On February 22, 2018, the Court of Justice of the European Union ruled [3] in European Commission v. Poland that Poland had breached EU air quality standards and “persistently exceeded” pollutant limits set under a 2008 EU directive for the protection of human health. The press release [4] notes that the European Commission brought the case because Poland was not in compliance with the daily and annual limit values for PM₁₀, “a mixture of organic and non-organic substances present in the air [that] may contain toxic substances such as polycyclic aromatic hydrocarbons, heavy metals, dioxin and furan.” The Court stated that between 2007 to 2015, Poland “regularly exceeded, first, the daily limit values for PM₁₀ concentrations in 35 zones and, second, the annual limit values for such concentrations in nine zones,” which is sufficient in itself to establish a failure to fulfill its obligations under the directive. The Court also found that Poland’s reasoning for the delays in compliance due to necessary structural changes could not justify such long deadlines for conforming and “that, by exceeding in four zones the daily limit values for PM₁₀ concentrations in ambient air (increased by the margin of tolerance), Poland has infringed EU law.”