ClientEarth’s response to the Commission roadmap: revision of the Environmental Crime Directive

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:

• the ongoing review of the fisheries control regulation;
• the ongoing review of both the FLEGT Regulation and the EU Timber Regulation;
• the upcoming Commission legislative proposal to address deforestation and forest degradation;
• the 8th Mutual Evaluation Round on the practical implementation and operation of European policies preventing and combating environmental crime (which also includes CITES).

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.