"See reply #6 for CR's testing details."
Except that there's almost no detail in the attachment. For example, at what speeds was the vehicle driven and for how long? How much idle time at stop lights? What sort of acceleration and braking was employed and how often? What were the temperature and road conditions? I assume that the car was empty except for the driver but it would be nice to know. I realize this is a track and not a real road but all of these factors are significant in testing any car and especially with a hybrid.
All in all, 26 MPG seems so out of line with my own experience that I have a hard time believing that it represents any likely drivers likely mileage. Heck, I beat 26 MPG driving back from picking my son up from college this week even though the car was loaded with three adults and about 350 lbs of stuff. This was partly highway but also included about 2 hours of low-speed driving due to traffic and a bad accident. So unless CR tested the Rav4 hybrid pulling a trailer uphill in winter, I don't believe that 26 MPG city is realistic.