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The third factor is that the actual tests are different. The US EPA highway cycle includes things like running the A/C, accelerating and decelerating, and runs at a higher speed. Many European tests simulate driving at a steady, low speed with nothing running. I think the Prius in Japan is rated for something silly like 120mpg, but you bring a Japanese Prius over to the US and it gets the same average fuel economy as ours.
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