The following statement was submitted on 26 January 2026 to the European Commission’s call for evidence consultation on the Revision of EU rules on public procurement. The aim of the revision is to modernise and simplify procurement rules, aligning them with the EU’s strategic priorities, including strategic autonomy and sustainability.
Introduction
In response to the European Commission’s call for public consultation on the revision of the EU public procurement rules, this statement sets out Climate Leadership Coalitions (CLC) position on the proposed initiative to revise the public procurement directives, aiming to give preference to European products in public procurement, and to modernise and simplify procurement rules.
CLC considers a coherent EU-level and forward‑looking procurement framework essential for realising the full potential of industrial renewal, emissions reductions, and circularity markets, while reducing Europe’s dependence on fossil‑based materials and strengthening investment security. By including requirements for low carbon, European-produced products, like steel or plastic, in procurement processes, public investments can help create stable early demand, support industrial resilience, and contribute to scaling up green steel production in Europe.
Our recommendations:
- Leverage public procurement, harmonize operating practices and introduce non-price criteria such as climate and environment factors to stimulate demand for clean and circular solutions
- Introduce minimum mandatory carbon and circular content thresholds to be central to awarding contracts
- Secure a level playing field for the public procurement of sustainable low carbon and circular solutions
- Simplify the procurement process to enable broader participation
Context and key message
The ongoing revision represents a key opportunity to strengthen the role of public procurement as a driver of emission reductions, circularity, resilience, European competitiveness, and the regionality principle to boost uptake of European made materials. Public procurement is one of the EU’s most powerful yet underused instruments for advancing the green transition and strategic targets. Each year, close to EUR 2.6 trillion, or about 15% of GDP, is used on goods and services. The public spending power can play a significant role in creating demand for innovative low-carbon products, driving a circular economy, and strengthening Europe’s industrial competitiveness.
While the current EU public procurement framework allows the use of environmental criteria, it does not require them. As a result, the implementation of green public procurement remains limited and fragmented.
Demand-side measures, including strategic public procurement, are both crucial and effective. When properly implemented, they enhance market security and ensure reliable offtake, which in turn creates the necessary conditions for private investments. At the same time, these measures preserve healthy competition between sustainable alternatives, rather than picking winners in advance.
Our recommendations:
- Leverage public procurement, harmonize operating practices and introduce non-price criteria such as climate and environment factors to stimulate demand for low carbon and circular solutions
Public procurement can shape long‑term demand conditions that are essential for unlocking investment in low carbon and circular technologies. When procurement obligations are aligned with strategic objectives, they act as a catalyst for scaling the technologies Europe needs to meet its climate goals and industrial renewal. Harmonised EU‑wide standards and procurement rules reduce investment risk, ensure fair competition, and support early movers in deploying near‑zero- carbon and circular solutions. Award criteria should explicitly differentiate between offers based on their level of recycled and circular material content, ensuring that higher circularity performance results in higher evaluation scores. Efforts should initially focus on the most strategic sectors, including steel, cement, aluminium, and plastics.
A strengthened and expanded set of procurement programmes can support all levels of public administration, including local authorities, by ensuring consistent access to tools, incentives, and capacity building.
- Establish mandatory minimum thresholds for carbon and circular content as key factors in awarding contracts
Mandatory and progressively increasing minimum thresholds for carbon intensity and recycled content should be applied across all relevant public procurement categories. Binding requirements across member states streamline procedures, reduce legal uncertainty, and create a level playing field. Clear, predictable targets send strong market signals, stimulating investment in sustainable goods and services.
Price should never be the sole determinant in awarding contracts; environmental performance must be central to evaluation. To be effective, circularity and environmental criteria must be given substantial weighting in relation to price in the overall evaluation. This is essential to ensure that tenders offering higher and more desirable quality are genuinely rewarded and can compete on equal footing with conventional alternatives.
- Secure a level playing field for the public procurement of sustainable low-carbon and circular solutions
Any future provision granting preference to European products must clearly recognise and support European low‑carbon and recycled materials, as well as the European‑based value chains that produce them. These value chains play a critical role in strengthening the EU’s strategic autonomy, reducing dependence on virgin fossil‑based resources, and delivering major emissions reductions. Integrating environmental performance requirements into European preference rules will ensure that public procurement effectively supports European industry, strengthens the internal market, and aligns industrial policy with climate and resource‑efficiency goals.
- Simplify the procurement process to enable broader participation
The existing procurement procedures at EU-level are complex and administratively burdensome. This makes it particularly difficult for SMEs to access public contracts, limits innovation potential and hinders cross border participation. Therefore simplifying, flexibilising and digitising processes is essential in order to make the procedure more efficient and facilitate access for SMEs and start-ups. Also, large bundled contracts can limit participation. Default lotting would support proportionality and broaden participation.
Contracting authorities apply divergent local processes and interpretations, creating fragmentation and unnecessary administrative burdens for bidders. This increases advisory costs, requires extensive, repetitive documentation and can reduce participation.
Standard acceptance of verified e-signatures and agreement on “maximum documentation” lists (e.g., corporate authorities, beneficial ownership, financials) would reduce repetitive legalisation and apostille requirements.
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