Beyond the permit: unpacking unlawfulness in the EU’s revised Environmental Crime Directive

Daniel Bertram & Michaël Faure

Journal of Environmental Law2025https://doi.org/10.1093/jel/eqaf037article
ABDC B
Weight
0.37

Abstract

On 11 April 2024, the EU adopted a significantly revamped version of the 2008 Environmental Crime Directive. One of the new Directive’s many innovations lies in its broadened definition of unlawfulness, which now extends to acts carried out in compliance with an administrative authorization where such acts amount to a ‘manifest breach of relevant substantive legal requirements’. In this article, we argue that this provision marks an important step towards a more autonomous environmental criminal law. Yet, the Directive’s conceptualization of unlawfulness remains enigmatic, leaving Member States significant discretion in transposing this concept into domestic law. Building on both principled and practical considerations, we explore various legal pathways that Member States could pursue in this respect. Our aim in doing so is not to argue in favour of any single option but to highlight some of the broader tensions that arise when the purposive character of environmental law meets with the principled constraints of criminal justice.

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https://doi.org/https://doi.org/10.1093/jel/eqaf037

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@article{daniel2025,
  title        = {{Beyond the permit: unpacking unlawfulness in the EU’s revised Environmental Crime Directive}},
  author       = {Daniel Bertram & Michaël Faure},
  journal      = {Journal of Environmental Law},
  year         = {2025},
  doi          = {https://doi.org/https://doi.org/10.1093/jel/eqaf037},
}

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Beyond the permit: unpacking unlawfulness in the EU’s revised Environmental Crime Directive

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Evidence weight

0.37

Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40

F · citation impact0.16 × 0.4 = 0.06
M · momentum0.53 × 0.15 = 0.08
V · venue signal0.50 × 0.05 = 0.03
R · text relevance †0.50 × 0.4 = 0.20

† Text relevance is estimated at 0.50 on the detail page — for your query’s actual relevance score, open this paper from a search result.