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ClientEarth welcomes the opportunity to provide feedback to the roadmap published by the European Commission on its initiative to revise the Environmental Crime Directive for improving EU rules on environmental protection through criminal law.
In our reply, ClientEarth favours revising the Directive to ensure that environmental crime is a self-standing concept, to avoid a situation where the Directive becomes obsolete as legislation evolves.
In particular, CE urges the Commission to take into consideration:
CE also highlights the need to include all existing environmental legislation in the relevant annexes of the Environmental Crime Directive.
We also particularly underline the need to include serious infringements to CFP rules in the list of offenses that may constitute a criminal offense, and the need to ensure a level playing field in EU waters, as regard the definition of these offenses and the related level of sanctions.