The EA189 issue is largely an American one where Volkswagen wanted to break in to the college student market with a cheap-spec Jetta 1.6 TDI. This would not pass the American NOx limit of 0.043g/km, which was much lower then the EU5 limit of 0.12g/km and even than the EU6 limit of 0.08g/km. The Volkswagen engineers were ordered to come up with a cheap fix, which they did. So wheres in Europe this can be addressed by a software fix and by modifying the airbox, in the USA the 1.6 TDI engines need new injectors and possibly even the addition of an SCR system.