Climate Policy Engagement Overview: Volkswagen is strategically engaged with European, UK and US climate regulation in 2021-23. As well as its advocacy becoming more negative in 2023, Volkswagen’s positions on global internal combustion engine (ICE) phase-out targets and zero-emission vehicle (ZEV) mandates appear to be misaligned among its various subsidiaries.

Top-line Messaging on Climate Policy: Volkswagen supported the EU’s 2050 climate neutrality target in an October 2021 position paper. It expressed support for a 1.5°C global warming target in its 2022 Annual Report, published in February 2023. Volkswagen also supported the Paris Agreement and government policy around carbon pricing in its 2023 Association Climate Review, published in May 2023

Engagement with Climate-Related Regulations: Volkswagen appears to have increasingly negative engagement with CO2 standards for cars in the EU since September 2022. In a March 2023 Automotive News article, Porsche reportedly opposed the EU's 2035 zero-emissions target in seeking an e-fuels exemption. Audi’s CEO took a conflicting view in a March 2023 Spiegel magazine interview, urging the German government to support the target. Similarly, the CEO of the Volkswagen brand appeared to support the 2035 target in an April 2023 Automotive News article. MAN and Scania both opposed an 100% CO2 emissions reduction target for heavy-duty vehicles (HDVs) in the EU in their respective March 2022 consultation responses.

In the US, in an August 2023 consultation response, Volkswagen supported a weaker pathway than the more stringent alternatives proposed by the Environmental Protection Agency (EPA) in the 2027 GHG emission standards for light- and medium- duty vehicles. Porsche similarly advocated to reduce the proposed GHG emissions reductions targets in its July 2023 consultation response. In a May 2022 consultation response, Volkswagen subsidiary, Navistar, opposed the tightening of Phase 2 GHG emissions standards for HDVs from 2027, calling it “disruptive, unnecessary, and premature”. Similarly, in a May 2023 testimony on the EPA’s Phase 3 HDV GHG emission standards, Navistar appeared unsupportive of the proposed regulation, calling for it to regulate infrastructure rather than vehicles. In a June 2023 consultation response, the truckmaker appeared to support the Phase 3 standards with major exceptions, including advocating for flexibilities and less ambitious timelines.

In Australia, in a May 2023 consultation response, Volkswagen supported an Australian CO2 fuel efficiency standard with minor exceptions, including advocating for some flexibilities that may weaken the stringency of the policy.

In the EU, in an October 2021 position paper, Volkswagen supported a carbon border adjustment mechanism (CBAM), however without specifying a position on the removal of existing carbon leakage protection measures in the EU Emissions Trading System (ETS). Volkswagen disclosed support for the expansion of the EU ETS to road transport in its 2022 CDP disclosure. In a December 2022 joint letter, Volkswagen supported speeding up renewable energy permitting and accelerating existing renewable energy projects in Europe.

Positioning on Energy Transition: Volkswagen, through its numerous subsidiaries, takes varying positions on ICE phase-out targets and ZEV mandates globally. In the EU, in March 2022 consultation responses, MAN and Scania both opposed a heavy-duty ZEV mandate. In March 2023 Automotive News article, Porsche appeared to oppose the EU's 2035 ICE phase-out date for light-duty vehicles, advocating for an e-fuel exemption. On the other hand, Thomas Schäfer, CEO of the Volkswagen brand, supported the phase-out date according to an April 2023 Automotive News article.

In a May 2022 California consultation response, Volkswagen took an unclear position on California's proposed Advanced Clean Cars II regulation, while proposing several flexibilities to reduce the stringency of the policy. In a June 2023 US consultation response, Navistar supported a heavy-duty ZEV transition with major exceptions. Similarly, in a May 2023 testimony, Navistar advocated for policies to expand EV infrastructure in place of regulations requiring manufacturers to sell an increasing amount of EVs. At the state-level, Navistar urged policymakers to delay the adoption of the Advanced Clean Truck (ACT) rule in Oregon in an October 2021 email, and New York in a November 2021 oral testimony. In July 2023, Navistar signed a compromise agreement with the California Air Resources Board (CARB) that commits truckmakers to meet California’s ZEV requirements.

In the UK, in an August 2023 Times article, Seat and Cupra CEO criticized the UK's 2030 ICE-phase out date as "dogma". In a September 2021 UK consultation response obtained via FOI request, both Volkswagen and Bentley appeared to oppose a UK ZEV mandate, including for HDVs.

Volkswagen generally appeared to support measures promoting the electrification of transportation, such as Volkswagen CEO, Oliver Blume, supporting increased charging infrastructure in Germany in a February 2023 Bild article.

Industry Association Governance: Volkswagen has published a partial account of its industry associations' positions and engagement activities on climate-related policies in its 2023 Association Climate Review. Volkswagen’s CEO, Oliver Blume, sits on the board of both European Automobile Manufacturers Association (ACEA) and the German Automotive Association (VDA). The company is a member of numerous industry groups, which have opposed climate policies, including Business Europe, Alliance for Automotive Innovation, and the Society of Motor Manufacturers and Traders (SMMT). Volkswagen is also a member of the Truck and Engine Manufacturers Association (EMA) and the Federal Chamber of Automotive Industries (FCAI), which have negative engagement with climate policy in the US and Australia respectively.

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 Q3 2023.