dieselgate: when regulators looked the other way

2026-01-29 21:00 723 words 4 min read

no table of contents
the volkswagen emissions scandal revealed more than corporate fraud. it revealed regulatory complicity.

the numbers first

metricvalue
vehicles affected11 million worldwide
real-world NOx emissionsup to 40x legal limits
estimated premature deaths (europe)1,200+ (mit 2017)
us fines$30+ billion
eu finesfraction of us

the data tells a story that’s hard to ignore.


what happened

in september 2015, the us environmental protection agency issued a notice of violation against volkswagen.

the charge: defeat device software that detected when vehicles were being tested and reduced emissions only during those tests. on real roads, with real people breathing, the cars emitted nitrogen oxides at up to 40 times the legal limit.

the affected brands: volkswagen, audi, seat, skoda, porsche.

interesting detail: the us epa caught this. not european regulators.


what european regulators knew

the eu’s joint research centre published studies in 2011, 2013, and 2014 documenting significant gaps between laboratory and real-world emissions.

yearfinding
2011jrc study shows lab-road gap
2013further studies confirm discrepancies
2014defeat devices discussed in technical circles
pre-2015”open secret” in industry

the studies were publicly available. no enforcement action followed.


the regulatory architecture

eu type approval allows manufacturers to choose which member state tests their vehicles.

featurepractical effect
manufacturer picks test authorityregulatory shopping
member states compete for businessrace to lax standards
limited real-world testingcheating not detected
german kba tests volkswagenheadquarters and regulator in same country

the system appears designed to minimize oversight rather than maximize public health protection.


response comparison

the same corporate fraud. different regulatory responses.

united states

actionresult
criminal chargesyes
executive arrestsyes
prison sentencesmultiple
total fines$30+ billion
consumer buybacksoffered

european union

actionresult
criminal chargeslimited
executive arrestsdelayed
prison sentencesminimal
total finesfraction of us
consumer buybacksnot required

the disparity is difficult to explain through legal differences alone.


the conformity factor response

after dieselgate, the eu introduced real driving emissions testing. this was the appropriate response.

then conformity factors were added.

standardallowed NOx
legal limit80 mg/km
with conformity factor (initial)168 mg/km
stated justification”measurement uncertainty”

the industry lobbied for these factors. the industry received them. the scientific basis for the specific values chosen remains contested.


not just volkswagen

subsequent testing revealed broader issues.

findingsource
most diesel vehicles exceed limits in real conditionsicct, transport & environment
average exceedance4-7x legal limits
”legal” thermal windowsstill being used
euro 6 vehiclesstill problematic

volkswagen was caught. the industry-wide problem persists with less attention.


the german government factor

documented lobbying positions:

  • opposed stricter eu emission limits
  • delayed real driving emissions implementation
  • lobbied for conformity factors
  • maintained weak domestic enforcement
  • resisted consumer compensation requirements

automotive manufacturing is germany’s largest export sector. the regulatory posture appears consistent with that economic interest.


what this suggests

the dieselgate scandal provides a useful case study for understanding:

  1. regulatory capture in practice
  2. the gap between stated environmental commitments and enforcement
  3. how economic interests shape regulatory architecture
  4. why external oversight (in this case, us epa) sometimes catches what domestic regulators miss

the data doesn’t support the narrative of an isolated corporate failure. it supports a narrative of systematic regulatory accommodation.


sources

  • us epa. notice of violation documents (2015)
  • european commission. dieselgate timeline
  • joint research centre. real driving emissions studies (2011-2014)
  • icct. defeat device discovery research
  • transport & environment. emissions testing reports
  • mit study. mortality estimates (2017)
  • bundestag. inquiry documents
  • transparency register. automotive lobbying data
  • court documents. various jurisdictions

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