As is well known, the European Union (EU) started off as a markedly economic project, reflected in the names of the three integration organisations created in the 1950s, the European Coal and Steel Community, the European Economic Community (EEC) and the European Atomic Energy Community (Euratom). Mainly since the 1970s, things started to change and the integration agenda began to include values, objectives and principles which cannot be defined as purely economic or as promoting exclusively an internal economic market. Already in 1969, in Stauder, the European Court of Justice (ECJ) had held that the general principles of Community law include fundamental rights. Among sectoral subjects and themes, environmental protection emerged early on as a frontrunner (“wallbreaker”) for opening up the economic project to broader concerns. That declarations, programmes and directives started to see the daylight at the beginning of the 1970s can be seen against the background of the 1972 Stockholm Conference on the Human Environment, which demonstrated that environmental concerns also began to be seen as a universal challenge. As before the Single European Act, the EEC Treaty did not contain any explicit legal basis for environmental protection, the European legislator resorted to an internal market legal basis and/or the then Article 235 EEC (now Article 352 of the Treaty on the Functioning of the European Union—TFEU) which enabled the Council to ‘fill the gaps’ if action of the Community was considered necessary to attain, in the course of the operation of the common market, one of the objectives of the Community. In both cases, unanimity was required. In the same way as the ECJ already in 1969 had showed sensitivity with regard to human rights and fundamental rights concerns, it now showed a similar willingness to pay heed to the need to protect the environment by accepting, first (1980), that some environmental concerns could be addressed within the confines of the internal market legal basis and, then (1985) that environmental protection was one of the Community’s ‘essential objectives’, despite the fact that Articles 2 and 3 EEC did not list the environment as one of its tasks or objectives. In 1978, the Court had accepted that restrictions on the free movement of goods could be grounded in ‘mandatory requirements’ which did not figure explicitly in the derogation clause provided for such restrictions in the Treaty (now Article 36 TFEU) and it did not take long before the Court acknowledged that such mandatory requirements could include environmental concerns, thus supplementing the explicit reference in the derogation clause to ‘the protection of health and life of humans, animals or plants’.