Looks like industrial fall out to me. I get the same problem with my CW Golf. I get it from my work, we have a plasma and laser cutter which releases metal particles into the air. Since using a good paint sealer i don't get as much fall out sticking to the paint. I still have to clay the car every few weeks. My brother was telling me he is getting alot of black dots on the back of his CW GTI too.
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