The development of an environmental policy must be regarded as one of the most notable achievements of the European Community. While action so far has certainly not proved adequate to halt the general decline in the state of the European environment, Community activity has contributed to certain positive developments in recent years including a significant reduction in sulphur dioxide emissions from industrial plants, 1 the phasing out of the use and production of ozone layer depleting substances, the decline in heavy metal environmental concentrations due to reductions in lead and mercury emissions, and the recovery of some of the Community’s most polluted lakes and rivers as a result of improvements in water and sewage treatment. 2 Major challenges unquestionably lie ahead but significant measures have been adopted in a variety of fields, and no lawyer practising in the Community’s Member States can now regard himself as competent in this field without a thorough appreciation of the intricacies of the Community’s environmental legislation. The importance of the Community’s environmental strategy has indeed been reflected in the fact that environmental protection has been identified by the European Court of Justice as being one of the Community’s essential objectives. 3 In addition, the need to integrate environmental requirements into the definition and implementation of the Community’s other policies and activities is now constitutionally recognised in the EC Treaty. 4