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 inst

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.