Climate Lobbying Overview: Volkswagen is actively engaged on European and US climate regulation, and appears to have become more positive on climate regulation since early 2019. However, Volkswagen has a history of opposition to stringent measures to decrease emissions from road vehicles in both the EU and US prior to this time.

Top-line Messaging on Climate Policy: Volkswagen recognises the science of the IPCC and, since early 2019, has explicitly supported the aims of the Paris Agreement, which it calls a “yardstick” for its operations. Volkswagen has continually signalled its commitment to the aims of the Paris Agreement on its website and through it’s CEO, Herbert Diess, who called climate change “the greatest challenge of our time” and pointing to the Volkswagen Group’s “clear commitment to the Paris climate targets” in an October 2020 LinkedIn post. The company has also been a supporter of the EU Green Deal, writing an open letter to the President of the EU Commission, Ursula von der Leyen in June 2020 with ten other companies to support the Green Deal and its net-zero target for the EU, and reaffirming this support in an October 2020 press release.

Engagement with Climate-Related Regulations: Since 2019 Volkswagen has framed much of its lobbying around the idea of putting a price on carbon. As such, the company has supported the extension of the EU ETS to cover road transport, stating in a September 2019 blog that “a CO₂ price should fundamentally be based on the price within the emissions trading system.” Evidence also suggests that Volkswagen supports higher carbon costs in the EU, with the company’s chief lobbyist Thomas Steg stating that all sectors should face a price of at least “60 euros per tonne of CO2 in 2023,” according to a September 2020 article in Euractiv. Volkswagen also supported emissions trading for road transport as part of Germany’s climate protection law in September 2019. Volkswagen does not appear to have clearly disclosed whether it supports an extended EU ETS working in concert with or replacing other regulations such as EU emissions standards for vehicles.

In October 2018, Volkswagen CEO Dr Herbet Diess strongly criticized EU proposals to tighten vehicle CO2 targets for 2030, warning of job losses and that “the transformation in speed and impact is difficult to manage”. However, more recently the company has seemed more supportive of the EU standards, with Diess supporting the maintenance of the standards through the COVID-19 crisis in March 2020. Diess also signalled his support of the revision of vehicle CO2 standards to align with the EU’s revised 2030 CO2 targets, although Diess still emphasised the economic costs of the regulations. A 2021 consultation response from Volkswagen appeared to support the EU's CO2 standards but was unsupportive of increasing 2025 CO2 standards and qualified its support for increased 2030 CO2 vehicle standards with exceptions. In addition, while the company did not support the complete rollback of US CAFE standards in line with the proposals of the Trump Administration, it did support the significant weakening of the standards. In July 2019 Volkswagen entered into a voluntary compromise agreement with California regulators on emissions standards. Whilst this agreement represents a weakening for an overall regulatory program in California, the deal represents a significant increase in stringency compared to the US Federal Administration’s SAFE law.

Positioning on Energy Transition: Volkswagen has supported a number of measures to support the electrification of the transport sector. The company has publicly supported the expansion of electrified infrastructure in the EU in 2021 as well as in a number of countries including Germany (2019), South Africa (2019) and Spain (2020). Volkswagen CEO Herbert Diess has also been a vocal critic of the continued use of coal in the EU’s energy mix, stating in January 2020 that "We need clear exit times for every single member state of the EU." However, while the company has sometimes opposed measures to decarbonise transport, including opposing the Irish government’s ZEV mandate in 2019, and appearing unsupportive of a potential EU 100% ZEV mandate in a 2021 EU consultation response, a July 2021 media report suggested VW "welcomed" the EU's Fit for 55 package, including a 2035 phase out date for EVs.

Industry Association Governance: Volkswagen publicly discloses a list of its industry associations on its memberships but has not published an audit of its alignment with its trade associations. The company is a member of a number of groups which have opposed climate policies in a number of regions including Business Europe, the Alliance of Automobile Manufacturers (now the Alliance for Automotive Innovation) and the Society of Motor Manufacturers and Traders. Volkswagen’s CEO Herbert Diess 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 a number of 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.