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I think it is some kind of manslaughter or willful negligence.

If a local government enacted a law for factories that they should all have fire sprinklers installed, to save x number of lives per year.

Then the a factory operator decides to pretend they installed sprinklers, but did not.

Shouldn't they be culpable for excess death?

I think it's similar here - the EU mandated a safety measure (a certain limit on NOx and particles), the car companies merely pretended to comply.



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