Criminologist and PhD candidate Sammie Verbeek at Vrije Universiteit Amsterdam is investigating how manure fraud became such a distinctly Dutch phenomenon – and what it reveals about how we deal with environmental crime more broadly.
The hidden world of environmental crime
“Environmental crime has always fascinated me,” says Verbeek. “These are complex issues where the damage is significant but not immediately visible. Consider chemical plants that discharge toxic substances, whose health effects only become apparent years later. We don’t feel or see those consequences right away. This may be due to a physical distance between that damage and ourselves, but also a temporal one: the environmental harm that we cause today will only become truly noticeable generations from now.”
The consequences are enormous, but because they’re diffuse and indirect, they rarely receive the urgency they deserve. “Manure fraud is a clear example of that,” Verbeek explains. “It’s politically sensitive, emotionally charged and touches on various interests. Plus, numerous stakeholders are involved: from farmers and transporters to laboratories and regulatory bodies. Major economic interests are at play, but so too are broader societal concerns such as clean drinking water and biodiversity.”
Too much manure in the Netherlands
Compared with other countries, the Netherlands has an exceptionally high density of livestock on a small area of land. “We simply have too much manure,” Verbeek explains. “More than the land can handle. Our crops cannot absorb all the nutrients contained in it. Once they reach saturation, nitrogen compounds enter the water and the air, leading to pollution and, over time, serious environmental damage. This also affects biodiversity: plants that thrive on excess nitrogen flourish – such as nettles, brambles and certain algae – crowding out other species and disrupting entire ecosystems. The effects therefore extend far beyond a single plant or animal species: manure fraud ultimately affects all life within an ecosystem, from the small – insects and algae – to the large – meadow birds, and even humans.”
A long history of manure legislation
The problem has existed for decades. “Since the introduction of manure legislation in 1984, it’s been clear that enforcement is difficult,” says Verbeek. “Historically, we already had earlier laws on manure, but it’s only since 1984 that manure legislation has primarily focused on protecting the environment.”
“As early as the late 1980s, public prosecutors warned that the system of laws and measures surrounding manure was unenforceable in practice. In the 1990s, the Netherlands Court of Audit published a damning report: compliance and enforcement were inadequate. Those problems have never really disappeared.”
What exactly is manure fraud?
The term “manure fraud” is relatively new. “It’s not a legal term,” Verbeek explains. “It’s a societal concept that first appeared in newspapers in the late 1980s. In 1996, it was used for the first time in parliamentary questions, and now we even see it appearing in court rulings.”
Essentially, manure fraud involves manipulating manure records: figures on production, transport and processing that don’t add up. “Sometimes it happens unintentionally, within a tangle of complex rules, but often it’s deliberate – intended to bypass environmental regulations and the associated costs,” says Verbeek.
According to the Public Prosecution Service, there is often “a discrepancy between paper and physical flows”: what is recorded in the bookkeeping does not always match what ends up in trucks or on the land. “Those two worlds can differ greatly,” she explains.
The scale of the problem remains uncertain. “Estimates vary widely,” says Verbeek. “But in 2016, the Netherlands Environmental Assessment Agency (PBL) estimated that around 30–40% of manure is not disposed of in line with regulations. That shows how deeply rooted the problem is.”
Farmers caught between rules and reality
Recent farmer protests have drawn attention to the pressures that farmers face. For decades, government policy and banks encouraged upscaling: more cows, pigs and poultry, with higher production. Meanwhile, environmental regulations kept getting stricter.
“The government places responsibility on individual farmers, while in fact it’s a collective problem. We’ve created a system in which farmers have almost no choice but to expand in order to survive. And then they’re penalised for the environmental damage that expansion causes,” says Verbeek.
Policy decisions have even reinforced the problem. “In 2015, for example, the EU abolished the milk quota, which gave the market a huge push to produce more. And if you increase production, prices go down – that’s how markets work. But it also means farmers may need to keep expanding to maintain their income. And more growth means more livestock, and thus more manure.”
The accumulation of rules, controls and obligations creates uncertainty. “Farmers no longer know where they stand. And every new measure opens up new opportunities for fraud. That makes manure fraud a constantly evolving and difficult-to-grasp phenomenon.”
Research in both public and private sectors
In her PhD research, Verbeek combines archival work with interviews with experts from both the public and private sectors. “I talk to civil servants from ministries, inspectors from the Netherlands Food and Consumer Product Safety Authority (NVWA) and the Netherlands Enterprise Agency (RVO), but also to industry representatives, lobby groups and farmers themselves. It’s precisely the interaction between government and market – the public and private domains – that makes this topic so interesting.”
A critical green criminology perspective
Verbeek aims to reconstruct the history of manure fraud and understand why this problem has persisted for decades already. She explores it from the perspective of critical green criminology: an approach that examines environmental crime not only in terms of individual offenders but also in relation to economic and political structures. “I’m interested in the interplay between policy, market forces and individual choices. The latter matter, too: if government policy and market dynamics were the only explanations, every farmer would commit manure fraud – but they don’t. By studying these developments side by side, I hope to understand better why some farmers choose to break the rules and others don’t.
“Within this approach, I draw on theories such as the ‘treadmill of crime’ and ‘state-corporate crime’. These explore how the interaction between government, legislation and market forces can lead to societal damage.”
What makes manure fraud unusual is that it is prosecuted under criminal law. “For many types of environmental damage, we actually see deregulation: rules and laws being abolished or relaxed. Or enforcement being shifted to administrative law, which mainly governs the relationship between government and citizens or businesses, for instance in the context of permits. Theoretically, that’s what you’d expect: the interaction between state and industry creates a climate that facilitates business activity. So it’s interesting to study why manure fraud is handled not only under administrative law but also under criminal law.
In addition to fines – which are possible under both criminal and administrative law – prison sentences can also be imposed. Criminal law enforcement is often seen as a more severe measure due to its ethical implications. The question is whether the same theories that normally explain deregulation also apply here.”
