybrid electric M1 vehicles, which confirms the disconnect between both values.  

Figure 11: Distribution of real-world CO2 emissions (blue) and WLTP CO2 emissions 
(orange) for petrol (left) and diesel (right) plug-in hybrid electric M1 vehicles 

As seen in the distribution of CO2 emission gaps in Figure 12, only very few plug-in hybrid 
electric vehicles (1.8% of petrol OVC-HEV and 0.3% of diesel OVC-HEV) were driven 
more efficiently than what their WLTP values indicate.  

Figure 12: Distribution of the CO2 emission absolute gap (g CO2/km) for M1 vehicles 
per powertrain/fuel type 

6.1.2.3.Vehicle mass 

In Figure 13 (petrol vehicles) and Figure 14 (diesel vehicles) the average CO2 emissions 
and gap are shown for groups of vehicles with a similar mass. As expected, vehicles with 
higher mass have increasingly higher emissions, both under WLTP and on the road. 

However,  from  the  real-world  data  it  appears  that  petrol  vehicles  have  an  absolute 
emissions gap which is relatively stable at lower weights at around 20-40 g CO2/km. From 
1 800 kg onwards, the absolute gap appears to grow, with heavier petrol vehicles having 

35 

 
 
 
 
CO2 emissions and a gap in CO2 emissions which is 1.5-2.5 times greater than lighter petrol 
vehicles. 

For  diesel  vehicles,  the  absolute  emissions  gap  also  grows  with  weight.  However,  the 
relative emissions gap (%) is relatively constant for diesel vehicles. 

Figure 13: Distribution of CO2 emissions (bottom), gap (middle) and proportion (top) of 
vehicles based on vehicle mass for petrol cars (ICEVs/NOVC-HEVs) 

While the heavier mass is accounted for in the WLTP, it should be noted that real-world 
vehicle energy consumption is affected by a multitude of factors (40). Hence it is difficult 
to pinpoint the exact causes of the real-world discrepancies observed in the case of heavier 
gasoline and diesel vehicles. Further investigation is necessary. 

(40) Ktistakis, M.A., Tansini,  A., Laverde Marín, A., Suarez Corujo, J., Komnos, D., Fontaras, G., 2022. 
Understanding  the  fuel  consumption  of  plug-in  hybrid  electric  vehicles:  a  real-world  case  study,  in: 
Conference  on  Thermo-and  Fluid  Dynamics  of  Clean  Propulsion  Powerplants.  Presented  at  the 
THIESEL 
Spain. 
2022,  Editorial  Universitat 
https://doi.org/10.4995/Thiesel.2022.632801. 

de  València,  Valencia, 

Politècnica 

Pavlovic,  J.,  Fontaras,  G.,  Ktistakis,  M. et  al. Understanding  the  origins  and  variability  of  the  fuel 
consumption gap: lessons learned from laboratory tests and a real-driving campaign. Environ Sci Eur 32, 
53, 2020. https://doi.org/10.1186/s12302-020-00338-1. 

36 

 
 
 
 
 
Figure 14: Distribution of CO2 emissions (bottom), gap (middle) and proportion (top) of 
vehicles based on vehicle mass for diesel cars (ICEVs/NOVC-HEVs) 

6.1.3.  N1 vehicles: Fuel Consumption and CO2 emissions 

The 2021 final real-world dataset included 6 581 ICEV/NOVC-HEV vans and 86 OVC-
HEV vans. As there was no obligation for N1 Class II and III vehicles to have an OBFCM 
device equipped in 2021, and as there are fewer than 1% of N1 vehicles for which data 
was reported, the results in this section are merely indicative and cannot be considered as 
representative for the N1 fleet.  

As can be seen in Table 13, the average fuel consumption and CO2 emissions gap for petrol 
and  diesel  vans  was  18.6%  (1.13  l/100km,  25.5  g/km)  and  16.5%  (1.12  l/100km,  29.4 
g/km) respectively.  

In  the  limited  sample  of  N1  petrol  plug-in  hybrids,  the  fuel  consumption  gap  and  CO2 
emissions gap appears to follow a similar trend as in M1 vehicles, with the average real-
world  fuel  consumption  and  CO2  emissions  of  these  vehicles  being  three  times  greater 
(207%) than the tested emissions. 

37 

 
 
 
 
Table 13: Average real-world  and WLTP fuel  consumption (FC), CO2 emissions and 
gap for N1 vehicles  

average  
real-world 
FC 
(l/100km) 

average  
WLTP  
(41) FC 
(l/100km) 

average  
real-world  
CO2 
emissions 
(gCO2/ 
km) 

average  
WLTP 
CO2 
emissions 
(gCO2/ 
km) 

arithmetic 
average  
gap (%) 

km-
weighted 
average  
gap (%) 

7.16 

7.92 

7.80 

6.03 

6.80 

6.68 

163.0 

208.2 

201.5 

137.5 

178.8 

172.6 

18.6 

16.5 

16.7 

14.8 

14.0 

14.0 

5.58 

1.82 

127.1 

41.4 

207.3 

201.1 

Petrol 

Diesel 

Petrol + 
Diesel 

Petrol 
plug-in 
hybrid 

6.2.  Manufacturer-level assessment 

In accordance with Article 12 of Regulation (EU) 2021/392, the Commission must publish 
anonymised and aggregated datasets per manufacturer, split between passenger cars and 
light commercial vehicles powered by internal combustion engines (ICEV/NOVC-HEV), 
and off-vehicle charging hybrid electric vehicles (OVC-HEV). These datasets for the 2022 
reporting year, covering vehicles first registered in the EU in 2021, are provided in Annex 
D. 

6.2.1.  Coverage  of  the  vehicle  manufacturers  2021  fleet  in  the  final  real-

world dataset 

The  number  of  vehicles  reported  per  manufacturer  and  retained  in  the  final  real-world 
dataset after data processing,  as well as  the coverage of the  2021  registrations  for each 
manufacturer are shown in Figure 15. A table with the underlying data is provided in Annex 
A. 

This  illustrates  the  significant  variability  in  coverage  amongst  manufacturers.  This  also 
shows that in this first reporting year and after data processing only a few manufacturers 
achieved meaningful coverage of their fleet of vehicles registered in 2021, in particular 
Jaguar  Land  Rover  Limited  (43%),  Ford  Werke  GMBH  (34%),  Ford  Motor  Company 
(27%), Mercedes-Benz AG (27%), and Volvo (24%).  

The variability can in part be explained by the different degree to which the available data 
collection options were used, with only a few manufacturers making comprehensive use 
of over-the-air data transmissions. 

As can be seen in  Figure 16,  which shows how many manufacturers reported a certain 
percentage of their fleet, over half of manufacturers (26) reported fewer than 5% of their 

(41)  WLTP fuel consumption converted from the WLTP CO2 emissions. 

38 

 
 
 
 
vehicles first  registered in 2021, and nine manufacturers  even  reported less  than 1% of 
their vehicles.  

While certain manufacturers had higher initial coverage before data processing, the low-
mileage filter reduced a significant number of vehicles. This was the case for Volvo and 
Jaguar Land Rover, which had the highest initial coverage, but a large portion (70% for 
Volvo and 31% for JLR) of the reported vehicles had driven less than 500 km. 

Figure  15: Number  of  vehicles  reported  per  manufacturer  (left)  and  coverage  (%)  of 
2021 registrations covered by the real-world dataset (right) before (blue) and after (red) 
data processing 

39 

 
 
  
Figure  16: Vehicle  fleet  coverage  in  the  final  2021  real-world  dataset  (%)  per 
manufacturer  

After data processing, the real-world dataset consists mainly of vehicles by Ford Werke 
GMBH (23%) and Mercedes-Benz AG (21%). Together with Volvo (9%), Volkswagen 
(9%) Renault (7%), BMW AG (6%), these 6 manufacturers make up three quarters of the 
real-world data. 

For  plug-in  hybrid  electric  vehicles,  the  real-world  data  is  dominated  by  five 
manufacturers:  Mercedes-Benz  AG  (40%),  Volvo  (20%),  Ford  Werke  GMBH  (16%), 
BMW AG (6%), and Volkswagen (5%), who contribute 88% of the real-world OVC-HEV 
data. For the diesel plug-in hybrid vehicles, these were all reported by Mercedes-Benz AG, 
the only manufacturer which registered diesel plug-in hybrids in 2021. 

When interpreting and comparing the results of the manufacturer level calculations for this 
first reporting year, these differences in fleet coverage across manufacturers should be duly 
taken into account, in particular for those cases where very few vehicles were reported.  

Several manufacturers had communicated issues  with the retrieval of data, in particular 
with  relation  to  vehicles  not  returning  to  dealership  within  the  first  year  and 
implementation  of  the  reporting  requirements,  causing  only  a  low  share  of  their  2021 
registrations to be reported. Following discussions with certain manufacturers who faced 
severe delays in implementing OBFCM devices and collecting data from these devices, 
these were advised to report data in the following year to ensure a more comprehensive 
coverage. 

Overall, for most manufacturers, the fleet  coverage was below expectations  and further 
steps should be taken to significantly improve this in the coming years, both for cars and 
vans. To ensure a more comprehensive dataset, and understanding the reasons why data is 
missing, as of April 2023 it will be mandatory for all manufacturers to report the reasons 
why data was not reported for vehicles registered in 2021.  

40 

 
 
 
 
6.2.2.  CO2 emissions and fuel consumption gap  

6.2.2.1.ICEVs and NOVC-HEVs  

The average CO2 emissions, fuel consumption, and gaps per manufacturer are provided in 
Figure 17 for petrol vehicles.  

While  the  fleet-wide  average  gap  is  23.7%  (34.5  g  CO2/km  or  1.51  l/100km),  the 
manufacturer-specific gaps range from 1% (1 g CO2/km or 0.04 l/100km) to 45% (132 g 
CO2/km or 5.8 l/100km). The highest and lowest gaps are observed for manufacturers with 
few vehicles reported, causing higher uncertainties.  

Considering only manufacturers with over 500 petrol vehicles in the final dataset, the gaps 
range from 9% (11 gCO2/km or 0.5 l/100km) to 32% (82 gCO2/km or 3.6 l/100km).  

Figure  17: Petrol  M1  vehicles  average  real-world  (blue)  and  WLTP  (orange)  CO2 
emissions  and  fuel  consumption  (left),  absolute  real-world  gap  (middle),  and  relative 
real-world gap (right) per manufacturer (42) 

For  diesel  vehicles,  the  fleet-wide  average  CO2  emissions  and  fuel  consumption  gap  is 
18.1% (27.8 gCO2/km or 1.06 l/100km). As shown in Figure 17, the manufacturer-level 
gaps range from 14% (18 gCO2/km or 0.7 l/100km) and 27% (41 gCO2/km or 1.6 l/100km). 
Similar  to  petrol  vehicles,  the  highest  and  lowest  CO2  emissions  gaps  are  observed  for 
manufacturers with few vehicles reported. The gap for diesel vehicles varies less across 
manufacturers. 

(42)  Ordered by number of vehicle registrations reported and retained in the final dataset. 

41 

 
 
 
 
 
Figure  19: Diesel  M1  vehicles  average  real-world  (blue)  and  WLTP  (orange)  CO2 
emissions and fuel consumption (left), absolute gap (middle) and relative gap (right) per 
manufacturer 

6.2.2.2.OVC-HEVs  

The  average  CO2  emissions,  average  fuel  consumption  and  gap  per  manufacturer  are 
shown in Figure 21 for petrol plug-in hybrid electric vehicles.  

This  indicates  that  the  average  gap  per  manufacturer  for  petrol  plug-in  hybrid  vehicles 
ranges from 161% to 428%, compared to the average fleet-wide gap of 238%. The absolute 
gap ranges between 2.4 l/100km and 13.2 l/100km (average fleet-wide is 4.2 l/100km), or 
54 gCO2/km and 300 gCO2/km (average fleet-wide is 95.7 gCO2/km). Most manufacturers 
have a gap between 190-320%, and with an absolute gap between 3-5 l/100km or 70-120 
gCO2/km. 

This  indicates  that,  irrespective  of  the  manufacturer,  the  current  use  of  plug-in  hybrid 
electric vehicles does not correspond to what was assumed under the WLTP. However, 
there are still large discrepancies between manufacturers. 

42 

 
 
 
 
 
 
 
 
Figure  21: Petrol  plug-in  hybrid  vehicles  (M1)  average  real-world  (blue)  and  WLTP 
(orange) CO2 emissions and fuel consumption in l/100km (left), absolute real-world gap 
(middle) and relative real-world gap (right) per manufacturer 

6.3.  Country-level assessment  

In  this  Section,  the  real-world  data  is  assessed  at  country  level,  to  find  out  whether 
geographical differences between the gaps can be observed. Differences may exist due to 
differing landscapes, ambient temperatures, driving habits, fuel densities, and, in the case 
of plug-in hybrid electric vehicles, enabling policies and frameworks and the availability 
of charging infrastructure. 

For this analysis, the countries referred to are those in which the vehicle had been  first 
registered, as reported in the WLTP dataset. It may of course be the case that the vehicles 
are (also) driven in another country during their lifetime, but this can not be found out from 
the data. 

6.3.1.1.ICEVs and NOVC-HEVs  

Figure 23 shows the average real-world CO2 emissions and fuel consumption and the gap 
per country for petrol M1 vehicles. Leaving apart the countries with a very low number of 
vehicles in the dataset, which show very low (Iceland, Norway), or very high (Malta) gaps 
due to the specifics of the fleet or a few outliers, the findings are as follows. 

For the four countries with the highest number of petrol vehicles in the real-world dataset 
the gap ranges from 23% to 26%. 

Countries with the highest relative gap are Romania (36%, 5 738 vehicles), Greece (34%, 
2 578 vehicles), Cyprus (33%, 296 vehicles), Bulgaria (33%, 533 vehicles) and Portugal 
(32%, 3 592 vehicles), followed by Croatia (28%, 632 vehicles) and Poland (28%, 16 435 
vehicles).  

43 

 
 
 
The  countries  with  the  lowest  relative  gap  are  Finland  (13%,  3 361  vehicles),  Sweden 
(14%, 5 482 vehicles), Denmark (17%, 4 048 vehicles), Slovakia (18%, 1 957 vehicles), 
Estonia (18%, 435 vehicles), and the Netherlands (18%, 11 126 vehicles).  

Figure  23: Petrol  M1  vehicles  average  real-world  (blue)  and  WLTP  (orange)  CO2 
emissions and fuel consumption (left), absolute and relative real-world gap (middle and 
right) per country of first registration 

For diesel vehicles, the results are presented in Figure 25, which shows a similar pattern 
as for petrol cars, with lower gaps observed in Finland, Sweden, Denmark, Estonia, and 
the  Netherlands,  and  higher  gaps  for  Poland,  Romania,  Bulgaria,  Greece,  Cyprus,  and 
Croatia (43).  

The variations observed for petrol and diesel vehicles seem to point at lower gaps found 
for northern  countries, and higher gaps for southern or eastern countries. Various other 
elements could play a role in this, including ambient temperature (affecting the use of air 
conditioning and heating systems), fleet composition, driving behaviour and vehicle use 
patterns (speed, trip distance, etc.). There are also differences between the average fuel 
density of market fuels in northern countries and southern countries, as described in Annex 
B, which add uncertainty to the results. In particular, the average market fuel density in 
Finland and Sweden is lower throughout the year than other countries, which may in part 
explain  the  lower  gap  when  a  conversion  is  performed  using  reference  fuels.  Further 
analysis  is  needed  to  better  understand  whether  the  WLTP  representativeness  really  is 
country-dependent and what could be the underlying drivers. 

(43)  Leaving out the countries with  very few (less than 100) diesel vehicles in the real-world dataset, i.e. 

Malta (12 vehicles), Iceland (55 vehicles), and Norway (88 vehicles). 

44 

 
 
 
 
 
Figure 25: Diesel M1 vehicles average real-world CO2 emissions and fuel consumption 
(left) and real-world gap (right) per country of first registration 

6.3.1.2.OVC-HEVs  

The average real-world CO2 emissions and fuel consumption as well as the real-world gap 
per  country  of  first  registration  for  petrol  plug-in  hybrid  electric  vehicles  are  shown  in 
Figure 27. An analysis of CO2 emisisons of plug-in hybrids per country can provide an 
indication of how well countries promote the electric driving and charging of these vehicles 

For the countries  with  more than 500 vehicles in  the real-world  dataset, the  gap ranges 
from  176% (75 g  CO2/km) for Finland to  287%  (124 gCO2/km)  for Poland. High gaps 
were also found for vehicles first registered in Romania (284%, 117 g CO2/km), Germany 
(276%,  103  g  CO2/km),  Hungary  (271%,  116  g  CO2/km),  and  France  (250%,  106  g 
CO2/km).  

For only three countries the gap was below 200%: Finland (176%, 76 g CO2/km), Ireland 
(180%, 82 g CO2/km) and Sweden (183%, 84 g CO2/km). 

45 

 
 
 
Figure 27: Petrol plug-in hybrid electric M1 vehicle average real-world CO2 emissions 
and fuel consumption (bottom) and real-world gap (top) per country of first registration 

The average real-world CO2 emissions and fuel consumption as well as the real-world gap 
per  country  of  first  registration  for  diesel  plug-in  hybrid  electric  vehicles  are  shown  in 
Figure 29.  

For countries with more than 500 vehicles in the real-world dataset, the gap ranges from 
240% (87 g CO2/km) for Sweden to 385% (131 gCO2/km) for Italy. No country had a gap 
below 200%. 

Figure 29: Diesel plug-in hybrid electric M1 vehicles average real-world CO2 emissions 
and fuel consumption (bottom) and real-world gap (top) per country of first registration 

46 

 
 
 
 
Annex A 

List of manufacturers  

Manufacturers that were expected to report real-world data in 2022 

Manufacturer 

Reported 
vehicles 
(M1)  

Final 
(M1) 

Percentage 
reported of 
2021 M1 
registration
s  

ALFA ROMEO 
AUDI AG 
AUDI HUNGARIA 
AUDI SPORT 
AUTOMOBILES 
CITROEN 
AUTOMOBILES 
PEUGEOT 
BENTLEY 
BMW AG 
BMW GMBH 
CHRYSLER 
DACIA 
DFSK 
FERRARI 
FIAT GROUP 
FORD MOTOR 
COMPANY 
FORD WERKE 
GMBH 
GENERAL MOTORS 
HOLDINGS LLC 
HYUNDAI 
HYUNDAI ASSAN 
HYUNDAI CZECH 
HONDA MOTOR CO 
LTD 
IVECO 
JAGUAR LAND 
ROVER LIMITED 
KIA 
KIA SLOVAKIA 
MAGYAR SUZUKI 
MAHINDRA 
MAN 
MAZDA 
MERCEDES AMG 

2 185 
17 670 
71 
683 
12 418 

2 147 
13 347 
44 
464 
4 324 

18 670 

9 191 

359 
39 899 
1 577 
6 699 
16 073 
0 
151 
25 429 
831 

71 
37 432 
1 519 
5 804 
15 248 
0 
149 
22 657 
811 

139 888 

136 633 

0 

0 

361 
543 
1 819 
0 

328 
527 
1 792 
0 

0 
49 262 

0 
27 101 

1 481 
2 288 
3 628 
0 
0 
6 418 
129 

1 137 
1 781 
2 798 
0 
0 
2 116 
95 

47 

9.4 
4.4 
2.4 
6.2 
4.3 

6.9 

23.8 
6.7 
16.1 
10.0 
12.0 
0 
4.6 
5.9 
27.6 

35.0 

0 

0.5 
0.5 
1.0 
0 

0 
77.7 

0.8 
1.3 
4.6 
0 
0 
6.5 
16.0 

Percenta
ge final 
of 2021 
M1 
registrat
ions  
9.3 
3.3 
1.5 
4.2 
1.5 

Report
ed N1 
vehicle
s  

48 
0 

0 

0 
800 

Final 
N1 

46 
0 

0 

0 
43 

3.4 

1 189 

38 

4.7 
6.3 
15.5 
8.3 
11.4 
0 
4.5 
5.3 
26.9 

0 

2 

0 
202 
0 

0 

0 
688 
0 

0 

2 

0 
195 
0 

0 

0 
629 
0 

34.2 

971 

963 

0 

0.4 
0.5 
1.0 
0 

0 
42.7 

0.6 
1.0 
3.6 
0 
0 
2.1 
11.8 

0 

0 

0 

0 

0 

5 
2 25
3 

9 

0 

0 

0 
30 
3 

0 

0 

0 

0 

0 

0 

0 
1 691 

9 

0 

0 

0 
24 
0 

0 

 
 
 
 
MERCEDES-BENZ 
AG 
MITSUBISHI 
MOTORS 
CORPORATION 
MITSUBISHI 
MOTORS THAILAND 
NISSAN 
AUTOMOTIVE 
EUROPE 
OPEL AUTOMOBILE 
PORSCHE 
PSA  
RENAULT 
ROLLS ROYCE 
SAIC MOTOR 
CORPORATION 
SEAT 
SKODA 
SSANGYONG 
MOTOR COMPANY 
SUBARU 
SUZUKI MOTOR 
CORPORATION 
TOYOTA 
TOYOTA MOTOR 
CORPORATION 
VOLKSWAGEN 
VOLVO 
ZHEJIANG GEELY 
AUTOMOBILE CO 
LTD 

175 633 

127 517 

6 

3 

6 

3 

9 541 

6 872 

5 599 
8 726 
46 459 
49 288 
22 
88 

8 947 
9 278 
0 

13 
2 928 

6 806 
61 

2 457 
3 402 
17 944 
41 524 
20 
29 

6 712 
7 646 
0 

10 
2 263 

6 386 
52 

65 219 
179 006 
0 

54 993 
51 784 
0 

36.8 

0.02 

0.01 

6.2 

3.0 
18.7 
6.6 
7.9 
9.1 
1.0 

2.9 
2.0 
0 

0.08 
3.2 

1.1 
0.3 

7.0 
82.2 
0 

26.7 

524 

115 

0.02 

0 

0 

0.01 

0 

0 

4.5 

56 

32 

1.3 
7.3 
2.6 
6.7 
8.3 
0.3 

2.1 
1.7 
0 

0.06 
2.5 

1.0 
0.2 

5.9 
23.8 
0 

74 
0 
836 
16 
0 

0 

4 

0 

0 

0 
273 

55 
0 

10 
0 
119 
16 
0 

0 

4 

0 

0 

0 
110 

42 
0 

3 399 
864 
0 

2 487 
92 
0 

Manufacturer(s) voluntarily reporting 2021 real-world data 

Manufacturer 

Reported 
vehicles 
(M1)  

Final 
(M1) 

Percentage 
reported  of 
2021  M1 
registrations  

Percentage 
final of 2021 
M1 
registrations  

Reported 
N1 
vehicles  

Final 
N1 

CNG 
TECHNIK 

63 

58 

6.2 

5.7 

0 

0 

48 

 
 
 
 
Annex B 

Conversion from real-world fuel consumption 
to  CO2  emissions  and  from  WLTP  CO2 
emissions to fuel consumption 

As the OBFCM devices record the fuel consumption of the vehicles, their corresponding 
real-world  CO2  emissions  have  to  be  calculated.  The  CO2  emissions  of  a  vehicle  are 
directly proportional to its fuel consumption according to the following formula: 

𝐶𝑂2  [

𝑔
𝑘𝑚

] = 𝐹𝐶  [

𝑙
100 km

] × 𝐸𝐹 

where the conversion factor EF depends on two parameters: 

–  the density of the fuel (g/l) 

–  the carbon content of the fuel (kg CO2 /kg fuel) 

To  determine  these  two  parameters,  different  approaches  were  considered,  using 
specifications of  either reference fuels  or market fuels. The results of those approaches 
showed limited variability. 

For new vehicles registered in 2021, fuel consumption was an optional parameter under 
the WLTP data reporting. This caused many records to be missing this entry and, for many 
of the values reported, there were doubts about their accuracy. Therefore, in order to allow 
comparison with the real-world fuel consumption values, it was decided not to rely on the 
reported  fuel  consumption  values,  but  to  calculate  the  2021  WLTP  fuel  consumption 
values from the reported WLTP CO2 emissions. As of 2022, it is mandatory to report the 
fuel consumption parameter as part of the WLTP data reporting. 

In order to ensure consistency between the WLTP and real-world data, it was also decided 
to use the reference fuels characteristics as the basis for both for the conversion from real-
world fuel consumption to CO2 emissions and for the conversion of WLTP CO2 emissions 
to fuel consumptions. 

UN Regulations Nos. 83 (44)  and 101 (45)  provide the specifications for the  density and 
carbon content of the reference fuels to be used at type-approval. Based on the average 
fuel  density  values from  those Regulation, the EF  values shown  in  Table 14 have been 
calculated. 

(44)  Regulation No 83 of the Economic Commission for Europe of the United Nations (UN/ECE) – Uniform 
provisions concerning the approval of vehicles with regard to the emission of pollutants according to 
engine fuel requirements (OJ L 375 27.12.2006, p. 223) 

(45)  Regulation  No  101  of  the  Economic  Commission  for  Europe  of  the  United  Nations  (UN/ECE) — 
Uniform provisions concerning the approval of passenger cars equipped with an internal combustion 
engine with regard to the measurement of the emission of carbon dioxide and fuel consumption and of 
categories M1 and N1 vehicles equipped with an electric power train with regard to the measurement of 
electric energy consumption and range (OJ L 95 31.03.2004, p. 89) 

49 

 
 
 
Table 14: Emission factors of petrol (E10) and diesel (B7) 

Fuel 

E10 

B7 

Density range 
(g/l) 

Average 
density (g/l) 

Carbon content (100 kg/kg) 

EF 

743.0 – 756.0  

749.5 

833.0 – 837.0 

835.0 

0.03039 

0.03151 

22.78 

26.31 

These EF have been used for the conversion of the real-world fuel consumption into CO2 
emissions. For the conversion of the WLTP CO2 emissions into fuel consumption values, 
the inverse of these EF values (1/EF) are applied. 

A  drawback  of  this  simplified  approach  is  that  the  emission  factors  are  determined 
assuming a specific blend, while the real-world data is reported on a vehicle lifetime basis, 
during which different market fuel blends might have been used.  

Insight on the fuels actually put on the market in the EU can be found in the Technical 
Assessment of Transport Fuel Quality Parameters report (46), which summarises ranges of 
densities for petrol and diesel respectively according to standards EN 228 and EN 590, and 
in  the  EEA  Quality  and  greenhouse  gas  intensities  of  transport  fuels  in  the  EU  in 
2017 report (47), which provides fuel density values depending on countries/regions and 
seasons (winter/summer/whole year). 

As  shown  in  Figure  31,  the  density  of  the  reference  diesel  fuel  falls  within  the  range 
observed in most Member States, across all seasons, except for Estonia (winter), Finland 
and Sweden (both winter and summer).  

Figure 31: Density distribution of diesel per country 

(46)  Technical  Assessment  of  Transport  Fuel  Quality  Parameters  –  Final  report  –  Study  contract  no. 
https://op.europa.eu/en/publication-detail/-

340201/2019/815556/ETU/CLIMA.C4: 
/publication/0dd983bf-ee82-11eb-a71c-01aa75ed71a1/language-en  

(47) https://www.eea.europa.eu/publications/quality-and-greenhouse-gas-intensities-1/at_download/file  

50 

 
 
 
 
Annex C 

Electric energy consumption and utility factor 
(plug-in hybrid electric vehicles) 

For OVC-HEVs, next to the calculations regarding CO2 emissions and fuel consumption, 
Implementing Regulation (EU) 2021/392 also foresees the calculation of the average real-
world  electric  energy  consumption  (kWh/100km)  and  a  comparison  with  the  WLTP 
electric energy consumption recorded in the certificate of conformity. This analysis would 
seek  to  understand  the  efficiency  of  the  vehicle’s  electric  powertrain  when  operated  in 
charge depleting mode, i.e. when the electric engine is contributing to the driven distance. 

However,  in  undertaking  this  analysis,  a  number  of  issues  have  arisen,  in  particular  as 
regards  the  calculation  of  the  electric  energy  consumption  value  in  the  real-world,  and 
which WLTP value to compare this to. 

A first question is how to compare the real-world electric energy consumption calculated 
on  the  basis  of  the  data  read  out  from  the  OBFCM  devices  with  the  electric  energy 
consumption value recorded in the certificate of conformity. The latter is a utility factor-
weighted  value,  which  only  provides  an  indication  of  the  expected  average  electric 
consumption  per  km  (Wh/km)  over  the  lifetime  of  a  vehicle  if  it  were  to  be  driven  as 
assumed  under  the  WLTP  conditions,  i.e.  with  the  same  charging  and  electric  driving 
behaviour. Meanwhile, calculating the electric energy consumption gap on the basis of the 
real-world data is not straightforward, as there are various methods to do so, and because 
OVC-HEVs having multiple operating modes (charge depleting with the engine on, charge 
depleting without the engine on, charge increasing, and charge sustaining). 

In relation to this, a second question arises on how to calculate a “real-world” utility factor 
(share  of  charge  depleting  driving),  which  could  usefully  be  compared  with  the  utility 
factor determined during type-approval. 

These issues are elaborated on in the following Sections of this Annex. 

1.  REAL-WORLD AND COC ELECTRIC ENERGY CONSUMPTION VALUES  

As it is not possible to know at type-approval to what degree a vehicle will be driven in 
charge depleting mode throughout its lifetime, an assumption has to be made to allow to 
the calculation of combined values covering all of the driving modes. This is the aim of 
the ‘utility factor’, which assigns the charge depleting and charge sustaining operation with 
a  meaningful  lifetime  statistical  significance  (i.e.  weight),  to  obtain  a  likely  real-world 
performance based on the WLTP test cycles.  

The determination of the utility factor in type-approval (WLTP) is based on the vehicle’s 
electric  range,  as  well  as  a  number  of  assumptions  regarding  its  use,  in  particular  the 
charging  pattern  (starting  everyday  from  a  full  charge)  and  the  daily  driven  distance 
(probability  of  driving  short  versus  long  distances,  as  specified  in  standard  SAE 
J2841 (48)). Through the utility factor weighting, the overall OVC-HEV fuel consumption, 
CO2 and pollutants emissions and electric energy consumption are calculated. 

(48)  Hybrid-EV  Committee,  2010,  Utility  Factor  Definitions  for  Plug-In  Hybrid  Electric  Vehicles  Using 

Travel Survey Data, J2841_201009. 

51 

 
 
In the certificate of conformity of OVC-HEVs there is only one value reported for electric 
energy  consumption:  𝐸𝐶𝐴𝐶,𝑤𝑒𝑖𝑔ℎ𝑡𝑒𝑑.  This  is  the  utility  factor-weighted  electric  energy 
consumption,  based  on  the  electric  energy  from  the  mains  (Wh/km).  It  represents  the 
expected lifetime average electric energy consumption from driving with a certain mix of 
charge depleting and charge sustaining modes. This means that this value does not provide 
an indication of the average electrical consumption of the battery when the electric engine 
is engaged. It is only a representative value under the same charging frequency and driving 
habits  as  assumed  at  type-approval.  Therefore,  in  order  to  provide  a  meaningful 
comparison with the average real-world electric consumption, this value would have to be 
decoupled from the utility factor. Otherwise, vehicles which have been driven electrically 
minimally  would  have  a  lower  value  for  the  electric  consumption  in  kWh/100km  than 
𝐸𝐶𝐴𝐶,𝑤𝑒𝑖𝑔ℎ𝑡𝑒𝑑, only  reflecting the utility  of the vehicle rather than the  efficiency of the 
electric powertrain. 

The electric energy consumption of OVC-HEVs on the road can be calculated from the 
data read-out from the OBFCM devices in different ways.  

One  way  to  do  so  is  to  divide  the  total  lifetime  amount  of  grid  energy  into  the  battery 
(gridtot) in kWh by the total lifetime distance travelled (dtot): 

𝐸𝐶𝐴𝐶,𝑅𝑊 [𝑘𝑊ℎ/100 𝑘𝑚] =

𝑔𝑟𝑖𝑑𝑡𝑜𝑡[𝑘𝑊ℎ]
𝑑𝑡𝑜𝑡[𝑘𝑚]

× 100 

When using this approach, it should be taken into account that the value gridtot does not 
include the losses taking place during a charging event between the mains and the vehicle’s 
battery. It therefore represents the energy recharged at the level of the battery, which is 
lower than the energy supplied by the mains.  

The value 𝐸𝐶𝐴𝐶,𝑅𝑊 gives an indication of the electric energy consumption consumed over 
the lifetime of the vehicle. However, it does not give an indication of how efficient the 
electric  engine  has  been  running.  To  meaningfully  compare  this  value  with  the  electric 
energy consumption (ECAC, weighted) recorded in the certificate of conformity, the real-world 
charging behaviour and driving habits (i.e. real-world utility factor) should be taken into 
account.  Otherwise,  the  comparison  between  𝐸𝐶𝐴𝐶,𝑤𝑒𝑖𝑔ℎ𝑡𝑒𝑑  and  𝐸𝐶𝐴𝐶,𝑅𝑊  would  mostly 
provide an indication of the laboratory-to-real-world difference in utility factor rather than 
of  the  difference  in  the  electric  energy  consumption  of  the  vehicle  in  charge  depleting 
mode. 

A second option for comparing the electric energy consumption in WLTP and real-world 
conditions could be to use the Equivalent All-Electric Range (EAER) (49). In the WLTP 
this is defined as the portion of the total charge-depleting actual range (RCDA) attributable 
to  the  use  of  the  electricity  from  the  Rechargeable  Electric  Energy  Storage  System 
(REESS) over the charge-depleting range test. Similarly, the EAER in the real-world could 
be determined by taking the distance in charge-depleting mode that can be attributed to the 
use of the electric motor. While this would decouple the electric energy consumption from 
the utility factor, the calculation of the electric energy consumption based on the EAER 
determined  in  the  WLTP  requires  further  information  specific  to  charge  sustaining  and 
charge depleting driving during the WLTP, which is not readily available. 

(49)  ICCT, Plug-in hybrid vehicle CO2 emissions: How they are affected by ambient conditions and driver 

mode selection, 2021 

52 

 
 
One  way  to  determine  the  real-world  EAER  is  by  using  the  calculated  average  fuel 
consumption in charge sustaining mode (FCCS), the average fuel consumption while the 
vehicle is in charge depleting mode with the engine running (FCCD,Engine on ), and the total 
distance driven in the charge depleting modes (dCD,Eng off and dCD,Eng on), as suggested by 
the ICCT in their 2021 White Paper (50): 

𝐸𝐴𝐸𝑅𝑟𝑒𝑎𝑙−𝑤𝑜𝑟𝑙𝑑 = 𝑑𝐶𝐷,𝐸𝑛𝑔 𝑜𝑓𝑓 + (

𝐹𝐶𝐶𝑆 − 𝐹𝐶𝐶𝐷,𝐸𝑛𝑔𝑖𝑛𝑒 𝑜𝑛
𝐹𝐶𝐶𝑆

) × 𝑑𝐶𝐷,𝐸𝑛𝑔 𝑜𝑛 

The average real-world electric consumption could then be calculated as follows: 

𝐸𝐶𝐼𝐶𝐶𝑇 [

𝑘𝑊ℎ
100𝑘𝑚

] =

𝑔𝑟𝑖𝑑𝑡𝑜𝑡
𝐸𝐴𝐸𝑅𝑟𝑒𝑎𝑙−𝑤𝑜𝑟𝑙𝑑

The  key  condition  for  applying  this  approach  is  that  the  average  charge-depleting  fuel 
consumption  with  the  engine  running  (FCCD,Engine  on)  is  lower  than  the  average  charge 
sustaining fuel consumption (FCCS). While this would generally be expected to be the case, 
as the charge-depleting operation would use energy stored in the battery with the aim of 
reducing fuel consumption, analysis of OBFCM data showed that this only applies when 
taking both  the distance  in  charge depleting  operation with  the engine off and  with  the 
engine  on  into  consideration  for  the  calculation  of  the  average  charge-depleting  fuel 
consumption (FCCD). Possible reasons for this are being further investigated. 

An approximation of the real-world EAER could be made if the majority of the charge-
depleting driving occurred with the engine off, i.e. fully electric. This would simplify the 
equation by only dividing the total grid energy (gridtot) by the distance in charge depleting 
with the engine off (dCD,Eng off). However, based on the real-world data, such approximation 
is often not possible as the aforementioned condition is not met.  

Because of the elements described above, it is concluded that the calculation of the charge 
depleting  electric  energy  consumption  on  a  per-vehicle  basis  is  currently  not  possible 
without combining the real-world data with other datasets. Given that the conditions for 
this analysis are not met, alternative ways for assessing the energy consumption of OVC-
HEVs need to be explored further to provide a meaningful comparison between the real-
world and WLTP.  

2.  UTILITY FACTOR (%)  

2.1.  Calculation methodologies 

The concept of the utility factor (‘UF’) is defined in UN Regulation 154, based on driving 
statistics, as the ratio between the range achieved in charge-depleting conditions and the 
total  driven  distance,  and  is  used  to  weigh  the  charge-depleting  and  charge  sustaining 
exhaust emissions and fuel consumption for OVC-HEVs. The utility factor determination 
under type-approval follows a UF curve based on driving statistics as described in SAE 
J2841,  and  is  calculated  based  on  equations  set  out  in  Annex  XXI  to  Regulation  (EU) 
2017/1151. 

(50)  ICCT, Plug-in hybrid vehicle CO2 emissions: How they are affected by ambient conditions and driver 

mode selection, 2021. 

53 

 
 
 
The utility factor is a necessary assumption to generalise the vehicle’s charging and driving 
behaviour over a vehicle’s lifetime and assign meaningful certified values. This is the case 
as there is no a priori information of the vehicle charging and driving behaviour over the 
lifetime.  However,  overestimating  the  utility  factor  in  the  WLTP  test,  meaning  that 
vehicles  are  not  recharged  and  driven  electrically  as  regularly  as  assumed,  results  in  a 
significant underestimation of the real-world CO2 emissions. Therefore, it is important to 
calculate a meaningful real-world utility factor and use the results to modify the existing 
utility factor determination. 

There are multiple approaches possible based for deriving a “utility factor” based on real-
world data, which could be compared to the one defined in Regulation (EU) 2017/1151. 

In real-world conditions, the utility factor concept most directly translates to the share (%) 
of distance travelled in CD mode (i.e. with the electric motor running): 

𝑈𝐹𝐶𝐷 (%) = 100 ×

𝑑𝐶𝐷,𝐸𝑛𝑔 𝑜𝑛 + 𝑑𝐶𝐷,𝐸𝑛𝑔 𝑜𝑓𝑓 [𝑘𝑚]
𝑑𝑡𝑜𝑡 [𝑘𝑚]

However, this approach gives equal weighting to the distances travelled with and without 
operating  the combustion engine.  This  means that  vehicles could  in  theory have  a high 
utility factor while driving mainly in charge-depleting mode with the engine on, i.e. still 
consuming fuel, while making little use of the electric battery. Therefore, this would only 
give an upper-bound estimation of the utility factor. 

The real-world data as it is currently recorded and collected does not allow differentiating 
between the power provided by the electric engine or the combustion engine, hence it does 
not  give  a  clear  indication  of  the  utility  of  the  electric  engine  and  the  corresponding 
electrified distance.  

A utility factor reflecting only the pure electric driving would give a better indication of 
the effective electrified distance. This can be calculated by only considering the distance 
driven  in  charge  depleting  mode  without  the  combustion  engine  on,  as  a  lower-bound 
estimation of the utility factor: 

𝑈𝐹𝑃𝑢𝑟𝑒 𝐸𝑙𝑒𝑐𝑡𝑟𝑖𝑐  (%) = 100 ×

𝑑𝐶𝐷,𝐸𝑛𝑔 𝑜𝑓𝑓 [𝑘𝑚]
𝑑𝑡𝑜𝑡 [𝑘𝑚]

These first two approaches are distance-based. An energy-based approach to the real-world 
utility factor could also be considered. This would take the contribution of work delivered 
by the electric engine from the energy from the grid and comparing it to the total energy 
consumed by the vehicle over its lifetime. 

This  energy-based utility  factor  can be calculated by taking the ratio of the usable grid 
energy as follows:  

𝑈𝐹𝐸𝑛𝑒𝑟𝑔𝑦−𝑏𝑎𝑠𝑒𝑑 (%) = 100 ×

𝑔𝑟𝑖𝑑𝑡𝑜𝑡 ∗ 𝐸𝑓𝑓𝑒𝑙𝑒𝑐𝑡𝑟𝑖𝑐
𝑔𝑟𝑖𝑑𝑡𝑜𝑡 × 𝑓𝑐ℎ𝑎𝑟𝑔𝑖𝑛𝑔 × 𝐸𝑓𝑓𝑒𝑙𝑒𝑐𝑡𝑟𝑖𝑐 + 𝑓𝑢𝑒𝑙𝑡𝑜𝑡 × 𝜌𝑓𝑢𝑒𝑙 × 𝐿𝐻𝑉𝑓𝑢𝑒𝑙 × 𝐸𝑓𝑓𝐼𝐶𝐸

This  approach  takes  into  account  the  electric  powertrain’s  efficiency  to  convert  battery 
energy into propulsion work (‘EffElectric’), and the total usable energy as sum of the usable 
grid energy and usable energy from the internal combustion engine (ICE).  

54 

 
 
 
 
Here  𝑔𝑟𝑖𝑑𝑡𝑜𝑡 and 𝑓𝑢𝑒𝑙𝑡𝑜𝑡 are the OBFCM parameters from the real-world dataset. The 
former  is  adjusted  by  a  factor  to  account  for  battery  charging  losses  (𝑓𝑐ℎ𝑎𝑟𝑔𝑖𝑛𝑔)  by 
assuming a generic charging efficiency of 85% to reflect the actual grid energy that was 
used to support the real-world charge depleting operation. The average fuel density and 
LHV, together with the engine efficiencies (𝐸𝑓𝑓𝑒𝑙𝑒𝑐𝑡𝑟𝑖𝑐 and 𝐸𝑓𝑓𝐼𝐶𝐸) were derived using 
WLTP test data from the DICE dataset.  

The process followed to derive these efficiencies consisted in the calculation of the energy 
at wheels that each vehicle in the dataset delivered during the charge-sustaining test cycle 
according to SAE J2951 and using the specific vehicle’s road loads. This has been later 
divided by the energy contained in the fuel consumed. In such operating mode the energy 
for propulsion is coming primarily from fuel and the contribution from the battery can be 
neglected, especially  if the fuel  consumption corrected for battery balance is  used. The 
average of the resulting efficiencies was therefore calculated for gasoline and diesel OVC-
HEVs separately. Efficiencies per vehicle type will differ, therefore, these results primarily 
apply at a fleet-wide level. 

Table  15:  Parameters  used  for  converting  grid  energy  into  the  battery  and  fuel 
consumption into usable energy (51) 

Parameter 

fcharging 

Effelectric (%) 

EffICE, petrol (%) 

EffICE, diesel (%) 

ρpetrol (kg/l) 

ρdiesel (kg/l) 

Definition 

Charging efficiency to go from ‘grid energy into the 
battery’ to ‘total grid energy’, factoring in the 
charging losses. 

Energy conversion efficiency from electric energy 
to kinetic energy. 

Conversion efficiency of chemical potential energy 
in the fuel (petrol) to kinetic energy. 

Conversion efficiency of chemical potential energy 
in the fuel (diesel) to kinetic energy. 

Density of petrol. 

Density of diesel. 

LHVpetrol (kWh/kg) 

Lower heating value for petrol. 

LHVdiesel (kWh/kg) 

Lower heating value for diesel. 

Value 

1/0.85 

85 

30.7 

36.9 

0.7475 

0.8325 

41.5/3.6 

42.7/3.6 

2.2.  Calculation methodology results 

The  results  for  the  utility  factor  calculation  are  provided  for  the  three  utility  factor 
calculation methodologies as previously described. This calculation was performed on the 
processed real-world data, with an additional quality check where vehicles were excluded 

(51)  Prussi, M., Yugo, M., De Prada, L., Padella, M. and Edwards, R., JEC Well-To-Wheels report v5, EUR 
30284 EN, Publications Office of the European Union, Luxembourg, 2020, ISBN 978-92-76-20109-0, 
doi:10.2760/100379, JRC121213. 

55 

 
 
 
for which the utility factor could not be calculated due to missing specific data regarding 
the total grid energy into battery or charge-depleting distances (52). 

Therefore, these results are based on 115 587 plug-in hybrid vehicles, and provide a first 
indication  of  the  results  obtained  by  the  three  methodologies.  The  arithmetic  and  km-
weighted average utility factor value for each of the methodology are provided Table 16.  

Table 16: Calculated real-world fleet-wide utility factors for 2021 plug-in hybrid electric 
vehicles  

Distance-based 
Utility Factor (UFCD) 

Pure electric distance 
based utility factor 
(UFPure Electric) 

Energy-based utility 
factor (UFEnergy-based) 

Arithmetic 
average  

Km-
weighted 
average 

Arithmetic 
average  

Km-
weighted 
average 

Arithmetic 
average 

Km-
weighted 
average 

42.0 

37.9 

31.3 

26.3 

27.6 

22.2 

Utility 
Factor (%) 

The  results  show  that  there  is  a  large  variability  between  the  different  utility  factors 
obtained with the three calculation methods.  

The distance-based utility factors provide more optimistic results on the utility,  ranging 
from 42% for the charge-depleting utility factor to 31% for the pure electric utility factor. 
The lower utility factors found when using a km-weighted average show that for vehicles 
which have driven further distances, the electric engine is used less proportionally to the 
combustion engine, likely  due to  increased  energy demand (e.g. higher  average vehicle 
speed) and/or less charging with respect to the driven distance. 

The energy-based approach gives a lower estimation of 27.6% for the utility factor, with 
the km-weighted approach indicating this to be as low as 22.2%.  

An  initial  comparison  between  these  results  and  the  real-world  CO2  emissions  gap 
indicates that the energy-based utility factor approach provides the strongest correlation. 

Further investigation of the three approaches will be required in the context of the review 
of the utility factor. 

(52)  Volkswagen plug-in hybrid vehicles (3 049) were also excluded, as they did not correctly report the ‘grid 
energy  into  battery’  parameter,  alongside  the  other  (5 104)  excluded  vehicles  missing  relevant 
parameters. 

56 

 
 
 
 
 
Annex D 

Aggregated data per manufacturer 

The aggregated data per manufacturer is provided, split between passenger cars and light 
commercial  vehicles  powered  by  internal  combustion  engines  and  off-vehicle  charging 
hybrid electric vehicles (OVC-HEVs) of the same categories as required under Regulation 
(EU) 2021/392, ordered by the share of 2021 first registrations reported.  

Results  may  not  be  representative  for  manufacturers  with  a  low  share  of  reported 
registrations.  For  light  commercial  vehicles,  as  N1  Class  II  and  III  vehicles  were  not 
required to be fitted with OBFCM devices in 2021, the first year results are not considered 
as representative for N1 registrations. 

1.  M1 VEHICLES 

The order of the manufacturer tables based on the reported share of 2021 M1 registrations, 
after the processing steps. 

Table 17: Manufacturer order 

Manufacturer 

JAGUAR LAND ROVER 
LIMITED 

FORD WERKE GMBH 

FORD MOTOR COMPANY 

MERCEDES-BENZ AG 

VOLVO 

BMW GMBH 

MERCEDES AMG 

DACIA 

ALFA ROMEO 

CHRYSLER 

ROLLS ROYCE 

PORSCHE 

RENAULT 

BMW AG 

VOLKSWAGEN 

CNG TECHNIK 

FIAT GROUP 

BENTLEY 

Share reported of 2021 
M1 registrations (%) - 
before processing 

Share reported of 2021 
M1 registrations (%) - 
after processing 

77.65 

35.04 

27.61 

36.79 

82.23 

16.11 

16 

11.96 

9.41 

9.6 

9.09 

18.74 

7.91 

6.69 

6.99 

6.17 

5.9 

23.82 

57 

42.72 

34.23 

26.94 

26.71 

23.79 

15.52 

11.79 

11.35 

9.25 

8.32 

8.26 

7.31 

6.66 

6.28 

5.89 

5.68 

5.26 

4.71 

 
Manufacturer 

FERRARI 

NISSAN AUTOMOTIVE 
EUROPE 

AUDI SPORT 

MAGYAR SUZUKI 

AUTOMOBILES PEUGEOT 

AUDI AG 

PSA 

SUZUKI MOTOR 
CORPORATION 

MAZDA 

SEAT 

SKODA 

AUTOMOBILES CITROEN 

AUDI HUNGARIA 

OPEL AUTOMOBILE 

TOYOTA 

KIA SLOVAKIA 

HYUNDAI CZECH 

KIA 

HYUNDAI ASSAN 

HYUNDAI 

SAIC MOTOR 
CORPORATION 

TOYOTA MOTOR 
CORPORATION 

SUBARU 

MITSUBISHI MOTORS 
CORPORATION 

MITSUBISHI MOTORS 
THAILAND 

Share reported of 2021 
M1 registrations (%) - 
before processing 

Share reported of 2021 
M1 registrations (%) - 
after processing 

4.52 

4.48 

4.19 

3.55 

3.41 

3.33 

2.55 

2.5 

2.13 

2.13 

1.67 

1.51 

1.49 

1.32 

1.05 

1.01 

0.99 

0.6 

0.45 

0.42 

0.32 

0.21 

0.06 

0.02 

0.01 

4.58 

6.22 

6.17 

4.6 

6.93 

4.41 

6.61 

3.24 

6.47 

2.85 

2.03 

4.33 

2.4 

3.01 

1.12 

1.3 

1 

0.79 

0.46 

0.46 

0.97 

0.25 

0.08 

0.02 

0.01 

58 

 
 
1.1.  Manufacturers reporting over 20% of registered vehicles 

Table 18: JAGUAR LAND ROVER LIMITED 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (53.0% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

4 918 
19 663 
24 581 
4 918 
19 663 
24 581 

 # of 
vehicles 

2 520 
0 

2 520 
2 520 
0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
11.81 
8.31 
8.71 
268.93 
218.52 
224.34 

11.91 
8.41 
9.11 
271.41 
221.34 
231.35 
OVC-HEVs (16.8% of vehicles registered) 

9.54 
7.10 
7.59 
217.28 
186.84 
192.93 

weighted 
9.73 
7.10 
7.40 
221.58 
186.70 
190.72 

2.38 
1.31 
1.52 
54.13 
34.50 
38.42 

weighted 
2.08 
1.21 
1.31 
47.35 
31.82 
33.61 

24.91% 
18.46% 
20.08% 
24.91% 
18.46% 
19.92% 

weighted 
21.37% 
17.04% 
17.70% 
21.37% 
17.04% 
17.62% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

9.38 

weighted 
9.71 

2.91 

weighted 
2.99 

6.47 

weighted 
6.72 

222.20% 

weighted 
224.68% 

9.38 
213.57 

9.71 
221.12 

2.91 
66.28 

2.99 
68.10 

6.47 
147.28 

6.72 
153.02 

222.20% 
222.20% 

224.68% 
224.68% 

2 520 

213.57 

221.12 

66.28 

68.10 

147.28 

153.02 

222.20% 

224.68% 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
Table 19: FORD WERKE GMBH 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (33.4% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

84 828 
31 986 
116 814 
84 828 
31 986 
116 814 

 # of 
vehicles 

19 819 
0 

19 819 
19 819 
0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
7.00 
6.67 
6.85 
159.50 
175.62 
167.17 

7.13 
6.76 
7.03 
162.53 
177.94 
166.75 
OVC-HEVs (44.0% of vehicles registered) 

5.66 
5.79 
5.70 
129.03 
152.44 
135.44 

weighted 
5.68 
5.75 
5.71 
129.32 
151.34 
139.80 

1.47 
0.97 
1.33 
33.50 
25.50 
31.31 

weighted 
1.32 
0.92 
1.13 
30.18 
24.28 
27.37 

25.96% 
16.73% 
23.39% 
25.96% 
16.73% 
23.12% 

weighted 
23.34% 
16.04% 
19.84% 
23.34% 
16.04% 
19.58% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

4.72 

weighted 
4.84 

1.56 

weighted 
1.61 

3.16 

weighted 
3.23 

202.99% 

weighted 
200.12% 

4.72 
107.55 

4.84 
110.26 

1.56 
35.50 

1.61 
36.74 

3.16 
72.06 

3.23 
73.52 

202.99% 
202.99% 

200.12% 
200.12% 

19 819 

107.55 

110.26 

35.50 

36.74 

72.06 

73.52 

202.99% 

200.12% 

60 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
Table 20: FORD MOTOR COMPANY 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (26.9% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

811 
0 
811 
811 
0 
811 

14.95 

14.95 
340.60 

weighted 
14.60 

11.61 

weighted 
11.57 

3.34 

weighted 
3.03 

28.75% 

weighted 
26.18% 

14.60 
332.50 

11.61 
264.55 

11.57 
263.52 

3.34 
76.05 

3.03 
68.99 

28.75% 
28.75% 

26.18% 
26.18% 

340.60 
OVC-HEVs (0.0% of vehicles registered) 

332.50 

264.55 

263.52 

76.05 

68.99 

28.75% 

26.18% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

61 

 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
 
 
Table 21: MERCEDES-BENZ AG 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (23.1% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

 # of 
vehicles 

29 995 
49 124 
79 119 
29 995 
49 124 
79 119 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
10.68 
6.81 
7.98 
243.30 
179.05 
198.60 

10.53 
7.06 
8.38 
239.83 
185.87 
206.33 
OVC-HEVs (35.9% of vehicles registered) 

8.46 
6.01 
6.94 
192.71 
158.16 
171.25 

weighted 
8.67 
5.90 
6.75 
197.61 
155.27 
168.15 

2.07 
1.05 
1.44 
47.13 
27.72 
35.07 

weighted 
2.01 
0.90 
1.24 
45.68 
23.78 
30.45 

24.45% 
17.52% 
20.73% 
24.45% 
17.52% 
20.48% 

weighted 
23.12% 
15.32% 
18.37% 
23.12% 
15.32% 
18.11% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

23 506 
24 892 

5.80 
5.83 

weighted 
6.30 
5.94 

48 398 
23 506 
24 892 

5.81 
132.12 
153.30 

6.08 
143.49 
156.40 

1.49 
1.41 

1.45 
33.86 
37.20 

weighted 
1.56 
1.42 

4.31 
4.41 

weighted 
4.74 
4.52 

1.47 
35.54 
37.43 

4.36 
98.26 
116.10 

4.60 
107.95 
118.97 

290.21% 
312.11% 

301.20% 
290.21% 
312.11% 

weighted 
303.73% 
317.81% 

312.20% 
303.73% 
317.81% 

48 398 

143.02 

151.53 

35.58 

36.72 

107.44 

114.81 

301.99% 

312.67% 

62 

 
  
  
 
 
Table 22: VOLVO 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (22.4% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

 # of 
vehicles 

8 988 
18 674 
27 662 
8 988 
18 674 
27 662 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
8.24 
7.05 
7.32 
187.82 
185.51 
186.02 

8.47 
7.28 
7.66 
192.86 
191.48 
191.93 
OVC-HEVs (25.6% of vehicles registered) 

7.24 
6.23 
6.56 
164.89 
163.86 
164.20 

weighted 
7.25 
6.19 
6.43 
165.19 
162.98 
163.48 

1.23 
1.05 
1.11 
27.97 
27.62 
27.73 

weighted 
0.99 
0.86 
0.89 
22.62 
22.53 
22.55 

16.96% 
16.85% 
16.89% 
16.96% 
16.85% 
16.89% 

weighted 
13.70% 
13.82% 
13.79% 
13.70% 
13.82% 
13.79% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

24 121 
1 

6.62 
10.47 

weighted 
6.76 
10.47 

24 122 
24 121 
1 

6.62 
150.71 
275.52 

6.76 
154.00 
275.52 

2.26 
1.82 

2.26 
51.58 
48.00 

weighted 
2.26 
1.82 

4.35 
8.65 

weighted 
4.50 
8.65 

2.26 
51.50 
48.00 

4.35 
99.13 
227.52 

4.50 
102.50 
227.52 

192.18% 
474.00% 

192.19% 
192.18% 
474.00% 

weighted 
199.02% 
474.00% 

199.02% 
199.02% 
474.00% 

24 122 

150.72 

154.01 

51.58 

51.50 

99.14 

102.50 

192.19% 

199.02% 

63 

 
 
  
  
 
1.2.  Manufacturers reporting 10-20% of registered vehicles 

Table 23: BMW GMBH 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (15.5% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

 # of 
vehicles 

1 519 
0 
1 519 
1 519 
0 
1 519 

 # of 
vehicles 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

14.76 

14.76 
336.28 

weighted 
14.80 

11.17 

weighted 
11.26 

3.59 

weighted 
3.55 

32.15% 

weighted 
31.51% 

14.80 
337.22 

11.17 
254.47 

11.26 
256.42 

3.59 
81.81 

3.55 
80.80 

32.15% 
32.15% 

31.51% 
31.51% 

336.28 
OVC-HEVs (0.0% of vehicles registered) 

337.22 

254.47 

256.42 

81.81 

80.80 

32.15% 

31.51% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

64 

 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
Table 24: MERCEDES AMG 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (11.8% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

95 
0 
95 
95 
0 
95 

18.53 

18.53 
422.06 

weighted 
18.13 

12.74 

weighted 
12.73 

5.79 

weighted 
5.40 

45.48% 

weighted 
42.43% 

18.13 
412.89 

12.74 
290.11 

12.73 
289.90 

5.79 
131.95 

5.40 
122.99 

45.48% 
45.48% 

42.43% 
42.43% 

422.06 
OVC-HEVs (0.0% of vehicles registered) 

412.89 

290.11 

289.90 

131.95 

122.99 

45.48% 

42.43% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

65 

 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
 
 
Table 25: DACIA 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (11.3% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

 # of 
vehicles 

14 415 
833 
15 248 
14 415 
833 
15 248 

 # of 
vehicles 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
6.92 
5.85 
6.81 
157.72 
153.98 
157.34 

7.16 
5.81 
7.08 
163.04 
152.74 
162.47 
OVC-HEVs (0.0% of vehicles registered) 

5.55 
4.89 
5.52 
126.46 
128.59 
126.58 

weighted 
5.54 
4.88 
5.48 
126.28 
128.28 
126.48 

1.61 
0.92 
1.57 
36.57 
24.15 
35.89 

weighted 
1.38 
0.98 
1.34 
31.44 
25.69 
30.85 

28.92% 
18.78% 
28.43% 
28.92% 
18.78% 
28.36% 

weighted 
24.90% 
20.03% 
24.46% 
24.90% 
20.03% 
24.39% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

66 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
 
 
1.3.  Manufacturers reporting 5-10% of registered vehicles 

Table 26: ALFA ROMEO 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (9.3% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

396 
1 751 
2 147 
396 
1 751 
2 147 

 # of 
vehicles 

0 
0 
0 

0 
0 
0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
11.14 
7.31 
7.80 
253.75 
192.29 
200.20 

11.59 
7.42 
8.19 
264.00 
195.11 
207.82 
OVC-HEVs (0.0% of vehicles registered) 

8.60 
5.85 
6.36 
195.99 
153.86 
161.63 

weighted 
8.52 
5.84 
6.19 
194.00 
153.76 
158.94 

2.99 
1.57 
1.83 
68.01 
41.25 
46.19 

weighted 
2.62 
1.46 
1.61 
59.76 
38.53 
41.26 

34.70% 
26.81% 
28.78% 
34.70% 
26.81% 
28.57% 

weighted 
30.80% 
25.06% 
26.08% 
30.80% 
25.06% 
25.96% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

67 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
Table 27: CHRYSLER 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (8.5% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

2 216 
2 468 
4 684 
2 216 
2 468 
4 684 

 # of 
vehicles 

1 120 
0 

1 120 
1 120 
0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
8.21 
6.00 
6.84 
187.02 
157.76 
168.94 

8.46 
6.10 
7.22 
192.73 
160.49 
175.74 
OVC-HEVs (7.6% of vehicles registered) 

6.89 
5.10 
5.95 
156.96 
134.14 
144.94 

weighted 
6.88 
5.10 
5.78 
156.74 
134.11 
142.75 

1.57 
1.00 
1.27 
35.77 
26.35 
30.81 

weighted 
1.33 
0.90 
1.06 
30.28 
23.66 
26.19 

22.79% 
19.64% 
21.37% 
22.79% 
19.64% 
21.26% 

weighted 
19.32% 
17.64% 
18.40% 
19.32% 
17.64% 
18.34% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

6.72 

weighted 
6.50 

2.49 

weighted 
2.38 

4.23 

weighted 
4.12 

169.74% 

weighted 
173.26% 

6.72 
153.05 

6.50 
148.11 

2.49 
56.74 

2.38 
54.20 

4.23 
96.31 

4.12 
93.91 

169.74% 
169.74% 

173.26% 
173.26% 

1 120 

153.05 

148.11 

56.74 

54.20 

96.31 

93.91 

169.74% 

173.26% 

68 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
Table 28: ROLLS ROYCE 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (8.3% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

20 
0 
20 
20 
0 
20 

18.79 

18.79 
428.10 

weighted 
17.63 

15.97 

weighted 
15.97 

2.82 

weighted 
1.65 

17.66% 

weighted 
10.36% 

17.63 
401.54 

15.97 
363.85 

15.97 
363.84 

2.82 
64.25 

1.65 
37.69 

17.66% 
17.66% 

10.36% 
10.36% 

428.10 
OVC-HEVs (0.0% of vehicles registered) 

401.54 

363.85 

363.84 

64.25 

37.69 

17.66% 

10.36% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

69 

 
 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
 
Table 29: PORSCHE 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (6.5% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

2 192 
0 
2 192 
2 192 
0 
2 192 

 # of 
vehicles 

1 210 
0 

1 210 
1 210 
0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

13.45 

13.45 
306.50 

weighted 
13.06 

11.16 

weighted 
11.15 

2.30 

weighted 
1.91 

20.57% 

weighted 
17.14% 

13.06 
297.55 

11.16 
254.21 

11.15 
254.01 

2.30 
52.28 

1.91 
43.55 

20.57% 
20.57% 

17.14% 
17.14% 

306.50 
OVC-HEVs (9.4% of vehicles registered) 

297.55 

254.21 

254.01 

52.28 

43.55 

20.57% 

17.14% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

10.79 

weighted 
10.80 

3.03 

weighted 
3.02 

7.76 

weighted 
7.78 

256.01% 

weighted 
257.58% 

10.79 
245.71 

10.80 
246.06 

3.03 
69.02 

3.02 
68.81 

7.76 
176.69 

7.78 
177.25 

256.01% 
256.01% 

257.58% 
257.58% 

1 210 

245.71 

246.06 

69.02 

68.81 

176.69 

177.25 

256.01% 

257.58% 

70 

 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
Table 30: RENAULT 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (6.7% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

28 846 
10 434 
39 280 
28 846 
10 434 
39 280 

 # of 
vehicles 

2 244 
0 

2 244 
2 244 
0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
7.29 
6.05 
6.81 
166.16 
159.06 
163.41 

7.48 
6.25 
7.15 
170.42 
164.46 
168.83 
OVC-HEVs (6.4% of vehicles registered) 

5.72 
5.25 
5.60 
130.35 
138.03 
132.39 

weighted 
5.72 
5.15 
5.50 
130.32 
135.60 
132.36 

1.76 
1.00 
1.56 
40.07 
26.42 
36.44 

weighted 
1.57 
0.89 
1.31 
35.84 
23.46 
31.05 

30.74% 
19.14% 
27.85% 
30.74% 
19.14% 
27.53% 

weighted 
27.50% 
17.30% 
23.81% 
27.50% 
17.30% 
23.46% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

4.13 

4.13 
94.13 

weighted 
4.20 

1.47 

weighted 
1.48 

2.66 

weighted 
2.72 

180.77% 

weighted 
184.33% 

4.20 
95.67 

1.47 
33.53 

1.48 
33.65 

2.66 
60.61 

2.72 
62.02 

180.77% 
180.77% 

184.33% 
184.33% 

2 244 

94.13 

95.67 

33.53 

33.65 

60.61 

62.02 

180.77% 

184.33% 

71 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
Table 31: BMW AG 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (6.3% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

10 876 
19 035 
29 911 
10 876 
19 035 
29 911 

 # of 
vehicles 

7 521 
0 

7 521 
7 521 
0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
8.84 
6.96 
7.46 
201.33 
183.15 
187.95 

8.89 
7.08 
7.74 
202.40 
186.40 
192.22 
OVC-HEVs (6.1% of vehicles registered) 

7.02 
5.71 
6.19 
160.01 
150.20 
153.77 

weighted 
7.12 
5.66 
6.04 
162.18 
148.82 
152.34 

1.86 
1.38 
1.55 
42.39 
36.20 
38.45 

weighted 
1.72 
1.31 
1.41 
39.15 
34.34 
35.60 

26.49% 
24.10% 
25.09% 
26.49% 
24.10% 
25.01% 

weighted 
24.14% 
23.07% 
23.40% 
24.14% 
23.07% 
23.37% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

6.73 

weighted 
6.95 

1.65 

weighted 
1.63 

5.08 

weighted 
5.32 

308.65% 

weighted 
327.54% 

6.73 
153.29 

6.95 
158.33 

1.65 
37.51 

1.63 
37.03 

5.08 
115.78 

5.32 
121.29 

308.65% 
308.65% 

327.54% 
327.54% 

7 521 

153.29 

158.33 

37.51 

37.03 

115.78 

121.29 

308.65% 

327.54% 

72 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
Table 32: VOLKSWAGEN 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (5.6% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

21 296 
27 374 
48 670 
21 296 
27 374 
48 670 

 # of 
vehicles 

6 323 
0 

6 323 
6 323 
0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
7.43 
6.35 
6.67 
169.20 
167.13 
167.73 

7.49 
6.50 
6.93 
170.71 
170.97 
170.85 
OVC-HEVs (10.8% of vehicles registered) 

6.47 
5.60 
5.98 
147.39 
147.27 
147.32 

weighted 
6.53 
5.53 
5.82 
148.65 
145.50 
146.42 

1.02 
0.90 
0.95 
23.32 
23.70 
23.53 

weighted 
0.90 
0.82 
0.85 
20.55 
21.62 
21.31 

15.82% 
16.09% 
15.96% 
15.82% 
16.09% 
15.97% 

weighted 
13.83% 
14.86% 
14.52% 
13.83% 
14.86% 
14.56% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

5.34 

weighted 
5.65 

1.33 

weighted 
1.37 

4.01 

weighted 
4.28 

300.51% 

weighted 
311.31% 

5.34 
121.73 

5.65 
128.76 

1.33 
30.39 

1.37 
31.30 

4.01 
91.33 

4.28 
97.45 

300.51% 
300.51% 

311.31% 
311.31% 

6 323 

121.73 

128.76 

30.39 

31.30 

91.33 

97.45 

300.51% 

311.31% 

73 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
Table 33: CNG TECHNIK 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (5.7% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

58 
0 
58 
58 
0 
58 

5.81 

5.81 
132.28 

weighted 
5.81 

5.76 

weighted 
5.75 

5.81 
132.39 

5.76 
131.26 

5.75 
131.08 

132.28 
OVC-HEVs (0.0% of vehicles registered) 

132.39 

131.26 

131.08 

0.04 

0.04 
1.02 

1.02 

weighted 
0.06 

0.06 
1.32 

0.78% 

0.78% 
0.78% 

weighted 
1.01% 

1.01% 
1.01% 

1.32 

0.78% 

1.01% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

74 

 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
 
 
Table 34: FIAT GROUP 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (5.2% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

15 126 
6 470 
21 596 
15 126 
6 470 
21 596 

 # of 
vehicles 

1 061 
0 

1 061 
1 061 
0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
6.80 
5.64 
6.37 
154.97 
148.48 
152.54 

7.01 
5.85 
6.66 
159.72 
153.96 
158.00 
OVC-HEVs (6.2% of vehicles registered) 

5.85 
4.93 
5.57 
133.18 
129.74 
132.15 

weighted 
5.89 
4.88 
5.51 
134.09 
128.39 
131.96 

1.17 
0.92 
1.09 
26.55 
24.22 
25.85 

weighted 
0.92 
0.76 
0.86 
20.88 
20.09 
20.58 

19.93% 
18.67% 
19.60% 
19.93% 
18.67% 
19.56% 

weighted 
15.57% 
15.65% 
15.59% 
15.57% 
15.65% 
15.60% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

6.49 

weighted 
6.48 

2.07 

weighted 
2.07 

4.42 

weighted 
4.41 

213.97% 

weighted 
212.73% 

6.49 
147.81 

6.48 
147.64 

2.07 
47.08 

2.07 
47.21 

4.42 
100.73 

4.41 
100.43 

213.97% 
213.97% 

212.73% 
212.73% 

1 061 

147.81 

147.64 

47.08 

47.21 

100.73 

100.43 

213.97% 

212.73% 

75 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
1.1.  Manufacturers reporting 1-5% of registered vehicles 

Table 35: BENTLEY 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (5.0% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

70 
0 
70 
70 
0 
70 

14.82 

14.82 
337.54 

weighted 
14.57 

12.56 

weighted 
12.71 

2.25 

weighted 
1.86 

17.95% 

weighted 
14.66% 

14.57 
331.86 

12.56 
286.19 

12.71 
289.42 

2.25 
51.36 

1.86 
42.43 

17.95% 
17.95% 

14.66% 
14.66% 

337.54 
OVC-HEVs (0.9% of vehicles registered) 

331.86 

286.19 

289.42 

51.36 

42.43 

17.95% 

14.66% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

1 
0 

1 
1 
0 

1 

12.97 

weighted 
12.97 

3.60 

weighted 
3.60 

9.37 

weighted 
9.37 

260.37% 

weighted 
260.37% 

12.97 
295.50 

12.97 
295.50 

3.60 
82.00 

3.60 
82.00 

9.37 
213.50 

9.37 
213.50 

260.37% 
260.37% 

260.37% 
260.37% 

295.50 

295.50 

82.00 

82.00 

213.50 

213.50 

260.37% 

260.37% 

76 

 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
Table 36: FERRARI 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (2.0% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

58 
0 
58 
58 
0 
58 

16.28 

16.28 
370.91 

weighted 
15.33 

11.20 

weighted 
11.20 

5.08 

weighted 
4.13 

45.35% 

weighted 
36.86% 

15.33 
349.19 

11.20 
255.19 

11.20 
255.14 

5.08 
115.72 

4.13 
94.04 

45.35% 
45.35% 

36.86% 
36.86% 

370.91 
OVC-HEVs (21.2% of vehicles registered) 

349.19 

255.19 

255.14 

115.72 

94.04 

45.35% 

36.86% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

91 
0 

91 
91 
0 

91 

20.06 

weighted 
19.59 

6.88 

weighted 
6.88 

13.18 

weighted 
12.72 

191.51% 

weighted 
184.92% 

20.06 
457.03 

19.59 
446.34 

6.88 
156.78 

6.88 
156.66 

13.18 
300.25 

12.72 
289.69 

191.51% 
191.51% 

184.92% 
184.92% 

457.03 

446.34 

156.78 

156.66 

300.25 

289.69 

191.51% 

184.92% 

77 

 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
Table 37: NISSAN AUTOMOTIVE EUROPE 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (4.5% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

 # of 
vehicles 

6 872 
0 
6 872 
6 872 
0 
6 872 

 # of 
vehicles 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

7.76 

7.76 
176.77 

weighted 
7.55 

6.15 

weighted 
6.15 

1.61 

weighted 
1.40 

26.15% 

weighted 
22.76% 

7.55 
172.07 

6.15 
140.13 

6.15 
140.17 

1.61 
36.64 

1.40 
31.90 

26.15% 
26.15% 

22.76% 
22.76% 

176.77 
OVC-HEVs (0.0% of vehicles registered) 

172.07 

140.13 

140.17 

36.64 

31.90 

26.15% 

22.76% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

78 

 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
 
 
 
Table 38: AUDI SPORT 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (4.2% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

464 
0 
464 
464 
0 
464 

14.44 

14.44 
329.00 

weighted 
14.23 

11.54 

weighted 
11.77 

2.91 

weighted 
2.46 

25.18% 

weighted 
20.87% 

14.23 
324.21 

11.54 
262.82 

11.77 
268.23 

2.91 
66.18 

2.46 
55.98 

25.18% 
25.18% 

20.87% 
20.87% 

329.00 
OVC-HEVs (0.0% of vehicles registered) 

324.21 

262.82 

268.23 

66.18 

55.98 

25.18% 

20.87% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

79 

 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
 
 
Table 39: MAGYAR SUZUKI 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (3.5% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

 # of 
vehicles 

2 798 
0 
2 798 
2 798 
0 
2 798 

 # of 
vehicles 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

6.72 

6.72 
153.12 

weighted 
6.64 

5.63 

weighted 
5.70 

1.10 

weighted 
0.94 

19.49% 

weighted 
16.48% 

6.64 
151.24 

5.63 
128.15 

5.70 
129.83 

1.10 
24.98 

0.94 
21.40 

19.49% 
19.49% 

16.48% 
16.48% 

153.12 
OVC-HEVs (0.0% of vehicles registered) 

151.24 

128.15 

129.83 

24.98 

21.40 

19.49% 

16.48% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

80 

 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
 
 
Table 40: AUTOMOBILES PEUGEOT 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (3.4% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

1 817 
5 940 
7 757 
1 817 
5 940 
7 757 

 # of 
vehicles 

1 434 
0 

1 434 
1 434 
0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
7.35 
5.92 
6.13 
167.35 
155.69 
157.40 

7.37 
5.99 
6.31 
167.96 
157.53 
159.97 
OVC-HEVs (3.7% of vehicles registered) 

6.17 
5.18 
5.41 
140.60 
136.22 
137.25 

weighted 
6.23 
5.14 
5.30 
141.87 
135.30 
136.26 

1.20 
0.81 
0.90 
27.35 
21.31 
22.73 

weighted 
1.12 
0.77 
0.83 
25.48 
20.39 
21.14 

19.45% 
15.65% 
16.66% 
19.45% 
15.65% 
16.56% 

weighted 
17.96% 
15.07% 
15.57% 
17.96% 
15.07% 
15.51% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

5.40 

weighted 
5.65 

1.35 

weighted 
1.34 

4.05 

weighted 
4.30 

301.04% 

weighted 
320.15% 

5.40 
122.95 

5.65 
128.70 

1.35 
30.66 

1.34 
30.63 

4.05 
92.29 

4.30 
98.07 

301.04% 
301.04% 

320.15% 
320.15% 

1 434 

122.95 

128.70 

30.66 

30.63 

92.29 

98.07 

301.04% 

320.15% 

81 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
Table 41: AUDI AG 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (3.2% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

2 978 
7 766 
10 744 
2 978 
7 766 
10 744 

 # of 
vehicles 

2 603 
0 

2 603 
2 603 
0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
8.58 
7.07 
7.35 
195.43 
186.02 
187.78 

8.53 
7.20 
7.57 
194.35 
189.45 
190.81 
OVC-HEVs (3.8% of vehicles registered) 

7.01 
6.01 
6.29 
159.76 
158.11 
158.57 

weighted 
7.15 
5.96 
6.19 
162.96 
156.90 
158.03 

1.52 
1.19 
1.28 
34.59 
31.35 
32.25 

weighted 
1.43 
1.11 
1.17 
32.47 
29.12 
29.75 

21.65% 
19.83% 
20.39% 
21.65% 
19.83% 
20.34% 

weighted 
19.92% 
18.56% 
18.85% 
19.92% 
18.56% 
18.82% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

6.90 

weighted 
7.20 

1.63 

weighted 
1.66 

5.27 

weighted 
5.53 

323.06% 

weighted 
333.06% 

6.90 
157.28 

7.20 
163.93 

1.63 
37.18 

1.66 
37.85 

5.27 
120.11 

5.53 
126.07 

323.06% 
323.06% 

333.06% 
333.06% 

2 603 

157.28 

163.93 

37.18 

37.85 

120.11 

126.07 

323.06% 

333.06% 

82 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
Table 42: PSA 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (2.5% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

8 357 
8 116 
16 473 
8 357 
8 116 
16 473 

 # of 
vehicles 

1 471 
0 

1 471 
1 471 
0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
6.69 
5.45 
5.89 
152.36 
143.27 
146.51 

6.80 
5.46 
6.14 
155.00 
143.55 
149.36 
OVC-HEVs (4.0% of vehicles registered) 

5.68 
4.68 
5.19 
129.41 
123.02 
126.26 

weighted 
5.70 
4.67 
5.04 
129.81 
122.95 
125.39 

1.12 
0.78 
0.95 
25.59 
20.53 
23.09 

weighted 
0.99 
0.77 
0.85 
22.55 
20.32 
21.11 

19.77% 
16.69% 
18.40% 
19.77% 
16.69% 
18.29% 

weighted 
17.37% 
16.53% 
16.87% 
17.37% 
16.53% 
16.84% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

5.94 

weighted 
6.07 

1.47 

weighted 
1.48 

4.47 

weighted 
4.59 

303.83% 

weighted 
309.29% 

5.94 
135.42 

6.07 
138.28 

1.47 
33.53 

1.48 
33.79 

4.47 
101.88 

4.59 
104.49 

303.83% 
303.83% 

309.29% 
309.29% 

1 471 

135.42 

138.28 

33.53 

33.79 

101.88 

104.49 

303.83% 

309.29% 

83 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
Table 43: SUZUKI MOTOR CORPORATION 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (2.5% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

2 231 
0 
2 231 
2 231 
0 
2 231 

 # of 
vehicles 

32 
0 

32 
32 
0 

32 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

5.40 

5.40 
123.06 

weighted 
5.27 

4.94 

weighted 
4.96 

0.47 

weighted 
0.31 

5.27 
120.15 

4.94 
112.46 

4.96 
112.98 

0.47 
10.61 

0.31 
7.17 

9.43% 

9.43% 
9.43% 

weighted 
6.34% 

6.34% 
6.34% 

123.06 
OVC-HEVs (1.7% of vehicles registered) 

120.15 

112.46 

112.98 

10.61 

7.17 

9.43% 

6.34% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

5.10 

weighted 
5.10 

0.97 

weighted 
0.97 

4.14 

weighted 
4.14 

428.25% 

weighted 
428.19% 

5.10 
116.22 

5.10 
116.20 

0.97 
22.00 

0.97 
22.00 

4.14 
94.22 

4.14 
94.20 

428.25% 
428.25% 

428.19% 
428.19% 

116.22 

116.20 

22.00 

22.00 

94.22 

94.20 

428.25% 

428.19% 

84 

 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
Table 44: MAZDA 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (2.1% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

 # of 
vehicles 

1 950 
166 
2 116 
1 950 
166 
2 116 

 # of 
vehicles 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
7.61 
6.80 
7.53 
173.41 
178.98 
173.96 

7.61 
7.09 
7.57 
173.28 
186.51 
174.32 
OVC-HEVs (0.0% of vehicles registered) 

6.66 
6.15 
6.62 
151.79 
161.70 
152.57 

weighted 
6.81 
6.14 
6.74 
155.14 
161.42 
155.75 

0.94 
0.94 
0.94 
21.49 
24.81 
21.75 

weighted 
0.80 
0.67 
0.79 
18.27 
17.56 
18.20 

14.16% 
15.34% 
14.24% 
14.16% 
15.34% 
14.25% 

weighted 
11.78% 
10.88% 
11.70% 
11.78% 
10.88% 
11.69% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

85 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
 
 
Table 45: SEAT 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (1.6% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

2 934 
1 495 
4 429 
2 934 
1 495 
4 429 

 # of 
vehicles 

2 283 
0 

2 283 
2 283 
0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
8.10 
6.47 
7.32 
184.61 
170.11 
177.68 

8.21 
6.57 
7.65 
186.99 
172.79 
182.19 
OVC-HEVs (5.6% of vehicles registered) 

6.81 
5.30 
6.30 
155.09 
139.55 
149.85 

weighted 
6.85 
5.29 
6.10 
156.09 
139.12 
147.97 

1.40 
1.26 
1.35 
31.90 
33.23 
32.35 

weighted 
1.25 
1.18 
1.22 
28.52 
30.99 
29.70 

20.57% 
23.81% 
21.49% 
20.57% 
23.81% 
21.59% 

weighted 
18.27% 
22.28% 
19.93% 
18.27% 
22.28% 
20.07% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

4.98 

weighted 
5.09 

1.31 

weighted 
1.31 

3.66 

weighted 
3.79 

279.47% 

weighted 
290.09% 

4.98 
113.34 

5.09 
116.02 

1.31 
29.87 

1.31 
29.74 

3.66 
83.47 

3.79 
86.28 

279.47% 
279.47% 

290.09% 
290.09% 

2 283 

113.34 

116.02 

29.87 

29.74 

83.47 

86.28 

279.47% 

290.09% 

86 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
Table 46: SKODA 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (1.6% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

2 494 
4 295 
6 789 
2 494 
4 295 
6 789 

 # of 
vehicles 

857 
0 

857 
857 
0 

857 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
7.16 
6.12 
6.38 
163.03 
161.14 
161.61 

7.29 
6.22 
6.61 
166.07 
163.69 
164.57 
OVC-HEVs (3.2% of vehicles registered) 

6.13 
5.14 
5.50 
139.60 
135.25 
136.85 

weighted 
6.12 
5.09 
5.35 
139.45 
134.01 
135.36 

1.16 
1.08 
1.11 
26.47 
28.44 
27.72 

weighted 
1.03 
1.03 
1.03 
23.57 
27.13 
26.25 

18.96% 
21.03% 
20.18% 
18.96% 
21.03% 
20.25% 

weighted 
16.90% 
20.25% 
19.30% 
16.90% 
20.25% 
19.39% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

5.04 

weighted 
5.21 

1.13 

weighted 
1.14 

3.91 

weighted 
4.07 

345.26% 

weighted 
357.83% 

5.04 
114.86 

5.21 
118.76 

1.13 
25.80 

1.14 
25.94 

3.91 
89.07 

4.07 
92.82 

345.26% 
345.26% 

357.83% 
357.83% 

114.86 

118.76 

25.80 

25.94 

89.07 

92.82 

345.26% 

357.83% 

87 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
Table 47: AUTOMOBILES CITROEN 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (1.5% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

 # of 
vehicles 

2 457 
1 867 
4 324 
2 457 
1 867 
4 324 

 # of 
vehicles 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
6.35 
5.35 
5.74 
144.75 
140.88 
142.36 

6.49 
5.39 
6.02 
147.95 
141.78 
145.29 
OVC-HEVs (0.0% of vehicles registered) 

5.63 
4.70 
5.23 
128.15 
123.67 
126.22 

weighted 
5.64 
4.68 
5.04 
128.37 
123.08 
125.10 

0.87 
0.69 
0.79 
19.79 
18.12 
19.07 

weighted 
0.72 
0.68 
0.69 
16.38 
17.80 
17.26 

15.44% 
14.65% 
15.14% 
15.44% 
14.65% 
15.11% 

weighted 
12.76% 
14.47% 
13.74% 
12.76% 
14.47% 
13.80% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

88 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
 
 
Table 48: AUDI HUNGARIA 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (1.5% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

34 
10 
44 
34 
10 
44 

weighted 
8.97 
7.08 
8.28 
204.26 
186.20 
197.71 

9.13 
7.15 
8.68 
207.88 
188.03 
203.37 
OVC-HEVs (0.0% of vehicles registered) 

7.47 
5.71 
7.07 
170.26 
150.30 
165.73 

weighted 
7.52 
5.63 
6.83 
171.28 
148.16 
162.89 

1.65 
1.43 
1.60 
37.61 
37.73 
37.64 

weighted 
1.45 
1.45 
1.45 
32.99 
38.03 
34.82 

22.09% 
25.10% 
22.64% 
22.09% 
25.10% 
22.71% 

weighted 
19.26% 
25.67% 
21.18% 
19.26% 
25.67% 
21.37% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

89 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
 
 
Table 49: OPEL AUTOMOBILE 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (1.2% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

1 146 
994 
2 140 
1 146 
994 
2 140 

 # of 
vehicles 

317 
0 

317 
317 
0 

317 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
6.91 
6.01 
6.33 
157.32 
158.03 
157.78 

6.97 
6.00 
6.52 
158.73 
157.74 
158.27 
OVC-HEVs (3.1% of vehicles registered) 

5.95 
4.92 
5.47 
135.54 
129.56 
132.76 

weighted 
5.99 
4.93 
5.31 
136.42 
129.69 
132.11 

1.02 
1.07 
1.04 
23.18 
28.18 
25.50 

weighted 
0.92 
1.08 
1.02 
20.90 
28.34 
25.66 

17.10% 
21.75% 
19.05% 
17.10% 
21.75% 
19.21% 

weighted 
15.32% 
21.86% 
19.20% 
15.32% 
21.86% 
19.43% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

5.47 

weighted 
5.53 

1.36 

weighted 
1.36 

4.12 

weighted 
4.18 

303.31% 

weighted 
308.11% 

5.47 
124.71 

5.53 
126.00 

1.36 
30.92 

1.36 
30.87 

4.12 
93.79 

4.18 
95.13 

303.31% 
303.31% 

308.11% 
308.11% 

124.71 

126.00 

30.92 

30.87 

93.79 

95.13 

303.31% 

308.11% 

90 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
Table 50: TOYOTA 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (1.1% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

6 338 
8 
6 346 
6 338 
8 
6 346 

 # of 
vehicles 

40 
0 

40 
40 
0 

40 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
5.67 
10.41 
5.68 
129.15 
273.78 
129.38 

5.60 
10.73 
5.60 
127.52 
282.18 
127.72 
OVC-HEVs (0.2% of vehicles registered) 

4.99 
9.34 
4.99 
113.59 
245.75 
113.75 

weighted 
5.05 
9.37 
5.06 
115.00 
246.55 
115.22 

0.61 
1.38 
0.61 
13.93 
36.43 
13.96 

weighted 
0.62 
1.04 
0.62 
14.14 
27.23 
14.17 

12.27% 
14.82% 
12.27% 
12.27% 
14.82% 
12.27% 

weighted 
12.30% 
11.05% 
12.30% 
12.30% 
11.05% 
12.30% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

4.09 

4.09 
93.21 

weighted 
3.88 

0.97 

weighted 
0.97 

3.13 

weighted 
2.91 

323.68% 

weighted 
301.38% 

3.88 
88.30 

0.97 
22.00 

0.97 
22.00 

3.13 
71.21 

2.91 
66.30 

323.68% 
323.68% 

301.38% 
301.38% 

93.21 

88.30 

22.00 

22.00 

71.21 

66.30 

323.68% 

301.38% 

91 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
Table 51: KIA SLOVAKIA 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (1.2% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

1 391 
308 
1 699 
1 391 
308 
1 699 

 # of 
vehicles 

82 
0 

82 
82 
0 

82 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
7.93 
6.08 
7.47 
180.62 
160.08 
175.56 

8.01 
6.11 
7.66 
182.40 
160.64 
178.45 
OVC-HEVs (0.3% of vehicles registered) 

6.69 
5.30 
6.44 
152.36 
139.41 
150.01 

weighted 
6.63 
5.27 
6.29 
150.94 
138.69 
147.92 

1.32 
0.81 
1.23 
30.04 
21.23 
28.44 

weighted 
1.30 
0.81 
1.18 
29.68 
21.39 
27.64 

19.72% 
15.23% 
19.05% 
19.72% 
15.23% 
18.96% 

weighted 
19.66% 
15.42% 
18.79% 
19.66% 
15.42% 
18.68% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

3.87 

3.87 
88.13 

weighted 
2.82 

1.48 

weighted 
1.44 

2.39 

weighted 
1.38 

161.38% 

weighted 
95.43% 

2.82 
64.21 

1.48 
33.72 

1.44 
32.86 

2.39 
54.41 

1.38 
31.35 

161.38% 
161.38% 

95.43% 
95.43% 

88.13 

64.21 

33.72 

32.86 

54.41 

31.35 

161.38% 

95.43% 

92 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
1.1.  Manufacturers reporting < 1% of registered vehicles 

Table 52: HYUNDAI CZECH 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (1.1% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

1 592 
141 
1 733 
1 592 
141 
1 733 

 # of 
vehicles 

59 
0 

59 
59 
0 

59 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
7.09 
5.55 
6.88 
161.59 
146.02 
159.41 

7.22 
5.64 
7.09 
164.36 
148.39 
163.06 
OVC-HEVs (0.3% of vehicles registered) 

6.26 
4.84 
6.15 
142.64 
127.45 
141.41 

weighted 
6.23 
4.77 
6.03 
141.95 
125.39 
139.64 

0.95 
0.80 
0.94 
21.72 
20.93 
21.66 

weighted 
0.86 
0.78 
0.85 
19.63 
20.64 
19.77 

15.23% 
16.42% 
15.30% 
15.23% 
16.42% 
15.31% 

weighted 
13.83% 
16.46% 
14.12% 
13.83% 
16.46% 
14.16% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

5.53 

weighted 
5.68 

1.36 

weighted 
1.36 

4.17 

weighted 
4.31 

306.55% 

weighted 
317.06% 

5.53 
126.03 

5.68 
129.29 

1.36 
31.00 

1.36 
31.00 

4.17 
95.03 

4.31 
98.29 

306.55% 
306.55% 

317.06% 
317.06% 

126.03 

129.29 

31.00 

31.00 

95.03 

98.29 

306.55% 

317.06% 

93 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
Table 53: KIA 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (0.6% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

 # of 
vehicles 

1 025 
37 
1 062 
1 025 
37 
1 062 

 # of 
vehicles 

75 
0 

75 
75 
0 

75 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
6.33 
8.16 
6.47 
144.17 
214.62 
149.66 

6.39 
8.03 
6.44 
145.50 
211.38 
147.80 
OVC-HEVs (0.4% of vehicles registered) 

5.56 
6.66 
5.60 
126.76 
175.16 
128.45 

weighted 
5.60 
6.69 
5.69 
127.66 
175.91 
131.42 

0.82 
1.38 
0.84 
18.74 
36.22 
19.35 

weighted 
0.72 
1.47 
0.78 
16.51 
38.70 
18.24 

14.78% 
20.68% 
15.03% 
14.78% 
20.68% 
15.06% 

weighted 
12.93% 
22.00% 
13.76% 
12.93% 
22.00% 
13.88% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

5.00 

weighted 
3.12 

1.59 

weighted 
1.49 

3.42 

weighted 
1.63 

215.53% 

weighted 
109.88% 

5.00 
114.01 

3.12 
71.10 

1.59 
36.13 

1.49 
33.87 

3.42 
77.88 

1.63 
37.22 

215.53% 
215.53% 

109.88% 
109.88% 

114.01 

71.10 

36.13 

33.87 

77.88 

37.22 

215.53% 

109.88% 

94 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
Table 54: HYUNDAI ASSAN 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (0.4% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

527 
0 
527 
527 
0 
527 

6.09 

6.09 
138.69 

weighted 
6.02 

5.28 

weighted 
5.28 

0.81 

weighted 
0.74 

15.25% 

weighted 
14.09% 

6.02 
137.10 

5.28 
120.34 

5.28 
120.17 

0.81 
18.35 

0.74 
16.93 

15.25% 
15.25% 

14.09% 
14.09% 

138.69 
OVC-HEVs (0.0% of vehicles registered) 

137.10 

120.34 

120.17 

18.35 

16.93 

15.25% 

14.09% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

95 

 
 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
 
Table 55: HYUNDAI 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (0.4% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

258 
48 
306 
258 
48 
306 

weighted 
5.90 
6.73 
6.11 
134.46 
177.11 
145.34 

6.36 
7.31 
6.51 
144.93 
192.23 
152.35 
OVC-HEVs (0.3% of vehicles registered) 

5.77 
6.38 
5.87 
131.43 
167.96 
137.16 

weighted 
5.61 
6.52 
5.84 
127.80 
171.44 
138.93 

0.59 
0.92 
0.64 
13.50 
24.27 
15.19 

weighted 
0.29 
0.22 
0.27 
6.66 
5.67 
6.41 

10.28% 
14.45% 
10.99% 
10.28% 
14.45% 
11.08% 

weighted 
5.21% 
3.31% 
4.67% 
5.21% 
3.31% 
4.61% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

22 
0 

22 
22 
0 

22 

5.55 

weighted 
3.05 

1.47 

weighted 
1.32 

4.08 

weighted 
1.74 

277.21% 

weighted 
132.21% 

5.55 
126.36 

3.05 
69.59 

1.47 
33.50 

1.32 
29.97 

4.08 
92.86 

1.74 
39.62 

277.21% 
277.21% 

132.21% 
132.21% 

126.36 

69.59 

33.50 

29.97 

92.86 

39.62 

277.21% 

132.21% 

96 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
Table 56: SAIC MOTOR CORPORATION 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (0.0% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

0 
0 
0 
0 
0 
0 

 # of 
vehicles 

OVC-HEVs (0.3% of vehicles registered) 

Average 

Arithmetic  km-

Arithmetic  km-

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

29 
0 

29 
29 
0 

29 

6.21 

weighted 
6.33 

1.80 

weighted 
1.80 

4.41 

weighted 
4.53 

245.23% 

weighted 
251.91% 

6.21 
141.54 

6.33 
144.28 

1.80 
41.00 

1.80 
41.00 

4.41 
100.54 

4.53 
103.28 

245.23% 
245.23% 

251.91% 
251.91% 

141.54 

144.28 

41.00 

41.00 

100.54 

103.28 

245.23% 

251.91% 

97 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
Table 57: TOYOTA MOTOR CORPORATION 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (0.2% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

52 
0 
52 
52 
0 
52 

5.37 

5.37 
122.26 

weighted 
5.26 

4.80 

weighted 
4.76 

0.57 

weighted 
0.50 

11.91% 

weighted 
10.55% 

5.26 
119.87 

4.80 
109.25 

4.76 
108.43 

0.57 
13.01 

0.50 
11.44 

11.91% 
11.91% 

10.55% 
10.55% 

122.26 
OVC-HEVs (0.0% of vehicles registered) 

119.87 

109.25 

108.43 

13.01 

11.44 

11.91% 

10.55% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

98 

 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
 
 
Table 58: SUBARU 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (0.1% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

10 
0 
10 
10 
0 
10 

9.50 

9.50 
216.50 

weighted 
9.23 

8.18 

weighted 
8.22 

1.32 

weighted 
1.01 

16.15% 

weighted 
12.28% 

9.23 
210.19 

8.18 
186.40 

8.22 
187.20 

1.32 
30.10 

1.01 
22.98 

16.15% 
16.15% 

12.28% 
12.28% 

216.50 
OVC-HEVs (0.0% of vehicles registered) 

210.19 

186.40 

187.20 

30.10 

22.98 

16.15% 

12.28% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

99 

 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
 
 
Table 59: MITSUBISHI MOTORS CORPORATION 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (0.0% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

0 
0 
0 
0 
0 
0 

OVC-HEVs (< 0.1% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

6 
0 

6 
6 
0 

6 

6.22 

weighted 
6.60 

2.02 

weighted 
2.02 

4.20 

weighted 
4.58 

207.80% 

weighted 
226.63% 

6.22 
141.59 

6.60 
150.25 

2.02 
46.00 

2.02 
46.00 

4.20 
95.59 

4.58 
104.25 

207.80% 
207.80% 

226.63% 
226.63% 

141.59 

150.25 

46.00 

46.00 

95.59 

104.25 

207.80% 

226.63% 

100 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
 
 
Table 60: MITSUBISHI MOTORS THAILAND 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (< 0.1% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

3 
0 
3 
3 
0 
3 

5.76 

5.76 
131.13 

weighted 
5.33 

4.92 

weighted 
4.92 

0.84 

weighted 
0.42 

17.08% 

weighted 
8.45% 

5.33 
121.47 

4.92 
112.00 

4.92 
112.00 

0.84 
19.13 

0.42 
9.47 

17.08% 
17.08% 

8.45% 
8.45% 

131.13 
OVC-HEVs (0.0% of vehicles registered) 

121.47 

112.00 

112.00 

19.13 

9.47 

17.08% 

8.45% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

101 

 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
  
  
 
 
2.  N1 VEHICLES 

Given the limited representativeness of the dataset for vans, the manufacturer-specific information below is presented in alphabetical order. 

102 

 
 
 
Table 61: ALFA ROMEO 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (12.1% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

1 
45 
46 
1 
45 
46 

weighted 
10.41 
7.23 
7.31 
237.18 
190.32 
191.49 

10.41 
7.37 
7.43 
237.18 
193.80 
194.74 
OVC-HEVs (0.0% of vehicles registered) 

8.65 
5.57 
5.63 
197.00 
146.47 
147.57 

weighted 
8.65 
5.54 
5.62 
197.00 
145.72 
147.00 

1.76 
1.80 
1.80 
40.18 
47.33 
47.18 

weighted 
1.76 
1.70 
1.70 
40.18 
44.60 
44.49 

20.40% 
32.32% 
31.92% 
20.40% 
32.32% 
31.97% 

weighted 
20.40% 
30.61% 
30.22% 
20.40% 
30.61% 
30.27% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

103 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 62: AUTOMOBILES CITROEN 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (0.1% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

6 
37 
43 
6 
37 
43 

weighted 
5.86 
5.77 
5.78 
133.44 
151.72 
148.26 

5.70 
6.63 
6.50 
129.91 
174.42 
168.21 
OVC-HEVs (0.0% of vehicles registered) 

5.43 
5.39 
5.39 
123.67 
141.76 
139.23 

weighted 
5.41 
4.43 
4.62 
123.15 
116.68 
117.91 

0.27 
1.24 
1.11 
6.24 
32.67 
28.98 

weighted 
0.45 
1.33 
1.17 
10.29 
35.03 
30.35 

5.05% 
23.04% 
20.52% 
5.05% 
23.04% 
20.81% 

weighted 
8.36% 
30.03% 
25.23% 
8.36% 
30.03% 
25.74% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

104 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 63: AUTOMOBILES PEUGEOT 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (< 0.1% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

0 
37 
37 
0 
37 
37 

7.23 
7.23 

5.86 
5.86 

6.38 
6.38 

5.26 
5.26 

190.35 
190.35 
OVC-HEVs (3.2% of vehicles registered) 

154.15 
154.15 

167.89 
167.89 

138.34 
138.34 

0.85 
0.85 

22.46 
22.46 

0.60 
0.60 

15.80 
15.80 

13.38% 
13.38% 

11.42% 
11.42% 

13.38% 
13.38% 

11.42% 
11.42% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

1 
0 

1 
1 
0 

1 

6.48 

weighted 
6.48 

1.36 

weighted 
1.36 

5.11 

weighted 
5.11 

375.84% 

weighted 
375.84% 

6.48 
147.51 

6.48 
147.51 

1.36 
31.00 

1.36 
31.00 

5.11 
116.51 

5.11 
116.51 

375.84% 
375.84% 

375.84% 
375.84% 

147.51 

147.51 

31.00 

31.00 

116.51 

116.51 

375.84% 

375.84% 

105 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 64: BMW AG 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (8.0% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

1 
1 
2 
1 
1 
2 

weighted 
8.30 
6.96 
7.25 
189.16 
183.13 
184.44 

8.30 
6.96 
7.63 
189.16 
183.13 
186.14 
OVC-HEVs (0.0% of vehicles registered) 

6.50 
6.04 
6.27 
148.00 
159.00 
153.50 

weighted 
6.50 
6.04 
6.14 
148.00 
159.00 
156.61 

1.81 
0.92 
1.36 
41.16 
24.13 
32.64 

weighted 
1.81 
0.92 
1.11 
41.16 
24.13 
27.82 

27.81% 
15.18% 
21.72% 
27.81% 
15.18% 
21.27% 

weighted 
27.81% 
15.18% 
18.08% 
27.81% 
15.18% 
17.77% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

106 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 65: CHRYSLER 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (9.0% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

5 
188 
193 
5 
188 
193 

weighted 
8.05 
9.28 
9.26 
183.33 
244.11 
242.99 

8.29 
9.91 
9.86 
188.77 
260.63 
258.77 
OVC-HEVs (7.1% of vehicles registered) 

6.59 
8.46 
8.41 
150.20 
222.61 
220.74 

weighted 
6.59 
8.12 
8.09 
150.03 
213.61 
212.44 

1.69 
1.45 
1.45 
38.57 
38.02 
38.04 

weighted 
1.46 
1.16 
1.16 
33.31 
30.50 
30.55 

25.68% 
17.08% 
17.25% 
25.68% 
17.08% 
17.23% 

weighted 
22.20% 
14.28% 
14.40% 
22.20% 
14.28% 
14.38% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

2 
0 

2 
2 
0 

2 

6.31 

weighted 
6.13 

2.19 

weighted 
2.19 

4.11 

weighted 
3.93 

187.38% 

weighted 
179.13% 

6.31 
143.69 

6.13 
139.56 

2.19 
50.00 

2.19 
50.00 

4.11 
93.69 

3.93 
89.56 

187.38% 
187.38% 

179.13% 
179.13% 

143.69 

139.56 

50.00 

50.00 

93.69 

89.56 

187.38% 

179.13% 

107 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 66: FIAT GROUP 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (0.6% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

320 
308 
628 
320 
308 
628 

weighted 
6.45 
7.54 
6.77 
146.90 
198.41 
162.28 

6.55 
8.05 
7.28 
149.20 
211.75 
179.88 
OVC-HEVs (2.4% of vehicles registered) 

5.81 
7.00 
6.39 
132.27 
184.16 
157.72 

weighted 
5.79 
6.49 
6.00 
131.96 
170.74 
143.53 

0.74 
1.05 
0.89 
16.93 
27.59 
22.16 

weighted 
0.66 
1.05 
0.77 
14.94 
27.68 
18.74 

12.80% 
14.98% 
13.97% 
12.80% 
14.98% 
14.05% 

weighted 
11.32% 
16.21% 
12.90% 
11.32% 
16.21% 
13.06% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

1 
0 

1 
1 
0 

1 

2.93 

2.93 
66.83 

weighted 
2.93 

1.98 

weighted 
1.98 

0.96 

weighted 
0.96 

48.51% 

weighted 
48.51% 

2.93 
66.83 

1.98 
45.00 

1.98 
45.00 

0.96 
21.83 

0.96 
21.83 

48.51% 
48.51% 

48.51% 
48.51% 

66.83 

66.83 

45.00 

45.00 

21.83 

21.83 

48.51% 

48.51% 

108 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 67: FORD WERKE GMBH 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (0.7% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

337 
594 
931 
337 
594 
931 

weighted 
6.67 
6.17 
6.27 
152.03 
162.31 
160.32 

6.95 
6.36 
6.57 
158.27 
167.33 
164.05 
OVC-HEVs (3.6% of vehicles registered) 

5.28 
5.42 
5.37 
120.28 
142.53 
134.48 

weighted 
5.28 
5.30 
5.30 
120.39 
139.53 
135.82 

1.67 
0.94 
1.21 
38.00 
24.80 
29.58 

weighted 
1.39 
0.87 
0.97 
31.64 
22.78 
24.50 

31.59% 
17.40% 
22.45% 
31.59% 
17.40% 
21.99% 

weighted 
26.29% 
16.33% 
18.25% 
26.29% 
16.33% 
18.03% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

32 
0 

32 
32 
0 

32 

5.18 

weighted 
5.19 

1.34 

weighted 
1.36 

3.84 

weighted 
3.83 

287.69% 

weighted 
280.92% 

5.18 
118.00 

5.19 
118.16 

1.34 
30.44 

1.36 
31.02 

3.84 
87.57 

3.83 
87.14 

287.69% 
287.69% 

280.92% 
280.92% 

118.00 

118.16 

30.44 

31.02 

87.57 

87.14 

287.69% 

280.92% 

109 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 68: JAGUAR LAND ROVER LIMITED 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (60.2% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

 # of 
vehicles 

2 
1 689 
1 691 
2 
1 689 
1 691 

 # of 
vehicles 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
18.17 
8.70 
8.71 
413.91 
229.00 
229.02 

18.37 
8.88 
8.89 
418.55 
233.58 
233.80 
OVC-HEVs (0.0% of vehicles registered) 

12.97 
7.55 
7.55 
295.50 
198.53 
198.64 

weighted 
12.49 
7.50 
7.50 
284.46 
197.40 
197.41 

5.40 
1.33 
1.34 
123.05 
35.05 
35.16 

weighted 
5.68 
1.20 
1.20 
129.45 
31.60 
31.61 

41.64% 
17.66% 
17.71% 
41.64% 
17.66% 
17.70% 

weighted 
45.51% 
16.01% 
16.01% 
45.51% 
16.01% 
16.01% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

110 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 69: KIA 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (1.5% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

8 
1 
9 
8 
1 
9 

weighted 
6.01 
7.78 
6.38 
136.96 
204.67 
151.00 

6.00 
7.78 
6.20 
136.78 
204.67 
144.32 
OVC-HEVs (0.0% of vehicles registered) 

5.00 
5.55 
5.06 
114.00 
146.00 
117.56 

weighted 
5.00 
5.55 
5.11 
113.91 
146.00 
120.57 

1.00 
2.23 
1.14 
22.78 
58.67 
26.77 

weighted 
1.01 
2.23 
1.26 
23.05 
58.67 
30.43 

19.98% 
40.19% 
22.44% 
19.98% 
40.19% 
22.77% 

weighted 
20.23% 
40.19% 
24.72% 
20.23% 
40.19% 
25.24% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

111 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 70: MAN 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (0.3% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

0 
24 
24 
0 
24 
24 

10.51 
10.51 

10.12 
10.12 

9.94 
9.94 

9.81 
9.81 

276.53 
276.53 
OVC-HEVs (0.0% of vehicles registered) 

266.32 
266.32 

261.46 
261.46 

258.20 
258.20 

0.57 
0.57 

15.07 
15.07 

0.31 
0.31 

8.12 
8.12 

5.76% 
5.76% 

5.76% 
5.76% 

3.14% 
3.14% 

3.14% 
3.14% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

112 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 71: MERCEDES-BENZ AG 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (0.1% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

1 
114 
115 
1 
114 
115 

weighted 
15.12 
9.30 
9.35 
344.54 
244.68 
245.53 

15.12 
9.35 
9.40 
344.54 
245.91 
246.77 
OVC-HEVs (0.0% of vehicles registered) 

10.84 
8.15 
8.17 
247.00 
214.41 
214.70 

weighted 
10.84 
8.24 
8.27 
247.00 
216.90 
217.15 

4.28 
1.20 
1.22 
97.54 
31.50 
32.07 

weighted 
4.28 
1.06 
1.08 
97.54 
27.78 
28.37 

39.49% 
14.69% 
14.98% 
39.49% 
14.69% 
14.94% 

weighted 
39.49% 
12.81% 
13.10% 
39.49% 
12.81% 
13.06% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

113 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 72: NISSAN AUTOMOTIVE EUROPE 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (0.2% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

32 
0 
32 
32 
0 
32 

8.57 

8.57 
195.26 

weighted 
8.31 

6.28 

weighted 
6.25 

2.30 

weighted 
2.06 

36.57% 

weighted 
32.92% 

8.31 
189.34 

6.28 
142.97 

6.25 
142.44 

2.30 
52.29 

2.06 
46.90 

36.57% 
36.57% 

32.92% 
32.92% 

195.26 
OVC-HEVs (0.0% of vehicles registered) 

189.34 

142.97 

142.44 

52.29 

46.90 

36.57% 

32.92% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

114 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 73: OPEL AUTOMOBILE 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (< 0.1% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

4 
6 
10 
4 
6 
10 

weighted 
7.90 
5.15 
6.24 
180.04 
135.53 
153.20 

8.02 
5.34 
6.41 
182.67 
140.63 
157.44 
OVC-HEVs (0.0% of vehicles registered) 

6.51 
4.83 
5.50 
148.25 
127.00 
135.50 

weighted 
6.16 
4.62 
5.23 
140.34 
121.52 
128.99 

1.51 
0.52 
0.92 
34.42 
13.63 
21.94 

weighted 
1.74 
0.53 
1.01 
39.70 
14.01 
24.20 

23.22% 
10.73% 
16.64% 
23.22% 
10.73% 
16.19% 

weighted 
28.29% 
11.52% 
19.36% 
28.29% 
11.52% 
18.76% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

115 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 74: PSA 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (0.1% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

89 
30 
119 
89 
30 
119 

weighted 
7.83 
5.27 
7.13 
178.47 
138.77 
167.49 

8.31 
5.62 
7.63 
189.34 
147.84 
178.88 
OVC-HEVs (0.0% of vehicles registered) 

6.98 
4.96 
6.47 
159.04 
130.40 
151.82 

weighted 
6.91 
4.68 
6.29 
157.39 
123.16 
147.93 

1.33 
0.66 
1.16 
30.30 
17.44 
27.05 

weighted 
0.93 
0.59 
0.83 
21.08 
15.61 
19.57 

19.05% 
13.37% 
17.95% 
19.05% 
13.37% 
17.82% 

weighted 
13.39% 
12.67% 
13.25% 
13.39% 
12.67% 
13.23% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

116 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 75: RENAULT 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (< 0.1% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

3 
13 
16 
3 
13 
16 

weighted 
5.67 
5.59 
5.62 
129.24 
147.05 
141.48 

6.94 
5.95 
6.13 
158.09 
156.42 
156.74 
OVC-HEVs (0.0% of vehicles registered) 

5.38 
5.23 
5.26 
122.67 
137.62 
134.81 

weighted 
5.29 
5.07 
5.14 
120.62 
133.28 
129.32 

1.56 
0.71 
0.87 
35.42 
18.81 
21.92 

weighted 
0.38 
0.52 
0.48 
8.62 
13.77 
12.15 

28.88% 
13.67% 
16.59% 
28.88% 
13.67% 
16.26% 

weighted 
7.15% 
10.33% 
9.30% 
7.15% 
10.33% 
9.40% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

117 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 76: SEAT 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (2.1% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

0 
4 
4 
0 
4 
4 

6.03 
6.03 

6.18 
6.18 

5.21 
5.21 

5.34 
5.34 

158.74 
158.74 
OVC-HEVs (0.0% of vehicles registered) 

162.50 
162.50 

137.00 
137.00 

140.36 
140.36 

0.83 
0.83 

21.74 
21.74 

0.84 
0.84 

22.14 
22.14 

15.87% 
15.87% 

15.77% 
15.77% 

15.87% 
15.87% 

15.77% 
15.77% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

118 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 77: SUZUKI MOTOR CORPORATION 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (1.2% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

110 
0 
110 
110 
0 
110 

7.19 

7.19 
163.74 

weighted 
7.17 

7.59 

weighted 
7.59 

7.17 
163.36 

7.59 
173.00 

7.59 
173.00 

-0.41 

-0.41 
-9.26 

weighted 
-0.42 

-5.35% 

weighted 
-5.57% 

-0.42 
-9.64 

-5.35% 
-5.35% 

-5.57% 
-5.57% 

163.74 
OVC-HEVs (0.0% of vehicles registered) 

163.36 

173.00 

173.00 

-9.26 

-9.64 

-5.35% 

-5.57% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

119 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 78: TOYOTA 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (0.1% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

1 
41 
42 
1 
41 
42 

weighted 
5.09 
10.43 
10.42 
116.03 
274.48 
273.98 

5.09 
10.50 
10.38 
116.03 
276.38 
272.57 
OVC-HEVs (0.0% of vehicles registered) 

4.52 
9.40 
9.28 
103.00 
247.20 
243.76 

weighted 
4.52 
9.42 
9.41 
103.00 
247.95 
247.49 

0.57 
1.11 
1.10 
13.03 
29.19 
28.80 

weighted 
0.57 
1.01 
1.01 
13.03 
26.53 
26.49 

12.65% 
11.81% 
11.82% 
12.65% 
11.81% 
11.82% 

weighted 
12.65% 
10.70% 
10.70% 
12.65% 
10.70% 
10.70% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

120 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Table 79: VOLKSWAGEN 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (2.1% of vehicles registered) 

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

 # of 
vehicles 

37 
2 450 
2 487 
37 
2 450 
2 487 

 # of 
vehicles 

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

0 
0 

0 
0 
0 

0 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 
7.83 
6.95 
6.96 
178.38 
182.84 
182.80 

8.07 
7.42 
7.43 
183.80 
195.14 
194.97 
OVC-HEVs (0.0% of vehicles registered) 

6.43 
6.42 
6.42 
146.54 
168.79 
168.46 

weighted 
6.31 
6.20 
6.20 
143.65 
163.01 
162.86 

1.64 
1.00 
1.01 
37.26 
26.35 
26.51 

weighted 
1.52 
0.75 
0.76 
34.73 
19.82 
19.94 

25.43% 
15.61% 
15.76% 
25.43% 
15.61% 
15.74% 

weighted 
24.18% 
12.16% 
12.26% 
24.18% 
12.16% 
12.24% 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

weighted 

weighted 

weighted 

weighted 

121 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
Table 80: VOLVO 

Year of first registration: 2021 

Real-world data 

WLTP Monitoring 
data (Art.7 of Reg 
(EU) 2019/631) 

Gap 

ICEV + NOVC-HEVs (5.1% of vehicles registered) 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol 
Diesel 
Petrol+Diesel 

CO2 emissions (g/km)  Petrol 
Diesel 
Petrol+Diesel 

31 
11 
42 
31 
11 
42 

weighted 
8.51 
6.87 
7.72 
193.97 
180.84 
187.58 

8.98 
6.70 
8.38 
204.63 
176.17 
197.18 
OVC-HEVs (17.9% of vehicles registered) 

7.24 
6.26 
6.98 
164.84 
164.64 
164.79 

weighted 
7.24 
6.39 
6.83 
164.95 
168.05 
166.46 

1.75 
0.44 
1.40 
39.80 
11.53 
32.39 

weighted 
1.27 
0.49 
0.89 
29.02 
12.79 
21.12 

24.14% 
7.00% 
20.12% 
24.14% 
7.00% 
19.66% 

weighted 
17.59% 
7.61% 
13.05% 
17.59% 
7.61% 
12.69% 

 # of 
vehicles 

Arithmetic  km-

Arithmetic  km-

Average 

Absolute 
Arithmetic  km-

% 

Arithmetic  km-

Fuel consumption 
(l/100km) 

Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

CO2 emissions (g/km)  Petrol/Electric 
Diesel/Electric 
Petrol+Diesel 
Electric 

50 
0 

50 
50 
0 

50 

5.84 

weighted 
5.97 

2.11 

weighted 
2.10 

3.73 

weighted 
3.87 

176.34% 

weighted 
184.73% 

5.84 
133.03 

5.97 
135.97 

2.11 
48.14 

2.10 
47.76 

3.73 
84.89 

3.87 
88.22 

176.34% 
176.34% 

184.73% 
184.73% 

133.03 

135.97 

48.14 

47.76 

84.89 

88.22 

176.34% 

184.73% 

122