Since the 1990s, the new car market has been inundated with car-like trucks and truck-like car-based crossovers. It’s getting so you can’t tell the difference between a car and a truck without a flowchart. Luckily, the EPA and NHTSA now have one. Let’s take why this became necessary, what the federal flowchart says, and why it’s become a problem.
Thirty-odd years ago, when testing the first-generation Toyota RAV4 for their April 1996 issue, Car and Driver asked a Toyota executive to define the difference between a car and a truck. This unnamed executive apparently gave the matter some thought, and then declared, “If you can sell fruit out of the back, then it’s a truck.”
It was a silly answer, but an apt question: The first XA10 RAV4, which had debuted at the 1993 Tokyo Motor Show and went on sale (in three-door form) in Japan in May 1994, certainly looked truckish, and it had full-time 4WD, but Toyota admitted that it “will not be seen as an off-road vehicle in the same way that the Land Cruiser is.” Like its “cute-ute” contemporaries, a lot of its hardware was actually borrowed from passenger cars (principally the Corolla and Celica All-Trac models). So, was the RAV4 a miniature truck or just a tall subcompact station wagon in hiking boots?
For the EPA and NHTSA, these philosophical questions aren’t just idle musing. In the U.S., cars and trucks have long been subject to different sets of standards for safety, emissions, and fuel economy — trucks have been exempt from some of the requirements that apply to passenger cars, and subject to lesser standards in other areas. Four or five decades ago, that seemed to make a reasonable amount of sense: New cars were far more numerous than new trucks, and few people had any difficulty telling the difference between a car and a truck, van, or off-road vehicle. The second-generation Ford Bronco pictured above was based on the contemporary F-Series pickup truck; you could tell.
There had always been a few ambiguous areas, of course. SUVs are not a recent invention, and since the 1950s, the Automobile Manufacturers Association had tried to draw a distinction between “station wagons on passenger car chassis” and “station wagons on truck chassis” (like the old Willys Jeep wagons). However, the latter were still strictly a niche item.
Even when the earliest car-based crossovers began to appear in the ’80s, there were still too few of them for regulators to worry very much about how best to clarify the distinction between “car” and “truck.”
It took quite a while for car-based crossovers to catch on, but by the late 1980s, the U.S. market was seeing a big surge in the popularity of family-oriented truck-based SUVs. There were earlier antecedents, but it was really the 1984 Jeep Cherokee XJ that kicked it off, since the XJ managed to combine off-road prowess with surprisingly civilized on-road manners, making it a vehicle suburban yuppies could easily justify driving year-round.
However, it was the 1991 Ford Explorer that opened the SUV floodgates, driving the traditional full-size car-based station wagons to extinction. First-generation Explorers like this were technically trucks, like the Bronco II they replaced, but most people didn’t use them that way. Automakers quickly grasped that there was big money in SUVs that could act like station wagons, and eventually a growing market for tall car-based station wagons that looked like trucks. Today, it’s gotten awfully hard to tell the difference.
Things eventually got so complicated that the National Highway Traffic Safety Administration (NHTSA), which sets standards for auto safety and corporate average fuel economy (CAFE), had to create this convoluted “decision tree” based on the various statutory and regulatory definitions. (The above flowchart doesn’t apply to everything — for instance, there are some regulations that are based strictly on gross weight.)
You’ll notice that the first and most important criterion in this table is gross vehicle weight rating (GVWR), which is a vehicle’s rated maximum load with passengers and cargo. Because I know people sometimes get hung up on this point, I want to emphasize that GVWR is NOT the same as curb weight, which is the vehicle’s weight ready to drive with a full fuel tank, but WITHOUT occupants or cargo. For obvious reasons, GVWR is always higher (often a lot higher) than curb weight.
Although it’s not defined in the above flowchart, “MDPV” means a “medium-duty passenger vehicle.” The NHTSA created this category in 2011 to describe certain jumbo-size SUVs and passenger vans with GVWRs of 8,500 to 10,000 lb. The defunct Ford Excursion would have fallen into this category, although it had been discontinued by the time the MDPV term was coined. A pickup truck is not considered an MDPV even if its GVWR falls in this range.
The EPA admits that even these convoluted definitions are still somewhat arbitrary, and “can lead to similar vehicles having different car or truck classifications, and different [fuel economy] requirements under the CAFE regulations.”
A good example of this issue is the two vehicles shown in our lead image and the photos above: the 2026 Kia Niro (top) and Honda CR-V (bottom). Many of us would consider both of these vehicles to be crossovers (although the EPA doesn’t use that term). The Honda is actually bigger than the Kia (the CR-V is 10.8 inches longer, 1.6 inches wider, and over 250 lb heavier than the Niro) and has more cargo space, but their passenger volumes are almost identical. Both vehicles are normally FWD, although the CR-V is also available with AWD. Either vehicle is likely to spend most of its life in a similar mix of solo commuting, school runs, and the occasional family road trip. However, based on the “decision tree” flowchart shown above, the Kia is considered a truck (the federal www.fueleconomy.gov website classifies it as a small SUV), while the CR-V is classed as a car (www.fueleconomy.gov classifies it as a midsize station wagon).
The problem, from an environmental and socioeconomic standpoint, is that vehicles classed as trucks are still allowed to drink a lot more fuel than ones classed as cars. In certain cases, small “trucks” may actually be more fuel efficient than larger “cars” — the hybrid Kia Niro has a 2026 EPA combined rating of 50 mpg, whereas a FWD Honda CR-V Sport Hybrid rates only 40 mpg — but they aren’t required to be, and they often aren’t. As the above charts indicate, the average real-world fuel economy of modern trucks is still much lower than modern cars’, and the gap is even wider if you exclude the absurdly generous adjustments the EPA makes when averaging in plugin hybrid and battery electric vehicles (PHEVs and BEVs). Even WITH those BEV/PHEV adjustments, the overall average fuel economy of 2024-model truck-based SUVs was over 30 less than passenger sedans, and pickups remain over 25 percent thirstier than truck-based SUVs. And that’s with truck fuel economy now at what the EPA calls historic all-time highs.
As the above graph illustrates, until about 1985, cars represented more than three-fourths of the U.S. market, and so it was their emissions and fuel economy that had the greatest total impact. Today, cars and car-based SUVs together make up only about one-third of new vehicle production, and their market share has been shrinking for years. If you look at how much market share trucks now have, their heavier fuel consumption is bad news for both U.S. oil consumption and total greenhouse gas emissions. Moreover, since the domestic automakers have now completely abandoned most of their passenger sedans, it would be difficult for the market to shift en masse back to cars even if consumers decide that they’d like to.
You can find these charts, and a lot of other data about new car and truck trends in the U.S., in the annual EPA Automotive Trends Report, prepared each year by the EPA Office of Transportation and Air Quality. The most recent report, which has data through the 2024 model year (and provisional data for 2025), was released in late February 2026.
Related Reading
Data Diving EPA’s 2021 Automotive Trends Report: Charting The Big Changes Since 1975 (by Paul N)
The Toyota executive’s definition is good, but would lump a Country Squire in with the trucks.
My rules are simple. If ground clearance at the driver’s door is more than 10″, it’s a truck. If clearance is less but my butt has to go up instead of down to get into the seat, it’s a truck.
I don’t care about the car/truck distinction as it applies to gas mileage as long as the buyer is told. I’ve found those calculations to be grossly inaccurate but they seem to be consistently so, which allows reasonably good comparisons. I am concerned for the car/truck distinction in regard to safety and emissions. I would never buy a truck but majority does and I’m concerned that this reduces air quality. I live in farm country and don’t like being told that global warming is my responsibility when tractors and F-350s have fewer restrictions. For the record, I’m not on the EV bandwagon for a variety of reasons.
According to that flow chart, my 1964 Oldsmobile Vista Cruiser is a truck.
I always thought they were more like a bus. 🙂
Any set of statutory definitions is nothing more than a playground for lawyers. And it’s not the lawyers’ fault. There are always ambiguities and a lot riding on how they are resolved.
It is little wonder that “trucks” have been crowding “passenger cars” from the market. The attributes of cars in the broad middle of the market from the 40s through the 70s are now mostly found in trucks. The regulatory setup has created an incentive to build something as close to a traditional car as you can get, but that can come under the definition of truck, which allows far more flexibility in size and powertrains.
I’m confused as to how the decision tree classifies the Niro as a truck. The GVWR is nowhere near 6000 pounds and I don’t see any other way for it to reach the truck category.
The rear seat of the Niro can be removed to increase cargo capacity. That automatically puts it in the truck category.
https://www.reddit.com/r/KiaNiro/comments/bodd8j/just_converted_niro_into_camping_beast_seats_were/
Huh, what a strange little pathway to truck designation. Didn’t expect that.
Is that what started in earnest with the PT Cruiser?
Yes.
I recall the 2-door convertible version of the PT Cruiser that was later added had to be classified as a car. (online sources are in disagreement about this)
Not only are there some differences between the EPA and FHWA classifications of truck vs. car, but Customs uses a separate classification system for tariff purposes. While generally consistent with EPA and FHWA treatment, the need to pigeon hole a vehicle into one of the HTS categories can lead to a different outcome for tariff purposes.
https://www.usitc.gov/publications/docs/tata/hts/bychapter/1000c87.pdf
California has its own definition of commercial vehicle for registration purposes, primarily built to carry cargo rather than passengers. A pickup is obviously a truck and a truck based station wagon, including Tahoe/Suburban/Yukon, etc is fairly obvious, but vans are not. My Dodge A-100 was a cargo van and my dad’s A-108 Sportsman was a station wagon because it had a (removable) back seat and windows all around, but still a huge open cargo area.
An annual weight fee is paid if it is a “truck”, based on unladen weight. Best I can tell, that is curb weight minus fuel, certified by the manufacturer when new, or from a certified truck scale. Also, if I permanently attach my camper to my pickup, I may re-title it as a “housecar” and not pay weight fee, but must pay annual tax based on the total value, not just the pickup.
You also have an option (or you did anyway when I lived there) to classify your windowed van or station wagon or minivan as a commercial vehicle instead of a regular one and pay more for the plates via the weight fee, but it did then allow you to park in commercial loading zones, a huge advantage if in sales in San Francisco for example. Our first Minivan (A Sienna XLE, absolutely a passenger vehicle) was registered that way and a colleague did it with her Honda Accord station wagon It had no effect on anything fuel economy related though.
Our 2020 Ford Transit is a cargo van, per Ford, two seats only. The DMV registration was handled by the dealer as is typical here, and I was surprised to get passenger car license plates which are as different alphanumeric format than commercial plates, a few weeks after we bought it. We don’t pay the weight fee. Our Tacoma, which is 4wd and body on frame bla bla bla, but is really a body-on-frame 4wd sedan without a trunk lid, has commercial plates and we pay the weight fee.
Transit shows still another car vs truck legal distinction, the “chicken tax” duty on imported trucks from the 1950’s.
Ford imports the Transit cargo van with a back seat installed and then removes the seats after clearing Customs, and ships them back to the final assembly plant in Turkey. So, Ford does not give California an unladen weight, since it is some sort of multipurpose vehicle to them.
So if I’m reading this right, anything with 6,000+ lbs of GVWR and a 3rd row is a truck?
In this case, the only thing needed to make a Porsche Taycan Sport Turismo into a truck is a jump seat in the back.
It’s the equivalent of our tax code: inconsistent, illogical, unfair, and endlessly modified to serve special interests.
👍👍
Leave it to crony capitalism and bureaucracy to come up with a convoluted flow chart to define a truck.
If it has a bed it’s a truck.
The problem is the definition of a bed.
If you take the trunklid off an Accent or a Mirage, does it become a truck by the virtue of having a “cargo bed that is enclosed by three low walls with no roof” (to quote Wikipedia)?
Conversely, if a Mirage or an Accent isn’t a truck because the “bed” can be covered up, then where does it leave any actual truck, which can be fitted with a bed cover?
Even a requirement for the bed to be separate from the body doesn’t clear things up, because that would make stuff like early 60s “unibody” Fords, HD Avalanches, or even actual Hummer H1 pickups into passenger cars.
Well I’m largely being facetious, however it’s really not hard for me to define a truck bed; walled in with steel fully isolated from the passenger compartment, bare steel floor, tailgate of which is flush with the floor… sure a shade tree owner can make a sedan’s trunk into a makeshift bed but as far as manufactured products are concerned, unless automakers want to offer sedans without trunklids, carpet etc. to get truck classification(sort of a reverse Subaru Brat if you will), it’s not a difficult distinction.
Then the difficulties continue – what about the folding rear seat on the Silverado EV? Does a plastic bed liner invalidate a truck? What if there is no tailgate – e. g. flatbeds?
Laws usually have to be complicated because life isn’t black and white.
Or more succinctly law is blind… literally
It is a good example of how regulatory simplicity instead of deregulation would be preferable. What if instead of CAFE we simply had a maximum permitted combined MPG for new vehicle sales which declined every year. That would prompt electrification first of exotics, then commercial and luxury vehicles, then light duty trucks and so on, putting the expense of transitioning to ZEVs where the market could best bear it.
Because we have a protected market economy and your proposal would put the “domestic” manufacturers besides Tesla out of business which might not be the actual end of the world compared to all the other candidates for that distinction currently vying for attention… They simply cannot (or willfully choose not to) compete on a fair and even footing with the world’s best when it comes to the full gamut of vehicle types but instead in aggregate with the oil companies lobby our “elected” officials to favor them.
The best use for electrification (full EV or hybridized) is for smaller (which is not the same as small) personal and even many commercial use vehicles, the ones that in aggregate travel the most number of miles in total. And the gas/diesel tax should increase significantly in order to dissuade the use of less efficient vehicles in excess of “genuine” need/use.
As far as gas taxes being “regressive” and penalizing the poors that can’t afford efficient vehicles, fuel efficient vehicles achieving well over 30mpg have been being produced and sold on the used market for 50 years now. The average age of a vehicle in a pick and pull junkyard is 10-15 years old, efficent vehicles are not rare or new. There is NO reason why someone unable to purchase the latest and great hyrbid or EV has to purchase a 25 year old V8 Explorer getting 14 mpg for $3000 instead of for example a 20 year old Subaru Legacy wagon getting a stil inefficient 28mpg and holding the same number of passengers for the same amount of money. Lose the AWD and you’ll hit 30mpg in the Subaru and over that in a Camry or Accord sedan. If they HAVE TO tow a 20 foot ski boat, well, how poor are they really then?
That’s quite the place you’re living in if the poors around you are hauling around ski boats in V8 explorers. Around here the poors do in fact drive 15-25 year old small sedans shuttling around the DoorDash, Instacart, Uber Eats etc. deliveries for peanuts all day to McMansions with brand new Teslas in the driveway…
But yeah penalize them with even more tax(on top of the whopping self employment taxes) because others are just larping as poor and can afford to get with the program.
Well, if you can’t recognize a little facetiousness in my writings by now I can’t help with that, it’s not your first week here. And anyone who does Uber, Lyft, DoorDash, GrubHub or anything remotely similar using their own vehicle and doesn’t realize they are being shamelessly exploited by their “employer platform” and usually actually losing money once the vehicle and its expenses/depreciation/repairs itself are factored in is beyond my help (besides acknowledging and admitting that our society as a whole does basically zero to help those needing help from the day they are born). Good to hear the exploitees around you seem to be smarter than the average and are at least choosing vehicles with less expense demands, likely due to Chicagoland gas prices having been more elevated than surrounding areas for a long time, around here it’s not unheard of to see a fairly recent Jeep Grand Cherokee or similar being used for those things, you can tell the pros (used 300k mile Camry Hybrid) vs the desparate housewives (JGC, GMC Acadia etc) easily enough. It is though a fact that there are other jobs/income opportunties that don’t require literally using fuel all day long, at every employment or income level.
No role-playing here, but I myself pay those self-employment taxes in my self-chosen income streams along with a higher rate of healthcare premium than you can likely imagine. The self-employment taxes are not “whopping” compared to eveything else (it’s simply the part your own employer pays FOR you instead of paying TO you in the form of more salary/pay), it’s also commensurate with your actual income, not a flat fee, if you have no income due to your expenses wiping it out you have basically no tax due and that applies at a level far higher than zero.
Proof that this was all a bureaucratic game for carmakers to jump through hoops that Trump was justified to get rid of it: Chrysler PT Cruiser and Chevy HHR were classified as trucks.
Two models that ceased production five years before his first term. But what did he get rid of? The post describes present day policies, the whole point of the post is how convoluted and ridiculous it is.
Thanks for this explanation – the “decision tree” helps – well, it helps as much as possible with these convoluted processes.
Though just tangentially related to the car/truck definition, I find it interesting in the market share chart at the end, that the market penetration of actual pickups has held remarkably steady over the last 50 years. I would have guessed these market rates to have at least doubled over that period.
So would I, which is I guess why these kinds of charts are useful. It should be said that the size of the total light vehicle market has increased by roughly 50 percent since the late ’70s, so the actual number of new pickup trucks on the road is generally higher even if the market share is similar.
When I worked as a contractor to NHTSA in the early ’90s, I counted at least fourI different ways different branches of government classified cars vs. trucks – in addition to CAFE/MPG, safety, and emissions, there was also the “voluntary” import quotas on Japanese cars (which IIRC didn’t apply to trucks or vans), and the “chicken tax” on imported trucks which had its own distinction of truck vs. car (passenger vans were cars).
I think every vehicle used primarily for personal transportation/family car/etc. should be lumped together – cars, crossovers, most SUVs, passenger vans, light pickups. Vehicles used primarily for cargo transport or commercial use would be the only ones with most legal distinctions. Of course, the problem remains wherever you draw the line, there will be some vehicles that seem misclassified. Like the Toyota Sienna and Chrysler Pacifica are clearly primarily family transportation, whereas the Ford Transit Connect or Ram Promaster City passenger vans are primarily commercial vehicles used as shuttles, small businesses, and such. But what do you point to to make a legal distinction between the two? “I know a commercial vehicle when I see one” won’t fly. Light-duty pickups with four doors and very short beds are often used as regular cars despite being traditionally considered trucks, especially obviously car-based models. And crossovers (and even BOF SUVs) are almost all used as cars despite often being classified as trucks. Yet it does seem that something like a Wrangler or Defender, especially in off-road-oriented specification, is off-roady enough to qualify as a truck, and while often purchased by suburbanites who just like the looks, is also needed by many farmers and rural dwellers. No easy answers.
(also: transformers like the old Nissan Pulsar or upcoming which allow owners to change body styles themselves)
*upcoming Slate
My DD is a 2017 Mazda CX-5 FWD. I believe the CX-5 was such a knife-edge case that the FWD models were cars and the AWD models were trucks. What did Mazda do with that? They stopped exporting FWD models to the US. Sigh. It was difficult to find the FWD model used, but not impossible in the desert Southwest. I really like my “car”.
Last year around this time, our family had four vehicles, 2015 Odyssey Van, 2011 Venza, 2011 328ix E92 wagon, and 2004 Matrix. According to New Jersey DMV, the first three vehicles are non-commercial truck, annual registration fee is $71.50. Matrix is passenger vehicle with lower registration fee around $51. What amazing to me, the BMW wagon is clearly a compact car and yet classified as a truck, and Matrix is definitely a CUV with tall body, high seating and lift gate even it is based on a Corolla. In my view, the car and truck classifications no longer make sense with more and more vehicles produced as SUV or CUV. As EPA rule, I believe car manufacturers prefer to categorize their vehicles as trucks to get a break from fuel economy regulations.
Side story I want to share here is many years ago based on the vehicle gross weight for lease owners IRS allowed the vehicle expenses as deductible, my friend, an independent IT consultant, was told by his accountant to buy a heavy vehicle for tax purposes, theoretically he could get a Rolls-Royce for that tax deductible. My friend got a top of line Suburban, he even wanted to have a Original civilian version of Humvee, his wife was dead against that.
You can always deduct your legitimate vehicle expenses if you are a business or an independent contractor that has themselves set up correctly. Section 179 of the tax code allows for accelerated depreciation again so you can deduce the entire cost the first year for qualifying vehicles, basically (grossly oversimplifying here) anything with a GVWR of over 6000lbs (not curb weight, but GVWR). A Nissan Frontier qualifies on the low end as does pretty much anything full size and plenty of mid-size SUVs (but not a Tesla Model Y as it is lighter than most people think and has a GVWR below 6000 – you can though still depreciate it the regular way over time).
Anyway, it’s still a tax DEDUCTION which is not the same as a tax CREDIT and way too many tax payers don’t understand the (very significant) difference because it is not taught in our schools… So if you are in the 24% tax bracket taking the section 179 deduction will save you 24% of the purchase price assuming it doesn’t bump you down a bracket and a portion of that is then only credited at the next lower bracket. It obviously makes most sense for people in the 35 or 37% tax bracket but can work to a lesser but still very useful extent for plenty of people in lower brackets as well, they just don’t “save” as much. And should consider not buying more than they really “need” anyway, i.e. only do what gets the most benefit, at the end of the day you are still spending more if you don’t really need anything. Note that when/if you sell or trade in the vehicle you then have to reconcile that and pay taxes back on the then-value vs what you depreciated and saved. So if your friend did buy a Rolls Royce Cullinan SUV for its $432,000 base price and was in the 35% tax bracket he may have been able to deduct that cost and save $151200 on his taxes ($432k x 35%)(well not quite since the bracket isn’t wide enough to absorb that whole cost, some of it would be only at the next lower bracket). But he would still have the pay for the rest of the car ($280,800) which was probably too much, so he got a Chevy…(wiser choice). If he sold the Rolls-Royce in five years and gets $200,000 for it then he has to add that $200k to that year’s taxable income. Hopefully he had a good year. Or preferably a very bad year but had money set aside for the tax man.
If the current ACA rules don’t change, at the end of this year there is an interesting wrinkle where it will make all kinds of sense for some people that are marginally above the cut-off point for claiming a healthcare premium subsidy vs paying the entire premium. For some people/familes that can be literally multiple tens of thousands of dollars that can potentially be saved by buying just enough vehicle (or other capital expenses) to deduct enough from their Modified Adjusted Gross Income to get it below the limit – Assuming they have a legitimate business use for the vehicle or equipment of course. It doesn’t have to be a new vehicle either, used is fine.
Excellent explanation. Thank you, Jim
Fascinating .
In the mid 1960’s I was logging serious time in two Chevy Suburbans, one was a c/10 with rows of seats, the other was a K/10 4X4 we used as a plow rig and general building maintenance vehicle .
Both were clearly trucks if light duty by design .
Now I have the 2000 Chevy Tracker, a tiny little 5 passenger mini SUV 4X4, it’s body on frame so I guess it’s a truck (?) .
-Nate
Very informative & detailed article. In my old age I prefer to keep things simple. I like the old saying, “If it walks like a duck, and looks like a duck, its a duck.” So if it looks like a truck, its a truck, and if it looks like a car, its a car.
It was 1990 and I lived in Manhattan and bought a summer cabin in the Catskills. I almost bought a 1990 Ford Bronco Eddie Bauer Edition. Not too big, not too small, room for the cats & dog. A big bear tried to enter the cabin one night and ended the idea of summers in the woods and buying a truck (SUV?) for those back mountain roads. Following summers I rented at the beach and never worried about a shark breaking in late at night.