So yes, it is now ridiculously complicated to replace lights. But here’s the kicker — my wife’s dealer had never had to do it before. They are so reliable that this was the first time they had to replace a light in that model. We walked in and asked them to replace it as if it was routine. They didn’t believe us that it was out.
So, my guess, not knowing anything about the VW in question is that it really was that complicated, but not something that is expected to happen often.
However, while it's possible to do it without removing the bumper (I go in through the wheel well), it's harder that way. The reality is that there isn't a lot of room in the first place, and headlights can last a very long time, so for an infrequent service it does make sense.
Honestly not sure if it was a scam by the dealership or if the car was really that poorly designed.