2021/0422(COD) · In Force
23 submissions from 23 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 528 submissions on this file. Shown here: the 23 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
7 submissions from industry — companies and their trade associations — against 10 from civil society: NGOs, consumer organizations, environmental groups and trade unions.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 21 Apr 2022 — it ran from 15 Dec 2021.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned.
Showing 23 of 23 submissions.
The proposed revision adds many provisions to the originally revised Directive, but these provisions are still unclear. Our contribution focuses on the definition of offences (Articles 2 and 3 of the proposal). The principle of clarity and precision of criminal law All unlawful acts as defined in Article 2, as detailed in Article 3, constitute infringements.
Filed in French · English published by the European Commission
· · filed 21 Apr 2022 · source
Seas At Risk (SAR) welcomes the possibility to provide feedback to the proposal of the revised Environmental Crime Directive for improving EU rules on environmental protection through criminal law. SAR supports the main elements of the proposal and in particular welcomes the inclusion of the killing of and trade in protected wildlife species among the conducts that constitute a criminal offence.
· · filed 21 Apr 2022 · source
The National Federation of Public Works (FNTP) is particularly committed to preserving biodiversity and combating climate change. In this context, action by national authorities to detect and sanction infringements against the environment is essential. However, the FNTP expresses a number of reservations regarding this proposal for a revision of the Directive.
Filed in French · English published by the European Commission
ECSA, ICS and the IG P&I Clubs welcome the efforts of the European Commission to reinforce environmental protection in particular by setting as a high priority the preservation of the oceans and the seas. However, in the context of shipping, the new proposal on the protection of the environment through criminal law (ECD) which aims to replace Directive 2008/99/EC, leads to discrepancies in the interpretation of…
· · filed 21 Apr 2022 · source
We welcome the Commission's proposal for a new Directive on the protection of the environment through criminal law that intends to increase environmental protection and requires Member States to implement stronger criminal provisions more likely to dissuade potential criminals. Eurogroup for Animals and Four Paws call on the European Institutions to support this strong proposal and the necessary improvements.
Cefic welcomes the opportunity to comment on the Commission’s proposal. Effective enforcement of EU environmental legislation is crucial to the EU chemical industry and this requires both adequate tools and resources to detect, investigate, prosecute criminal activity and effective coordination and cooperation mechanisms across Member States.
Polskie Górnictwo Naftowe i Gazownictwo S.A. (Polish Oil and Gas Company; hereafter: PGNiG) welcomes the opportunity to comment on the proposal for a directive on the protection of the environment through criminal law (COM (2021) 851 final). PGNiG recommends extending the scope of Article 9 so that it includes additional circumstances that may be regarded as mitigating circumstances.
· · filed 14 Apr 2022 · source
We "Europeans for Safe Connections" welcome this update of the Directive 2008/99/EC. Page 6/69: We are happy that the Commission has identified new offence categories currently not covered by the Directive. However, we would like to add three more: • operating RF EMF in nature reservations • operating RF EMF in nature generally • launching, operating and destroying satellites above the territory of EU Page 30/69: We…
· · filed 15 Mar 2022 · source
The EEB welcomes the Commission’s proposal as well as the choice to revise the directive rather than to amend it. The EU has an international leadership role to play in the fight against global climate change and biodiversity loss by strengthening of the protection of the environment through criminal law within the EU is a necessary step to support the enforcement of the European Green Deal and the 2030 Climate…
WWF acknowledges that Directive 2008/99/EC on the protection of the environment through criminal law provided a harmonised framework to address environmental crimes in the European Union. Nonetheless, its implementation was limited, and environmental crimes remained largely under-detected, under-reported, and under-investigated, with sanction levels too low to be dissuasive.
· · filed 23 Feb 2022 · source
Pro Wildlife welcomes the Commission’s proposal to revise the Directive. We agree with the EU Commission’s analysis of existing problems; however, we recommend several steps for further improvement of the Directive. As Pro Wildlife’s focus is wildlife trade and wildlife crime our feedback below is limited to this aspect of environmental crime.
· · filed 9 Feb 2022 · source
The International Fund for Animal Welfare (IFAW) welcomes the Commission’s proposal of the revised Environmental Crimes Directive. Environmental crime is one of the most profitable and growing crimes in the world.
· · filed 9 Feb 2022 · source
Humane Society International/Europe (HSI) welcomes the Commission’s proposal to revise the Environmental Crime Directive. Given the weaknesses in the current legislation and the disparities in its application by Member States, we are pleased that the legislation is being revised, rather than simply being amended.
· · filed 9 Feb 2022 · source
BirdLife Europe and Central Asia welcomes the Commission’s proposal revising the directive. Strengthening the protection of the environment through criminal law is essential to support the enforcement of the European Green Deal, and places the EU as a leader in the fight against global biodiversity loss and climate change.
· · filed 30 Dec 2020 · source
The Finnish Nature Conservation Association considers that the Commission’s proposal to improve EU environmental protection rules through criminal law is necessary and supported. Harmonisation of environmental crime in the Member States can: The current circumstantial crime directive has not sufficiently ensured full compliance with environmental protection legislation in the Member States.
Filed in Finnish · English published by the European Commission
· · filed 30 Dec 2020 · source
The Government Offices are in favour of options 3 and 4. The Environmental Crime Directive plays an important role in EU law by establishing a common framework for environmental criminal law and facilitating cross-border cooperation in law enforcement activities. Proper implementation of the Directive means that all Member States have environmental criminal law that meets the minimum requirements of the Directive.
Filed in Swedish · English published by the European Commission
Please find enclosed the reply of the French authorities to the European Commission to the consultation “Have your opinion on environmental crime — improving EU rules on the protection of the environment through criminal law”.
Filed in French · English published by the European Commission
· · filed 27 Dec 2020 · source
Comment provided by EFCTC: European Fluorocarbons Technical Committee. EFCTC considers the Environmental Crime Directive could further enhance these efforts through its horizontal approach across EU measures, including the F-Gas Regulation, to help develop a more coherent and effective framework that better achieves the EU’s climate action objectives.
suggestions to tackle wildlife crime: * include obligations for specialist platforms that sell wildlife on their online platforms. A study on the online trade of reptiles and birds in BE and NL has shown that 50% of the listings were found on specialist platforms and that less than 25% of the online platforms provided clear information on relevant legislation and/or policies regarding trade in wildlife.
FOUR PAWS / VIER PFOTEN welcomes the opportunity to provide feedback to the consultation on the Roadmap on Environmental crime - improving EU rules on environmental protection through criminal law. For an animal welfare organisation like FOUR PAWS, wildlife trafficking constitutes one of the most immediate threats to biodiversity.
Veolia supports the Directive on the protection of the environment through criminal law (ECD) and shares answers to the Inception impact assessment. The EU needs to strengthen its efforts to combat environment crime and thus contribute to the goals of the European Green Deal and the Biodiversity Strategy for 2030.
· · filed 21 Dec 2020 · source
The Commission's own Inception Impact Report states the following: "Environmental crime is not a problem that stops at national borders. The trafficking of waste, wildlife and chemicals, and the pollution of water including maritime pollution and air typically have cross-border effects, also beyond the EU." The EU Law Committee of the Bar Council of England and Wales supports the EU's planned revision of the…
The Netherlands thanks the European Commission for the evaluation of the Directive on the protection of the environment through criminal law 2008/99/EC and welcomes the opportunity to provide input to the Roadmap on the review of the Environmental Crime Directive. The input is provided in the attached document.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.