Climate Lobbying Overview: Volkswagen is actively engaged with European, UK and US climate regulation, with mixed engagement in all three regions in 2021-23. Despite initial support, the company appears to have supported weakening the EU’s light-duty vehicle CO2 2035 zero-emission target in 2023, and has also opposed a UK ZEV mandate. The positioning of Volkswagen’s subsidiaries appears to be misaligned, with some appearing more positive than others in their climate policy engagement.

Top-line Messaging on Climate Policy: Volkswagen supports the EU’s 2050 climate neutrality target, according to an October 2021 position paper, and has expressed support for a 1.5°C global warming target, for example in a December 2022 joint letter. The company has repeatedly voiced its commitment to the Paris Agreement, for example in a September 2022 Twitter post. Its 2021 Sustainability Report also indicates that Volkswagen supports government policy around carbon pricing. Former Volkswagen CEO, Herbert Diess, expressed support for government regulation in the mobility transition in a June 2022 press release, and advocated for increased ambition in climate policy in a March 2021 media report.

Engagement with Climate-Related Regulations: Volkswagen appears to have mixed engagement with CO2 standards for light-duty vehicles in the EU, with its position appearing to have become more oppositional since the company’s change in CEO in September 2022. In a March 2023 Automotive News Europe article, Porsche, a Volkswagen subsidiary, was reported to have opposed the EU's 2035 zero-emissions target in seeking to influence Gemany's decision to abstain from voting in its favor and water down the regulation in its final stages through an e-fuels exemption. A March 2023 Financial Times article appeared to confirm Volkswagen’s position to support an e-fuels exemption, with its CEO appearing to oppose the 2035 target and stating that “the federal government has to undertake the respective steps” in reference to Germany. On the other hand, Audi CEO, Markus Duesmann took a conflicting view in a March 2023 Spiegel magazine interview, urging the German government to support the 2035 zero-emissions target. Shortly before, Volkswagen stated that the EU’s 2035 target is “ambitious but achievable”, claiming “we accept the EU‘s decision and are prepared to deliver on it”, according to a February 2023 Detroit News article. Earlier, in June 2022, Volkswagen expressed support for the EU's proposed 2035 zero-emissions CO2 target for cars in a media statement reported by Automotive News. The company appeared to explicitly support the 2035 zero-emissions CO2 target for the first time in an October 2021 position paper, while appearing to previously take a more negative position on EU CO2 targets for cars, such as in a February 2021 EU consultation response.

In the US, in December 2020, Volkswagen entered into a voluntary arrangement with California regulators accepting the state's GHG emission standards and ZEV program, despite proposals by the federal government to revoke the state's power to implement them. Furthermore, a June 2022 Reuters article reported that Volkswagen supported the US EPA’s decision to restore California's ability to set its own stricter GHG emissions standards independent of federal standards under the Clean Air Act. Volkswagen also expressed support for federal US GHG emissions standards for vehicles in an August 2021 joint statement on the Biden Administration’s Steps to Strengthen American Leadership on Clean Cars and Trucks. With regards to heavy-duty policy, in a May 2022 consultation response, Navistar, a major Volkswagen subsidiary, appeared to oppose a proposal in the US Environmental Protection Agency’s (EPA) “Clean Trucks Plan” that would tighten “Phase 2” GHG emissions standards for heavy-duty vehicles for 2027 and beyond for certain vehicle categories, arguing that the changes would be “disruptive, unnecessary, and premature”.

In the EU, evidence from a July 2021 letter signed by former Volkswagen CEO, Herbert Diess, and an October 2021 position paper suggests that the company supports a carbon border adjustment mechanism, however without specifying a position on the removal of existing carbon leakage protection measures in the EU ETS. In an October 2021 Wirtschafts Woche article, the company appeared to support a higher German CO2 trading price and in a September 2021 LinkedIn post, Herbert Diess recommended that the new German government support a €65 carbon price by 2024. Volkswagen also appears to support the expansion of the EU ETS to road transport, according to its 2021 Sustainability Report, published in 2022. Moreover, according to an October 2021 position paper, the company supports higher renewable energy targets in Germany for wind, solar and offshore wind. It has also advocated for the EU 2030 55% GHG emissions target, as evidenced in a May 2021 press release.

Positioning on Energy Transition: While Volkswagen generally appears to support measures promoting the electrification of transportation, it has mixed engagement globally on ICE phase-out and ZEV mandate policies. In a March 2023 Automotive News Europe article, Porsche, a Volkswagen subsidiary, appeared to oppose the EU's 2035 ICE phase-out date for light-duty vehicles by appearing to support Germany's decision to abstain from voting in its favor and seeking a loophole for synthetic e-fuels at the final stages of the regulation. Similarly, in a July 2022 DW news article, Volkswagen CEO, Oliver Blume, was reported to advocate for the long-term role of ICE vehicles and the use of e-fuels directly to German policymakers. However, earlier, in an October 2021 position paper and a June 2022 Automotive News media report, Volkswagen appeared supportive of the EU’s 2035 ICE phase-out target. In a September 2021 interview with CNN, former Volkswagen CEO, Herbert Diess, stated that “electrification is not the solution in every place”, suggesting an unsupportive position to a global phase-out of ICE vehicles. Volkswagen also did not sign a global pledge made at COP26 to phase out ICE-powered vehicles in leading markets by 2035 and globally by 2040, emphasizing concerns around “regions developing at different speed combined with different local prerequisites”, which “need different pathways towards zero emissions”, according a November 2021 Detroit News media report.

Moreover, in a September 2021 UK consultation response obtained via FOI request, both Volkswagen and its subsidiary, Bentley, appeared to oppose a UK ZEV mandate, including for heavy-duty vehicles. However, Volkswagen and Bentley expressed support for only the sale of PHEVs and ZEVs in the UK from 2030-35 as part of the UK's ICE phase-out date. In the US, in a May 2022 California consultation response, Volkswagen appeared to take an unclear position on California's proposed Advanced Clean Cars II regulation, which would require an increasing percentage of new light-duty EV sales each year until a 100% ZEV mandate in 2035, while proposing several flexibilities to reduce the stringency of the policy.

Furthermore, Navistar, a major Volkswagen subsidiary, has mixed to negative engagement on heavy-duty vehicle policy in the US. The company has urged policymakers to delay the adoption of the Advanced Clean Truck (ACT) rule, which requires manufacturers to sell increasing percentages of zero-emission trucks, in numerous states. This includes Oregon in an October 2021 email, and New York in a November 2021 oral testimony and consultation response. The company also appeared to oppose the rule in Colorado in an April 2022 consultation response submitted by the Partners for a Zero-emission Vehicle Future (PZEVF) coalition (of which Navistar is a member), and New Jersey in a July 2021 joint letter signed by the coalition, both found via FOIA request. Navistar also appeared to oppose the ACT rule more broadly in April 2022 public comments from the PZEVF coalition to the Clean Air Association of the Northeast States.

However, Volkswagen generally appears to generally support measures promoting the electrification of transportation. In January 2023, the CEO of Volkswagen’s Seat brand called for “ambitious decisions" to be taken to accelerate vehicle electrification in Spain, which he argued is falling further behind leading European countries in the EV transition. Similarly, a February 2023 Bild article reported that Volkswagen CEO, Oliver Blume, called on the German federal government and local authorities to increase charging infrastructure in Germany. In an October 2021 position paper, Volkswagen advocated for an extended German purchase premium for EVs, supporting higher company car taxes for ICE-powered vehicles and plug-in hybrids (PHEVs) over EVs, as well as electrifying heavy-duty transport. The company also signaled support for the Biden Administration’s steps towards electrification in the US in an August 2021 joint statement. Additionally, Volkswagen has publicly supported the expansion of EV charging infrastructure across the EU, advocating for mandatory charging infrastructure requirements for all EU member states in a February 2021 EU consultation response, and supporting higher EV infrastructure targets across the EU and Germany in an October 2021 position paper.

Former Volkswagen CEO, Herbert Diess, has vocally criticized the use of coal in the EU’s energy mix, in June 2021 advocating for policy to phaseout coal. In September 2021, Diess further listed ten recommended policies for German coalition negotiations, including ending fossil fuel subsidies and supporting renewable energy expansion. Volkswagen also supported the end of fossil fuel subsidies in Germany in an October 2021 position paper. In an April 2022 Automotive News media report, Markus Duesmann, CEO of Audi (a Volkswagen subsidiary), advocated for the complete phase-out of fossil fuel use across the European automotive industry by 2040, urging Europeans to "put all their energy towards battery-electric vehicles for individual mobility".

Industry Association Governance: Volkswagen publicly discloses a list of its memberships to industry associations, but it does not provide any further details of the company's role within each organization's governing bodies, nor its influence over their climate change policy positions. Volkswagen has not published an audit of its alignment with its trade associations. Volkswagen’s CEO, Oliver Blume, sits on the board of both European Automobile Manufacturers Association (ACEA) and the German Automotive Association (VDA). It is worth noting, however, that Volkswagen has publicly distanced itself from the VDA on several occasions, for example in March 2019 when Volkswagen reportedly threatened to withdraw from the VDA due to the association's failure to promote electric vehicles. Additionally, evidence from 2021 suggests that VW has been internally pushing ACEA to advocate for more ambitious EU policies around the electrification of vehicles and vehicle CO2 standards. The company is also a member of numerous industry groups, which have opposed climate policies including Business Europe, the Alliance for Automotive Innovation, and the Society of Motor Manufacturers and Traders (SMMT). A Volkswagen senior executive sits on the executive committee of the German Industrial Federation (BDI). Volkswagen is also a member of the Truck and Engine Manufacturers Association (EMA), which has negative engagement with climate policy in the US.

InfluenceMap collects and assesses evidence of corporate climate policy engagement on a weekly basis, depending on the availability of information from each specific data source (for more information see our methodology). While this analysis flows through to the company’s scores each week, the summary above is updated periodically. This summary was last updated in Q1 2023.