After carefully reading again what they stating stating, it appears that even when they talk about CO2 emissions, they actually base their claims on self reported fuel consumption data from
http://www.spritmonitor.deIt looks to me that the following is entered (I have not used the app) by the users.
Objective data:
Date of fuelling,
Current odometer value,
Amount and price of fuel.
Type of tires (summer/winter) [should be mostly objective]
Subjective data:
Driving style used (Moderate, Normal, Fast),
Roads driven (Motor-way, City, Country roads)
For roads driven all the options could be selected and are then doubly reported in the detailed statistics.
This means that there is no objective acceleration and speed profile and also elevation difference data is missing (is not collected).
To illustrate this I will compare two different entries for BMW 3er 320d touring efficient dynamic
1) http://www.spritmonitor.de/en/detail/595885.html?cdetail=1 (2012, 120 kW, 4,14 l/100km)
2) http://www.spritmonitor.de/en/detail/672858.html?cdetail=1 (2011, 120 kW, 5,54 l/100km)
As both cars have the same power, I assume that they are the same model.
The consumption difference is 33%!
Driver one believes that driving style has been mostly moderate and driver two believes that driving style has mostly been normal.
Edit: I think that it illustrates that it is possible to drive this car close to its spec but it also easy to have more courageous driving style.