EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 16.7.2008 
SEC(2008) 2124 
  
COMMISSION STAFF WORKING DOCUMENT 
accompanying the  
 
COMMUNICATION FROM THE CO MMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMI TTEE OF THE REGIONS 
 
Public procurement for a better environment  
  
IMPACT ASSESSMENT  
{COM(2008) 400 final} 
{SEC(2008) 2125} {SEC(2008) 2126} 
 
EN 2   EN EXECUTIVE SUMMARY  
Lead DG:  ENV - Other involved services : SG, LS, MARKT; ENTR; TREN, EMPL, OIB, 
ADMIN, AGRI, RELEX, DEV, TRADE, SG; REGIO  
WP reference: 2007/ENV/ Our current consumption in the EU causes environmental damage at rates that are 
unsustainable. If the wo rld as a whole followed traditiona l patterns of consumption, global 
resource use might quadruple within 20 years. It is necessary therefore to stimulate the faster 
development and diffusion of environmentally beneficial products. 
Public authorities yearly spend a sum which equa ls 16 % of EU GDP, particularly in sectors 
with relatively high environmental impact s and at the same time serious scope for 
improvement (transport, buildi ngs and building fittings..).  
Considering this purchasing power, Green public procurement has been identified as a cost-
effective tool for "leading by example", "greening" the supply side and pulling environmentally beneficial goods into the market place. 
Green public procurement (GPP) is  defined as a process where by public authorities seek to 
procure goods, services and works with a reduc ed environmental impact throughout their life 
cycle when compared to goods, services and work s with the same primary function that would 
otherwise be procured. It is a process that promotes, but not n ecessarily leads to, the purchase 
of a "green" product and which fully respects the EU legislation on public procurement.  
Research carried out in 2006 has shown that only 7 Member  States were practising a 
significant amount of GPP and that in the re maining 20 Member States, GPP was applied 
much less, or not at all.  
Following problems have been identified as hindering EU wide uptake of GPP: 
(1) Lack of awareness of benef its, misperception of the extent  of costs, and lack of 
political priority for GPP 
(2) Lack of legal clarity 
(3) Lack of information and tools for GPP, inadequate training structures, lack of 
knowledge of priority areas and abse nce of easy to apply GPP criteria 
(4) Lack of similarity between GPP procedur es and criteria across the EU, which also 
results in increased administrative costs in particular for SMEs and hindering the 
internal market  
In the light of these problems, the Commission ha s identified a series of actions and measures 
aimed at radically increasing the quantity and qu ality of GPP in the EU 27. Those actions can 
be bundled into different policy options.  
– Option 1 relates to "Business as usual": the Commission would continue to provide 
guidance on its GPP website, including relevant studies  and the GPP Handbook, and hold 
regular meetings with national GPP experts to exchange best practice. Only minor 
improvements may be expected because th e underlying problems will not be properly 
addressed. 
– Option 2 would address problems 1 to 4, thro ugh the provision of a package including 
political support, lega l and operational guidance, recommen dations and concrete actions on 
establishing GPP criteria and GPP training in view of increased and improved GPP, some 
of which would be delive red through a Communication. 
 
EN 3   EN – Option 3 would necessarily complement th e previous option by maximizing political 
support through a legal instrument setting mand atory targets for GPP. It includes various 
alternative sub-options, ranging from mandatory targets for life cycle costing (3A), over 
mandatory targets for "basic" (not necessari ly outcome based) GPP (3B), to mandatory 
targets linked to compliance with GPP criteria set in comitology procedure (3C).  
– Option 4 would also seek to maximize politic al support through a legal instrument which 
would make GPP mandatory, eith er for certain types of contracting authorities when 
purchasing certain types of products (Option 4A),  either for contracts above the thresholds 
of the Public procurement Directives (Option 4B ); either for certain types of environmental 
criteria to be included in services and works contracts above certain thresholds (Option 4C) 
– Option 5 would be complementary to all other op tions insofar as it would seek to ease the 
burden of monitoring for the Member States  and the EU, by proposing a modification of 
the Commission Directive on standard forms for use in public procurement, to include also 
information on the environmental aspects of te nders in the contract  advice and contract 
award notices 
The impact assessment has shown that option 2 is the most timely option which addresses 
different problems hindering the uptake of GPP. The Commission therefore proposes, as a 
result of the current impact assessment, to adopt a Communication proposing voluntary GPP 
targets and providing operational and legal guidance and kicking off a process of co-operation 
with the Member States to identify GPP criteri a. This option therefore includes quantification 
of the (voluntary) GPP target set forth by  EU leaders in their renewed Sustainable 
Development Strategy, namely that by 2010, the EU level of GPP shoul d be at the current 
level of GPP in the best performing Member States. 
However, the impact assessment has also sh own that, increased po litical support would 
maximize the aggregate benefits of the meas ures proposed under opt ion 2. Options 3 and 4 
include various alternative options which would ha ve the effect of rais ing political support to 
varying degrees, ranging from mandatory target s for GPP to mandatory GPP for all contracts 
covered by the public procurement Directives. Option 5 finally would be complementary to 
any of the other options, as it would make it ma ndatory for contracting authorities to include 
information on environmental considerations into  the standard forms used for contracts above 
the thresholds of the public procurement directives.  
The current impact assessment al so shows that further research  needs to be undertaken into 
the impacts of Options 3, 4 and 5 to allow selection of the mo st appropriate policy measures, 
if any, to increase political support. The Commission will therefore not propose these 
measures now, but carry out additional impact assessment of options and publish its conclusions. 
 
EN 4   EN 1. I NTRODUCTION  
1.1. Procedural issues  
This impact assessment examines the benefits  and costs of various  policy options to 
raise the quantitative and qualitative level of  Green public procurement, in line with 
the Commission Legislative and Work Pr ogramme for 2007 and relevant roadmap 
published in the light of this1.  
1.2. Consultation and use of expertise 
This impact assessment is drafted on the basis of relevant studies (Annex 1), the 
input of an Inter Service Group gatheri ng relevant Commissi on services including 
DG MARKT, ENTR, SG, LS, TREN, EMPL, REGIO, TRADE, AGRI, AIDCO, DEV, ADMIN, BUDG, RELEX, establis hed for the purpose of the impact 
assessment and consultation with  stakeholders (Annex 2).  
1.3. Integration of the Impact A ssessment Board's recommendations 
On 11 October the Impact Assessment Board adopted an opinion on the draft version 
of the Impact Assessment of the Communication. 
All the recommendations for improvements have been fully integrated into the 
impact assessment as outlined below: 
(1) The IA report should be more conclusive in its –at least qualitative- assessment 
and comparison of a number of comprehens ive policy options, and be more explicit 
on which options to be withheld, re jected or put up for further study 
The policy options have been bundled into 5 comprehensive policy options, 
including several sub-options (replacing prior 10 options). It has been made clear that 
Option 2 is the currently preferred option but  that it could be complemented, in the 
future, with one or more mandatory meas ures envisaged under options 3, 4 and 5, 
subject to additional, future impact a ssessment to be carried out, including a 
preliminary subsidiarity test. 
(2) Need for better assessment of the economic imp acts of a higher GPP uptake in 
general and of the variou s options in particular 
The revised report better highlights the impact on competition and international 
competitiveness and includes reference to possible side-effects such as "crowding out"; whilst also better illustrating the effect on administrative burden.  
(3) Need to elaborate on th e context of the proposed set of actions, which can impact 
their effectiveness 
The revised report points at expected diffe rentiated impacts linked to the type of 
product/service addressed as well as the le vel of government agencies targeted. The 
heterogeneity of the types of goods and se rvices potentia lly covered by GPP has led 
to the identification of prio rity product and se rvice groups, based on an assessment of 
their financial and environmental impact. The probable differentiated impact of the 
policy on central and local government has led to the proposal of differentiated targets for GPP.  
                                                
 
1 COM(2006)629 final of 24.10.2006 
 
EN 5   EN 2. P ROBLEM DEFINITION  
2.1. Background 
2.1.1. Background: the unachieved potential of Green Public Procurement 
Green public procurement (hereafter referred to  as GPP) is defined here as a process 
whereby public and semi-public authoritie s seek to procure goods, services and 
works with a reduced environmental im pact throughout their life cycle when 
compared to goods, services and works with  the same primary function that would 
otherwise be procured.  
It is a process that promot es, but does not nece ssarily lead to, th e purchase of a 
"green" product2 and which fully respects the EU legislation on public procurement3.  
GPP procedures can bring a number of diff erent benefits, the extent of each benefit 
below depending on both the product group a nd the criteria used in purchasing.  
• Direct financial benefit to purchasing authorities 
For products that consume resources over their lifetime, the purchase of more 
resource efficient products can significantly cut costs for users, even where the initial 
expenditure is higher. Examples are office equipment, lighting, vehicles, buildings.  
Example: A Life Cycle Cost evaluation of alternative HVAC Systems (Heating, 
ventilation and airconditioning systems) carried out in the US in 2005, has led a public authority to buy a HVAC system, based on an alternative energy-efficient 
"green" technology, whose energy consumpti on was markedly lower so that cost 
savings outweighed higher capital and ma intenance costs as well as yielding 
environmental benefits in terms of reduced greenhouse gases and other air 
pollutants
4. 
Example: A recent study carried out for the UK Government showed that the use of 
sustainable construction t echniques in the Newport Southern Distributor Road 
resulted in benefits valued at £2.1 m(€ 3.1m), part of which came through reduced purchase cost of recycled materials.  
• Stimulating development and diffusion  of environmentally beneficial 
technologies 
Our current consumption in the EU causes environmental damage at rates that are 
unsustainable. If the world as  a whole followed traditiona l patterns of consumption, 
global resource use might quadruple within 20 years.
5 It is necessary therefore to 
                                                 
2 For simplicity of presentation, the impact assessment only mentions products: this should be taken to 
include also services and works 
3 Directive 2004/18 of the European Parliament and of the Council of 31 March 2004 on the coordination 
of procedures for the award of public works contracts, public supply contracts and public service 
contracts (hereinafter: Directive 2 004/18) and Directive 2004/17 of the European Parliament and of the 
Council of 31 March 2004 coordinating the procuremen t procedures of entities operating in the water, 
energy, transport and postal services sect ors (hereinafter: Directive 2004/17).  
4 Fuller, Sieglinede and Stephen R. Petersen, 1996 Life-Cycle Costing Manual for the Federal Energy 
Management Program, referred to in 2003 OECD Report on the environmental performance of public 
procurement 
5 Estimated population growth of 3 billio n people (a 50% increase) by 2050 : World Population 
Prospects: The 2006 Revision  and World Urbanization Prospects: The 2005 Revision  Population 
Division of the Department of Economic and Social Affairs of the United Nations Secretariat, 
http://esa.un.org/unpp 
 
EN 6   EN stimulate the faster development and di ffusion of environmentally beneficial 
products. 
GPP rewards firms that develop such goods  and provides incentives for the future 
development of technologies, promoting innovation that supports the EU economy.  
There are two effects: 
– Environmentally better goods are often niche products for which increased 
demand will lead to economies of scale, allowing products to move into mainstream markets. Ultimately, the ec onomic benefits from the reduced costs 
may accrue not to the public procurer but to other buyers. 
– The pull of public procurement may stim ulate greater and faster technological 
innovation or breakthrough that will ultimat ely lead to lower unit costs and mass 
market availability.  
A recent OECD Report on the Environmental Performance of Public Procurement 
(2003) refers to several examples of green product invention in response to 
procurement initiatives, including the devel opment of highly energy efficient clothes 
dryers, electric motors, and office copiers (Westling 2000).  
According to an expert study
6 on Technology procurement, the US Department of 
Energy, early 1998, set out to develop the ma rket for a new generation of smaller, 
brighter and less expensive CFLs – a s ub-compact lamp, through procurement. The 
initial sales goal of one million lamps was exceeded by more than 50 percent and as a result of the programme, 16 new lamp models have been introduced into the US 
market at reasonable prices.  
A recent study carried out for the Commission on cost/benefits of GPP
7 refers to the 
procurement of public railcars with pa rticle filter for the Taunusbahn, Germany 
(2004-2005). The Eco-Technology ‘p article filter for diesel  railcars’ corresponds to 
recent technologic developments whose ob jective is to reduce emissions by 
improving the engine technologies in order to reach high emission standards that will 
come into foce in 2012. The ‘Taunusbahn’ procurement approach not only stimulated R&D to develop economic effi cient eco-solutions at Alstom, MTU and 
Hug Engineering, but also provided a business case that  ended in a breakthrough of 
this Eco-Technology on international markets. 
• Cost efficient achievement of environmental goals 
Where GPP leads to the purchase of green er products, the reduced environmental 
impact from those products will contribute to achieving existing environmental goals 
– and could do so more cheaply than other available policy instruments. This would 
lead to a reduction in the cost of  achieving those environmental goals.  
For example, it may be cheaper for an authority to meet local air quality standards 
through the additional cost of purchasing cl eaner buses than by setting (more costly) 
restrictions on pollution from domestic boilers.  
                                                
 
6 "Experiences with Technology Procurement as an Instrument for Changes on the Market", report 
written by Hans Nilsson, 2003-02-19, FourFact 
7 Costs and Benefits of Green Public Procurement in Europe, Final Report, 26 July 2007, by Öko-Insitut 
e.V. and ICLEI  
 
EN 7   EN The above mentioned study on costs/benefits of GPP compared prices of "green" and 
"non green" goods in the EU and concluded th at it cannot be generalised that green 
products always have higher purchase pr ices than non green product versions, 
suggesting great scope for cost-effective acti on to achieve policy goals through GPP.  
The RELIEF project8, which has measured the environmental impact of GPP in EU 
15, has for instance calculated that, if all public authorities used water saving toilet 
cisterns, this would result in an annua l saving of an amount of 190.407.539 m³ of 
drinking water per year. The use of water- saving devices with the water tap could 
economise a further 60.639.140 m³ of drinking water. Considering the water prices, 
this would moreover allow public au thorities to save 527.110.000€ annually. 
• Maximising social benefit from public expenditure 
Environmental problems impose costs on soci ety, for example through sickness from 
poor air quality or social costs from waste disposal. As the goal of public expenditure 
is to improve social benefit, where purchas es contribute to environmental problems, 
they are reducing the real social benefit from the expenditure. GPP helps to reduce 
the environmental problems resulting from  public purchases, better achieving the 
efficiency of public spending. It is rare th at the operation of good GPP would lead to 
a decision that did not increase the social benefit.  
By way of example, a recent German study has established that, for instance, the 
"green" electricity generated by renewabl e electricity producers who received €2.4bn 
through Germany’s “feed in” preferential tariffs in 2005, allowed to avoid €2.8bn of social costs that would have occurred if it had been produced in fossil fuel power 
stations
9. 
2.1.2. Background: The Scope for Impact of Green Public Procurement 
Public authorities in Europe have a purch asing power equivalent to 16% of the EU 
GDP (approximately 1800 billion EUR)10. Office machinery, transport, food and 
catering, energy, construction, waste mana gement are all areas with major 
environmental impacts where public authorit ies, because of their relatively large 
spending power in those areas, have the cap acity to trigger th e supply of products 
with improved environmental performan ce and reduce their own environmental 
impact.  
Example 1: Public procurement represents for instance about 33 % of the European 
bus market: specifying requirements aimed at reducing CO² and pollutant emissions 
                                                 
8 Project funded by the EC under the 5th Annual Framework Programme, by full name "Environmental 
Relief Potential Of Urban Action On Avoidance And Detoxification Of Waste Streams Through Green 
Public Procurement" (September  2003); more information at http://www.iclei-
europe.org/index.php?id=1781   
9 "Externe Kosten der Stromerzeugun g aus erneuerbaren Energien im Vergleich zur Stromerzeugung aus 
fossilen Energieträgern" by Wolfram Krewitt, DLR, Institut für Technische Thermodynamik, Abteilung 
Systemanalyse und Technikbewertung, Stuttgart an d Barbara Schlomann, Fraunhofer Institut für 
System- und Innovationsforschung (I SI), Abteilung Energi epolitik und Energiesysteme, Karlsruhe, 6 
april 2006 
10 See 2004 Commission report on the economic gains of public procurement at: 
http://ec.europa.eu/internal_market/publicprocurement/studies_en.htm   
 
EN 8   EN could be expected to significantly improve the offer of cleaner busses to the mass 
market as economies of scale are achieved within this market segment11. 
Example 2: Buildings account for approximately 40 % of the final energy 
consumption in Europe. For most public authorities, constr uction and renovation 
works, and running costs of buildings repr esent a major share of annual expenditure, 
in some cases over 50 %. By applying stri cter standards to those public buildings, 
overall energy consumption co uld be importantly reduced. 
2.1.3. Background: Political re cognition of Benefits  
The European Commission, the Council an d the European Parliament have 
recognized the importance of GPP as a means of stimulating sustainable 
consumption and production and pulling envi ronmental technologies  into the market 
place12.  
In June 2006, the Council has adopted the renewed EU Sustainable Development 
Strategy13 including the goal to bring the averag e level of EU GPP up to the standard 
currently achieved by the best pe rforming member states by 2010.  
Directive 2006/32/EC on Energy efficiency and energy services14 provides that the 
public sector should fulfil an exemplary role  by adopting at least two measures from 
a list in Annex aimed at procurement of energy efficient equipment and buildings. 
The new Energy Star Regulation15 obliges central government to apply, in their 
procurement procedures for office equipment, at least the energy efficiency requirements as included in Energy Star St andards, for contracts situated above the 
thresholds of the Public Procurement Di rectives (which, fo r supply and service 
contracts is 137.000 EUR, for work s contracts 5 million EUR).  
                                                
 
11 Impact Assessment of the proposal of the Commiss on for a Directive on the support of clean vehicles 
by public procurement (COM(2005)634); see also the study carried out for the revised Proposal on the 
promotion of clean and energy efficient vehicles at: http://ec.europa.eu/transport/clean/index_en.htm 
12 The Commission Communication on Integrated Product Policy (IPP) of 18 June 2003 encouraged 
Member states to “draw up publicly available acti on plans for greening their public procurement". The 
Environmental Technologies Action Plan (ETAP) of 24 January 2004 identified GPP as a priority 
instrument to stimulate the development and diffusion of environmental technologies. The EP, in a resolution of 5 July 2005 on the Communication on the implementation of ETAP (COM(2005) 16 
final), expressly “Calls on the Commission to set an ambitious target with regard to the role of public 
procurement, the goal being to establish as a general rule that all public procurement should include environmental criteria and that Member States shou ld develop standardised guidelines for the most 
important products and services by 2007 as well as provide training to public procurers on these 
guidelines"; () and “Welcomes the work done by the Commission with regard to creating a handbook on environmental public procurement and is looking forward to an assessment of its impact in order to 
see if more binding rules would be useful". In its spring summit (23/24 March 06) conclusions, The 
European Council endorsed the following lines for action: () " exploration of specific actions to bring 
about more sustainable consumptio n and production patterns at EU and global level, including the 
development of an EU SCP Action plan, and fostering green public procurement, inter alia by 
promoting environmental criteria and performance targets, by examining the proposal for a Directive 
on the promotion of clean road transport vehicles as soon as possible and by making progress with the 
realization of an ambitious European source based policy " 
13 http://ec.europa.eu/sustainable/sds2006/index_en.htm   
14 OJ L 114, 27/04/2006 
15 http://ec.europa.eu/energy/demand/legislation/energy_star_programme_en.htm   
 
EN 9   EN 2.1.4. Background: The Current situation  
The EU currently lags behind its global trad e partners in implementation of GPP. In 
the USA, federal state department is requi red to acquire environmentally preferable 
products and services, referred to in a database16. In Japan, a 2001 Law on Promoting 
Green Purchasing requires public purchas ers at all levels of government to 
implement green purchasing activities and en courages the inclusion of environmental 
considerations "whilst givi ng due consideration to ap propriate use of the budget"17. 
In Canada, the Green public procurem ent legislation focuses on government 
purchasers, emphasizing in particular life cycle costing as a way to ensure the cost effective uptake of environmental requirements in procurement
18. 
An EU wide study carried out for the Co mmission in 2006 (here-after the "Take-5" 
Study)19 concludes that only 7 Member Stat es (Sweden, Finland, Denmark, Austria, 
Germany, the Netherlands and the UK) are currently practising a significant amount 
of GPP, with over 40 % of all tender doc uments examined for the purpose of the 
study including environmenta l considerations. Even so, many of those "green" 
tenders proved non compliant with EU procurement legislation as environmental requirements were often formulated in a non transparent way. In the remaining 20 
Member States, GPP was applied much less, or not at all.  
Despite the strong recommendation of th e Commission, in its 2003 Communication 
on Integrated Product Policy, for Member St ates to adopt national action plans on 
GPP by the end of 2006, only 13 Member States  have, to date, adopted such plans. 
2.2. Specific Problems 
The Commission, through consul tation and expert studies, ha s identified the specific 
problems which hinder the realisation of the potential benefits of GPP: 
2.2.1. First problem: Lack of awareness of benefit s, misperception of th e extent of costs, 
and lack of political priority for GPP 
There is a common misperception that GPP will always lead to additional costs. In 
many cases, this perception results from sub-optimal budgeting practices or from a 
lack of life cycle costing
20 in award procedures.  
Lack of appreciation of the benefits partly arises from uncertainty on how to take 
account of wider non-monetary benefits from green purchasing: this is for instance 
the case of organic food, where the economic benefits are indirect and acknowledged 
through reduced health care costs at a later stage.  
                                                 
16 Executive Order 13101  and Federal Acquisition Regulation (FAR)  - more information at 
http://www.epa.gov/epp/pubs/about/about.htm   
17 More info at http://www.env.go.jp/en/laws/policy/green/index.html . The Japanese Green Purchasing 
Network (GPN) has developed a series of purchasing guidelines and a database with product 
information on more than 10,000 products from approximately 600 companies. http://www.gpn.jp/English/index.html
  
18 As of 1 April 2006, Canada applies a green procurement policy, which applies to all departments within 
the meaning of section 2 of the Financial Administration Act , unless specific acts or regulations 
override it. For more information see http://www.pwgsc.gc.ca/greening/text/proc/pol-e.html   
19 TAKE 5 Study : more information at: http://ec.europa.eu/environment/gpp/studies.htm#state   
20 Whole life cost should cover the purchase pri ce and associated costs (delivery, installation, 
commissioning…), operating costs (including energy, sp ars, maintenance) and end of life costs such as 
decommissioning and removal 
 
EN 10   EN According to the above mentioned OECD 2003 Report, financial barriers relate 
primarily to the implementation of public expenditure management systems and not to financial costs per se. Following main causes were identified :  
– usual practice of not attr ibuting responsibil ity for operating costs (energy and 
water use, paper consumption..) directly to  the relevant operational level; this is, 
in environmental terms, particularly impor tant in the case of energy and water use, 
but also in other cases such as paper c onsumption in administrative offices. When 
operating costs are borne by a central fund ra ther than the managers who are able 
to exercise influence over the means by which energy-using and water-using are 
used, then there are incentives to use them inefficiently; 
– historical reliance on single-year budgeting procedures, resulting in an inefficient 
use of funds within public authorities 
In general, a lack of high level political s upport results in a l ack of resources for 
implementing GPP. Where strong government  support exists, as in the UK, France 
and the Netherlands -who have all issued ambitions to be am ongst the leaders in 
Sustainable public procurement- resources ar e made available to make studies, draft 
criteria, monitor implementation, facili tate country wide uptake of GPP.  
A lack of a strong centra lised political message on GPP is reflected down the 
individual purchasing organi sations who display a lack of management support for 
GPP by their purchasers, which further increases the effects of the problem.  
The "Take-5" study reveals that 33 % of public authorities surveyed state that lack of 
management support is a barrier.  
The lack of political support may result from  a lack of clarity on the leadership and 
accountability for GPP, at ministerial level as well as within procuring authorities: 
Finance or Economics departments are respons ible for the correct implementation of 
procedures within certain budgetary and legal constraints, whereas Environment 
departments are responsible for reducing the environmental impact of procurement. 
2.2.2. Second problem: Legal Problems 
All Stakeholders have raised the need to clarify certain outstanding legal issues 
(Annex 2). In particular, it need s to be clarified to what extent purchasers can include 
in their tender documents environmental criteria which relate to the production process. According to the Public Procur ement Directives, production process related 
criteria can be used as technical specificat ions or award criteria, on the condition that 
those criteria are relevant for characterisi ng the product. Technica l specifications are 
minimum conditions that all bids need to comply with. Award criteria will be used 
by the contracting authority to compare the offers against each other and choose the bid offering best value for money. If give n a significant weighting, most bids will 
comply with an environmental award criter ion, but not necessaril y. If the "relevance" 
for the product is to be determined on a life cycle basis, this may include for instance 
the inclusion of criteria rela ted to emissions to water and air during the production 
process. It also needs to be clarified how  to specify methods of proof (to verify 
compliance of claims by suppliers with tec hnical specifications or  selection criteria). 
Member States are not in a position to give concrete guidance on GPP if they are uncertain about these legal issues.  
 
EN 11   EN 2.2.3. Third problem: lack of information and tools for GPP, inadequate training 
structures, lack of knowledge of priority  areas and absence of easy to apply GPP 
criteria  
Lack of implementation tools, in  particular access to GPP criteria 
In many Member States, there is a lack of  implementation tools, such as freely 
accessible environmental databases for criteri a, guidance, helpdesks, training. This 
results in poor quality of GPP both in terms of legal compliance and quality of environmental specifications. This lead s to added costs and less GPP activity. 
The EC Commission has adopted a Handbook on Environmental Public procurement 
in 2004 and translated it  into all EU languages
21. The Handbook clarifies the 
possibilities provided under th e new public procurement Directives to include 
environmental specifications in a procur ement procedure. It gives several good 
practice examples. However usef ul, the results of the stak eholder consultation clearly 
show that not all legal issues have been clarified. The EC services have recently 
launched a new website on GPP22, including examples of G PP criteria. However, the 
website is in English only and it does not s eem the appropriate tool for implementing 
GPP in local authorities. Several GPP work shops have been organised in 5 Member 
States, evidencing the willingness of in par ticular local authorities to practice GPP, 
subject to training and info rmation on cost/benefits.  
The "Take-5" study shows that a large num ber of tenders analysed included badly 
defined environmental criteria which were unlikely to result in a greener purchase. 
Lack of information and tools were however felt to be less of a barrier in the best 
performing Member States. Member States w ho have set high ambitions in the field 
of GPP, such as the UK, France, the Neth erlands, have or are in the process of 
developing databases including GPP criteria23, which are essential for implementing 
GPP. Sweden and Denmark, which have the longest tradition in the field of GPP, 
base their policy on extensive databases with environmental specifications, established in co-opera tion with industry.  
Lack of knowledge of priority areas 
Public purchasers who want to start impl ementing GPP should focus on areas where 
the best results can be expected in term s of cost-effectiveness and environmental 
improvement. However, many contracting authorities don't know how to prioritise 
certain sectors in view of applying GPP.  
In the UK, the Sustainable
24 Procurement Task Force has raised the need for giving 
clear indications on where to focus efforts firs t: this has resulted in a "prioritisation" 
of sectors, based on a review  of procurement spend data  sources and evidence of 
associated environmental and socio-ec onomic impacts, aimed at identifying the 
"largest, quickest and easies t" sustainable procurement opportunities. Similarly, the 
aforementioned "Take-5" study has also id entified 11 product groups which can be 
considered as most suitable for greening, based on the environmental impact of 
                                                 
21 SEC (2004/1050) see http://ec.europa.eu/environment/gpp/guideline_en.htm 
22 http://ec.europa.eu/environment/gpp/index_en.htm 
23 More information on national databases can be found in the overview of national GPP policies and 
guidelines at: http://ec.europa.eu/environment/gpp/national_gpp_strategies_en.htm   
24 The UK, as well as other Member States such as Fr ance, the Netherlands, Belgium, apply the notion of 
"sustainable" public procurement, which covers both "environmental" and "social" 
 
EN 12   EN greening, the availability of green products in the market place and the analysis of 
good practices of Member States.  
2.2.4. Fourth Problem: A lack of similarity between GPP procedures and criteria across 
the EU  
Current GPP activity tends to be set locally. Different environmental criteria apply in 
different geographical markets (different  areas and levels of environmental 
performance, different measurement methods), causing following problems:  
• Increased administrative costs for replyi ng to different procurement requests, 
which may involve re-measurement, or re statement of environmental attributes. 
This can be an economic cost for the business, or it may reduce the number of offers and thereby the efficiency of the process. SMEs may be particularly disadvantaged, because administrative costs ar e a larger part of their costs. SMES 
being frequently amongst the most i nnovative companies, this presents a 
particular problem for the effectiveness of GPP. If for instance Member State X refers in its GPP guidance for paper to the underlying criteria  of the European 
Ecolabel (or equivalent) and Member St ate Y to the underlying criteria of the 
Nordic Swan criteria (or equivalent) and Member State Z to the underlying 
criteria of the Blue Angel criteria (or equivalent), a company preparing bids for 
contracting authorities in those 3 different Member St ates will ha ve to prove 
compliance with slightly different techni cal specifications, providing evidence of 
compliance through slightly different veri fication methods. Administrative costs 
linked to certification are re latively higher for SMEs.  
• Barriers to the free movement of goods a nd services in the internal market. 
Although the EU Treaty obliges contracti ng authorities to re cognize –as a matter 
of principle- goods and services legally  produced or provided in other Member 
States, the Court of Justice has explicit ly stated that the protection of the 
environment may justify certain market re strictions (Judgment of the Court of 
Justice in Case C-513/99 Concordia Bu s case). In the absence of harmonised 
criteria, a contracting authority could th erefore restrict intra-community trade by 
setting national environmental criteria wh ich are not currently met by products in 
other Member States, justif ying this by reference to the need to protect the 
environment. 
• Reduced rewards from innovation to supp liers whose greener  products may only 
meet some of a wide variety of environm ental criteria and reducing the clarity of 
the public sectors requirements, both reducing incentives to innovate. It will be much more stimulating for a supplier to  invest in eco-in novation and seek to 
comply with high environmental standards if this will raise his chances of competing in not just one but different national procurement markets, based on the 
same sets of environmental standards.  
2.3. Affected Parties  
Global citizens are affected by reduced ch ances to achieve sustainable production 
and consumption through lack of devel opment and uptake of environmentally 
beneficial products.  
Purchasing authorities are missing opportunitie s to reduce costs and provide better 
value as a whole to their citizens as a result of their activities. 
 
EN 13   EN Member States and purchasing authorities already applying green purchasing policies 
are affected by a relative lack of competition in the ‘green’ segment of the market which would otherwise be likel y to lead to lower prices. 
Companies supplying more environmental performing products are affected by the 
lack of demand for such goods, which hi nders innovation. As companies tend to 
trade more in their domestic markets than export markets, the comparative lack of 
demand compared to the GPP policies of  our trading partners weakens EU 
companies development of environmentally  efficient products when compared to 
trading partner competitors. Companies not in a position to supply green products may see their ability to compete in intern ational trading partner markets, already 
applying GPP, restricted.  
2.4. Does the EU have the right to act?  
Under Article 6 of the Treaty, environmen tal protection requirements are to be 
integrated into the definition and implementation of Community policies, in particular with a view to prom oting sustainable development.  
GPP is about integrating environmental cons iderations in the In ternal Market policy 
of public procurement, which seeks to open up European procurement markets to EU 
wide competition, whilst ensuring non-disc rimination, equal treatment of bidders, 
free movement of goods and services and be st value of tax payer's money. The EU 
new public procuremen t directives of 31
st March 2004 allow public authorities to 
include environmental elements into  their procurement procedures.  
Increased GPP would contribute to achiev ing the EU environment and energy policy, 
in particular to the target  adopted by the EU leaders at the 2007 Spring Council, of 
cutting 20 % of EU greenhouse gas emissions by 2020.  
EU Action is also required to tackle the fourth problem above which adversely 
affects achievement of internal market, energy and environment goals, but which can 
not be readily solved by Member States action.  
In the absence of EU action in this field -except for those [7] Member States with 
high levels of political support and experience with GPP- the extent of GPP is likely 
to increase slowly from low or zero levels, and as it does, in all Member States, the 
lack of similarity between procedures is likely to exacerbate administrative costs for 
tendering firms. In the continuing abse nce of legal securi ty, of transparent 
environmental criteria and of evidence of cost effectiveness, Member States are 
likely to refrain from stepping up efforts in this field, and will not allow to reach the 
environmental objectives resul ting from more and better GPP. 
3. O BJECTIVES  
3.1. General policy objectives 
• increase innovation in environmental tec hnologies and products , strengthening the 
EU economy and reducing the environm ental impact of EU consumption; 
• reduce the environmental damage caused from public sector consumption; 
• reduce internal market barriers cau sed by non harmonised GPP criteria; 
through the achievement of appropriate quantities  of GPP of a quality  that will lead 
to these goals, by raising the number a nd value GPP procedures with 50 % by 2010. 
 
EN 14   EN 3.2. Specific objectives (linke d to the defined problems) 
• increase understanding of the bene fits and political support for GPP 
• reduce legal barriers to GPP 
• provide new, and support the provision of existing, implementation tools  
• increase similarities between GPP crite ria across the EU to improve market 
signalling, guarantee a true internal ma rket and reduce administrative costs 
3.3. Consistency with other EU policies and horizontal objectives 
GPP will contribute to the following EU policies by: 
• promoting energy-efficient procurement in vi ew of reaching the binding targets on 
climate protection and clean energy agreed  upon by the EU leaders at their Spring 
Summit on 9 March 200725  
• supporting Directive 2006/32/EC on ener gy end-use efficiency and energy 
services, which obliges the public sector to play an exemplar y role in taking 
energy efficient improvement measures by using public procurement  
• reinforcing the objectives of the En vironmental Technologies Action Plan26 and 
contributing to the Lisbon Strategy27, by offering large scale markets for newly 
developed environmental technologies  
• contributing to the establishment of a prope r Sustainable Industrial Policy and the 
proposed development of "lead markets" in the field of 'sustainable construction', 
'recycling' and 'bio-based products 
• contributing to the objectives of the EU  Sustainable Development Strategy, in 
particular the forthcoming framework of  Sustainable Consumption and Production 
• reinforcing the implementation of EMAS28 and Ecolabelling schemes29, which are 
voluntary policy tools aime d at improving the environmental performance of 
organisations and products , currently under revision 
• contributing to the objectives of the Community health and social policies, in 
particular by taking into account seve ral EU policies in this field when 
establishing GPP criteria (the new ch emicals regulation REACH, the renewed 
Community strategy to reduce CO2 from light vehicles)  
The identification of suitable GPP criteria wi ll be co-ordinated and complementary to 
new and existing Eco-label, En ergy Star and EuP Regulations30, as well as with other 
                                                 
25 30 % greenhouse gas reduction for developed countries by 2020, at least 20 % GHG reduction for EU 
by 2020, 20 % energy efficiency savings by 2020, 20 % binding target for renewables by 2020 and 10 
% binding target for biofuels by 2020, http://ec.europa.eu/councils/bx20070308/index_en.htm   
26 http://ec.europa.eu/environment/etap/index_en.htm   
27 http://ec.europa.eu/growthandjobs/reports/index_en.htm 
28 More information at : http://ec.europa.eu/environment/emas/index_en.htm   
29 More information at : http://ec.europa.eu/environment/ecolabel/index_en.htm   
30 Regulation 1980/2000 of the European Parliament and the Council of 17 July 2000 on a revised 
Community Eco-labelling Award Scheme, OJ L 237, 21/09/2000, currently under revision; Directive 2005/32/EC of the European Parliament and the Council of 6 July 2005 establishing a framework for 
the setting of ecodesigne requirements for energy-usi ng products, OJ L 191, 22/07/2005; Energy Star 
Regulation to comply with Council Decision of 18 December 2006 concerning conclusion of the 
 
EN 15   EN EU initiatives aimed at setting volunt ary environmental product or production 
process related criteria, including reference to standards for the assessment of the energy performance of products and servic es (as foreseen under Energy Performance 
in Buildings Directive and C onstruction Products Directive)
31. 
4. P OLICY OPTIONS  
4.1. Option 1: Business as Usual 
Under this option, the Commission would c ontinue to provide the existing guidance 
on its GPP website, including the Handbook on environmental public procurement, 
reference to existing national and interna tional product databases and to relevant 
studies. It would continue to hold regular  meetings with national GPP experts to 
exchange information and best practice.  
4.2. Option 2: adoption of a package of  guidance, support, recommendations and 
future actions, some of which would be delivered through a Communication proposing voluntary targets, legal and opera tional guidance and a process of co-
operation for establishing GPP criteria for priority product groups  
4.2.1. Proposing voluntary targets for GPP, bas ed on a quantification of the EU wide 
target set forth in the EU renewed Sustainable Development Strategy  
The Member States have committed to a formal GPP target in the renewed 
Sustainable Development Strate gy, stating that by  the year 2010, the average level of 
GPP should be at the current level in the best performing Member States.  
Against this background, the Commission would propose a common political target 
of 50 % use of GPP by 2010, without giving it any legal force. 
This target is in effect a quantifica tion of the above mentioned Sustainable 
Development Strategy commitme nt. The baseline for setting the percentage results 
from an assessment of the situation in the best performing Member States in 2005-
2006, carried out in the "Take-5" study. A ccording to the results of this study, 
between 40 to 60 % of all analysed tender documents in the relevant Member States included green criteria. Taking into account precision rates,  it is proposed to set the 
target at the averag e level of 50 %.  
4.2.2. Provision of new and highlighting of existing implementation tools 
• Highlight the most useful  existing guidance and tool s on GPP through description 
in an Annex to a Commission Communication. This will facilitate the exchange of best practice. 
• Develop and publish additional guidance on: 
– Life cycle costing as an award criteri on, including the provis ion of easy-to-use 
calculator tools  
                                                                                                                                                        
 
Agreement between the Government of the United States of America and the European Community on 
the coordination of energy-efficiency labelling programmes for office equipment  
31 Directive 2002/91/EC of the Euro pean Parliament and of the Co uncil of 16 December 2002 on the 
energy performance of buildings , OJ L 1, 4/1/2003; Council Dir ective 89/106/EEC of 21 December 
1988 on the approximation of laws, regulations and administrative provisions of Member states relating 
to construction Products. 
 
EN 16   EN – budgetary practices facil itating the uptake of GPP,  including the use of 
performance contracting or similar financ ing models, where the risks for installing 
new and more energy efficient equipment is left to the private investor who will be paid through sharing of savings 
– joint procurement to reduce administra tive costs and stimulate innovation  
– how to define environmental award criteria for products for which no EU or 
national environmental performan ce levels have been identified 
– a management model facilitating uptak e of GPP within an organisation  
– how to use GPP to stimulate the diffusi on of new eco-technologies, based on the 
recently published Guide on Procurement and innovation
32 
• Develop and publish a Training programme,  based on the recently developed web 
based Training Toolkit on GPP, on EC f unded "train the trai ner" workshops and 
integration of GPP into regular procurement training. 
• Highlight existing co-operation platforms to  facilitate greater regional and local 
dissemination of GPP and integrate GPP in the implementation of other EU 
policies, for instance by using the networks set up or promoted under the EU Urban Strategy, or the co-operation networks  in the field of the implementation of 
the Structural Funds.  
For instance, the ac tivities financed under the U RBACT II 2007-13 programme (The 
Urban Development Network Programme) coul d be used as building blocks for the 
exchange of experience on GPP. The programme generally aims to provide 
structured information on urban issues to  local authorities across Europe through 
networks of cities in the Member States, as part of the Cohesion Policy for the period 
2007-2013
33. 
4.2.3. Provision of key information on prioritisation and easy to use core and more 
advanced GPP criteria for priority sectors  
• Provision of a list of 10 "priority" sect ors covering product and service groups, 
considered most suitable for starti ng to apply GPP by reason of their 
environmental/financial impact and scope for improvement  
On the basis of abovementioned DEFRA an d "Take-5" studies and analysis of 
existing national GPP strategies, the Commission would propose the following 
priority sectors: Construction (both c onstruction works and products including raw 
materials such as wood, cement, aluminiu m, steel); Food and catering services; 
Transport (cars, light and heavy duty vehicl es, buses, metro's, trams and trains) and 
transport services; Energy; Office machin ery (computers, monitors, printers and 
copiers); Clothing (uniforms and other text iles); Paper and printing services; Wood 
and wood products; Cleaning products and serv ices; Equipment used in the health 
sector. Both studies have been subject  to wide stakeholder consultation. The 
prioritisation study carried out for DEFRA ha s been subject to discussions in the UK 
Sustainable Public Procurement Task For ce, which was a private sector led task 
force, gathering representatives of bot h private and public organisations and 
companies. The final results of the Take -5 study are based on draft reports which 
                                                 
32 http://www.proin no-europe.eu/index.cfm?fuseaction=pa ge.display&topicID=89&parentID=0   
33 http://urbact.eu/urbact-programme.html   
 
EN 17   EN have been discussed at several stakeholde r meetings. The list of priority product 
groups and services was also included in  the document which was sent out for 
consultation to over 200 stakeholders (results  of the consultation are in Annex).  
These priority products cover a substantial part of total expenditure, particularly by 
larger authorities. In the UK, similar pr oduct groups have been  singled out based on 
a slightly different methodology, covering 59 % of total procurement. For example, 
construction is one of the heaviest pos ts, with £ 22.3 billion in 2003/2004. Public 
transport services cover more than 2 billi on EUR, Health and soci al care cover £ 21.3 
billion, Transport £ 5.4 billion, Office mach inery and computers £ 6.5 billion, Food £ 
3.2 billion. Also in the Netherlands, cons truction and maintenance, and road and 
water construction are the most important central government expenditure areas, with 
a budget of 6 to 10 billion €, Public transpor t services cover more than 2 billion €.  
• Provision of "core" and more advanced/com prehensive environmental criteria for 
use in GPP  
The core criteria would be designed to allow easy application of GPP, focussing on 
the key area(s) of environmental perfor mance of a product and aimed at keeping 
administrative costs for companies to a minimum. 
The more advanced or comprehensive GPP criteria would take into account more 
aspects or higher levels of environmental performance, for use by authorities that 
want to go further in supporting environmental and innovation goals. 
To date, the Commission services have esta blished criteria for 11 product and service 
groups. The criteria have been developed by a contractor in close co-operation with 
stakeholders (including Member States a nd industry).The Commission would seek to 
formalise the process by re-submitting these criteria for formal endorsement by the 
Member States. Formal endorsement woul d imply their uptake in national action 
plans and guidance on Green public procur ement. The Commission would continue 
its work on criteria setting, and gradually propose criteria for more and more product 
and service groups suitable for GPP. The Me mber States and relevant stakeholders 
would be involved from in the begi nning and the Minimum Standards for 
Consultation of interested parties fu lly respected. The Communication would, by 
way of example, publish in Annex GPP produc t sheets with core and comprehensive 
criteria for 4 product groups (cleaning produc ts and services, pape r, electricity and 
food and catering services). The criteria have  and will be put together on the basis of 
the extensive environmental criter ia information already available34 in the EU and 
elsewhere and from newly commissioned wo rk. The definition of criteria will 
consider the product market in question. Stak eholder expertise woul d be essential to 
providing criteria – and w ould be obtained through an informal, but structured, 
process of co-operation. The draft GPP cr iteria would be submitted for advice to 
relevant stakeholders (national GPP experts, Advisory Committee on Public 
Procurement, the EUEB = the European Union of Eco-labelling Bodies which include amongst its members national eco-labelling experts and stakeholders from industry and civil society). The final se t of criteria would be endorsed on the 
occasion of regular meetings organised with an expert group of national GPP experts.  
                                                
 
34 See also references under Section 3.3 on "Consistency with other policies". For example, Eco-label 
criteria or Euro standards for vehicles before they become mandatory 
 
EN 18   EN The Commission monitoring exercise woul d focus on priority product groups and 
relevant core GPP criteria , which would stimulate thei r EU wide uptake. Criteria 
would be published in a data-bas e in each MS working language. 
4.2.4. Legal guidance 
• Clarify to what extent production process re lated criteria, such as emissions to air 
and water during the production proces s, can be included as technical 
specifications or award criteria; in this  context, it would also clarify which 
elements of a production process may be c onsidered relevant for characterising a 
product as "sustainable".  
• Clarify whether public purchasers can reque st from bidders, by way of a contract 
performance clause, that they need to start up an environmental management 
system when awarded the contract. 
When providing legal guidance, the Co mmunication would ensure that the 
interpretation clarifies and was also fully in line with the World Trade Organisation 
and the Government Procurement Agreement concluded within the WTO. For more details on international asp ects of GPP, see Annex 4. 
4.2.5. Recommend Member states managing author ities to use GPP when implementing 
projects funded through Structural funds and other EU funding mechanisms  
A recommendation for Member States and managing authorities designated in view 
of the management and monitoring of Stru ctural programmes (which is the sole 
responsibility of the Member States) to ma ke the award of Structural Fund projects 
and other EU funds dependant upon co mpliance with GPP (where relevant).  
4.3. Option 3: Setting mandatory targets for GPP 
This option would tackle the problem of lack of political suppor t by setting targets 
for certain levels of GPP to be achie ved by Member Stat es and Community 
Institutions by certain dates. Targets would be set as a percentage of procurement, 
(measured by value and numbers of pr ocurement procedures/contracts).  
Various forms and levels of targets could be set:  
Sub-option 3.A) mandatory targets for life cycle costing 
Sub-option 3.B) mandatory targets for "basic" GPP Sub-option 3.C) mandatory targets for “outcome-based” GPP  
For the purposes of judging achievement of  the targets under sub-option B, GPP and 
"basic" GPP would be taken to be: 
Use of a procurement process which either: 
sets minimum environmental criteria co mparable with the minimum specifications 
described in the core criteria pr ovided by the Commission; or which 
grants a significant weighting to environm ental criteria in assessing tender bids. 
This definition of GPP would be chosen  because it reflects the two methods by 
which environmental considerations can easil y be incorporated into procurement and 
because it gives flexibility to procurers. It would therefore also include procedures 
which do not necessarily lead to a "green" outcome and would avoid that the use of 
GPP would result in significantly great er financial costs for authorities.  
Where environmental criteria are set as minimum technical specifications, they 
would relate to the core GPP criteria es tablished under Option 2. Where for instance 
 
EN 19   EN a minimum 15 % environmental aw ard criterion is set, this could be done either by 
awarding 15 % to offers complying with the core GPP criteria established under 
Option 3, or by weighing the different offe rs to for instance a maximum of 15 % (of 
overall award percentage) based on their re lative environmental performance against 
certain well described and ve rifiable environmental impacts. In the latter case, there 
would be no direct link to the core GPP criteria as established under Option 2. By 
providing this flexibility as regards ways to  reach the targets, it would be possible to 
set mandatory targets without there being a need to link those targets to compliance 
with core GPP criteria agreed  in a comitology process. Stakeholders state that a 
weighting of 15% would nevertheless still promote the development of better performing products. 
Mandatory targets under sub-option 3.C w ould require the purchase of products 
meeting set minimum standards for a pr oportion of public purchasers. For the 
purpose of judging achievement of target s, the notion of “outcome-based” GPP 
would cover only those procurement pro cesses in which minimum environmental 
criteria as described in the core criteria provided by the Commission have been set as minimum technical specificati ons (to be met by all offers). This option would be the 
only one to guarantee in all cases a “gre en” outcome. Because of the mandatory 
character of the GPP criteria, they w ould need to be established through a 
comitology process.  The Commission would intend to review targ ets for GPP, however set, every 5 years 
to encourage or oblige Member States to reach a level of  GPP equal to the 
quantitative and qualitative level that ha d been achieved by the best performing 
Member States 5 years before.  
Sub-Option 3.A): mandatory targ ets for life cycle costing 
Life cycle costing is the consideration of the full financial cost to an authority of 
purchasing a product: the initial purchase pr ice, the running and maintenance costs 
over the lifetime and the costs at the end of life (for example disposal). 
Under this sub-option the Commission woul d propose targets for use of life cycle 
costing for a % (by value) of all procurement contracts for which it was appropriate. Although it cannot be considered an environm ental criterion as such, given the fact 
that the life cycle cost would just repla ce the initial purchase price in the award 
procedure, it comes close –as to its e ffect- to a mandatory environmental award 
criterion where a certain nu mber of points would be aw arded for energy efficiency. 
Translating the energy efficiency immediat ely into the price of the product would 
ease its acceptance by public purchasers. Le gislation setting targets would include a 
description of the areas covered, focussi ng on resource using products, such as 
vehicles, electrical equi pment, lighting, buildings. 
Sub-Option 3.B) mandatory targets for "basic" GPP  
The Commission is developing a precise met hod for calculating levels of GPP, based 
on compliance with GPP criteria in priority sectors. It will implement this method in 
the seven best performing Member States, which would allow to translate the SDS 
target into a mandatory target, namely th at, by the year 2010, the average level of 
GPP would be at the current (= 2006) level in the best performing Member States. . 
The target would need to be reached in terms of numbers and (estimated) value of 
"green" tendering proc edures which have led to "green " contracts. If one would only 
consider the value, it would be sufficient to  "green" a small number of big contracts. 
 
EN 20   EN If only the number would be considered, it would be suffi cient to "green" a lot of 
small contracts without making a real envir onmental difference. Therefore, the target 
should be reached in terms of number and value.  
These targets would be based on the defini tion of "basic" GPP mentioned above. The 
option would be linked to the proposed proce ss for prioritisation and criteria setting 
under Option 2. Considering the fact that ach ievement with the targets may also be 
attested by procurement procedures in whic h environmental award criteria have been 
set without specifying certai n minimum levels of environmental performance, there 
would be no need to identify those crit eria by way of a comitology process.  
Sub-Option 3.C) mandatory target s for “outcome-based" GPP  
Considering the mandatory character of th e target and outcome-based definition of 
GPP used, the Commission would conduct addi tional research to propose appropriate 
targets for priority product groups and linki ng those to cost-effective minimum levels 
of environmental performance. Where the li fe cycle cost of environmental products 
is lower than that of the non-"green" versi on, targets could be set at a higher level. 
These minimum standards and targets would be set in advance at EU level in a 
Comitology procedure, based upon recomm endation from the Commission working 
with stakeholders where appropriate.  
4.4. Option 4: Make GPP mandatory for cert ain types of purchasing authorities and 
for certain specific products, or for certa in types of contracts, or for certain 
types of public spending 
Various forms of mandator y GPP can be identified: 
Sub-Option 4.A : Make GPP mandatory for certain types of contracting authorities 
when purchasing certain specific products Sub-Option 4.B:  Make GPP mandatory for all purcha ses above the thresholds of the 
public procurement directives Sub-Option 4.C : Make it mandatory for all contractors in service and works 
contracts above certain thresholds, to implement an environmental management 
system Sub-Option 4.D : Make it mandatory to use GPP in the implementation of EU 
funded projects, where appropriate  
Sub-Option 4.A. Make GPP mandatory for certain types of purchasing 
authorities and for certain specific products  
By analogy with the recently adopted ne w Energy Star Regulation (as presented 
under Option 1), such option would make  outcome based GPP mandatory (100 % 
target) for central government purchasers and for certain products, where advanced 
GPP criteria have been identified and the market is such that 100 % GPP by central government would be appropriate, taking into  account a transitional period sufficient 
to allow the market to adapt to change. It  is not yet possible to specify the products 
and services which would be covered by su ch proposal, as an additional impact 
assessment needs to be carried out to identify those product groups.  
 
EN 21   EN Sub-Option 4.B. Make GPP mandatory fo r all purchases ab ove the thresholds 
of the public procurement directives, by making the environmental award 
criterion mandatory 
The public procurement Directives lay down the rules that need to be followed by 
public authorities when buying goods, services or works. One of the basic rules is 
that purchasers can, when choosing the bid o ffering best value for money, either base 
themselves on the lowest price, either choose the “economically most advantageous 
bid”, meaning that, on top of the price, th e purchaser will take into account one or 
more award criteria, such as the technical quality, the delivery time, the energy efficiency and so on. The Directives provi de for a non exhaustive list of possible 
award criteria, including environmental award criteria. Under this option, public 
purchasers would be obliged to include , amongst the award criteria, a minimum 
environmental criterion (for instance 15 %). Hence the option of awarding a contract 
based on the lowest price only would no longe r exist. This option would not prevent 
purchasers from also specifying minimum e nvironmental technical specifications. In 
addition, the award of the contract would always need to be based upon, amongst 
other criteria, the relative environmental merits of the offers. This option would 
provide a strong incentive for innovation.  
Sub-Option 4.C: Make it mandatory to  include, for all service and works 
contracts above certain thresholds, a cont ract performance clause which obliges 
the winning bidder to set up an enviro nmental management system during the 
performance of the contract 
This option would also imply a modification of the public procurement Directives in 
view of making it mandatory for public purch asers to include a specific performance 
clause in all important services and work s contract (above certain thresholds, which 
could be the threshold currently applying for works contracts which is 5 million €). Considering the significant environmental im pact resulting in particular from the 
execution phase of these contracts, it is impor tant to oblige the contractor to set up 
and run an environmental management system  during its performance, as this will 
contribute to guaranteeing minimi sed environmental impacts.  
Sub-Option 4.D: Modify the rules governing the award of EU funding in view of 
making it mandatory to use GPP when  implementing EU funded projects, 
where appropriate 
A change in the EU rules governing the aw ard of structural funds and other EU 
funding mechanisms to make the award of funds dependant upon compliance with 
GPP, where relevant. 
4.5. Option 5: Modify the Co mmission Directive on Standard  forms for use in public 
procurement 
Modification of Commission Directive on the use of standard forms in the 
publication of public contract notices
35. 
                                                 
35 Commission Directive 2001/78/EC of 13 September 2001 amending Annex IV to Council Directive 
93/36/EEC, Annexes IV, V and VI to Council Directive 93/37/EEC, Annexes III and IV to Council Directive 92/50/EEC, as amended by Directive 97/52/EC, and Annexes XII to XV, XVII and XVIII to 
Council Directive 93/38/EEC, as amended by Directiv e 98/4/EC (Directive on the use of standard forms 
in the publication of public contract notices) 
 
EN 22   EN This Directive lays down the mandatory fo rms that have to be used by purchasers 
when publishing their intention to tender, as well as the results of any tendering procedure, covered by the public procurem ent Directives. The modification would 
oblige purchasers to indicate in both the c ontract advice and c ontract award notices 
information on relevant environmental speci fications or award cr iteria. This will 
allow Member States to easily monitor the situation and identify the amount and 
number of procurement procedures where e nvironmental criteria have been included 
and compare them to the amount and numbe r of procurement co ntracts which have 
actually also lead to the purchase of a "green" product or service. 
5. A
NALYSIS OF IMPACTS  
Presentation of the impact analysis presents difficulties. Each of the options below is 
likely to have direct and indirect impacts – and because of the nature of GPP, the 
indirect impacts (the outcomes that result from greater uptake of GPP) are the most 
significant. However, these are also the mo st difficult impacts to quantify, as the end 
result depends on a chain of action36. 
Additionally, the options are not  mutually exclusive and their impact will depend on 
the interaction between options.  
Impact would also depend on the process used. Administrative practices may vary 
greatly between Member States. Procedur es setting high minimum standards or 
weights for the environmental criteria are more likely to result in the purchase of 
substantially greener products and steer the market towards innovation. A high level 
of ambition of the environmental standard s set and the procedural stage at which 
these standards are introduced –either as a mandatory technical specification which 
all offers have to comply with or as a relatively important  award criterion on the 
basis of which offers will be compared ag ainst each other at the award stage, will 
give the strongest signal to the market place.  
Impacts would be product or market specif ic and depend in part icular on: the share 
of public procurement in that market; th e potential for innova tion for that product 
type; the difference in environmental perf ormance between the best and the average 
performing products; and the difference in in itial price and life-time costs between 
the best environmentally performing and the other products. 
To deal with these difficulties, the analysis of Options is divided into a description of 
the likely impacts of the aggregate effect s of increased GPP across the EU, then 
descriptions of the (additional) spec ific effects of different options.  
5.1. Aggregate impacts of increased GPP 
The overall impact would of course depend on the change in scale of uptake of GPP. 
To give an idea of the potential impact in  case of a 25 % uptake of GPP: Total public 
procurement in the EU is estimated at  around €1800bn a year. In  the UK, priority 
areas have been estimated to account for 59 % of total central government 
procurement. Based on this example, and considering the fact that the priority 
product groups proposed by the Commission are ve ry similar to the ones identified in 
                                                 
36 Commission action influences political motivation in central government which influences procurement 
procedures in regional authorities which then influences (but does not determine) the level of uptake of 
certain types of greener products, with the impact on the environment and the economy from the 
purchase of those products itself depending on the nature of the product and structure of the market. 
 
EN 23   EN the UK, and whilst reducing slightly the UK pe rcentage to take into account relative 
differences between Member States, public ex penditure on the priority areas could be 
estimated to be around 50 %, covering thus 50 % of €1800bn. If GPP procedures 
were used for 25% of the proc edures in those prio rity sectors, this would mean that 
€225bn worth of green tenders would be produced a year – offering substantial incentives to the market to offer greener products. Going an assumption further, if 
50% of those tenders did result in the purchase of greener goods, €112,5bn would move from less green to greener purchases. 
ECONOMIC IMPACTS
 
Direct Economic Impacts  
Direct financial impacts on authorities: 
• Savings or additional costs from purchases 
The net direct financial benefits or costs will depend on the savings  or costs from the 
"green" products purchased over their life ti me (compared to those that would have 
been purchased without GPP processes) and whether these more than compensate for or add to, administrative costs.  
The above mentioned study on Costs/benefits of GPP has compared prices of "green" 
and "non green" goods in the EU and conc luded that, for most  product groups, the 
‘make’ or brand of the product or other f eatures have a much higher influence on the 
purchase price than green criteria. For ex ample, cleaning products vary very much, 
both within the green or non gr een versions and between th e selected Member States. 
The resulting average purchase prices of th e green versions are partly higher, partly 
lower than the prices of the corresponding non green version. 
The future costs of greener goods, in par ticular of energy e fficient goods may not 
remain constant. Some stakeholders call for reduced VAT rates for these goods. This 
would lower their purchase price.  
Equally significant, GPP leads to better consideration of the whole-life costs of the 
product. In particular in cases of res ource efficient products, buying "green" products 
can also mean buying "cheaper" products fo r the purchaser over their lifetime. For 
instance, the RELIEF project calculated that, if all public authorities used water 
saving devices, this would resu lt in annual savings of €527m. 
A recent Study carried out a Cost Benef it Analysis of Sustainable Public 
Procurement for the UK government
37, showed for instance that the use of 
sustainable construction t echniques in the Newport Southern Distributor Road 
resulted in benefits valu ed at £2.1 m (3,100,000 EUR), part  of which came through 
reduced purchase cost of recycled materials.  
By focussing on the function to be delivered, the cost differences between some 
green and non green versions are put in rela tion to the overall costs to fulfil a certain 
function. This is most obvious for product gr oups used in servic e contracts (such as 
for instance ‘painting’ and ‘cleaning produc ts and services’) wher e costs are highly 
dominated by labour costs. However, also for products like coffee, the share of the 
ingredient which can be ‘greened’ (coffee beans) only contributes to a minor degree 
                                                 
37 See final Report to the UK Department for Environment, Food and Rural Affairs, completed by SQW 
Ltd May 2006 (Cost Benefit Analysis of Sustainable Public Procurement)  
 
EN 24   EN to the overall costs of the end product. In  these cases, the magnitude of the potential 
cost increase through GPP will be highly ove restimated by only looking at the direct 
cost differences of certain products or ingredients but not  at the full costs of the 
service or end product.  
• Start-up administrative a nd organisational costs 
The above mentioned study on cost/benef its of GPP has concluded that the 
administrative costs for setting-up and im plementing GPP in a local authority in 
Europe are higher than for st andard procurement. The bi ggest cost driver is the 
continuous awareness raising, training and s upport for procurers. Costs for setting up 
the policy are low compared to the ove rall procurement budgets. There may be 
additional costs resulting from the search of  environmental criteria in procurement.  
The level of these costs depends on the current management of the authority's 
procurement and the practices it follows to  put in place GPP processes. In cases 
where the adoption of GPP also streamlines  existing complex procurement practices, 
there may be cost savings resulting from  more effective procurement as such.  
The study found evidence that GPP does genera te monetary savings  after the initial 
period of developing a GPP strategy and in tegrating administrative tasks into the 
procurement process. Thus potential savi ngs through lower (life cycle) costs for 
green products and services might outwei gh the additional administrative costs.  
Administrative costs could be minimised through sharing good-pr actice, using only 
core environmental criteria, using trai ning and other tools developed by more 
experienced authorities.  
By way of example, it can be stated that , at the level of th e Danish government, 
Environment Ministry, purch asers use ¼ to 1/3 person a year for including green 
criteria/requirements in calls for tenders and informing decentralised purchasers on 
green requirements for product groups which are not purchased commonly.  
In the Netherlands, the administrative co sts for implementing the national strategy 
have been estimated at 6 to 7 m € over a period of 4 years. The administrative costs 
for individual organisations to set up green purchasing po licies, gather information 
and ensure appropriate traini ng of purchasers are considered  negligible and part of 
regular organisational management. 
The above study shows that individual purchasi ng authorities setting up and 
implementing GPP spend on average 223 Euro per 1 000 inhabitants (this takes into 
account both initial onetime costs and averag e annual costs) over a period of 2 to 6 
years. Those costs would cover the costs of setting up and implementing a GPP and 
costs for training. According to the study, base d on an analysis of the situation in 20 
EU public authorities of vari ed size and experience in G PP, the costs for setting up a 
GPP policy would amount to on average 69 additional Euro per 1000 inhabitants of 
the respective city or region. The costs for implementing the GPP policy relate to costs for assessing procurement practices , adapting tenders, developing criteria, 
analysing environmental impacts of products, verifying bids, participating in working 
groups and managing audits. They would amount to on average 41 Euro per 1000 
inhabitants. Costs for miscellaneous tasks and activities (dissemi nation, newsletters, 
raising awareness of employees and supplie rs) have been estimated to be at an 
average level of 28 Euro per 1000 inhabita nts. Finally, on training, local and regional 
authorities spend on average 38.854 Euro for training and events (equivalent to an 
average of 157 Euro per 1000 inhabitants). Mo st of the costs for training and events 
 
EN 25   EN (95%) derive from in-house st aff training with people atte nding different  training in 
GPP.  
Direct financial impact on vendors of products: 
In any procurement process, one bidder wi ns business and others lose. GPP would 
not change this. Currently, large firms wi n a disproportionate percentage of public 
procurement contracts. A shift towards environmentally friendly products may 
support producers who are smaller, newer, a nd who are not specialised in traditional 
mature products. Alternatively, the shift may also take place within large firms 
towards ‘green’ products However, it seem s likely overall that SMEs will be no 
worse off and, more likely, at le ast marginally advantaged.  
This would be subject to there being uniform environmental criteria applied 
throughout the EU; if not, bidders and in pa rticular SMEs (as bi dding costs tend to 
burden SMEs disproportionate ly) would run into additional administrative costs for 
preparing bids in different Member States or  for different procuring authorities. They 
would need to prove compliance with different  sets of criteria, which would result in 
additional administrative costs. 
Indirect Economic Impacts  
Promotion of Innovation 
It is likely that ‘green’ produc ts will be relatively new in the market and not currently 
enjoy economies of scale. Niche products wi ll be given the demand that allows them 
to expand and cut unit costs and so move into mainstream markets. Ultimately, the 
economic benefits of this may accrue not to the public procurer but to other buyers.  
According to above mentioned OECD 2003 Repor t, the benefit will be significant if 
the government demand is large enough to al low the realisation of  significant scale 
economies. Further, GPP would be most  promising when it focuses on product 
attributes, such as energy effi ciency, that will clearly be of interest to  private buyers. 
Finally, GPP may act as advertising or cer tification of the green product and set a 
moral example that some private purchasers may choose to follow.  
Increased Macro-economic Resource Effici ency and Cheaper Achievement of 
existing environmental and economic goals 
As described above, GPP is likely to prom ote innovations in products that spread 
more quickly through the private market  and most promising when focussing on 
product attributes, such as ener gy efficiency, that will clearl y be of interest to private 
buyers. It may set a moral example that some private purchasers may choose to 
follow. The faster adoption of resource saving products across the economy would 
have a macro-economic effect, reduci ng in particular energy consumption38, 
inflationary pressure and energy imports.  
Even in case of increased direct costs fo r the public sector, GPP could well be saving 
the financial costs for the economy as a whol e. Both the public and private sector 
currently face certain costs to meet diverse environmental and innovation goals: where GPP can help achieve these goals, it could do so at a lower cost than would be 
required to achieve the goals through other policy  instruments, implying other types 
                                                
 
38 An economy-wide rebound effect may reduce the aggregate energy savings,  but seems unlikely to 
exceed 25% of those savings. 
 
EN 26   EN of costs for the public and private sector. For example, GPP of less polluting vehicles 
or buses may avoid imposition of (more expensive) restrictions on boilers. 
Increased Competition 
The application of GPP criteria will tr igger a new form of competition (focussing on 
the environmental aspects of bids) in pub lic procurement procedures and increase 
transparent and competitive procedures throughout the EU. A recent study on the impact of public proc urement legislation
39 has identified that "Open, non-
discriminatory and transparent procedures can also help boost the competitiveness of firms operating in public procurement mark ets. Only firms confronted by foreign 
competitors at home will be able to perfor m efficiently and compete successfully in 
foreign markets and withstand foreign competition at home". GPP will boost the 
competition between firms operating in GPP markets. This was also recognized in 
the Commission's broad based innovation strategy for the EU
40, in which the 
Commission called for actions stimulati ng competitive demand, such as public 
procurement and standards, to facilitate the development of new lead markets for 
innovative products and services in Europe.  
Benefits for international competitiveness 
The promotion of innovation for green pr oducts, which are often growing markets 
worldwide, is likely to increase the future power of EU industry to compete in global 
environmental product markets. EU fi rms dominate the market for public 
procurement and hence innovative EU firms will gain greatest support. The aim of 
the Lisbon strategy for Growth and Jobs is to find solutions not only for the 
continuing underinvestment in R&D, but also to improve Eu rope's ability to convert 
new inventions into new products and jobs. The US is currently spending $50 Bn per year in public procurement of R&D, an amount which is 20 times higher than in 
Europe. In addition to improving the quality and efficiency of pub lic services, this 
has often played an important role in the emergence of globally competitive companies
41. For instance, in the area of ener gy and the environment several public 
institutions in US and Japan have significan tly reduced the installed system cost of 
fuel cell stations through R&D procurements . In China last year 's national long-range 
science and technology plan officially introduced public  technology procurement in 
China as a means to stimulate innovation42. EU wide Green public procurement is 
needed to give same strong signals to  the markets and se cure international 
competitiveness of EU industry.  
Potential negative side effects 
The aforementioned OECD Report of 2003 re fers to the potentially counteracting 
effect of GPP due to crowding out of pr ivate consumption of a certain "green" 
product as a result of increased public  demand. Crowding out could occur if 
suppliers are slow to respond to increased demand for their greener product but quick 
to respond to demand for the "brown" product,  In this case the "green" product that 
the government buys might otherwise have been purchased by a private buyer, who 
                                                 
39 More information at http://ec.europa.eu/internal_market/publicprocurement/studies_en.htm   
40 COM(2006)502final, Putting Knowledge into practice:  a broad-based innovation strategy for the EU 
41 "US Defence R&D spending: an analysis of the impacts", EURAB report ERA scope & vision, PREST, 
2004 
42 Draft Communication on pre-commercial procurement 
 
EN 27   EN will now turn to the brown product and the net impact on sales of greener products is 
reduced.  
The problem is not likely to be widespread  for GPP. Higher prices caused by demand 
from GPP will typically stimul ate greater supply, particular ly as demand for greener 
products from GPP will increase gradually ac ross the EU and be signalled in advance 
to suppliers. Where there are supply constraint s, prices will rise, which – as these are 
also taken into account in GPP deci sions – would limit any crowding out.  
When considering GPP in markets where th e production is yet in sufficient to cover 
both private and public demand and will be slow to change, for instance in the case of "green" electricity, explic it consideration should be given to stepwise approach 
e.g.not to aim at an immediate 100 % "green" electricity purchase.  
ENVIRONMENTAL IMPACTS
 
Reduction of environmental harm resulting from public purchases 
The extensive environmental damage from current government activities would be 
reduced. For instance: 
The UK Government Sustainable Procurem ent Action Plan includes a package of 
actions to ensure that supply chains and public services will be increasingly low 
carbon, low waste and water efficient, re spect biodiversity and deliver wider 
sustainable development goals. It is direc tly linked to the targets for sustainable 
operations on the Government Estate, aimed at materialising substantial changes in 
the fields of carbon emissions, energy effi ciency, waste and recy cling, biodiversity 
and water consumption. Action in the field of  procurement is thus considered crucial 
to achieving the Government's operations targets, which will deliver around 1 million tonnes of carbon dioxide savings by 2020.  
The French national action plan on sustai nable public procurement also links the 
actions on GPP to the achievement of ta rgets for reducing cer tain environmental 
impacts, such as reducing –by 2010- the carbon emissions linked to transportation 
activities by the government with 10 % and reducing carbon emissions from public 
buildings with 10 %. 
The RELIEF project has calculated that  the application of  organic farming 
requirements for domestic production aime d at public consumption of wheat, beef, 
pork, and milk would reduce nutrification impacts equivale nt to the nut rification 
impacts of over 2 million people.  
The Canada’s Federal Buildings Initia tive (FBI), focussing on the purchase of 
"green" power has led to a significant re duction of Green house gas emissions in 
targeted buildings. The average FBI project realised an estimated energy reduction of 
25 % and GHG emission reduction of 20 %. Projected energy savings (up to 2012) result in a projected CO2 emission reduc tion of 884 000 tonnes or about 2 % of the 
total Federal energy-related emissions
43.  
Increased Diffusion of Greener Pro ducts reducing societal impacts 
The public sector is estimated to buy a pproximately 150.000 GWh of electricity per 
year, representing about 6 to 7 % of the mark et. If –theoretically- this market would 
                                                 
43 See OECD Report 2006 on the environmental performance of public procurement 
 
EN 28   EN shift to green electricity, this could save up to 60 million tonnes of CO² emissions or 
18 % of the EU Kyoto commitments44. 
Public Procurement represents about 33 % of the annual Europ ean Bus market. GPP 
may drive this market towards less polluta nt and more energy efficient buses.  
The buildings sector accounts for 40% of th e EU’s energy requirements. It offers the 
largest single potential for energy efficiency. Research shows that more than one-fifth of the present energy consumpti on could be saved by 2010 by applying more 
ambitious standards to new and when re furbishing buildings. Public buildings 
covering an important share of those buildi ngs, public sector has been identified for 
its important role in terms of  leadership in this field
45.  
Promotion of new sustainable business models .  
GPP can promote resource saving business models: e.g. in case of cleaning, the use 
of dosage devices might lead to appropr iate, lower dosage of cleaning products, 
reducing the amount of chemicals flushed in the sewage system and reducing the amount of products bought.  
In Barcelona, a tender for th e purchase of 500 new bus shelters and adaptation of all 
1200 existing bus shelters has led to th e development of a unique bus shelter 
prototype, referenced to as the ‘Barcelona bus shelter model’
46.. The firm who won 
the tender on the basis of a package of inst allation and maintenance of the shelter has 
extended the offer of that successful  package to other municipalities. 
Support for other environment and economic policies 
As described in Section 3.3 "Consistency with other EU policies and horizontal 
objectives. 
SOCIAL, DISTRIBUTIONAL AND EMPLOYMENT IMPACTS  
In November 2005, the European Commissi on issued a report analysing the links 
between employment and environment policies47 in which it was held that studies 
show that environmental policy does not  decrease employment but instead has 
neutral or even mildly positive impact on the number of people in work.  
A more recent study aimed at analysing th e link between climate change and related 
energy efficiency policies and employment has come to the conclusion, that the net gain in employment would be of the or der of 1.5%. Employment in the energy 
production sector is sensitive to energy-savi ng policies. However, the jobs created 
from the development of energy savings options would largely outweigh the number of jobs lost in the coal sector. In the transport sector, the development and dissemination of clean technologi es could give a significan t technology lead to EU 
                                                
 
44 The Procura+ Manual : A guide to cost  effective public procurement, ICLEI 
45 The Commission working document annexed to the Energy Efficiency Action Plan, considers 
proposing an expanded role for the public sector to demonstrate new technologies and methods, based on an impact assessment to be carried out in 2009 
46 The roof consists of a beehive-shaped fibregla ss material, strengthening it and making it easier to 
disassemble at the end of its life cycle and recycle it; the advertising panel is unique for using 3 highly 
efficient T5 lamps of 35W each instead of 4 ineffi cient lamps. The new clean ing system uses osmosed 
water, avoiding the need to use soap/detergents - 2007 study on Costs and Benefits of Green public procurement in Europe, Öko-institut 
47 SEC (2005) 1530, of 17 November 2005, more information at 
http://ec.europa.eu/environment/integration/employment_en.htm   
 
EN 29   EN industry and represents ther eby a huge potential for job creation. The building and 
construction sector represents a major sour ce of employment, but it has to tackle the 
challenges of training in sust ainable building and innovation48. 
Increases in efficiency of public services , in particular increases in the energy 
efficiency of housing, are more likely to creat e benefits to the less-well off classes of 
society whose costs of heating and coo ling (whether paid direct or by public 
services) are likely to become relatively lower. 
Although GPP is in the first place about stimulating the use of environmental 
specifications in tender documents, legal guidance on GPP may im ply advice on the 
inclusion of both environmental and social  aspects and hence open the door also to 
more 'social' public procurement. Legal guidance would indeed include guidance on 
how to take into account aspects relate d to the legality of production processes, 
which may include respect of environmental, social or economic aspects.  
5.2. Specific economic, social and environm ental impacts of each of the Options 
5.2.1. Option 1: Business as Usual 
The option of continuing with the pres ent approach (dissemination of Handbook, 
website, regular meetings with national GPP experts) is not like ly to result in 
significant increases of GPP in the EU. Ev idence of this comes from an assessment 
of trends in uptake in recent years. 
Although Member States had been recommen ded to adopt nationa l action plans on 
GPP by the end of 2006, up to date, only 14 Me mber States have adopted such action 
plans, with varying levels of ambition. Furt her, when comparing the results of a GPP 
survey carried out in EU 15 in 200349 and in EU 25 in 200550, the situation remains 
grossly unchanged. Following the 2003 study, th e highest level of GPP was that 50 
% of all purchasing authorities (of a certain Member State) interrogated would include environmental criteria in more  than half of their tender documents. 
According to the 2005 study, the highest level of Green tenders in a certain Member 
State amounted to 60 % of  all tender documents analysed for the purpose of the 
study. However, many of those tenders scored very poor on legal compliance.  
Benefits 
Slow and scattered increase in GPP with  occasional benefits as mentioned above. 
Some recent and upcoming initiatives could benefit the uptake of GPP: 
The recently adopted new Energy Star Regu lation will adapt the implementation of 
the "Energy Star" programme to the new EU/US Energy Star Agreement (applicable 
5 years-entry into force 31.12.2006). It oblig es central government and Community 
Institutions to specify, in their supply contracts covered by the public procurement 
Directives (above the threshold of 137.000 €), energy-efficiency requirements not 
less demanding than the Energy Star Co mmon Specifications. This initiative may 
                                                
 
48 More information in Report “Climate change and employment” 
http://www.tradeunionpress.eu/Web/EN/Activitie s/Environment/Studyclimatechange/rapport.pdf  2007) 
49 See ICLEI study on state of play of GPP in Europe at http://ec.europa.eu/environment/gpp/studies.htm  
based on questionnaire sent to some 6300 contacts – reply rate of 10 %  
50 See Take-5 study under http://ec.europa.eu/environment/gpp/studies.htm#state  based on an analysis of 
of responses to 860 on line questionnaires and by analysing the use of environmental criteria in more 
than 1000 tender documents. 
 
EN 30   EN have considerable environmental impact, ta king into account the success of a similar 
obligation applied in the USA under the prev ious Energy Star Regulation. The latter 
has allowed overall penetrati on of Energy Star computer equipment and is estimated 
to have reduced total US energy needs by more than 200 billion kilowatt hours since 
1995 which translates into an estima ted carbon reduction of 9 million tonnes51. 
Increased energy efficiency requirements ar e also likely to provi de whole-life cost 
reductions for these products and lo wer costs for public purchasers.  
In the field of transport, the EC has recen tly adopted a proposal for a Directive on the 
promotion of clean and energy efficient vehicles. The approach is based on the 
internalisation of operational lifetime cost s of vehicles in the procurement award 
process. Common rules are defined for calculating lifetime costs for energy 
consumption, CO2 emissions, and pollutant  emissions linked to the operation of 
vehicles. These operational lifetime costs shou ld be included as award criteria for all 
procurement of vehicles or transport servi ces by public authorities. The application 
of these criteria will be optional in a fi rst phase and mandatory from 2012. Covered 
by the proposal are all road transport vehi cles procured by public authorities and by 
operators providing transport services under contract, license, perm it or authorisation 
by public authorities52. 
Costs 
As uptake of GPP slowly rises, difference s between the practices of Member States 
are likely to create increased market distor tions and additional administrative costs 
for suppliers and only provide very limite d stimulus for eco-innovation. In particular 
in the field of timber and timber products , Member States are adopting different 
approaches in their procurement policie s, focusing sometimes on legal only, or on 
sustainable only, or on legal and sustainabl e and referring to different verification 
schemes; This follows from the stakehol der consultation mentioned in annex and 
various contacts with this sector. On top of  that, there are great differences between 
the different certification schemes, which are not equally recognized in all member 
States. 
The obligation for central gove rnment to buy only Energy Star products will lead 
authorities to undertake training and change their procurement processes – which will incur initial administrative costs.  
International competitiveness in eco-technologies is likely to decline as domestic 
markets will not provide European compan ies with the stimulus to develop new 
green technologies that are found in trading partners. This won't be the case for 
energy star products, because of the manda tory implementation of minimum Energy 
Star requirements in central public procurement contracts. 
As demonstrated under Secti on 4.4, public purchasers are im portant market players, 
in particular in sectors with huge environmental impact, such as buildings and transport. If the situation would be left  unchanged, public authorities would continue 
to importantly contribute to the emi ssion of Green house Gases and pollutant 
emissions and an ever faster consump tion of natural resources, including 
jeopardising energy security.  
                                                
 
51 See Energy Star website http://ec.europa.eu/energy/demand/legislation/energy_star_programme_en.htm   
52 More information at: http://ec.europa.eu/transport/clean/promotion/index_en.htm   
 
EN 31   EN 5.2.2. Option 2: A package of options: proposi ng a voluntary target, providing operational 
and legal guidance, establishing a process of co-operation with the Member States to 
identify GPP criteria fo r priority product and serv ice groups and providing for 
increased awareness raising and traini ng on GPP, through dissemination of a 
training toolkit on GPP and use of GPP in the implementation of EU funded projects  
Benefits  
Voluntary target for GPP  
The additional value is to put in place the means for quantifying and benchmarking 
the achievement of the target already agr eed by the Member States in the renewed 
Sustainable Development Strategy.  
The agreement of a better defined target  may also have a political meaning, 
stimulating Member States towards reachi ng the SDS target. Considering that the 
SDS commitment already exists, it seems probable that Member States who are (almost) not implementing GPP now, will not significantly change their political 
motivation on the basis of voluntary targets.  
Further, as the monitoring of target achievement for EU level benchmarking will be 
based on an assessment of GPP for the product groups covered by GPP criteria 
which the Commission proposes to develop in  co-operation with the Member States 
under, there may be an important incentiv e for Member States to recommend the use 
of the GPP criteria.  
Highlighting of existing and provision of new guidance
 
This may help Member States to build up their own GPP strategies and increase 
GPP. It could substantially reduce the cost s typically associated with setting up and 
implementing GPP processes.  
It may also lead authorities to other ways to reduce their costs and increase the 
effectiveness of their GPP. For inst ance, joint procurement (combining the 
procurement actions of two or more public authorities) may lead to economies of 
scale through bundled demand and reduce administrative costs by exchanging 
experience on GPP criteria and on new pr oducts available on other than local 
markets. Guidance on the inclus ion of whole-life-costing as  an award criterion will 
also encourage purchasers to apply GPP, as  it will show that GPP is in many cases 
nothing else than efficient procurement, allowing to save money in the long run. 
The increased uptake and effectiveness of  GPP would be likely to increase the 
contribution of GPP to economic and environmental benefits. 
Central EU guidance may also reduce costs for Member States to develop its own 
rules and contribute to consistency. 
Training  
Training on GPP is essential to its wider uptake, in part icular by regional and local 
authorities who are more difficult to ta rget with general gui dance. Integrating 
environmental guidance in general public pr ocurement training will allow to cost-
effectively target many if not all relevant purchasers. Inversely, a "Train the trainer Toolkit on GPP" will add to the general public procurement knowledge of trained 
purchasers, as it would follow the struct ure of a public procurement procedure and 
draw the attention of trainees  to legal compliance issues. 
 
EN 32   EN Information on Prioritisation  
The identification of 10 product groups c onsidered most suitable for "greening" 
based on economic and environmental impact, will enhance targeting and the cost effectiveness of the whole pr ocess, inviting Member States to focus on areas where 
the biggest environmental improvements can  be expected, without the costs of 
carrying out the research themselves. The se lection of product gr oups will also give a 
strong market signal to  relevant industry.  
Provision of criteria
 
The provision of core-criteria would remove  one of the greatest hindrances to GPP, 
removing one of the greatest  costs and causes of diffi culty for practitioners.  
It would be likely to provide greater cons istency in the product characteristics asked 
for by authorities and give greater transpar ency to producers and so better signalling 
of rewarding innovation opportu nities, whilst also reducing their administrative costs 
from having to provide environmental produc t information in different procurement 
processes. 
Industry stakeholders who carry out green procurement for their own purchases have 
indicated that the prov ision of core criteria could al so raise their levels of green 
procurement, by reducing the costs and diffi culties of identifying suitable criteria. 
This would particularly be th e case if the public sector wa s widely seen to adopt and 
successfully use the criteria as part of a system. 
Provision of legal clarity  
By providing the necessary legal certainty and guidance to purchasers, the latter will 
no longer be refrained from adopting GPP policies. Recommend to use GPP when im plementing EU funded projects 
 
This recommendation would be particularly effective at initiating the uptake of GPP 
by local authorities, main beneficiaries of  Structural funds, who are traditionally 
more difficult to reach in view of rais ing awareness on GPP, providing political 
support, guidance and training. It would furthe rmore ensure cost effectiveness of an 
important part of the EU budget, meet the requirements of Art. 6 of the EC Treaty 
and give strong signals to local companies taking part in the calls for proposals and 
contracts awarded under t hose Structural Funds. 
Costs 
Proposing voluntary GPP targets  
Without political co-ordination from central  government, the uptake of GPP by local 
authorities, is unlikely to take a harmonised approach. 
Highlighting and provision of guidance  
Much guidance already exists, both at EU a nd Member State level,  from both central 
government and other organisations, for in stance the pro-inno guide on innovation 
and procurement53. The costs of providing additional guidance to fill the gaps will be 
negligible compared to the sums involved in GPP, and borne by the Commission. 
                                                 
53 http://ec.europa.eu/environment/gpp/related_policies_en.htm 
 
EN 33   EN Training  
The Commission has developed a Training T oolkit on GPP which could feed into the 
additional training programmes to be set up in each Member State, subject to 
translation and adaptation to the nationa l situation. The LIFE+ budget provides for 
support for capacity building to facilit ate the implementation of Community 
environmental policy at the local and regional level.  
Information on prioritisation and provision of criteria  
The work to identify priority  groups has already been unde rtaken and there would be 
no further costs. 
A huge amount of information already exis ts in various Member States and at 
European level, as well as in the product programmes of trading partners. 
Environmental product criteria are being established in va rious frameworks, such as 
the Energy-Using products Dire ctive, the Eco-label Regul ation, the field of Energy 
labelling and Euro standards for vehicles. The costs for criteria setting will therefore 
be shared with those other policy instruments.  
By way of example, the costs for deve loping new eco-label criteria may vary 
between 30.000 to 60.000 EUR. The costs for making new Energy using Product 
criteria (mandatory and based on a full LCA) would be over 300.000 €. 
An on-going contract will provide co re criteria for 10 product groups (150.000 € 
contract). Under the revised eco-label re gulation, whenever Eco-label criteria are 
being developed GPP criteria will simu ltaneously be developed. The Commission 
will sign a 150.000 € contract to establish GPP criteria for 10 more product groups.  
Provision of legal clarity  
The provision of legal guidance would not  involve any additional costs for the 
Commission. For Member States and public  authorities, it w ould involve some 
training and additional guida nce. Where GPP would be integrated into existing 
public procurement training, there would be no additional costs. 
Recommendation to use GPP when impl ementing EU funded projects, where 
appropriate  
A recommendation to the Memb er States would not imply any additional cost for the 
Commission. It may involve some training a nd additional guidance to be provided by 
the national managing authoritie s of the Structural funds.  
5.2.3. Option 3: Setting of mandatory targets for GPP 
General Benefits of Targets 
Targets would act as a political driver for Member States to step up their efforts in 
the field of GPP, the strength of which would depend on the seriousness with which 
the Member States (and Community Institutions) viewed the targets. Other Options are very likely to have a bigger and more  important impact if complemented by a 
target that generates political support. Targets would be likely to encourage the 
establishment and use of central guidance on GPP, coupled to inte rnal targets and/or 
to political or legal instructions to select ed (or all) regional and local authorities. 
The existence of targets woul d also provide an indication to industry of the likely 
direction of demand for greener products in  coming decades, allowing them to early 
respond to this new dema nd and plan innovation. 
 
EN 34   EN General Costs related to Targets 
A) The costs of Member State action in pr oviding national, regional or local advice 
on GPP. This would be reduced if the Co mmission services provi ded Member States 
with the guidance and practical t ools considered under Option 2.  
B) Costs of putting in place means to mon itor achievement of internal targets, 
responsibility for which would lie with the Member States. This would create 
administrative cost on th e public administration. 
For instance, the Swedish National Action Plan on GPP identifies ambitious 
objectives and proposes a series  of measures to achieve those objectives. The total 
cost of these proposals for th e duration of the th ree-year action plan (2007-2010) is 
estimated at approximately SEK 18 million (approximately €2 million). 
In the Netherlands, costs for implemen ting the action plan which makes GPP 
mandatory for central government and sets a mandatory target of 50 % for all other 
purchasers by 2010 (including costs for esta blishing criteria, communicating the 
policy etc.), amounted in 2006 to approximately € 6 to 7 million. Further, money is spent by the government on subsidies to or ganisations that contribute to the 
implementation (through training for inst ance): some € 5 million over a period of 5 
years. Costs for purchasers to implement GPP (training/monitoring/setting up action 
plans etc.) are considered costs which are inherent to management.  
The cost resulting from monitoring would be  similar whether targets are voluntary or 
mandatory. Those costs could be reduced  by a Commission pr oposal to modify 
Commission Directive on Sta ndard Forms in Public procurement so as to include 
information on environmental criteria in co ntract advice and contract award notices. 
It would also be reduced as the Commission would bear the administrative cost of 
identifying suitable indicators and methods for calculating (details in Section 7).  
Differences in impacts between sub-options 
Sub-Option 3.A) Mandatory targ ets for life cycle costing
 
Benefits 
This sub-option would be likely to lead to political and administrative action in 
Member States to change procurement practices. It would lead to increased 
identification of the real co sts of products and to very significant costs savings for 
public authorities. By making procurers familiar with the concept of looking at resource use during procurement, this w ould be likely to make adoption of GPP 
procedures much easier in future, with a large number of shared  concepts between 
the two systems. It would both directly cut resource use – particularly energy and 
water use – and provide incentives for industry to innovate in these areas. 
The introduction of life cycle costing is likely to promote new business models in 
which products or services are shaped in  such a way as to reduce the whole-life 
costs. The adoption of these practices in the public sector is likely to stimulate their offer and adoption in the wider private sector, as they are seen to be cost-efficient. This in turn has the potential to bring substantial economy wi de cost savings, 
increasing international competitiveness.  
For sectors where mandatory requirements on energy efficiency exist (for instance 
Energy Star Regulation for central government purchases, as well as all product groups that will gradually be covered by th e Energy Using Products Directives), the 
 
EN 35   EN benefits of the proposed option would be re duced as the obligation to take life cycle 
costing into account could be  redundant, due to the fact  that energy efficiency 
requirements achieve the same effect as life cycle costing.  
Costs 
There would be costs resulting from traini ng courses for procurers, in view of 
introducing new procurement procedures in relevant areas. There would also be a 
need for post-purchase testing of products  by authorities to be  extended to the 
resource use characteristics (for  example energy consumption). 
The scale of impacts of such targets is likely to be hugely bigger than the 
administrative costs.  
Sub-Option 3.B): Mandatory targets for basic GPP  
Benefits 
• Create the political obligation for Member States to set up and implement GPP 
policies allowing to achieve targets. It would promote action at both central and 
regional/local level if separate targets were to be set.  
• Promote greater consistency of EU wide  implemented GPP criteria, as targets 
would be linked to the GPP criteria established by the Commission and the 
Member States as under Option 2. Whilst under this option Member States and public authorities would have the flexibi lity to comply with targets by including 
an environmental award criterion not dire ctly linked to the GPP minimum criteria 
provided under Option 2, it is likely to crea te greater similarities than a voluntary 
approach. 
• Stimulate training programmes. 
• Provide a clear signal to industry, indicating both the l ongevity and trend in the 
market for consideration of environmental impacts, reducing the risk of investments in eco-innovation and in creasing the potential rewards. 
• Stimulate, through successful demonstra tion of GPP, greater uptake of green 
procurement practices by the private sector.  
• The faster adoption of environmental im provements in product s through increased 
GPP not only creates a level of performan ce for future years, but allows future 
increases in performance which will bri ng additional environmental benefits. The 
purchase of greener products in the EU is likely to affect supply chains, production and design outside the EU  stimulating the offer of better 
environmental performing products in non-EU countries. 
Costs 
Training costs for GPP would be additi onal to existing training and could be 
integrated into rolling on-goi ng public procurement training.  
Costs of procurement may be significantly lower, as: 
• Member States have the option of mee ting the targets by applying GPP to those 
contracts within the prior ity product groups which are most likely to lead to 
reductions (rather than increas es) in whole-life costs. 
• The definition of "basic" GPP used does not require the purchase of greener goods 
when they are much more expensive as  it would consider to be GPP also 
 
EN 36   EN procurement procedures in which sufficient weighting is given to the 
environmental characteristics (eg. 15 %) of the purchased product. With 
weightings like this, price will still be the main determinant of product selection. 
This may be particularly important in re gions characterised by a relatively small 
market of "green" goods at still more expensive prices.  
Sub-Option 3.C): Mandatory targets for "outcome-based" GPP  
Benefits  
• The impact on political support for GPP ma y be higher in some Member States – 
who see this sub-option as more tightly binding, and therefor e requiring greater 
activity to meet the perceived stricter compliance.  
• The official and binding character of targ ets will allow for easier, more objective 
monitoring and benchmarking.  
• The Comitology procedure would include an impact assessment of each set of 
criteria developed, includi ng trade-offs between any a dditional whole-life costs of 
a product and the environmenta l and economic benefits likely to result from its 
wider uptake. Minimum criteria are unlikely to be put in place where the costs to authorities exceeded the benefits to society.  
• The costs of participation in the com itology procedure are likely to be small 
compared to the economic costs and bene fits of implementation of GPP. The 
discussions for many product groups coul d be based on information gathered 
under other related pr oduct policies.  
• The adoption of minimum GPP criteria in comitology would be likely to ensure 
harmonised GPP across the EU, in full compliance with public procurement 
legislation for those product groups wher e criteria are being developed. Member 
States or purchasing author ities would in any case have the possibility to set 
higher environmental standards or award criteria. 
• Setting clear minimum EU wide standard s for a certain proportion of contracts 
would send a very clear signal to industry on the levels of performance to be met. 
Where applied to large percentages of pur chases, this would be very likely to 
promote innovation, including the knock-on e ffects in promoting green private 
procurement.  
• This stimulus would be re-enforced where targets for GPP in future years were set 
and commitments were given to review th e minimum standards for GPP after a set 
number of years, to reflec t technological progress.  
Costs 
• In some Member States, the obligation to apply precise requirem ents might reduce 
enthusiasm for GPP.  
• The comitology procedure for setting GPP criteria would require agreement of 
Member States to areas and levels of e nvironmental performance. Difficulties in 
reaching agreement accommodating nati onal and industry stakeholder 
considerations may slow the process and lead to a lower common standard being 
adopted than would be adopted where th e minimum standards were not binding. It 
may also lead to practical difficulties for re vising criteria in a way that keeps them 
relevant and useful for the fast-moving product groups. 
 
EN 37   EN • Regional differences might not be we ll picked up in a comitology impact 
assessment and could still lead to cost s exceeding benefits in some regions. 
• The cumbersome GPP criteria setting process may reveal, in the future, 
unnecessary or badly designed, considering the on-going initiatives in the field of 
environmental criteria setting; it may be appropriate to aw ait the outcomes of 
those initiatives before deciding on what t ype of procedure would be best for GPP 
criteria setting or the process may be limited to endorsement of environmental 
criteria developed in other frameworks. 
• The Budgetary autonomy of regional/local au thorities may make it more difficult 
for Member States to implement manda tory targets linked to mandatory GPP 
criteria. 
5.2.4. Option 4: Various forms of mandatory GPP 
Sub-Option 4.A): Mandatory G PP for certain types of purch asing authorities and for 
certain "niche" products  
Benefits 
A 100 % target for central government w ould provide, for the relevant product 
groups, a very clear signal to the market, and have the biggest potential for triggering 
change of the supply side towards ever  better performing products, with strong 
knock-on effects also on private consumption. Benefits are of a similar nature to but 
at the same time expected to be greater pe r product group than th e benefits that can 
be expected to result from Option 3.C) "m andatory targets for outcome-based GPP". 
This Option would be similar to the obligation for central government included in the 
recently adopted Energy Star Regulation, to only buy office equipment complying with energy-efficiency requirements not  less demanding than the Energy Star 
Specifications (described under Option 1) . However, it would focus on other 
products than office equipment covered by the Energy Star Regulation. To estimate 
the benefits of this option, an additional im pact assessment is necessary, to identify 
suitable sectors and estimate the potential benefits. 
Costs 
There would be costs for the Commission or  the Member States related to the 
transposition of a regulatory measure and the monitoring of compliance.  
Considering the 100 % target, the m easure would focus on cost-effective 
procurement, involving no extra costs for pur chasing authorities, taking into account 
whole-life-costing.  
Sub-Option 4.B): Make GPP mandatory for a ll purchases above the thresholds of the 
public procurement directives, by maki ng the environmental award criterion 
mandatory  
Benefits  
This integrated approach would give a very important political signal as it would 
integrate GPP directly into the relevant inte rnal market legislativ e tool. It would draw 
the attention of all purchasers to the importance of integr ating environmental 
concerns into public procurement, even for purchases below the thresholds, because many countries apply the same legislation or  principles also for those procedures.  
 
EN 38   EN In order for it to guarantee those benefits and not lead to unclear and non transparent 
procurement procedures, it would need to be complemented with relevant guidance 
on potential environmental awar d criteria for priority pr oducts and guidance on how 
to specify an environmental award criter ion in the absence of such criteria.  
It would not in all cases lead to the purchase of green goods. 
Costs 
Costs for Member states related to tran sposition and monitoring of compliance. 
It would certainly need to be complement ed with relevant tools and guidance on 
environmental criteria, as described unde r Option 2, including costs as described 
there. In the absence thereof, it ma y lead to non transparent procedures, 
discrimination, reduced competition and increas ed costs for purchasers as a result. 
Such proposal would call for a separate impact assessment. 
Sub-Option 4.C): Make it mandatory to incl ude, for all service and works contracts 
above certain thresholds, a contract perf ormance clause which obliges the winning 
bidder to set up an environmental manageme nt system during the performance of the 
contract  
Benefits 
This option would be expected to consti tute a cost-effective way of reducing the 
environmental impact resulting from important services and works contracts. The biggest environmental impact of such cont racts indeed occurs during its execution 
(use of resources during pe rformance, transportation i ssues, waste management and 
so on). The implementation of an envir onmental management system by the winning 
bidder would ease the burden of verificati on for the purchasing au thority and provide 
additional guarantees as to its complia nce with environmental performance 
standards. It would also help the contra ctor to comply with high environmental 
standards of the contract.  
Costs 
Considering the fact that the obligation w ould only apply to cont racts above a certain 
financial threshold (which could be the current threshold for application of the 
Directive to works contracts, namely 5 m illion €), the costs for the winning company 
to set up and run an environmental manageme nt system can be considered relatively 
small. When added up, the overall costs fo r all winning companies may be relatively 
important though. For a full examination of costs and benefits of implementing an environmental management system, reference can be made to the impact assessment for the on-going revision of the EMAS Regulation on the European Environmental 
Management and Audit Scheme
54. Costs for the Member States related to 
transposition and implementation of modified procurement Directives. 
This proposal would equally cal l for a separate impact assessment, to set appropriate 
thresholds or consider the possibility  of applying a similar obligation to 
subcontractors. 
                                                 
54 Costs for registering under the EMAS scheme basically involve re gistration fees and auditing and 
verification fees (paid to consultants). Registration fees differ per Member State and range from 18€ to 
2234 €. Consulting costs for a medium-size organisation with about 50 employees, are average about 
12.000 €, whereas the cost for verification range from about 500 to 8000 €.  
 
EN 39   EN Sub-Option 4.C): Mandatory GPP for the implementation of EU funded projects  
Benefits 
Making it mandatory to use GPP, wherever appropriate, that is in all cases where 
public authorities are implementing EU funded projects through use of a public 
procurement procedure, would be particular ly effective at initiating the uptake of 
GPP by local authorities, ma in beneficiaries of Structur al funds, who are traditionally 
more difficult to reach in view of rais ing awareness on GPP, providing political 
support, guidance and training. It would ensu re cost effectiveness of an important 
part of the EU budget, meet the requirement s of Article 6 of th e EC Treaty and give 
strong signals to local companies taking part  in the calls for proposals and contracts 
awarded under those Structural Funds. 
Costs 
Current EU rules governing Structural funds  have been adopted late 2006 for the 
period 2007-2013, after 2 years of difficult di scussions. A proposal to modify would 
need to wait the adoption of the new rule s for the next period (2014-…). Discussions 
may start in 2010. This would allow the Comm ission to carry out a separate impact 
assessment. A similar assessment would be made of the possible change in the rules 
for the award of other EU funding mechanisms (such as LIFE +, R&D grants etc.) 
5.2.5. Option 5: Modification of the Commission Di rective on the use of Standard forms in 
public procurement 
Benefits 
Contracting authorities have to make use of these Standard Forms for all contracts 
above the thresholds of the public procur ement Directives. Cont ract advice notices 
are published to invite potential bidders to  request tender documents and submit bids. 
They include information on the selection criteria and on the estimated total value of the contract to be conclude, and may also  include information on the award criteria. 
Contract award notices are published after the award of the cont ract and include 
information on the final total value, cont ractor withheld, award criteria used.  
The Standard forms are used for the coll ection of statistical evidence on number, 
value, type of contracts concluded. The inclusion of environmental information in 
those forms would allow to also collect sta tistical information on this aspect of public 
procurement procedures. This would serious ly reduce the burden of monitoring of 
GPP for both the Commission and the Member  States, the latter being in any case 
legally obliged to report public proc urement statistics to the Commission.  
Costs 
There will be administrative costs for au thorities from the provision of additional 
information in the standard forms. However,  as the use of standard forms is already 
mandatory for contracting authorities and as  Member States are already subject to 
statistical obligations in the field of public procurement, the fact of having to include 
environmental information (for the contracti ng authority) and of having to include in 
the public procurement statistics also in formation on GPP (for the Member States) 
would be the most efficient means of  information provision to monitor the 
implementation of targets for GPP. It woul d involve the transfer of the information 
that they have already pub lished (e.g. on award criteria) into a Standard Forms which 
they already prepare. 
 
EN 40   EN 6. C OMPARING THE OPTIONS  
6.1. Which are the best options for tacklin g the identified specific problems?  
Information and Tools 
For the problems associated with lack of information , policy development has 
focussed on identification of the inform ation that is missing, together with 
consideration of the best form in which it can be supplied. Options 2, 3 and 4 all 
tackle –to a certain extent - the problem of lack of information. Option 2 would 
provide the most complete solution for the ra ised problem on lack of information, as 
it would provide information on costs and benefits, propose GPP criteria, provide 
legal guidance and operationa l guidance which are essentia l building blocks of any 
national GPP strategy and imperative fo r achieving more and better GPP.  
The impact assessment above indicates that the generation and/or publication of 
information about GPP practices and tools to facilitate GPP at lower cost will remove 
or reduce some of the barriers to GPP and would do so at  negligible cost compared to 
the potential benefits of the policy. 
Options 3 and 4 would partially solve the pr oblem of a lack of information, as under 
both options (sub-options 3.B), 3.C) and sub-option 4A)), GPP criteria would be 
recommended or imposed for use in GPP. However, those options would not solve 
the other problems raised regarding legal uncertainty and lack of information on costs and benefits and implementing tools. 
On the other hand, additional information and tools do not appear likely to be 
sufficient to greatly increase uptake of G PP whilst there is a lack of political 
motivation to push GPP uptake. Provision  of greater information about the 
advantages and disadvantages of GPP and di fferent ways to put it into practice could 
have some effect on political support for G PP. Yet, in Member States where there is 
currently little interest in GPP, the provi sion of information is unlikely to have an 
impact, and may go unread. 
Generation of Necessary Political Support  
• Targets 
Mandatory targets appear to complement Option 2 and raise the political support in 
Member States needed for wider uptake of  GPP. There are various alternative sub-
options for the target setting for GPP, each with different advantages and disadvantages, mentioned above.  
For instance, mandatory targets with mi nimum standards set by Comitology would 
be likely to provide clearer, innovation-pr ompting signalling to industry, but might 
lead to lower levels of environmental performance and greater up-front costs of 
implementation in Member States. Targets only for life cycle costing would ensure 
cost savings for authorities, but have co mparatively weak environmental benefits. 
Purely voluntary targets woul d be likely to stimulate so me degree of greater Member 
State activities, but with more mixed stim ulus to innovation and potential friction in 
the internal market.  
Administrative process concerns must also be taken into consideration: For instance, 
a lack of mandatory use of criteria may make the informal process of co-operation 
proposed for criteria setting more succe ssful by reducing strategic behaviour, though 
on the other hand may reduce the incen tives for parties to co-operate.  
 
EN 41   EN The analysis of sub-options indicates that  all would bring net benefits and that 
therefore targets should be proposed. Ho wever, the evidence gathered up to now 
does not indicate which form of targets would maximise net benefits and therefore no recommendation is made on the adoption of mandatory targets. Greater investigation 
of the impacts of options for mandatory targets in the form of a separate legislative 
instrument is needed, that includes mark et analysis of rele vant product groups, 
performance levels and whole-life-costs.  
Therefore, whilst acknowledging the importa nce and usefulness of  setting mandatory 
targets, an additional impact assessment will be carried out in order to identify the most appropriate sub-option(s) , if any. In the meantime, quantification of the existing 
renewed SDS Strategy GPP target in a Commission Communication, as proposed 
under Option 2, may prove helpful as a cost -effective way of triggering political 
support.  
• Mandatory GPP 
As an alternative or in addition to mandato ry targets, Option 4 provides 4 alternative 
regulatory sub-options also aimed at raising political support for GPP. Additional 
impact assessment is needed to determin e whether one or more of these options 
could be complementary/a suitable alte rnative to mandatory GPP targets.  
Mandatory GPP for central governm ent for certain product groups 
Option 4.A): Whilst such approach would yiel d the best results in terms of triggering 
market transformation and continuous im provement towards better performing 
products, it would be limited in coverage. Additional impact assessment is being carried out to estimate its cost-e ffectiveness for any product group.  
Modification of public procurement Directives 
Option 4.B), 4C) and 4D) would in any case need to be complemented with relevant 
tools and guidance on environmental criter ia, as described under Option 2, including 
costs as described there. In the absence thereof, it may lead to non transparent 
procedures which could re sult in discrimi nation and reduced competition and 
increased costs for purchasers as a re sult of this. As regards option 4 C) on 
mandatory implementation of environmental management systems, it would be useful to examine the feasibility of applyi ng such obligation also  to subcontractors. 
Option 4 D) would imply a change of the EU rules governing structural funds. The 
Commission will further examine costs and benefits of those options before making a proposal, examining both subsidiarity and administrative burden. 
Modification of a Commission Directive on Standard forms for use in public 
procurement 
Option 5 is a stand-alone option which is co mplementary to all other options, as it 
seeks to facilitate the monitoring of GPP fo r procedures above th e thresholds of the 
Public procurement Directives. Appropriate monitoring is a pre-condition to any form of political target setting and an incentive for implementation. The Commission 
proposes to carry out an additional impact assessment to assess whether to develop this option into an appropriate proposal. 
 
EN 42   EN 7. M ONITORING AND EVALUATION  
7.1. Establish suitable indicators  and methods for calculating  
To identify the baseline of the renewed SDS target, according to which the average 
level of GPP in the EU should, by 2010, be at  the (2006) level of the best performing 
Member States, it's necessary to measure the level of GPP in 2006 in the best performing Member States.  
The "level of GPP" can be assessed through several types of indicators.  
Process-oriented indicators allow to assess for instance whether a national GPP 
policy has been established, whether guidan ce exists, whether and what sources of 
GPP criteria exist, levels of GPP training.  The Commission will regularly calculate 
those indicators, through contacts  with national GPP experts.  
Quantitative indicators allow to assess uptake and progress of the policy, by 
comparing the level of GPP (expressed in numbers and value of Green tendering procedures) to the overall leve l of public procurement. To assess also the effective 
impact on the supply side, the Commission proposes to calculate in addition the 
value of green contracts concluded as co mpared to the overa ll value of public 
procurement contracts. 
The Commission will establish a statistical  method for calculating those indicators. 
To guarantee uniform monitoring and be nchmarking, the monitoring exercise will 
focus on the priority product groups and corresponding core GPP criteria referred to 
under Option 3.  
Impact-oriented indicators allow to assess the environmental and financial gains 
delivered by GPP. An example of such  indicator would be "the estimated 
environmental (and financial) benefit of  a purchase of a certain "green" product 
volume, as compared to the purchase of  a similar "neutral" product volume. The 
Commission will develop such indicators an d integrate them in the monitoring 
exercise. 
7.2. Core indicators 
• Raise political profile of  GPP - Indicator :  
– number of action plans/strategies  adopted and implemented by 2010.  
• Raise, by 2010, the average level of GPP in the EU to the current level of best 
performing Member States – Indicators: 
– number and value of "green" tendering pr ocedures as compared to total number 
and value of tendering procedures 
– value of green contracts as compar ed to total value of contracts  
7.3. Additional indicators relate d to Operational objectives 
• Improve quality of GPP –Indicators :  
– number of product groups covered by GPP criteria 
– number of tenders compliant with public  procurement legislation, resulting from 
revision of the situation in 2010  
 
EN 43   EN 7.4. Monitoring by the EC  
The EC will monitor the situation in the best performing Member States in 2008 
(based on 2006 figures so as to establish the baseline of the renewed SDS target). 
The Commission will monitor the situation in the whole EU 27 in 2010, on the basis 
of the indicator(s) and appropriate calcu lation methods (under development). As the 
EC monitor would take as a reference G PP procedures which are compliant with 
recommended GPP criteria, Member States  should be encourag ed to apply those 
GPP criteria in their respective countries. This would ease the administrative burden for Member States, who will thus be ab le to focus on guidance and training. 
 
EN 44   EN ANNEX 1: STUDIES AND BACKGROUND DOCUMENTS CONSULTED  
Most relevant studies and background papers are:  
– TAKE-5 study carried out for the Commission in 2005-2006 and aimed at measuring the 
state of play of GPP in the EU and analysin g barriers for further uptake of GPP, final 
report August 2006 at http://ec.europa.eu/envi ronment/gpp/studies_en.htm  
– "Procuring the Future, the Sustainable procur ement Task Force National Action Plan" and 
its underlying studies, launche d 12 June 2006 to give advice to  the public sector on how it 
can be amongst the EU leaders in Sustaina ble Procurement by 2009, more information at 
http://www.sustainable-development.gov.uk/government/task-
forces/procurement/index.htm  
– 2003 OECD Report "the Environmental Performance of Public Procurement": 
http://www.oecd.org/document/21/0,3343,fr_2649_34487_37414933_1_1_1_1,00.html  
– Report on "Costs and Benefits of Green Public  Procurement in Europe", Öko-Institut and 
Iclei, final report July 2007; http://ec.europa.eu/envi ronment/gpp/index_en.htm . 
ANNEX 2 : STAKEHOLDER  CONSULTATION  : SUMMARY  
The TAKE-5 study has been drafted in clos e cooperation with Commission services and 
interested parties, in particular Member Stat e representatives. In a first stage, the Study 
proposed to develop a GPP definition. Stakehol ders have been involved throughout the study. 
A workshop was organised in October 2005 by the UK Department for Environment, Food 
and Rural Affairs (Defra), to co llect the opinions of representativ es of the Member States and 
other stakeholders on the inte rmediary report of the TAKE-5 Study. All recognised the need 
for improvement of the situation, through national guidelines and action plans. The 
intermediary report of the TAKE-5 Study was ap proved as a good basis for future actions and 
policies, although it was rec ognized that it could ha ve given a too positive view of the level of 
GPP in the EU, due to the risk of  biased answers to the questionna ire and to the fact that, even 
in the case of established GPP, the identified "green" criteria were often not clear or not ambitious enough. All stakeholders furthermore rec ognized the particular role for the EU to 
provide coherent and easily a ccessible information, enable ne tworking and exchange of good 
practices, gather evidence on environmental a nd economic benefits of GPP, hold regular 
benchmarking exercises on the ba sis of tender analysis and i nvolve the supply side. As 
regards the identified priority sectors, thos e have been establishe d on the basis of the 
measurements carried out in the framework of  the study, experience, practical know-how and 
analysis of the Take-5 Consortium, taking into account the environmenta l impact of greening, 
the availability of green versions of these pr oducts in the market, the available examples.  
A stakeholder meeting was organised on 25 June 2007, based on a background document 
proposing a definition of GPP (not only outcome based but covering also procedures 
including green award criteria), a list of priority product and service groups and listing main 
options for improvement, including the volunta ry and mandatory measures subject of the 
current impact assessment. The document was sent out to the "Green public procurement expert group", gathering over 80 Member States re presentatives in the field of GPP, as well as 
to the European Union Eco-labelling Board ga thering the competent bodies of the Member 
States responsible for eco-label issues as well as relevant stakeholders (representatives from 
industry, suppliers, civil soci ety, ngo's) and to a list of other potentially interested 
stakeholders, in particular from forestry a nd paper sector, Food industry, Textiles industry, 
 
EN 45   EN Packaging industry, IT industr y, Plastics industry, SMEs. Th e members of the Advisory 
Committee on public procurement have also been consulted in writing.  
The web-based consultation on the proposed Su stainable Production an d Consumption Action 
Plan (closed 23/09/2007) also included some qu estions as to the possi bility of making GPP 
mandatory, by setting an overall target  or focussing on specific sectors 
(http://ec.europa.eu/ enterprise/environment/sip_en.htm).  
In summary, the idea of setting voluntary G PP criteria was well received, subject to 
• Need to involve industry at an early stage of the criteria setting process 
• LCA approach 
• Product specific approach, rather  than materials (wood sector) 
• Call for simplicity of tender documents 
• Co-ordination with other EC initiatives 
• Call for more guidance on LCC 
• Strong call for more legal clar ity, in particular as regard s procurement of legal and 
sustainably harvested wood/wood products 
More specific comments by stakeholders and Member States: 
Construction sector  
– "construction" cannot be consid ered a product group as such 
– Need for taking into account lo cal and climatic differences 
– Points at useful on-going standardisation procedures concerning the environmental 
performance of buildings and construction products 
– Focus on energy efficiency and LCC – allow "green" variants to stimulate innovation  
– Need for training on LCA and LCC 
– Opposed to additional third- party certifica tion schemes  
– Would consider modification of public procurem ent directives to impose in all cases award 
of contracts on the basis of the economica lly most advantageous (as opposed to the 
cheapest) offer, including LCC and energy effici ency, and to require c ontracting authorities 
to accept variants in all cases (where  relevant), to stimulate innovation 
Food and Drink industry 
– Organic Food Regulation only c onsiders environmental impact on Agriculture; there is a 
need to also consider social and economic criteria and health issues 
American Forest and Paper Association 
– Need to consider equivalent environm ental standards and verification methods 
– Concern over inclusion of CO² criteria for paper and wood which my be inconsistent with 
WTO 
– Supports a neutral approach towards various mentioned certification schemes (to assure 
compliance with WTO) 
– Recommends work of UK's Central Poin t of Expertise on Timber (CPET)  
 
EN 46   EN CEPI 
– welcomes a harmonised EU wide approach 
– GPP criteria to be set for all products made from wood, ranging from paper to bio-energy, 
as well as for competing products 
– Insists on a "risk based" approach and not a "proof all" approach  
– Strong call for more legal clarity on the us e of production process related criteria, raw 
material criteria, social crit eria, on the use of EMS in criteria-setting, on the way to use 
references to ecolabels, certification systems and third party verification  
– Opposed to GPP award criteria (prefe rs minimum technical specifications) 
CITPA : International Confederatio n of Paper and Board Converters 
– Packaging would be inappropriate for GPP : combining an assessment of the product and 
the packaging is complex and could lead to mi sconceptions, if to be included, need to base 
itself on full LCA or require verification th at packaging conforms to the essential 
requirements of the Packaging a nd Packaging Waste directive  
Finnish Forest Industries Federation 
– EU guidelines should be general; detaile d instructions are country specific 
– Avoid discrimination (for instance in terms of fo rest certification)  
Plastics Industry  
– Favours voluntary GPP approach but with mandatory GPP crit eria and "result based" 
definition of GPP  
– Use of plastics in construction, food and transport can save energy 
– GPP to be based on all three pillars : economic, social and environmental 
PROMPTEX (Fédération européenne pour la prom otion des machés publics – Textile et Cuir) 
Satisfied with the inclusion of "clothing and textiles" amongst the priority groups for which 
GPP criteria will be identified. Giving examples is absolutely necessary.  
EUAPME 
– Is opposed to GPP if to lead to additional ad ministrative burdens for SMEs (to provide for 
instance complex life-cycle calculat ions or expensive certificates) 
– Is opposed to inclusion of full life-cycle- assessment into the definition of GPP 
– Prioritisation should take in to account impact on SMEs 
– Difficulty to continuous update GPP criteria 
– Opposed to recommended use of national databases 
– Prefers minimum environmental technical  specifications over award criteria  
– Opposed to additional third- party certification schemes; recommends use of EPDs  
UNIEP(International Federation of Pa inting and Decoratin g Associations) 
– Raises potential difficulties for SMEs 
– Avoid linking GPP to the genera l activities of a company, as this would adversely affect 
SMES 
 
EN 47   EN – Life-cycle certificates are not appropri ate in relation to the services sector 
– Favours voluntary promotion of environm ental standards by business over GPP 
Finland 
– Calls for greater legal clarity 
– In the field of wood products, one cannot allow only certified wood; fu rther examination of 
this issue needed, involving all market players  
France  
Against the inclusion of "medical devices" as a priority group, too sector specific 
Hungary 
The Environment Ministry welcomes proposal , but proposes to exclude the notion of 
"utilities" in the definition 
The Economy and Finance Ministry considers that concrete legal obligations in the field of 
GPP would increase the efficien cy of the policy. The Ministry further ag rees with proposed 
selection of priority sectors and welcomes the process for identifying GPP criteria. As regards 
monitoring, the Ministry would support a modi fication of the Standard forms for public 
procurement. The Ministry welcomes the addi tional guidance proposed. The Ministry agrees 
with differentiated and gradually implemented voluntary targets for central and local/regional 
government. However, when setting targets, account  would need to be taken of the fact that 
GPP may imply some additional burdens, which w ould weigh in particular  in Member States 
with less advanced economies.  
Italy 
– Suggests to raise political profile by linking GPP to financial support schemes  
– Co-operation with the Member States to be  based on efficient working methods, involving 
stakeholders 
– Opposed to the inclusion of  medical devices amongst the "priority" groups; could be 
replaced waste management or  urban management services 
Slovak Republic 
– need to clarify EU funding possi bilities for implementing GPP 
– welcomes work on a uniform methodology for monitoring GPP 
– questions effectiveness of a voluntary approach 
UK 
– Proposes to replace, in the definition, the not ion of "public/semi-pub lic authorities" by 
"contracting authorities" 
– Unnecessary to keep as a minimum 'beyond legal requirement', because some Member 
States may have very rest rictive legal requirements; 
– Asks for clarification of the reasons for c hoosing the proposed definition and the reason for 
rejecting the earlie r "outcome based" definition agr eed upon in the framework of the 
"Take-5" study 
– Would favour a structured pro cess of championing best practice 
 
EN 48   EN – GPP criteria to be based on cost/benefits ev idence and broad stakeholder consultation, 
linked to other EU policies, and to ensure le gal compliance – leaving it up to the Member 
States to mandate their use – draws the attention to several risks resulting from using complex ecolabel criteria not original ly drafted for the purpose of GPP 
– Offers to share experience, in particular as regards timber procurement, as there is a clear 
need to agree on minimum standards for this  commodity and assist Member States in 
adopting harmonized policies 
– Welcomes examples of GPP criteria for 4 product 
– Services may call for a different, case-by-case approach 
– Welcomes co-operation with Member States 
– Welcomes the quantification of the SDS target  but does not see a need to differentiate 
between central government and local government  nor to set targets for different product 
groups – Member States should be encouraged to set their own targets enabling them to 
contribute to the EU target 
– Welcomes EU activity to benchmark performance and champion best practice 
– Proposes to develop impact related indicato rs (for example educed CO2 emissions from 
the government estate); notion of "benchmarks" preferred over "targets" to underline 
voluntary character and allo w assessment of progress 
– Potential administrative burde n due to data collection; 
– Welcomes policy coherence 
– Welcomes economic and legal guidance on bounda ry issues 
Romania 
– welcomes the proposal, consider ing however that a regulatory  approach would yield better 
results  
– welcomes idea of giving examples of GPP crite ria Agrees with proposed indicators raises 
the need to address the issue of verification of compliance  
ANNEX
 3 – INTERNATIONAL ASPECTS  
A Government Procurement Agreement  (GPA) has been signed in the framework of the 
World Trade Organisation (WTO). It is a so-cal led plurilateral agreement, characterised by a 
narrower group of signatories than general WTO agreements. 
The GPA itself does not contain any reference to environmental protection. However, the 
Sixth Recital of the Preamble to  the WTO Agreement recognises th e need to act in accordance 
with the principle of sustainable development and to protect and preserve the environment. 
Therefore, it is broadly accepted that the GPA allows contracting entities to take into account 
environmental considerations when defining te chnical specifications (including process and 
production methods) and selection and award criteria, on condition that they are not 
discriminatory, and are sufficien tly objective and verifiable.  
One sector with particular international relevan ce is the wood sector. In this sector, frequent 
use is made of international con cepts of "legality" a nd "sustainability" a nd of many, slightly 
differing, international certification schemes attes ting the legal and/or sust ainable origin of the 
 
EN 49   EN harvested wood. In relation to this  sector, it needs to be clarifie d whether and to what extent 
the concepts of "legality" and "sustainability" can be used to define GPP criteria and which types of proof or certification can be asked from bidders to attest compliance with those 
criteria. Many different international certification schemes exist and clarity needs to be created as to the potential reference to those schemes in the field of GPP. The EU Forestry 
Action Plan adopted in 2006 foresees as one of  its actions co-operation and exchange of 
information between Member States in view of reducing market distortions due to preference 
given to different types of certification sche mes by different Member States. The notion of 
sustainable harvesting basically refers to complia nce with environmental and social aspects of 
the harvesting process, wh ereas the notion of legality refers  to compliance with elements of 
national legislation during harvesting. Insofar as national legislation may also include 
environmental and social aspects, both concepts can be overlapping; they are both used in the 
field of Green and/or sustainabl e public procurement. In relati on to the concept if "legality", 
account needs to be taken of  the EU FLEGT action plan  (Forest Law Enforcement 
Governance and Trade) which seeks to reduce the importation of illegally harvested wood (tropical wood) in the EU, by concluding bilatera l agreements with developing countries. If 
public authorities in the EU are increasingly buying lega lly logged wood, this may be an 
important incentive for trader partner countries to sign those agreements.  
Another international issue is the fact that G PP may have the effect of making market access 
more difficult for products from developing countries, which are le ss inclined to comply with 
certain environmental standards. However, this e ffect may be mitigated by the fact that, at an 
international level, the Marrakech Task for ce on Sustainable Procurement seeks to develop 
and implement a training toolkit on SPP in 12 to 14 developing countries, with the aim of 
drawing conclusions for further uptake and disse mination in more developing countries at the 
WSD in 2010 (more information at: http://marrakech.taskf orces.ewindows.eu.org/
).