That's according to talkSPORT pundit Jason Cundy, who claims the striker should have scored '60, 70, maybe 80 goals' for the Three Lions, and says Harry Kane will surpass his record with ease.
Former England captain Rooney scored 53 goals during his 15-year international career, but his record as the country's top scorer is under serious threat as Kane currently sits on 40 goals.
Rooney undoubtedly deserves immense praise and respect for becoming England's, as Manchester United's, all time leading scorer.
Speaking on talkSPORT, however, Cundy said: "He underachieved.
"How on Earth can Harry Kane be within touching distance of Rooney? How can he get close? He's going to overtake Rooney.
"He's not a better player than Rooney, I just think Rooney did not achieve his full potential. Wayne Rooney should be on 60, 70 maybe 80 goals for England.
"Kane hasn't played anywhere near the [amount of] games as Rooney, but he is going to breeze it.
"That record for [Sir] Bobby Charlton stood for 40 years and Wayne Rooney is only going to hold this record for 5, 6, 7 years.
"Kane gets the absolute maximum out of his ability, Rooney, I don't think has.
"It sounds harsh because of what he achieved in the game, but I don't think it is that harsh. I genuinely believe that."
Jamie O'Hara, however, came to Rooney's defence as the former Tottenham midfielder pointed at his list of major honours he lifted in a United shirt.
"He won 13 major trophies, he's England's and Man United's all time [top] goal scorer," he argued on the Sports Bar.
"I played against Wayne Rooney, he was the hardest player I have ever played against, he had everything and I think he's undervalued in England.
"He did not underachieve."
Sitting just 13 goals shy of Rooney's record, it does seem a matter of time until Kane becomes England's new all time top scorer.
And he'll be looking to reduce that number again as England travel to Warsaw to face Poland on Wednesday night in their last game of the September internationals.
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