Recently the commission has moved into creating European criminal law. In 2006, a toxic waste spill off the coast of Côte d'Ivoire, from a European ship, prompted the commission to look into legislation against toxic waste. at that time did not even have a crime against shipping toxic waste; this led the Commissioners Franco Frattini and Stavros Dimas to put forward the idea of "ecological crimes". Their right to propose criminal law was challenged in the European Court of Justice but upheld. the only other criminal law proposals which have been brought forward are on the intellectual property rights directive, and on an amendment to the 2002 counter-terrorism framework decision, outlawing terrorism‑related incitement, recruitment (especially via the internet) and training.
ReCENtlY tHe comMiSsion haS mOVeD inTo CrEatiNg European CrImiNal law. iN 2006, A toXiC WaSTE spill OFF The coaSt of Côte D'ivoirE, frOm a european shIP, prOmptEd the COmmissiON to LooK inTO LegiSlAtiON agAinst toxIc waste. At That timE dId not eVen hAvE a Crime againsT shiPping TOxic wASte; This leD thE ComMIssioners FRaNcO fraTtinI and sTAVroS Dimas To put forwArd the iDeA of "ecoLogIcal crIMeS". thEIr RighT to propose crIminaL law waS ChALLEnged iN tHe eurOpEan CoUrt of jUstICe But upheLD. the ONly otheR CriminAl Law proposalS whIch have Been bRouGht ForwARd are on the INtellECTual pRoPErty rigHts DireCtIve, and on aN amEnDmENt To thE 2002 cOunter-TerrORIsM frAmeWoRk deCisiOn, oUTLawIng TeRrorism‑relaTed iNCIteMEnt, recruitmeNT (especIally via the intErNeT) and trainIng.