Climate Lobbying Overview: Volkswagen is actively engaged with European and US climate regulation, and appears to have become more positive on climate regulation since early 2019. In 2019-21, while Volkswagen has stated support for some policies to electrify transportation, it does not appear to have taken a clear position on higher EU CO2 targets for light-duty vehicles or policies to phase out ICE vehicles.

Top-line Messaging on Climate Policy: Volkswagen recognizes 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 signaled its commitment to the aims of the Paris Agreement on its website and through its CEO, Herbert Diess, who called climate change “the greatest challenge of our time” and pointed 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. It reaffirmed this support in an October 2020 press release.

Engagement with Climate-Related Regulations: Volkswagen appears to have mixed engagement with CO2 standards for light-duty vehicles, with some evidence of more positive positioning in 2021. In October 2018, Volkswagen CEO Herbert 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 increasingly supportive of EU standards, with Diess supporting their maintenance through the COVID-19 crisis in March 2020. Diess also signaled his support for the revision of vehicle CO2 standards to align with the EU’s revised 2030 CO2 targets, although he still emphasized the economic costs of the regulations. A February 2021 consultation response from Volkswagen appeared unsupportive of increasing the EU’s 2025 CO2 standards, and qualified its support for increased 2030 CO2 vehicle standards with major exceptions, including the need for mandatory charging infrastructure in member states. However, a May 2021 Reuters article suggests Volkswagen has “softened its stance on tough new European carbon dioxide emissions targets for automakers”, privately supporting more ambitious CO2 targets than other automakers in talks with EU policymakers.

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.

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. In September 2021, in a Linkedin post, Herbert Diess recommended that the new German government support a 65 Euro carbon price by 2024.

Positioning on Energy Transition: Volkswagen has supported several 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 numerous 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", further criticizing G7 leaders on Twitter in June 2021 for not introducing a phase-out date for coal. In September 2021, Herbert Diess further listed ten recommended policies for German parliamentary coalition negotiations, including ending fossil fuel subsidies, supporting renewable energy expansion, keeping the German EV purchase premium until 2025, and expanding charging infrastructure for cars and trucks. However, VW has also opposed measures to electrify transportation, including opposing the Irish government’s ZEV mandate in 2019, and appeared unsupportive of a potential EU 100% ZEV mandate in a 2021 EU consultation response.

In a May 2021 press release, Volkswagen CEO, Herbert Diess stated that switching to EVs only makes sense in countries with adequate green energy supplies, and will likely come earlier in the EU than Latin America. Similarly, in September 2021, Herbert Diess, in an interview with CNN, stated that “we don't say we will finish production of combustion engine cars so soon because we will need them in some parts of the world”, and that “electrification is not the solution in every place”, suggesting an unsupportive position to a global phase-out of ICE vehicles. Volkswagen subsidiary, Porsche, also appeared to oppose a UK 2030 ICE phase-out date, arguing instead, in a 2021 media article, that “the problem is not the ICE itself, it's the fuel you burn”. Furthermore, Volkwagen does not appear to have yet taken a clear position on the EU’s proposed 2035 phase-out date for EVs in 2021.

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 numerous groups, which have opposed climate policies in 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 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.