I'm not sure if it would be the battery.
What I have observed, though, in 5 different 2019's is that no matter how nice or how "Old Man" I drive any of them, I really, really struggle to get to 5.3 miles / kWh. At first I thought it was just an outlier or two. But trying consistently, with 6 different cars.... I would swear that anyone that actually gets 5.5 miles / kWh in a 2017 or later, my hat's off to you, you must be doing it right.
Because right now, in a 2019, I sure as hell can't. And the temps during the days here are in the 80F range and all accessories are turned off. I am currently stumped on the cause. But now that I've made quite a few attempts, I sure as hell can see why everyone with a newer 2017 + e-Golf thinks I'm an obstruction to traffic getting what I do on my 2015. All of my test driving has been on Blvd's and streets, nothing over 40 mph, in traffic stop and go, same as I drive in my 2015. I can assure you, I move right along with traffic and keep up pretty much with the flow, in the car I own. I can't prove what VW has changed, going to China with the drivetrain, but it sure eats a lot more of the battery and delivers less miles per kWh than my 2015 does, 12 to 16% less per kWh.
And I don't know how they got it past the EPA, but it makes me wonder.