Mainly due to VW’s climate damaging product range and business strategy, Germanwatch accuses the company of violating the Guidelines in 15 concrete cases, grouped into the following categories:
First, given the problem of climate change and the two-degree-limit for global temperature rise, a company like VW must formulate and regularly evaluate detailed climate protection goals for single products as well as for the whole product range – Volkswagen has thus far not done this.
Second, VW does not sufficiently account for dangers to the climate emerging from its products. In order to properly do so, the company would have to forecast and evaluate the actual emissions of its products over their full life cycle and address this in the management and decision making process.
Third, VW has achieved less progress in complying with the self-commitment (ACEA Agreement) than the company agreed to with the European Commission in 1998. Given the company’s existing strategy and its current product range, it is doubtful that VW can achieve the self-commitment by 2008.
Fourth, VW advertises massively for vehicles with high fuel consumption, but fails to transparently inform consumers about the climate impact of such automobiles.
Fifth, VW has directly and indirectly (through association memberships) been involved in the distribution of false information about climate change or planned policy measures.
Finally, VW has directly and indirectly lobbied against various climate policy frameworks that include legislation to limit the consumption of new passenger cars.
Germanwatch’s complaint is the first that highlights the relevance of the climate change issue in the OECD Guidelines.
Relevant OECD Guidelines
- Version 2000 Chapter II
- Version 2000 Chapter II Paragraph II.11
- Version 2000 Chapter III
- Version 2000 Chapter III Paragraph III.1
- Version 2000 Chapter III Paragraph III.4 Subparagraph III.4.B
- Version 2000 Chapter III Paragraph III.4 Subparagraph III.4.C
- Version 2000 Chapter V
- Version 2000 Chapter V Paragraph V.1 Subparagraph V.1.A
- Version 2000 Chapter V Paragraph V.1 Subparagraph V.1.B
- Version 2000 Chapter V Paragraph V.2 Subparagraph V.2.A
- Version 2000 Chapter V Paragraph V.3
- Version 2000 Chapter V Paragraph V.6 Subparagraph V.6.A
- Version 2000 Chapter V Paragraph V.6 Subparagraph V.6.B
- Version 2000 Chapter V Paragraph V.6 Subparagraph V.6.C
- Version 2000 Chapter V Paragraph V.8
- Version 2000 Chapter VII
- Version 2000 Chapter VII Paragraph VII.4
The German NCP notified the complainants of receipt of the complaint and forwarded the complaint to Volkswagen. However, on 20 November 2007, the NCP rejected the case, claiming that the alleged violations are beyond the scope of the Guidelines. Germanwatch does not agree with the NCP’s decision not to investigate the case and is considering further steps, including legal approaches.