Special  Report How do the EU 
institutions and bodies 
calculate, reduce and 
offset their greenhouse 
gas emissions? EN 2014  NO 14
EUROPEAN
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Luxembourg:  Publications  Office  of the European  Union,  2014
ISBN  978-92-872-0862-0
doi: 10.2865/66560
© European  Union,  2014
Reproduction  is authorised  provided  the source  is acknowledged.
Printed in Luxembourg
EN 2014  NO 14
Special  Report How do the EU 
institutions and bodies 
calculate, reduce and 
offset their greenhouse 
gas emissions? 
(pursuant to Article 287(4), second subparagraph, TFEU )
02
 Contents
Paragraph
 Glossary
I–VII  Executive summary
1–7 Introduction
1–2 European Union policy on the environment aims at a high level of protection
3–4 Preventing dangerous climate change is a priority of the European Union
5–7 Public administrations play an important role in achieving climate targets
8 –11  Audit scope and approach
12–101  Observations
12– 61  The EU institutions and bodies have no common policies to monitor and mitigate  
their greenhouse gas emissions
12–29  The full carbon footprint of the EU institutions and bodies is not known and the patchy  
information available risks undermining the credibility of reporting
30–43  Evidence that emissions caused by EU institutions and bodies as a whole have been falling  
exists but only related to energy consumption in buildings
44–51  More than half of the audited EU institutions and bodies had not set any quantified targets  
for reducing their emissions and only two had quantified targets for 2020
52–61  Offsetting to compensate residual emissions is used to a limited extent and  
the EU institutions and bodies do not have a common approach
62–101  The EU institutions and bodies do not make full use of the environmental  
management tools promoted by the Commission
62–76  Progress in introducing the eco‑management and audit scheme EMAS is slow
77–89  Green procurement is an option rather than an obligation under the current rules  
and only a few used it systematically
90–101  Green building standards for energy performance are not systematically used for  
new buildings and major renovation projects
03 Contents
102–114  Conclusions and recommendations
 Annex  — Audit approach for assessing green public procurement
 Replies of
 — the European Council and the Council of the European Union
 — the European Commission
 — the Court of Justice of the European Union
 — the European Central Bank
 — the European Court of Auditors
 — the European External Action Service
 — the European Economic and Social Committee and the Committee of  
 the  Regions of the European Union
 — the European Investment Bank
 — the European Aviation Safety Agency
 — the European Environment Agency
 — the European Medicines Agency
 —  the Office for Harmonization in the Internal Market (Trade Marks and  
Designs)
04
 Glossary
Carbon dioxide (CO2): A naturally occurring gas and also a by‑product of burning fossil fuels such as oil, gas and 
coal, biomass burning, land ‑use changes and industrial processes (e.g. cement production). It is the principal 
anthropogenic greenhouse gas and the reference gas against which the impact of other greenhouse gases is 
measured.
Carbon footprint : A term used popularly to refer to the overall quantity of CO2 and other greenhouse gas emissions 
caused directly and indirectly by a product or an activity, or associated with the activities of an individual or an 
organisation. No mandatory EU rules exist for calculating carbon footprints.
Carbon neutrality : A state where net carbon emissions related to a product or activity equals zero once offsetting 
has taken place for emissions which could not be avoided.
Climate change : According to the United Nations Framework Convention on Climate Change, this means a change 
of climate which is attributed directly or indirectly to human activity that alters the composition of the global 
atmosphere and which is in addition to natural climate variability observed over comparable time periods.
CO2 equivalent (CO2e): A universal unit of measurement for emissions of greenhouse gases, reflecting their 
differing global warming potential.
EMAS : The voluntary eco‑management and audit scheme of the European Union. This scheme is compatible with 
ISO 14001 but goes beyond it in terms of requirements to be met.
Energy efficiency : Something is more energy efficient if it delivers more for the same energy input, or the same for 
less energy input. Improving energy efficiency is a way of reducing energy consumption or restraining growth in 
energy consumption.
Energy from renewable sources : Defined in Directive 2009/28/EC on the promotion of the use of energy from 
renewable sources as energy from non‑fossil sources, namely wind, solar, aerothermal, geothermal, hydrothermal 
and ocean energy, hydropower, biomass, landfill gas, sewage treatment plant gas and biogases.
European Code of Conduct for Energy Efficiency in Data Centres : A voluntary code of conduct promoted by 
the European Commission to deal with energy consumption in data centres and the need to reduce the related 
environmental, economic and energy ‑supply security impacts.
Full ‑time equivalent (FTE) : A unit to measure the number of persons in a way that makes them comparable 
although they may work a different number of hours per week.
GHG Protocol : A widely used voluntary accounting and reporting standard for greenhouse gas emissions, 
which has been developed by the GHG Protocol Initiative. This initiative is a multi‑stakeholder partnership 
of businesses, non‑governmental organisations, governments and others convened by the World Resources 
Institute, a Washington‑based environmental NGO, and the World Business Council for Sustainable Development, 
a Geneva‑based coalition of international companies.
Global warming potential (GWP) : This defines the impact a greenhouse gas will have on global warming over 
a time period as compared to the impact of carbon dioxide.
05 Glossary
GreenBuilding programme (GBP) : A voluntary European Commission programme to support cost‑effective 
measures for improving energy efficiency and introducing renewable energy sources in non‑residential buildings.
Green public procurement (GPP) : A process whereby public authorities seek to procure goods, services and works 
with a reduced environmental impact throughout their life cycles when compared to goods, services and works 
with the same primary function that would otherwise be procured.
Green public procurement (GPP) toolkit : Practical guidance provided by the European Commission’s 
Directorate‑General for the Environment on how to include green requirements in tender documents as part of the 
technical specifications, of the selection and/or award criteria and of performance clauses.
Greenhouse effect : The build‑up of heat in the atmosphere near the earth’s surface (troposphere) caused by 
greenhouse gases. Just as the glass walls in a greenhouse increase the temperature of the air inside, the greenhouse 
effect warms the surface of the planet. Without the natural greenhouse effect, the temperature would be below 
freezing point. However, human activities have greatly intensified the natural greenhouse effect, causing global 
warming and triggering climate change.
Greenhouse gases (GHG) : Carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O) and hydrofluorocarbons (HFCs) 
are examples of greenhouse gases whose absorption of solar radiation is responsible for the greenhouse effect. 
Taking into account their differing global warming potential greenhouse gas emissions are usually calculated and 
reported in carbon dioxide equivalents (CO2e).
ISO 14001 : This standard, developed by the International Organisation for Standardisation sets out the criteria for 
an environmental management system and can be certified to. It does not dictate requirements for environmental 
performance, but maps out a framework that a company or organisation can follow to set up an effective 
environmental management system.
Leakage : The portion of cuts in greenhouse gas emissions in countries trying to meet mandatory limits that may 
reappear in other countries not bound by such limits. For example, companies may shift production from developed 
countries to developing countries to escape restrictions on emissions.
Mitigation : Efforts to reduce the emissions or enhance the sinks of greenhouse gases. Examples include using 
fossil fuels more efficiently, switching to energy from renewable sources, improving the insulation of buildings and 
expanding sinks such as forests to remove greater amounts of carbon dioxide from the atmosphere.
06 Glossary
Nearly zero ‑energy building : Defined in the Directive 2010/31/EU on the energy performance of buildings as 
a building that has a very high energy performance. The nearly zero or very low amount of energy required should 
be covered, to a very significant extent, by energy from renewable sources, including energy from renewable 
sources produced on‑site or nearby.
Offsetting : Carbon offsetting is a mechanism whereby individuals or organisations compensate for their own GHG 
emissions or for a part of them by paying for an equivalent GHG saving made elsewhere in the world, e.g. emissions 
savings made through wind farms that replace coal‑fired power plants. Offsets are calculated relative to a baseline 
that represents a hypothetical scenario for what emissions would have been in the absence of the mitigation 
project that generates the offsets.
Organisation environmental footprint (OEF) method : A method recommended by the European Commission for 
measuring and communicating the life ‑cycle environmental performance of an organisation. It includes reporting 
on greenhouse gas emissions but is not limited to this.
Sustainable development : According to the 1987 ‘Brundlandt report’ for the General Assembly of the United 
Nations sustainable development is development that meets the needs of the present without compromising the 
ability of future generations to meet their own needs.
Upstream emissions : According to the GHG Protocol upstream emissions are indirect GHG emissions related to 
purchased or acquired goods and services. They occur up to the point of receipt by the reporting organisation and 
are therefore also referred to as ‘cradle‑to‑gate’ emissions.
07
I
For the European Union’s climate policy to be cred ‑
ible, the EU institutions and bodies need to be at the 
cutting edge in designing and implementing policies 
for reducing their greenhouse gas emissions (‘carbon 
footprint’) as public administrations. After 2005, the 
EU institutions and bodies managed to reverse the 
trend of increasing emissions related to their build ‑
ings. However, they missed the opportunity to draw 
up and implement a common policy for contributing 
to the Union’s 2020 goal of reducing emissions by 
20 % below the level of 1990.
II
Six of the 15 audited EU institutions and bodies did 
not report their emissions in 2012 and those doing so 
did not calculate or disclose the full extent of these 
emissions. Consequently, the full carbon footprint is 
not known and the patchy information available risks 
undermining the credibility of reporting and mitiga ‑
tion efforts.
III
Evidence that emissions caused by EU institutions and 
bodies as a whole have been falling exists only for 
energy consumption in buildings. Data available on 
other emissions, notably those caused by mobility, do 
not allow a clear trend to be identified.
IV
The overall reductions achieved so far are largely 
attributable to the purchase of electricity generated 
from renewable sources, which counts as a zero emis ‑
sion in carbon footprint calculations.V
The EU institutions and bodies do not make full use of 
the environmental management tools promoted by 
the Commission. Progress in introducing the Euro ‑
pean eco‑management and audit scheme (EMAS) is 
slow. EMAS registration for public administrations has 
been possible since 2001 and in June 2014 seven of 
the 15 audited EU institutions and bodies had been 
registered. Green procurement is treated as an option 
rather than an obligation and only a few institutions 
and bodies used it systematically.
VI
The upcoming EU 2030 target for reducing green ‑
house gas emissions provides the EU institutions and 
bodies with a new opportunity to develop and imple ‑
ment a common policy.
VII
The Court recommends that the Commission propose 
a common policy for reducing the carbon footprint of 
the EU institutions and bodies. Such a policy should 
include a quantified overall reduction target for green ‑
house gas emissions for the year 2030. EU institutions 
and bodies should:
(a) introduce a harmonised approach for reporting 
their emissions, also including all relevant indirect 
emissions;
(b) develop a common approach to compensate on 
a voluntary basis for those greenhouse gas emis ‑
sions which they cannot avoid;
(c) make full use of the environmental management 
tools promoted by the Commission, in particular 
as regards green public procurement.Executive  
summary
08
 Introduction
European Union policy on 
the environment aims at 
a high level of protection
01 
Article 11 of the Treaty on the Func ‑
tioning of the European Union (TFEU) 
provides that environmental protec ‑
tion requirements must be integrated 
into the definition and implemen ‑
tation of the Union’s policies and 
activities, in particular with a view to 
promoting sustainable development.
02 
Union policy on the environment aims 
at a high level of protection. It is based 
on the precautionary principle and on 
the principles that preventive action 
should be taken, that environmental 
damage should as a priority be recti ‑
fied at source and that the polluter 
should pay1.
Preventing dangerous 
climate change is a prior ‑
ity of the European Union
03 
For 2020, the EU has made a firm com ‑
mitment2 to achieve at least a 20 % 
reduction in its greenhouse gas (GHG) 
emissions compared to 19903.
04 
For 2030, the European Commission 
has proposed to set a GHG emission 
reduction target for domestic EU emis ‑
sions of 40 % relative to emissions in 
19904. The European Parliament has 
called for a reduction of at least 40 %5.Public administrations 
play an important role in 
achieving climate targets
05 
The two most important sources of 
GHG emissions in Europe are energy 
production through fuel combustion 
and transport6. Public administrations 
at all levels can influence the magni ‑
tude of these and other emissions by 
changing the way in which they oper ‑
ate. Through public procurement, they 
can promote environmentally sustain ‑
able solutions for the works, goods 
and services needed.
06 
For EU climate policy to be credible, it 
is important that the EU institutions, 
bodies, offices and agencies (here ‑
after referred to as ‘EU institutions 
and bodies’) lead by example and are 
at the cutting edge in designing and 
implementing strategies for mitigating 
the carbon footprint of public adminis ‑
trations. Box 1  provides some informa ‑
tion on how an organisation’s carbon 
footprint is calculated.
07 
In the light of the principles laid down 
in the Treaty, there are two comple ‑
mentary ways to mitigate the impact 
of the GHG emissions of the EU institu ‑
tions and bodies on the environment:
(a) as a priority, by reducing those 
emissions;
(b) by compensating for residual emis ‑
sions through offsetting.1 See Article 191 TFEU.
2 See Presidency conclusions of 
the European Council of 
8/9 March 2007, paragraph 32.
3 The European Council has 
offered to increase this 
commitment to an absolute 
emission reduction of 30 % if 
other major economies agree 
to undertake their fair share of 
a global emissions reduction 
effort.
4 COM(2014) 15 final of 
22 January 2014 — A policy 
framework for climate and 
energy in the period from 
2020  to 2030.
5 European Parliament 
resolution of 5 February 2014 
on a 2030 framework for 
climate and energy policies 
(2013/2135(INI)).
6 Eurostat pocketbook, Energy, 
transport and environment 
indicators , 2013 edition.
09 Introduction
Calculating an organisation’s carbon footprint
The carbon footprint corresponds to the overall quantity of greenhouse gas (GHG) emissions associated 
directly and indirectly with the activities of an organisation. Sources of these emissions are, for example, elec ‑
tricity production in power plants, heating with fossil fuels and transport operations.
Greenhouse gases such as carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O) and hydrofluorocarbons 
(HFCs) have differing global warming potentials. For example, 1 tonne of methane is equivalent to 25 tonnes 
of CO2. To take this into account, the quantity of each gas emitted is translated into carbon dioxide equivalents 
(CO2e), so that the total impact from all sources can be aggregated to one figure.
The widely used GHG Protocol distinguishes between three categories of emission sources (‘scopes’). The 
diagram below shows some sources most relevant to public administrations.
Initially the organisations’ reporting focus was on scope 1 and 2 emissions. Increasingly, however, scope 3 
emissions are also being taken into account in order to comprehensively manage GHG‑related risks and 
opportunities.
Source:  European Court of Auditors.Box 1
Greenhouse gases
Scope 1 — direct emissions Scope 2 — indirect emissions Scope 3 — indirect emissions
Own fuel combustion
Owned vehiclesPurchase of electricity
Urban heating and coolingCommuting
Business travel
Supplies and services
Fixed assets
10
 Audit scope  
and approach
08 
All EU institutions and bodies with 
more than 500 staff in 2012 were 
included in the scope of the audit. In 
addition, the European Environment 
Agency was included because of its 
specific tasks directly related to the 
audit topic. Table 1  lists the 15 EU 
institutions and bodies covered by 
the audit. For the purpose of the audit 
the European Council and the Council 
of the European Union (hereinafter 
also referred to as ‘the Council’) were 
treated as a single entity because the 
European Council does not have a sec ‑
retariat of its own but is assisted by 
the General Secretariat of the Council. 
Likewise, the European Economic and 
Social Committee and the Commit ‑
tee of the Regions (hereinafter also 
referred to as ‘the Committees’) were 
treated as a single entity because 
they share their buildings, logistics 
and translation services and manage 
them jointly. The audit paid particular 
attention to the European Commission 
not only because of its size but also 
because of its role as the EU institution 
which holds the power of legislative 
initiative.
09 
The Court’s audit assessed whether the 
EU institutions and bodies had policies 
to reduce the impact of their admin ‑
istrative operations on the environ ‑
ment and whether these policies were 
implemented effectively. The Court 
examined whether the EU institutions 
and bodies:
(a) calculated their greenhouse 
gas emissions, reduced those 
emissions and compensated 
for re  sidual emissions through 
offsetting;
(b) made full use of the environmen ‑
tal management tools promoted 
by the Commission to reduce 
emissions.10 
The audit was based on questionnaires 
and interviews and an analysis of 
documents and statistics published or 
made available by the audited EU insti ‑
tutions and bodies. It also included an 
examination of a sample of procure ‑
ment procedures.
11 
The audit was not a carbon audit, i.e. 
the objective was not to perform or 
re‑perform the calculation of the CO2 
emissions of the audited EU institu ‑
tions and bodies or to verify the ac ‑
curacy of the underlying data. Unless 
otherwise indicated, data quoted in 
this report refer to the year 2012.
11 Audit scope and approach Table 1The 15 EU institutions and bodies covered by the audit
Number of posts in  
establishment plan for 2012
(2014)Locations
European Commission25 065  
(24 901)Brussels, Luxembourg, Ispra, Geel, Karlsruhe, Petten, Seville, 
Grange, representations in Member States
European Parliament6 684  
(6 773)Brussels, Luxembourg, Strasbourg, information offices in Member 
States
European Council13 153  
(3 101)Brussels
Council of the European Union Brussels, Luxembourg
European Investment Bank2 2 1853 
(2 369)3 Luxembourg
Court of Justice of the European Union1 952  
(1 991)Luxembourg
European External Action Service1 670  
(1 661)Brussels4
European Central Bank1 448  
(2 602)Frankfurt am Main
European Economic and Social Committee51 255  
(1 252)BrusselsCommittee of the Regions of the European Union5
European Court of Auditors6 887 
(882)Luxembourg
Office for Harmonization in the Internal Market775 
(861)Alicante
European Aviation Safety Agency634 
(685)Cologne
European Medicines Agency590 
(599)London
European Environment Agency136 
(135)Copenhagen
1 The European Council is assisted by the General Secretariat of the Council of the EU.
2 The EIB participated in the audit on a voluntary basis.
3 The numbers of posts refer to end of 2012 and end of 2013.
4 Headquarters.
5 The Committees share their buildings, logistics and translation services and manage them jointly.
6 The findings on the European Court of Auditors have not been externally verified.
12
 Observations
The EU institutions and 
bodies have no common 
policies to monitor and 
mitigate their greenhouse 
gas emissions
The full carbon footprint of 
the EU institutions and  
bodies is not known and the 
patchy information available 
risks undermining the  
credibility of reporting
12 
In the Court’s view, reliable and com ‑
prehensive information on the actual 
size of the carbon footprint of the EU 
institutions and bodies is an essen ‑
tial precondition for drawing up and 
implementing effective mitigation 
strat  egies which are credible and con ‑
vincing as an example to follow. Such 
information is currently not available 
for most of the EU institutions and 
bodies.
There is no common approach 
to calculate the carbon 
footprint of the EU institutions 
and bodies
13 
Binding EU legislation on calculating 
the carbon footprints of public admin ‑
istrations does not exist. In principle, 
EU institutions and bodies are there ‑
fore free to decide on whether they 
want to report the emissions caused 
by their activities and, if so, how to 
calculate and monitor them. They may, however, be subject to 
certain reporting obligations in their 
respective host countries, for example 
with regard to the energy performance 
of their buildings. Such reporting obli ‑
gations are, however, not harmonised 
throughout the EU.
14 
In contrast to an evolving practice in 
the private sector7 the EU financial 
regulation (FR)8 does not require the 
inclusion of environmental information 
in the reports to be submitted pursu ‑
ant to its Title IX (‘Presentation of the 
accounts and accounting’)9. Interinsti ‑
tutional agreements in this respect do 
not exist either.
15 
Organisations participating in the vol ‑
untary EU eco‑management and audit 
scheme EMAS10 must report on a core 
indicator, ‘emissions’, which includes 
total annual GHG emissions, expressed 
in tonnes of CO2 equivalent. How ‑
ever, according to the Commission’s 
decision on the user’s guide to par ‑
ticipating in EMAS11, the approach to 
quantifying emissions still needs to be 
clarified. In any case, the guide does 
recommend that organisations report 
not only direct but also significant 
indirect GHG emissions (see Box 1 ).7 The fourth Council Directive 
78/660/EEC of 25 July 1978 
based on Article 54(3)(g) of the 
Treaty on the annual accounts 
of certain types of companies 
(OJ L 222, 14.8.1978, p. 11) 
provides that, where 
appropriate and to the extent 
necessary for an 
understanding of the 
company’s development, 
performance or position, the 
annual report must also 
contain non‑financial 
information, including 
information relating to 
environment matters. In 
April 2013, the Commission 
submitted a legislative 
proposal (COM(2013) 207 final 
of 16 April 2013) to make such 
reporting obligatory for 
companies where the average 
number of employees 
exceeds 500.
8 Regulation (EU, Euratom) 
No 966/2012 of the European 
Parliament and the Council of 
25 October 2012 on the 
financial rules applicable to 
the general budget of the 
Union and repealing Council 
Regulation (EC, Euratom) 
No 1605/2002 (OJ L 298, 
26.10.2012, p. 1). The 
regulation does not apply to 
the European Central Bank 
and the European Investment 
Bank. The EU agencies have 
financial rules which follow 
the rules applicable to the 
general budget of the Union.
9 The European Central Bank’s 
annual report includes 
a section on environmental 
issues. The European 
Investment Bank reports on 
environmental issues in its 
corporate responsibility 
report, which is part of the EIB 
Group’s annual report.
10 For more details on EMAS see 
paragraphs 62 to 76.
11 See pages 25 and 26 of 
Commission Decision 
2013/131/EU of 4 March 2013 
establishing the user’s guide 
setting out the steps needed 
to participate in EMAS, under 
Regulation (EC) No 1221/2009 
of the European Parliament 
and of the Council on the 
voluntary participation by 
organisations in a Community 
eco‑management and audit 
scheme (EMAS) (OJ L 76, 
19.3.2013, p. 1).
13 Observations
16 
In a recommendation adopted on 
9 April 201312, the Commission en ‑
courages the use of the organisation 
environmental footprint (OEF) method 
for measuring and communicating the 
life‑cycle environmental performance 
of public organisations, which includes 
reporting on GHG emissions. OEF was 
developed by the Commission’s Joint 
Research Centre taking into consider ‑
ation the recommendations of existing 
and widely accepted organisational 
environmental accounting methods 
and guidance documents.
17 
According to the Commission, the 
development of the OEF method was 
triggered by the fact that the ‘current 
proliferation of different methods and 
initiatives to assess and communicate 
environmental performance is leading 
to confusion and mistrust in environ ‑
mental performance information.’13 As 
the Court’s audit showed, this analysis 
also applies to the reporting of the EU 
institutions and bodies on their own 
carbon footprints.Six of the 15 audited EU 
institutions and bodies did not 
report their GHG emissions in 
2012 and those doing so did 
not calculate or disclose all 
elements
18 
The audit examined the information 
readily available in the EU institutions 
and bodies on their respective GHG 
emissions in 2012. The European Coun ‑
cil and the Council of the European 
Union, the European Court of Auditors, 
the European External Action Service, 
the European Aviation Safety Agency 
and the European Medicines Agency 
did not publish any information on 
their emissions in 2012. The others 
only reported incomplete information.
19 
In the absence of binding rules on how 
to calculate an organisation’s carbon 
footprint the audit used the European 
Parliament’s carbon footprint report 
as a benchmark because of its broad 
scope. Table 2  shows a comparative 
breakdown of emission sources taken 
or not taken into account and the 
emission levels reported.12 Commission 
Recommendation 
2013/179/EU of 9 April 2013 on 
the use of common methods 
to measure and communicate 
the life cycle environmental 
performance of products and 
organisations (OJ L 124, 
4.5.2013, p. 1).
13 See recital 2 of Commission 
Recommendation  
2013/179/EU.
14 Observations Table 2 
European ParliamentCourt of JusticeEuropean  
Investment BankEuropean Central BankOffice for Harmonization in 
the Internal MarketEuropean
Environment AgencyEuropean
CommissionThe Committees  
(EESC and CoR)European Council and 
Council of the EUEuropean Court of AuditorsEuropean External  
Action ServiceEuropean Aviation  
Safety AgencyEuropean Medicines Agency
Emissions in 2012 (tonnes of CO2e) 91 893 18 801 16 441 17 793 2 145 704 42 911 1 066 N/A N/A N/A N/A N/A
REPORTING SCOPE includes emissions from:
Energy consumed in buildings1 2 2x x x x x
Leakage of refrigerant gases x x x x x x x x x x
Transport of goods () x x x x x x x x x x x
Transport of persons 
Commuting x x x x x x x x x x
Business travel3 4x x x x x x
Visitors x x x x x x x x x
Purchase of supplies and services ()5 5x x x x x x x x x
Waste x x x x x x x x x x
Fixed assets6
Construction of buildings () x x x x x x x x x x x
Office furniture () x x x x x x x x x x x
IT equipment () x x x x x x x x x x x
Other equipment () x x x x x x x x x x x
1 No annual figure published, only global figure for 2010–12.
2 Only buildings within the scope of the environmental management system EMAS.
3 Travel of Members of Parliament to attend meetings in Brussels and Strasbourg is not included.
4 Only official cars included.
5 Only paper included.
6 Emissions generated during construction or manufacture of durable goods.
Note : Most emissions data are from the various annual environmental statements of the reporting EU institutions and bodies. In the case of the Court of Justice, data are 
from an external carbon footprint study. In the case of the EIB, data are from its carbon footprint report for 2012.CO 2e emissions reporting related to 2012 (information published or to be 
published only, European Parliament’s reporting scope used as a benchmark)
Legend:
 Covered
() Covered by an estimate
 Partly covered
x Not covered
N/A Not available
15 Observations
20 
As can be seen from Table 2 , the Euro ‑
pean Parliament took a wide range 
of emission sources into account for 
reporting its annual overall emissions. 
Due to this broad scope the amount of 
emissions reported by the Parliament 
is almost as high as the emissions 
reported by all other EU institutions 
and bodies taken together. Whilst the 
categories of emission sources consid ‑
ered by the Parliament are, in princi ‑
ple, comprehensive, it decided not to 
report on emissions caused by travel ‑
ling by its members from their home 
countries to meetings in Brussels and 
Strasbourg.
21 
The Commission’s reporting on GHG 
emissions in terms of CO2 equivalents 
in its 2013 annual environmental 
statement was limited to informa ‑
tion on emissions caused by energy 
consumption in buildings within the 
EMAS scope in Brussels, Luxembourg 
and Petten14 and by official cars used 
in these locations.
22 
The European Economic and Social 
Committee and the Committee of 
the Regions only reported emissions 
caused by energy consumption in 
buildings. The Committees explained 
that they were willing to reconsider 
whether or not to calculate a compre ‑
hensive environmental footprint once 
a harmonised methodology is ready in 
accordance with an EU standard, based 
on the OEF approach.Three EU institutions and 
bodies strived to improve 
reporting
23 
The scope of the European Central 
Bank’s reporting has been gradual ‑
ly extended since 2008. However, 
emissions caused by staff commuting 
between home and work and emis ‑
sions caused by the construction of 
the Bank’s new premises were not 
calculated.
24 
Starting with the 2012 exercise, the 
European Investment Bank has ap ‑
plied the GHG Protocol methodology15. 
However, emissions caused by the 
manufacturing of products purchased 
(other than paper), emissions caused 
by purchased services and emissions 
generated during the manufacture 
of capital goods (such as equipment 
and vehicles) are not included in the 
reporting scope.
25 
The Office for Harmonization in the 
Internal Market has planned to extend 
its reporting from 2013 onwards on the 
basis of a study by an external consult ‑
ant. However, the scope of this study 
did not include upstream emissions 
from purchased goods and services 
and from capital goods. Furthermore, 
it only covered emissions from flights 
but not those from other business trav ‑
el or travel of staff from the national 
authorities visiting the OHIM.14 See Table 6 .
15 World Business Council for 
Sustainable Development/
World Resources Institute, 
GHG Protocol corporate 
standard .
16 Observations
Three EU institutions must 
prepare for reporting on 
emissions as they have 
launched the process for 
joining EMAS
26 
The General Secretariat of the Council 
(GSC) has planned to order a study to 
establish the Council’s carbon foot ‑
print. The study will cover activities in 
Brussels only. The emissions caused by 
Member State representatives com ‑
muting from and to their home coun ‑
tries to attend meetings organised by 
the GSC do not fall within the scope of 
the planned study. Council meetings in 
Luxembourg or in Member States will 
not be considered either.
27 
The Court of Justice received a com ‑
prehensive external study of its carbon 
footprint in 2010. The approach for 
calculating the footprint was the same 
as for that of the Parliament. Updates 
were made for major emission sources 
in 2011 and 2012. The data were pub ‑
lished in June 2014.
28 
In November 2013 the Court of Audi ‑
tors concluded a contract with an ex ‑
ternal consultant to prepare for EMAS. 
A decision on how to proceed with 
emission reporting was pending at the 
time of the audit.The Commission has not yet 
decided whether to use the 
organisation environmental 
footprint method for its 
reporting
29 
A study on the OEF method conducted 
at the Ispra site of the Joint Research 
Centre showed that the method can 
be applied to a public administration. 
However, the Commission has not 
yet launched the process of prepar ‑
ing more detailed OEF sectorial rules 
(OEFSRs) for public administrations. 
Furthermore, a possible roll‑out of the 
method is, according to the Commis ‑
sion, subject to further analysis, in par ‑
ticular in view of the resources needed 
to implement the method.
Evidence that emissions 
caused by EU institutions and 
bodies as a whole have been 
falling exists but only related 
to energy consumption in 
buildings
30 
In the absence of comprehensive and 
reliable information on the actual 
size of the carbon footprint of the EU 
institutions and bodies, it is difficult 
to identify overall trends in their GHG 
emissions. In order to do so, the audit 
sometimes had to rely on assumptions 
which are plausible but with only limit ‑
ed supporting evidence available.
17 Observations
16 For instance, total energy 
consumption in the Brussels 
buildings of the Commission 
in 2005 was about 60 % above 
the level reached in 2000, the 
earliest year for which data 
were provided to the Court.
17 The overall level of energy 
consumption in buildings is 
influenced by various factors, 
in particular the following: the 
number and size of buildings, 
the intensity of their 
occupation in terms of 
number of occupants and 
periods of use, their energy 
performance in technical 
terms, the efficiency of 
building management, staff 
behaviour and climatic 
fluctuations.
18 Green electricity must meet 
the criteria for guarantee of 
origin set out in Directive 
2009/28/EC of the European 
Parliament and of the Council 
of 23 April 2009 on the 
promotion of the use of 
energy from renewable 
sources and amending and 
subsequently repealing 
Directives 2001/77/EC and 
2003/30/EC (OJ L 140, 5.6.2009, 
p. 16).
19 Green electricity is not 
reported with zero emissions 
in the Commission’s annual 
environmental statement for 
buildings in Brussels.31 
EU decisions made or proposed to re ‑
duce emissions use 1990 as a reference 
year (see paragraphs 3 and 4). How ‑
ever, specific emissions data for the 
EU institutions and bodies going back 
to the year 1990 are not available. As 
a consequence, it is not possible to as ‑
sess their current performance against 
their actual emissions in 1990.
32 
Nevertheless, there is some evidence 
to suggest that their overall emissions 
increased considerably after 1990 
until at least 200516. This increase was 
caused by the enlargement of the EU, 
the growing activities of existing insti ‑
tutions and bodies and the creation of 
new ones.
33 
Efforts to mitigate GHG emissions 
began on a larger scale in 2006. The 
turnaround focused on emissions 
caused by energy consumption in 
buildings. The magnitude of these 
emissions depends on the overall level 
of energy consumption for heating, 
cooling, lighting, cooking, electric and 
electronic devices and data centres17 
and on the share of energy consumed 
which is produced with low or zero 
GHG emissions.Using green electricity 
helped to reverse the trend of 
increasing emissions caused 
by energy consumption in 
buildings …
34 
In 2007, the EU institutions and bodies 
began to purchase electricity from re ‑
newable sources (‘green electricity’18) 
for the part of their electricity demand 
which was not covered by own pro ‑
duction. All audited EU institutions and 
bodies now cover all, or at least a sig ‑
nificant share, of their external elec ‑
tricity supply with green electricity.
35 
In carbon footprint calculations, green 
electricity is generally accounted for 
as being zero in terms of emissions19. 
The mitigating effect of green electri ‑
city on the overall footprint calcula ‑
tion is estimated to be in the order 
of 20 % provided that all electricity 
is from renewable sources and that 
an exhaust  ive reporting scope for 
GHG emissions is applied. Switching 
to green electri  city therefore has the 
effect of redu cing overall emissions, 
unless there is in parallel such a large 
increase in overall energy consump ‑
tion from non‑renewable sources that 
it cannot be cushioned by green elec ‑
tricity. However, no such scenario was 
observed in the audited EU institutions 
and bodies.
18 Observations
… but green electricity from 
external suppliers has its 
limitations as a tool to reduce 
GHG emissions
36 
Most of the green electricity that the 
EU institutions and bodies consume 
is procured from external suppliers, 
in Brussels and Luxembourg through 
interinstitutional contracts. However, 
green electricity provided by external 
suppliers has two significant limita ‑
tions in terms of the reduction of GHG 
emissions: it is currently not avail ‑
able to everyone and is not a tool for 
continuous improvement in energy 
performance.
37 
The amount of green electricity on the 
market is currently limited. Therefore, 
green electricity purchases reduce 
global GHG emissions only if, due to 
such purchases, electricity produced 
from fossil fuels is replaced by pro ‑
duction from new, additional renew ‑
able electricity production facilities. 
However, increased demand for green 
electricity is likely to trigger increased 
supply, at least in the longer term.
38 
Green electricity is a one‑off measure 
to achieve a quick and visible reduc ‑
tion in emissions but not a tool for 
continuous improvement. Switching to 
green electricity buys additional time 
before introducing further measures to 
reduce overall energy demand.Data available on emissions 
caused by mobility do not allow 
a clear trend to be identified
39 
Due to the specific nature of the EU 
institutions and bodies, emissions 
caused by mobility tend to be more 
significant than is the case with the 
majority of administrations in Member 
States. In order to make a compre ‑
hensive calculation of the emissions 
caused by mobility the following 
sources need to be taken into account:
(a) commuting to and from work;
(b) business/duty travel;
(c) visitors and external participants in 
meetings and conferences organ ‑
ised by the institutions and bodies.
40 
If these sources were included, mobil ‑
ity related emissions would make up 
at least half of the overall emissions to 
be reported by the EU institutions and 
bodies. However, most data available 
on emissions caused by mobility are 
currently less complete and reliable 
than the data on energy consump ‑
tion in buildings. For example, with 
regard to staff commuting between 
home and work, the data serving as 
a basis for calculations usually have 
a high margin of error. Only data of the 
European Parliament and of the Euro ‑
pean Investment Bank allowed a trend 
assessment over a longer time span 
and the respective results in absolute 
terms point in different directions.
19 Observations
20 Only travel subsidised by the 
Parliament has been taken 
into account.
21 For 2012, the Parliament 
reported that staff travel 
between the three main sites 
accounted for 2,5 % of the 
carbon footprint. Staff travel to 
other destinations (largely by 
plane) made up 6,9 % of the 
footprint.
22 The Parliament’s concept of 
‘full‑time equivalent’ (see 
glossary) includes not only 
members and staff but also 
visitors.
Fewer emissions caused by travel between Brussels, Luxembourg and Strasbourg
GHG emissions from European Parliament’s staff travel between Brussels, Luxembourg and Strasbourg have 
dropped by 34 % in 2012 compared to 2006. This is largely attributable to the fact that train travel largely 
replaced plane travel.
Kilometres
(millions )2006 2012 Evolution
By car 10,4 9,3 – 10 %
By train 3,0 7,1 + 139 %
By plane 4,8 0,5 – 90 %
Total 18,1 16,9 – 7 %
Source:  ECA calculations based on data provided by the Parliament.  
Note:  Detail may not sum to totals due to rounding.Box 241 
The European Parliament reported 
mobility‑related emissions which were, 
in absolute terms, about 20 % higher 
in 2012 than in 2006. This increase was 
largely due to increased emissions 
caused by travel by the Parliament’s 
visitors20 to Brussels and Strasbourg 
but also because savings in staff 
travel between Brussels, Luxembourg 
and Strasbourg (see Box 2 ) were 
outweighed by increases related to 
business travel outside these three 
sites21. However, in relative terms Par ‑
liament achieved a reduction of 3,3 % 
in its mobility‑related emissions per 
full‑time equivalent22.42 
The European Investment Bank 
reported that its mobility‑related 
emissions in 2012 were 6 % lower than 
in 2007. Per capita mobility emissions 
decreased by 36 %.
20 Observations
Fixed assets and supplies and 
services tend to be overlooked 
as emission sources despite 
their importance
43 
Supplies (such as food or office sup ‑
plies) or services (such as cleaning or 
catering) trigger emissions which were 
rarely assessed, with the exception of 
emissions related to paper. The same 
applies to emissions generated during 
the manufacturing of durable goods 
(such as IT equipment) and the con ‑
struction or renovation of buildings. 
Only the European Parliament calcu ‑
lated the full impact of fixed assets, 
supplies and services on its carbon 
footprint, which was in the order of 
30 % of the total reported for 2012. For 
the Court of Justice, their impact was 
estimated on the basis of figures for 
2010.
More than half of the audited 
EU institutions and bodies 
had not set any quantified 
targets for reducing their 
emissions and only two had 
quantified targets for 2020
44 
In the Court’s view, setting quanti ‑
fied reduction targets is important for 
planning and ensuring the sustainabil ‑
ity of an organisation’s environmental 
management. Communicating such 
targets publicly and attaining them is 
important for the credibility of the ef ‑
forts to reduce GHG emissions.45 
In 2013, more than half of the audited 
EU institutions and bodies had not set 
any quantified targets for reducing 
their GHG emissions. The others have 
established targets related to specific 
activities or emission sources or overall 
targets, with the European Parliament 
combining both (see Table 3 ).
Preference was given to targets 
with a short time horizon ...
46 
In the majority of the cases short‑term 
targets are used with a time horizon of 
between 1 year and 3 years. The audit 
found that such short‑term targets 
may prove useful as long as ‘quick 
wins’ are possible, for example in the 
case of reducing emissions by switch ‑
ing to green electricity. The major risk 
associated with short‑term targets is 
that they do not provide an appro ‑
priate time horizon for steps which 
require more preparation and which 
result in emission savings only several 
years after the initial decision (notably 
building projects). Furthermore, the 
audit found that short‑term targets set 
from one year to the next for energy 
consumption in buildings risk being 
distorted by climate fluctuations.
21 Observations Table 3Quantified GHG emissions reduction targets
Sectorial targets
Overall target
Absolute targets
Relative targets
Short-term targets  
(1 to 3 years)
Mid-term target 
(2020)
Long-term target
(2030)
European Parliament x x1x
European Commission x x x
European Central Bank x x x x
The Committees (EESC and CoR) x x x x
European Investment Bank x x x x
European Environment Agency x x x
European Council and Council of the EU x x x x x x x
Court of Justice x x x x x x x
European Court of Auditors x x x x x x x
European External Action Service x x x x x x x
Office for Harmonization in the Internal Market x x x x x x x
European Aviation Safety Agency x x x x x x x
European Medicines Agency x x x x x x x
1 Some intermediate reduction targets for 2016 for energy, paper and waste have been set in addition.
Quantified  targets set the amount of emission reductions to be achieved over time. Four types of quantified targets can be distinguished:
 ο sectorial  targets apply to emissions caused by specific activities (e.g. emissions from heating and cooling of buildings);
 ο an overall  target applies to the total of the emissions caused by the activities of an institution/body;
 ο absolute  targets aim to reduce emissions caused by specific activities or by an institution/body as a whole as compared to the 
amount(s) of emissions in a base year;
 ο relative  targets aim to reduce emissions per capita or per square metre as compared to a base year.Legend:
 Yes
x No
47 
Reduction targets have been set either 
in absolute terms (reduction of overall 
emissions) or in relative terms (reduc ‑
tion of emissions per capita or per 
square metre) or as a combination of 
both. Setting absolute reduction tar ‑
gets is more in line with the EU climate 
policy, which is committed to reducing 
overall emissions. Furthermore, pursuing absolute reduc ‑
tion targets implies that performance 
also improves in relative terms unless 
an institution or body is in a scenario 
of decreasing activities.
22 Observations
… and where targets for 2020 
exist, they are relative
48 
Targets for 2020 have been set by the 
European Parliament and the Euro ‑
pean Investment Bank. These targets 
are reported as relative targets.49 
In the Parliament’s environmental 
statement the target is to reduce 
emissions per full ‑time equivalent of 
staff by 30 % between 2006 and 2020. 
Table 4  compares emissions in 200623 
with emissions in 2012, both in abso ‑
lute terms and in relative terms per 
full‑time equivalent of staff24.23 The year 2006 was the first for 
which the Parliament’s carbon 
footprint was reported.
24 Net emissions (green 
electricity accounted for with 
zero emissions). The 
Parliament’s concept of 
‘full‑time equivalent’ (see 
glossary) includes not only 
members and staff of the 
Parliament but also visitors.
25 Net emissions (green 
electricity accounted for with 
zero emissions). It should be 
noted that the EIB figures for 
emissions cannot be 
compared with the Parliament 
figures for emissions as the 
underlying methodological 
concepts differ.Reduction of the Parliament’s GHG emissions in absolute 
and relative terms
2006 2012 Reduction
Total emissions in tonnes of CO2e 100 138 91 893 – 8,2 %
Emissions per full-time equivalent 9,37 6,89 – 26,4 %
Source:  EP environmental statement 2013.Table 4 Table 550 
In the EIB’s carbon footprint report 
for 2012, a target of reducing the per 
capita carbon footprint by at least 
20 % by 2020 is used for monitoring 
and reporting achievements against 
the base year 2007. Table 5  compares 
emissions in 2007 with emissions in 
2012, both in absolute terms and in 
relative terms per employee25.
Reduction of the EIB’s GHG emissions in absolute and  
relative terms
2007 2012 Reduction
Total emissions in tonnes of CO2e 17 932 16 441 - 8,3 %
Emissions per employee 11,9 7, 5 - 37 ,0 %
Source:  ‘European Investment Bank carbon footprint report 2012’.
23 Observations
Long‑term targets beyond 2020 
have not been set
51 
None of the EU institutions and bod ‑
ies has set long‑term targets beyond 
2020. The Commission’s proposal of 
January 2014 on a binding EU GHG re ‑
duction target for 2030 (see paragraph 
4) provides an opportunity for the EU 
institutions and bodies to develop 
and implement a common long‑term 
approach.
Offsetting to compensate 
residual emissions is used to 
a limited extent and the EU 
institutions and bodies do 
not have a common approach
52 
Carbon offsetting26 is a mechanism 
whereby an organisation compensates 
for its own GHG emissions or for a part 
of them by paying for an equivalent 
carbon dioxide saving made elsewhere 
in the world, for example emissions 
savings made through wind farms 
that replace coal‑fired power plants. 
High‑quality offsets should be veri ‑
fied under a recognised scheme to 
make sure that emission reductions are 
additional (i.e. excluding reductions 
that would have happened anyway), 
permanent and not double counted, 
and that leakage is avoided. If all the 
emissions that cannot be avoided are 
offset, an activity can be considered to 
be ‘carbon neutral’27.53 
EU institutions and bodies are not 
obliged to use carbon offsetting. How ‑
ever, some of them have started using 
it, albeit often to a limited extent. The 
audit found that the prices they paid 
for offsetting were in a range between 
3,45 and 24,5 euro per tonne of CO2e, 
and thus well below the maximum cost 
of 40 euro (in 2007 prices) set by the 
European Parliament and the Council 
in the clean vehicle directive28.
A minority of the EU 
institutions and bodies have 
been using offsetting on 
a voluntary basis
54 
The first to use offsetting was the 
Euro pean Environment Agency. In 
2006 a carbon offsetting scheme was 
introduced in relation to business 
 travel. The EEA’s travel agency calcu ‑
lates the emissions caused and the 
relevant offsets are used to support 
so‑called ‘Gold Standard’29 energy 
efficiency projects in Africa. The total 
offset costs in 2012 for 745 tonnes 
amounted to 11 286 euro, at a price of 
15,15 euro per tonne. Furthermore, the 
offsetting of heating‑related emissions 
in 2010, 2011 and 2012 was decided in 
July 2013 for an amount of 2 420 euro, 
at a price of 10 euro per tonne for 
a wind farm project in Turkey.26 Carbon offsetting should not 
be confused with the 
European Union emissions 
trading system (EU ETS), which 
is a mandatory cap and trade 
system of GHG emission 
allowances for heavy 
energy ‑consuming activities. 
See Directive 2003/87/EC of 
the European Parliament and 
of the Council of 
13 October 2003 establishing 
a scheme for greenhouse gas 
emission allowance trading 
within the Community and 
amending Council Directive 
96/61/EC (OJ L 275, 25.10.2003, 
p. 32).
27 See the definition provided by 
the UK Department of Energy 
and Climate Change in its 
document ‘A guide to carbon 
offsetting for the public 
sector’, version 2, 2011, p. 11: 
‘Carbon neutral means 
that — through a transparent 
process of calculating 
emissions, reducing those 
emissions and offsetting 
residual emissions  — net 
carbon emissions equal zero.’
28 See the Annex (Table 2) to 
Directive 2009/33/EC of the 
European Parliament and of 
the Council of 23 April 2009 on 
the promotion of clean and 
energy‑efficient road 
transport vehicles (OJ L 120, 
15.5.2009, p. 5).
29 The Gold Standard, initiated in 
2003 by a group of 
non‑governmental 
organisations, is a widely used 
voluntary certification 
standard for carbon offset 
projects.
24 Observations
55 
The Office for Harmonization in the In ‑
ternal Market has used offsetting since 
2010 with the objective of becoming 
carbon neutral gradually, taking into 
account that the reporting scope for 
its CO2 emissions will be broader in the 
coming years. For the 2 145 tonnes of 
emissions reported in 2012, offsetting 
was used at a cost of 52 549 euro, i.e. 
24,5 euro per tonne to support a pro ‑
ject for the dissemination of efficient 
fuel wood stoves in Nigeria.
56 
The European Parliament used a car ‑
bon offsetting scheme for the first 
time in 2012. The Parliament’s Bureau 
decided to offset certain categories 
of emissions (notably those related to 
energy consumption in buildings and 
duty travel by officials) which made 
up about 27 % of Parliament’s carbon 
footprint reported for 2011. Due to 
the drop in market prices for carbon 
offsetting credits, instead of the initial 
price forecast of 705 000 euro, the 
actual price paid by Parliament was 
89 558 euro30 (3,45 euro per tonne) for 
an energy efficiency project at a steel 
production plant in China complying 
with the ‘Gold Standard’ for quality31.
57 
The European Central Bank used 
offsetting for business travel by train. 
With 30,9 tonnes of CO2e in 2012, this 
represented only a small proportion 
of the emissions caused by business 
trips. For the procurement of interna ‑
tional business travel services, the ECB 
sustainable procurement guideline32 of 
December 2012 recommends a re ‑
quirement that the successful tenderer 
compensate 100 % of the greenhouse 
gas emissions caused by official travel.The guideline proposes that projects 
involved in delivering carbon offsets 
meet the criteria of additionality and 
permanence, that leakage and double 
counting are avoided and that offsets 
are verified by an independent third 
party verifier. At the time of the audit, 
the recommendation had not yet been 
implemented.
Two EU bodies decided to use 
offsetting but postponed or 
suspended implementation
58 
In 2007, the Management Commit ‑
tee of the European Investment Bank 
endorsed the principle of carbon 
neutrality and decided that it ‘will 
offset its residual emissions, after tak ‑
ing appropriate measures to reduce 
them, by means of high‑quality carbon 
credits.’ However, at the time of the 
audit the decision had not yet been 
implemented. The EIB decided that 
implementation will start in 2014 with 
the offsetting of the residual 2013 
carbon footprint.
59 
In 2008, the European Aviation Safety 
Agency signed a framework contract 
for the provision of carbon offsetting 
services to offset emissions caused by 
air travel. According to the EASA, the 
contract was suspended in 2010 after 
travel budget cuts were announced. In 
2012 the EASA used offsetting for busi ‑
ness travel by train.30 This was less than 10 % of the 
amount available under 
Article 239 of the Parliament’s 
budget for expenditure 
relating to carbon offsets 
(950 000 euro). However, the 
remaining amount under 
Article 239 was not used for 
buying more offsetting 
credits.
31 As for the countries of origin of 
the offsetting credits, no 
requirements were included in 
the technical specifications 
although the Parliament’s 
external consultant had 
recommended giving 
preference to EU Member 
States or to least ‑developed 
countries.
32 See also paragraph 88.
25 Observations
The Commission does not use 
offsetting
60 
On the Commission’s website33, the 
commissioner for climate action sug ‑
gests that EU citizens consider vol ‑
untary offsetting in connection with 
flights (see Box 3 ).
61 
However, like the majority of the EU in ‑
stitutions and bodies, the Commission 
does not currently offset its emissions, 
including those caused by air travel by 
its members and staff. Managers in the 
institutions and bodies currently not 
offsetting their emissions use various 
arguments which can be summarised 
as follows.
(a) Offsetting is not perceived as 
a complement to reducing own 
emissions but rather as an alter ‑
native option which is less cred ‑
ible than efforts to reduce own 
emissions. Therefore, all available 
budgetary appropriations should 
be invested in energy efficiency 
measures.(b) Offsetting is considered as pre ‑
mature as long as all other pos ‑
sibilities to eliminate or reduce 
existing emissions have not been 
exhausted.
(c) A policy to become carbon neutral 
with the help of offsetting would 
require an appropriate legal and 
financial framework common to all 
EU institutions and bodies.
(d) The quality of carbon offsets is not 
always sufficiently guaranteed.
In the Court’s view, using high‑quality 
offsets in addition to emission reduc ‑
tion measures (and not instead of such 
reduction measures) would address 
these issues appropriately.33 Ways you can fight climate 
change , January 2014  
(http://ec.europa.eu/clima/
citizens/tips/tips_04_en.htm ).
The European Commissioner for climate action suggests considering offsetting for 
flights that cannot be avoided
‘Flying is the world’s fastest ‑growing source of CO2 emissions. If you fly, then consider “offsetting” your carbon 
emissions. There are organisations that will calculate the emissions you have caused and invest money in 
renewable energy.’Box 3
26 Observations
The EU institutions and 
bodies do not make full 
use of the environmental 
management tools pro ‑
moted by the Commission
Progress in introducing the 
eco‑management and audit 
scheme EMAS is slow
62 
The Commission supports the pro ‑
motion of the EU eco‑management 
and audit scheme throughout the 
Member States. The objective of EMAS 
is continuous improvements in the 
environmental performance of organ ‑
isations by a systematic and regular 
evaluation of their management of all 
environmental aspects of their activ ‑
ities and thus not only with regard to 
GHG emissions. Accredited external 
environmental verifiers must validate 
the organisation’s compliance with 
the provisions of the EMAS regulation 
before it can be registered with the 
competent bodies in Member States, 
and regularly thereafter before such 
registration can be renewed34. Accord ‑
ing to the Commission, ‘EMAS is the 
most credible and robust environmen ‑
tal management tool on the market’35. 
It is also open to organisations outside 
the EU.63 
Participation in EMAS is voluntary and 
those participating ‘may gain added 
value in terms of regulatory control, 
cost savings and public image provid ‑
ed that they are able to demonstrate 
an improvement of their environmen ‑
tal performance.’36 The EMAS regula ‑
tion allows participants to register only 
parts of an organisation.
EMAS registration for public 
administrations has been 
possible since 2001 and in June 
2014 seven of the audited EU 
institutions and bodies were 
registered
64 
The first EMAS regulation, adopted in 
1993, was restricted to companies in 
industrial sectors. With the first revi ‑
sion of the EMAS regulation in 2001 
(EMAS II), the scheme was opened 
up to all economic sectors including 
public and private services. EU institu ‑
tions were invited ‘to endeavour to 
adopt the principles of the regula ‑
tion’37. The second revision (EMAS III), 
adopted in 2009, rendered the scheme 
more attractive for small organisations, 
including public authorities employing 
fewer than 250 persons.34 In January 2014, more than 
4 500 organisations and 
approximately 7 800 sites 
were EMAS registered.
35 See EMAS factsheet ‘EMAS 
and ISO 14001: 
complementarities and 
differences’ ( http://ec.europa.
eu/environment/emas/pdf/
factsheet/EMASiso14001_
high.pdf ).
36 See recital 8 of Regulation (EC) 
No 1221/2009 of the European 
Parliament and of the Council 
of 25 November 2009 on the 
voluntary participation by 
organisations in a Community 
eco‑management and audit 
scheme (EMAS), repealing 
Regulation (EC) No 761/2001 
and Commission Decisions 
2001/681/EC and 2006/193/EC 
(OJ L 342, 22.12.2009, p. 1).
37 See recital 21 of Regulation 
(EC) No 761/2001 of the 
European Parliament and of 
the Council of 19 March 2001 
allowing voluntary 
participation by organisations 
in a Community 
eco‑management and audit 
scheme (EMAS) (OJ L 114, 
24.4.2001, p. 1).
27 Observations
65 
In June 2014, seven of the audited EU 
institutions and bodies were EMAS 
registered and five others were prepar ‑
ing for it. Table 6  provides an overview 
of the situation.66 
Three of the EU institutions and bodies 
which are EMAS certified have used the 
option to register only parts of their 
sites or buildings. These scope limita ‑
tions are in most cases temporary and 
concern buildings which are not yet 
EMAS compliant or where it is planned 
to vacate them in the coming years.
Registration under the EU eco‑management and audit scheme
Institution/body EMAS registered or registration planned Coverage of buildings’ surface area in 2013
European Environment Agency Since 2005 100 %
European Commission Since 2005Brussels 85 %
Luxembourg 31 %
Petten (JRC) 100 %
Other JRC sites 0 %
Publications Office (Luxembourg) 0 %
Grange 0 %
Executive agencies 0 %
Representations in Member States 0 %
Total surface area covered 57 %
European Parliament Since 2007Three main sites 85 %
Offices in Member States 0 %
Office for Harmonization in the Internal Market Since 200877 % 
(one rented building not covered)
European Central Bank Since 2010100 % 
(excluding space in an external data centre)
European Economic and Social Committee Since 2011100 % of five buildings exclusively occupied 
0 % of the building shared with the Commission Committee of the Regions of the European Union
European Council  Under preparation, registration planned for 2015 N/ACouncil of the European Union
European Medicines Agency Under preparation, registration planned for 2015 N/A
Court of Justice of the European Union Under preparation, registration planned for 2016 N/A
European Court of Auditors Under preparation, registration planned for 2016 N/A
European Investment BankPreparation for an environmental management 
system
No decision to adopt EMAS (Alternatively ISO 14001 
is considered)N/A
European Aviation Safety Agency No decision to prepare for EMAS N/A
European External Action Service No decision to prepare for EMAS N/ATable 6
28 Observations
EMAS at the Commission 
currently has important scope 
limitations
67 
In the case of the Commission the cur ‑
rent EMAS scope limitations are more 
important than at other institutions 
and bodies. This can partly be ex ‑
plained by the size of the Commission, 
particularly with regard to its many 
sites in a number of Member States, 
and the high number of buildings to 
be covered. However, the delays are 
also attributable to a slow decision ‑
making process and a low priority in 
terms of staff resources available.
68 
After the successful completion of an 
EMAS pilot project for some depart ‑
ments covering eight buildings in Brus ‑
sels in 2005, it was not until September 
2009 that the Commission decided to 
extend the scope of the EMAS registra ‑
tion to all its activities and buildings in 
Brussels and Luxembourg. No dead ‑
line has been set for achieving this 
objective.
69 
In 2010, the management systems of 
the five sites of the Joint Research Cen ‑
tre were ISO 14001 certified. However, 
the opportunity was missed to obtain 
EMAS registration at the same time38.70 
In November 2013 the Commission 
undertook to apply EMAS ‘to all its 
activities and sites within the European 
Union in due course’39. The extension 
of EMAS registration to activities and 
installations of the Joint Research 
Centre and to the Food and Veterinary 
Office in Grange is explicitly men ‑
tioned in the decision. It is, however, 
silent about the executive agencies 
and the Commission’s representations 
in Member States (in more than 35 
buildings with a total surface area of 
about 38 000 square metres). Using 
the scheme in representations would 
provide an opportunity to actively 
promote EMAS in the Member States 
and to demonstrate that it can also be 
useful for small organisations40.
71 
Similar considerations apply to the EU 
delegations (in more than 140 coun ‑
tries with a total surface area of about 
250 000 square metres) which are now 
managed by the European External 
Action Service. The EEAS has not yet 
committed itself to adopting EMAS.38 EMAS includes all the 
requirements of ISO 14001 
and goes beyond them. Both 
systems can be validated and 
certified in one go. Thus, only 
limited additional costs, if any, 
are incurred in doing both at 
the same time.
39 Decision C(2013) 7708 final of 
18 November 2013 on the 
application by the 
Commission’s services of the 
Community eco‑management 
and audit scheme (EMAS).
40 The Commission has 
published an ‘EMAS toolkit for 
small organisations’ and 
promotes a standardised 
methodology called ‘EMAS 
easy’.
29 Observations
EMAS implies costs but 
triggers both environmental 
improvements and financial 
savings
72 
The audit found that the costs of 
running EMAS ranged between 
50 000 euro and 1 million euro per 
year depending on the size of the EU 
institution or body and the level of 
ambition as to the performance of the 
system. This estimate includes staff ex ‑
penditure and expenditure related to 
verification and internal audit services, 
but not EMAS‑driven investments.
73 
Typically, introducing EMAS triggers 
performance improvements which 
start to appear during the preparation 
phase for the first EMAS registration. 
For example, for 2012, both the Euro ‑
pean Central Bank (EMAS registered 
since 2010) and the Committees (EMAS 
registered since 2011) reported a per 
capita reduction of about 20 % in elec ‑
tricity consumption compared with 
2008, with a steady decrease starting 
in both cases from 2009.
74 
Such savings do not only have a posi ‑
tive impact on the environment but 
also in financial terms. Generally, the 
EU institutions and bodies which have 
introduced EMAS do not specifically 
monitor the financial savings realised 
due to it. However, EMAS has an imme ‑
diate positive financial impact where 
savings in the consumption of energy 
and other resources are obtained with ‑
out prior investments, notably through 
better management of buildings (e.g. 
adjusting heating periods and aver ‑
age temperature) or changes in the 
behaviour of staff (e.g. switching off 
electronic devices before leaving the 
office).75 
Where investments are required to 
achieve improvements in performance, 
financial savings will take longer. For 
example, the Office for Harmonization 
in the Internal Market assessed the 
financial impact of its EMAS‑driven 
investments aimed at increasing the 
energy efficiency of its building (solar 
panels, interior renovation, cooling 
plant) during the period 2010–12, this 
amounted to about 2,5  million  euro. 
According to the Office, the expected 
savings in energy costs suggest a pe ‑
riod of return on investment of around 
7 years.
76 
The Commission calculated gross 
savings of around 7 million euro, 
which were achieved in 2012 due to 
EMAS measures to reduce energy and 
water consumption in its buildings in 
Brussels41. In 2012, total energy con ‑
sumption in the Brussels Commission 
buildings42 was about 15 % lower than 
in 2005.
Green procurement is an 
option rather than an obli ‑
gation under the current 
rules and only a few used it 
systematically
77 
Green public procurement (GPP) is 
defined in the Commission communi ‑
cation ‘Public procurement for a better 
environment’43 as ‘a process whereby 
public authorities seek to procure 
goods, services and works with a re ‑
duced environmental impact through ‑
out their life cycle when compared to 
goods, services and works with the 
same primary function that would 
otherwise be procured.’41 In the methodology applied, 
2005 was the base year. A 2012 
‘virtual consumption’ (without 
the implementation of the 
EMAS energy and water 
saving measures) was 
calculated on the basis of the 
2005 energy consumption 
indicator (kwh/m2) and the 
actual 2012 surface areas. The 
‘virtual consumption’ in 2012 
was compared with the real 
2012 consumption. The cost of 
this ‘virtual consumption’ at 
2012 prices was then 
compared with the actual/real 
costs in 2012 to obtain the 
figure for financial savings 
achieved.
42 The data refer to the buildings 
occupied by the Commission 
and included in the real estate 
portfolio in each given year. 
The executive agencies were 
not included in the scope of 
the calculation.
43 COM(2008) 400 final of 
16 July 2008.
30 Observations
78 
The rules currently applicable to public 
procurement by the EU institutions 
and bodies, with one exception44, do 
not include any obligation to procure 
goods, services and works with a re ‑
duced environmental impact. Green 
public procurement is treated as an 
option and is not mandatory.
79 
The EU financial regulation does not 
refer to the use of green public pro ‑
curement45. Its rules of application46 
allow the use of environmental con ‑
siderations in public procurement and 
set out rules on how to proceed if such 
considerations are used in technical 
specifications, or as selection or award 
criteria, or in contract performance 
clauses. The provisions of the rules of 
application are aligned with the former 
EU directive on public procurement47.
80 
However, the provisions of the direc ‑
tive on the promotion of clean and 
energy‑efficient road transport vehi ‑
cles48, which require public author ‑
ities to consider lifetime energy and 
environmental impacts, have not been 
incorporated in the rules of applica ‑
tion. The same applies to the directive 
on energy labelling49, which required 
contracting authorities to endeavour 
to procure only products that comply 
with the criteria of having the highest 
performance levels and belonging to 
the highest energy ‑efficiency class50. Finally, the relevant provisions of the 
directive on energy efficiency51 have 
also not yet been taken into account 
in the financial regulation’s rules of 
application. As a result, the legal ob ‑
ligations currently imposed on all EU 
institutions and bodies with regard to 
green procurement are less demand ‑
ing than those imposed on Member 
State authorities.
The Commission promotes 
green procurement on 
a voluntary basis
81 
The ‘Vade‑mecum on public procure ‑
ment’52 issued by the Commission’s 
Directorate General for the Budget and 
its ‘Circular on the inclusion of environ ‑
mental considerations in public con ‑
tracts awarded by the EU institutions’53 
refer the reader to the voluntary green 
public procurement recommenda ‑
tions54 and the ‘GPP toolkit’ published 
by the Commission’s Directorate Gen ‑
eral for the Environment (hereinafter 
‘DG Environment’).44 There is currently only one 
area where green 
procurement is mandatory for 
EU institutions: 
energy‑efficient office 
equipment falling within the 
scope of the ‘Energy star’ 
programme. See Article 6 of 
Regulation (EC) No 106/2008 
of the European Parliament 
and of the Council of 
15 January 2008 on 
a Community 
energy‑efficiency labelling 
programme for office 
equipment (OJ L 39, 13.2.2008, 
p. 1).
45 More generally, the financial 
regulation also does not refer 
to the notions ‘environment’, 
‘sustainable development’ or 
‘sustainability’.
46 Commission Delegated 
Regulation (EU) No 1268/2012 
of 29 October 2012 on the 
rules of application of 
Regulation (EU, Euratom) No 
966/2012 of the European 
Parliament and the Council on 
the financial rules applicable 
to the general budget of the 
Union (OJ L 362, 31.12.2012, 
p. 1).
47 Directive 2004/18/EC 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 (OJ L 134, 
30.4.2004, p. 114).
48 Directive 2009/33/EC.
49 Directive 2010/30/EU of the 
European Parliament and of 
the Council of 19 May 2010 on 
the indication by labelling and 
standard product information 
of the consumption of energy 
and other resources by 
energy‑related products  
(OJ L 153, 18.6.2010, p. 1).
50 See Article 9 of Directive 
2010/30/EU.
51 Directive 2012/27/EU of the 
European Parliament and of 
the Council of 25 October 2012 
on energy efficiency, 
amending Directives 
2009/125/EC and 2010/30/EU 
and repealing Directives 
2004/8/EC and 2006/32/EC  
(OJ L 315, 14.11.2012, p. 1).
52 Version from April 2013.
31 Observations
82 
The GPP toolkit proposes green re ‑
quirements for inclusion in the techni ‑
cal specifications, the selection and/
or award criteria and performance 
clauses set out in tender documents. 
When the Court’s audit started, the 
GPP criteria promoted with the toolkit 
covered 19 product/service groups55. 
Two types of GPP criteria are proposed 
for each of these product/service 
groups. According to DG Environment:
(a) the core criteria are those suitable 
for use by any contracting author ‑
ity and address the key environ ‑
mental impacts; they are designed 
to be used with minimum ad ‑
ditional verification effort or cost 
increases to allow easy application 
of GPP;
(b) the comprehensive criteria are 
for those who wish to purchase 
the best environmental products 
available on the market; these may 
require additional verification ef ‑
fort and/or increase cost compared 
to other products with the same 
functionality.Most institutions and bodies 
used green procurement but 
few did so in a systematic 
manner
83 
The audit found that the European 
Environment Agency and the Euro ‑
pean Central Bank56 have made green 
procurement de facto  mandatory in all 
relevant cases by way of internal in ‑
structions and systematic monitoring. 
In the European Economic and Social 
Committee and the Committee of the 
Regions mandatory green procure ‑
ment applied only to calls for tenders 
by their joint services. The European 
External Action Service informed the 
Court that it did not yet use green 
procurement. All others used green 
procurement, but not in a systematic 
manner.
84 
The audit assessed the tender docu ‑
ments of 160 procurement procedures 
across the EU institutions and bodies 
which were relevant for green procure ‑
ment to see whether the GPP toolkit or 
other green criteria had been included 
in the documents relating to the calls 
for tenders. Most of these procedures 
were launched and/or finalised in 
2012. Table  7 summarises the results; 
more details on the audit approach are 
given in the Annex .53 May 2007, updated 
January 2013.
54 European Commission, Buying 
green! A handbook on green 
public procurement , second 
edition, 2011. An ‘indicative 
document of the Commission 
services’, which ‘cannot be 
considered binding to the 
institution in any way’.
55 1. Copying and graphic paper; 
2. Cleaning products and 
services; 3. Office IT 
equipment; 4. Construction; 
5. Transport; 6. Furniture; 
7. Electricity; 8. Food and 
catering services; 9. Textiles; 
10. Gardening products and 
services; 11. Windows, glazed 
doors and skylights; 
12. Thermal insulation; 
13. Hard floor coverings; 
14. Wall panels; 15. Combined 
heat and power (CHP); 
16. Road construction and 
traffic signs; 17. Street lighting 
and traffic signals; 18. Mobile 
phones; 19. Indoor lighting.
56 For the ECB it was too early to 
assess whether the 
instructions were fully 
complied with, whilst it was 
clear that progress had been 
made.
32 Observations
85 
More than half of the procedures 
were assessed as ‘not green’ or only 
‘light green’ for one of the following 
reasons:
(a) no environmental criteria had 
been included in the tender docu ‑
ments or there was only an obliga ‑
tion for the tenderer to comply 
with the applicable environmental 
legislation (not green);
(b) core criteria recommended in the 
GPP toolkit had not been used at 
all (not green) or only to a limited 
extent (light green);
(c) environmental award criteria had 
a low relative weighting which 
made any impact on the outcome 
of the procedure unlikely as long 
as they were not combined with 
environmental requirements 
included in the technical specifi ‑
cations or in the selection criteria 
(light green).The Commission’s GPP criteria 
do not cover all relevant 
procurement areas and the 
core criteria sometimes lack 
ambition
86 
Since 2008, the Commission has pub ‑
lished 22 sets of GPP criteria. However, 
a number of relevant procurement 
fields are not yet covered. No toolkit 
guidance is included in the 2014 GPP 
work programme of DG Environment57 
for the following fields: data centres58, 
building maintenance and repairs, and 
business travel (e.g. green hotels, air 
transport, car leasing). The existing 
criteria for copying and graphic paper 
do not include criteria for printing 
services.57 Work programmes are 
published on the website of 
DG Environment  
(http://ec.europa.eu/
environment/gpp/
gpp_criteria_wp.htm ).
58 However, this field is covered 
by the European Code of 
Conduct for Energy Efficiency 
in Data Centres 
(see paragraph 101).Table 7Use of green criteria in tender documents
Category Number Share in total
Green by nature 8 5 %
Very green 21 13 %
Green 32 20 %
Light green 57 36 %
Not green 42 26 %
Total number of procedures examined 160 100 %
33 Observations
87 
In some cases, the audit found that 
the GPP core criteria lacked ambition 
and were very easy to comply with or 
did not go beyond what was already 
required under the applicable legis‑
lation59. On the other hand, some 
authorising officers explained that 
they were reluctant to use the compre ‑
hensive criteria because of the risk that 
using them could restrict the number 
of potential bidders as not all bidders 
might be able to meet comprehensive 
criteria.
88 
Largely on the basis of the Commis ‑
sion’s GPP recommendations the 
European Central Bank has developed 
an internal guideline for sustainable 
procurement. The ECB guideline does 
not offer a choice between basic 
or more ambitious criteria, but pro ‑
poses a single set of criteria for each 
category of goods or services to be 
procured. The ECB criteria are usually 
more demanding than the core criteria 
in the GPP toolkit without fully meet ‑
ing the comprehensive criteria. In the 
case of IT equipment, however, the 
ECB criteria go beyond the toolkit’s 
comprehensive criteria. Furthermore, 
the guideline covers some areas for 
which no GPP toolkit criteria exist, i.e. 
office supplies/materials and interna ‑
tional travel.Life‑cycle costing is not 
comprehensively addressed
89 
Life‑cycle costing is included to some 
extent in the current GPP toolkit crite ‑
ria. However, the new public procure ‑
ment directive of February 201460 sets 
demanding requirements. It provides 
that, to the extent relevant, parts or 
all of the following costs over the life 
cycle of a product, service or works 
must be covered:
(a) costs, borne by the contracting au ‑
thority or other users, such as costs 
relating to acquisition, costs of use, 
such as consumption of energy 
and other resources, maintenance 
costs, end ‑of‑life costs, such as col ‑
lection and recycling costs.
(b) costs imputed to environmental 
externalities linked to the prod ‑
uct, service or works during its life 
 cycle, provided their monetary 
value can be determined and veri ‑
fied; such costs may include the 
cost of emissions of greenhouse 
gases and of other pollutant emis ‑
sions and other climate change 
mitigation costs.
Such comprehensive life ‑cycle costing 
is currently not covered by the GPP 
toolkit.59 See the core GPP criteria for 
mobile phone chargers 
(external power supplies) for 
average active efficiency, 
which simply repeat the 
requirements set out by the 
Commission Regulation (EC) 
No 278/2009 of 6 April 2009 
implementing Directive 
2005/32/EC of the European 
Parliament and of the Council 
with regard to ecodesign 
requirements for no‑load 
condition electric power 
consumption and average 
active efficiency of external 
power supplies (OJ L 93, 
7.4.2009, p. 3).
60 See Article 68 (Life‑cycle 
costing) of Directive 
2014/24/EU of the European 
Parliament and the Council on 
public procurement and 
repealing Directive 
2004/18/EC (OJ L 94, 28.3.2014, 
p. 65).
34 Observations
Green building standards for 
energy performance are not 
systematically used for new 
buildings and major renova ‑
tion projects
Improving the energy 
performance of buildings will 
be a major challenge for the 
coming years
90 
Buildings account for about 40 % of to ‑
tal energy consumption in the Union. 
Improving the energy perform  ance 
of buildings is therefore an important 
tool for reducing greenhouse gas 
emissions. It is through the design pro ‑
cess for a new building or for a major 
renovation that the greatest impact 
can be made on its future energy per ‑
formance. Consequently it is important 
that EU institutions and bodies set am ‑
bitious targets for their own buildings 
if they want to reduce emissions.
91 
In order to meet the highest standards 
of energy performance, the EU institu ‑
tions and bodies would need to strive 
for buildings which meet the compre ‑
hensive criteria for construction of the 
GPP toolkit. These voluntary criteria 
recommend two options:
(a) the energy performance of a build ‑
ing must meet the criteria underly ‑
ing a low‑energy or passive house 
standard;(b) alternatively, localised renewable 
energy resources (within the build ‑
ing site itself, such as solar panels, 
biomass boilers, wind turbines, 
etc.) must be available in combina ‑
tion with a maximum overall en ‑
ergy demand which is significantly 
lower than the maximum allowed 
in the relevant national legislation.
92 
The GPP toolkit’s less demanding core 
criteria recommend setting over ‑
all energy consumption standards 
which are significantly lower than the 
maximum specified in the relevant 
legislation. This approach is used for 
the ‘GreenBuilding programme’ (GBP) 
launched by the Commission’s Joint 
Research Centre in 2005. This volun ‑
tary programme addresses owners of 
non‑residential buildings to realise 
cost‑effective measures which en ‑
hance the energy efficiency of their 
buildings61. A ‘GreenBuilding partner’ 
must achieve the following:
(a) new buildings must consume 25 % 
less total primary energy, if eco ‑
nomically viable, than the building 
standard in force;
(b) existing buildings should consume 
at least 25 % less total primary en ‑
ergy, if economically viable, after 
refurbishment.61 Number of buildings 
registered under the 
programme: 936 (situation as 
at 24 February 2014).
35 Observations
The EU institutions’ buildings 
policy in Brussels has not been 
ambitious in terms of energy 
performance
93 
At the time of the audit, none of the 
audited EU institutions had adhered 
to the approach promoted under the 
GPP toolkit and the GBP for building 
projects in Brussels.
94 
The Commission’s Office for Infrastruc ‑
ture and Logistics in Brussels (OIB) 
used the ‘Manual of standard building 
specifications’ of December 2011 as 
a reference document to set out the 
technical performance and character ‑
istics required of buildings in which 
Commission departments are to be 
housed62. According to the manual it 
was sufficient that buildings comply 
with the regional legal minimum re ‑
quirements in terms of primary energy 
consumption.
95 
The Commission expects to have 
replaced or renovated 50 % of its total 
surface area in Brussels by 2025. The 
OIB had not yet assessed the impact of 
the provisions of Directive  
2010/31/EU on the energy perform ‑
ance of buildings (recast) on this pro ‑
ject. The directive requires that, after 
2018, new buildings occupied and 
owned by public authorities should be 
nearly zero‑energy buildings and that 
all other new buildings achieve this 
standard by the end of 2020.96 
When the European Parliament last 
prospected the local property market 
in Brussels in 2010, the selection criter ‑
ion relating to environmental perform ‑
ance required that information on the 
performance of the proposed projects 
was to be provided but without set ‑
ting any minimum requirements for 
such performance. For the selected 
‘Trebel’ project, the promoter made 
a commitment for this new building 
to respect the maximum level allowed 
for primary energy consumption under 
the applicable legislation in Brussels.
97 
In the coming years, the Parliament 
will need to renovate its main build ‑
ings in Brussels. The first to be reno ‑
vated will be the Paul Henri Spaak 
building. Parliament’s administration 
has proposed four options, the most 
ambitious being a nearly zero‑energy 
building. In September 2012, the 
Working Group on Building, Transport 
and a Green Parliament opted for the 
second best option in terms of envir ‑
onmental performance. A decision by 
Parliament’s Bureau was pending at 
the time of the audit.62 The manual applies to new 
buildings or buildings which 
have undergone large‑scale 
renovations.
36 Observations
98 
The Council considers that the GBP is 
not relevant for its Europa building 
currently under construction. Major 
parts of the building which have to be 
integrated in the project were built 
between 1922 and 1927 and are listed. 
According to the Council, this consti ‑
tutes an important technical constraint 
with a considerable impact on the 
building’s energy performance. Deci ‑
sions on the renovation of the Justus 
Lipsius Building were pending. The 
Council planned to start the renewal 
process for the building’s environmen ‑
tal permit in 2015.
New building projects have 
been launched on other sites 
which are ambitious in terms of 
energy performance
99 
The audit found that most ongoing 
building projects on other sites of the 
EU institutions and bodies were ambi ‑
tious in terms of energy performance 
standards to be met and were there ‑
fore in line with the approach promot ‑
ed under the GPP toolkit and the GBP . 
However, the European Central Bank 
is the only one which has formally 
registered under the GBP with its new 
premises on the site of the Grossmarkt ‑
halle in Frankfurt.100  
Some managers argue that it is 
preferable and/or sufficient to use 
the BREEAM (BRE63 environmental 
assessment method) or similar com ‑
mercial assessment schemes such as 
the DGNB64. However, the GBP is more 
focused on the energy efficiency of 
a building project than such assess ‑
ment schemes and adherence to the 
GBP can take place in parallel.
None of the audited EU 
institutions and bodies had 
signed up to the voluntary 
European Code of Conduct 
for Energy Efficiency in Data 
Centres
101  
Data centres are an important cause of 
rising energy demand in administra ‑
tive buildings. Since 2008 the Commis ‑
sion has been promoting the European 
Code of Conduct for Energy Efficiency 
in Data Centres. This voluntary code 
has been created in response to in ‑
creasing energy consumption in data 
centres65 and the need to reduce the 
related environmental, economic and 
energy ‑supply security impacts. The 
aim is to inform and encourage data 
centre operators and owners to reduce 
energy consumption in a cost‑effective 
manner. Adherence to the code is 
possible either as participant and/or 
endorser. None of the EU institutions 
and bodies had signed up to the code 
at the time of the audit.63 The Building Research 
Establishment (BRE) is 
a former UK government 
establishment (but now 
a private organisation) that 
carries out research, 
consultancy and testing for 
the construction and built 
environment sectors.
64 Deutsches Gütesiegel 
Nachhaltiges Bauen, DGNB 
GmbH.
65 For the purposes of the code 
of conduct, the term ‘data 
centres’ includes all buildings, 
facilities and rooms which 
contain enterprise servers, 
server communication 
equipment, cooling 
equipment and power 
equipment and provide some 
form of data service (e.g. 
large ‑scale mission ‑critical 
facilities all the way down to 
small server rooms located in 
office buildings).
37
 Conclusions and 
recommendations
102  
For EU climate policy to be credible, 
it is important that the EU institutions 
and bodies lead by example. They 
need to be at the cutting edge in 
designing and implementing policies 
for reducing the carbon footprint of 
public administrations.
103  
EU institutions and bodies have no 
common approach to tackle this chal ‑
lenge. They missed the opportunity to 
establish and implement a common 
policy for contributing to the Union’s 
2020 goal of reducing GHG emissions 
by 20 % below the level of 1990.
104  
The Commission has not proposed any 
specific binding rules for the adminis ‑
trative activities of the EU institutions 
and bodies to take into account the 
principle of sustainable development 
as provided in Article 11 of the Treaty 
on the Functioning of the European 
Union.
105  
Efforts to mitigate emissions have 
produced tangible results. After 2005, 
the EU institutions and bodies man ‑
aged to reverse the trend of increasing 
emissions related to their buildings. 
However, the absence of binding rules 
was a major cause for delayed, little or 
no action.
106  
The upcoming 2030 target for redu ‑
cing GHG emissions provides the EU 
institutions and bodies with a new op ‑
portunity to develop and implement 
a common policy.Recommendation  
Common policy to reduce 
greenhouse gas emissions
1.  The Commission should propose 
a common policy for reducing the 
carbon footprint of the administra ‑
tive operations of the EU institutions 
and bodies. Such a policy should:
(a) include a quantified overall reduc ‑
tion target for greenhouse gas 
emissions for the year 2030, and 
preferably also 5‑year intermediate 
milestones;
(b) be in line with the EU approach in 
international climate negotiations 
and therefore the target should 
be set as an absolute reduction 
target.
107  
The 15 audited EU institutions and 
bodies have no common approach for 
monitoring their GHG emissions. Six 
of them did not report their emissions 
and those doing so did not calculate or 
disclose their full extent. Consequent ‑
ly, the full carbon footprint of the EU 
institutions and bodies is not known 
and the patchy information available 
risks undermining the credibility of 
reporting and mitigation efforts.
38 Conclusions and recommendations
108  
Evidence that GHG emissions caused 
by EU institutions and bodies as 
a whole have been falling is only 
available for energy consumption in 
buildings. Data available on emissions 
caused by mobility do not allow a clear 
trend to be identified. Upstream emis ‑
sions caused by the production of pur ‑
chased goods, by the services bought 
and by the construction of buildings 
are often ignored.
109  
The reductions achieved so far are 
largely attributable to the purchase 
of electricity generated from renew ‑
able sources which generally counts 
as a zero emission in carbon footprint 
calculations.
Recommendation  
Harmonised calculating 
and reporting of emissions
2.  The EU institutions and bodies 
should introduce a harmonised ap ‑
proach for calculating and reporting 
their direct and indirect greenhouse 
gas emissions. Reporting should:
(a) include all relevant indirect emis ‑
sions, taking into account the 
development of the Commission’s 
organisation environmental foot ‑
print method;
(b) allow progress in achieving 
reduction targets in the various 
EU institutions and bodies to be 
measured.110  
Only limited use has been made of 
voluntary offsetting to compensate for 
residual emissions and the EU institu ‑
tions and bodies do not have a com ‑
mon approach to the issue.
Recommendations  
Common approach to 
voluntary offsetting
3.  The EU institutions and bodies 
should develop a common approach 
through EMAS to compensate for 
their residual greenhouse gas emis ‑
sions on a voluntary basis.
4.  When offsets are used, they should 
be of high quality and be verified 
under recognised schemes.
5.  When offsets are used, they should 
be targeted on projects which do 
not only contribute to reducing 
emissions but also to sustainable 
development in terms of benefits for 
the local population concerned by 
the projects.
111 
The EU institutions and bodies do not 
make full use of the environmental 
management tools promoted by the 
Commission. This risks undermining 
both their credibility and the credibil ‑
ity of these tools.
39 Conclusions and recommendations
112  
Progress in introducing the European 
eco‑management and audit scheme 
has been slow. EMAS registration for 
public administrations has been possi ‑
ble since 2001 and, in June 2014, seven 
of the audited EU institutions and 
bodies were registered. EMAS at the 
Commission had significant limitations 
in scope.
113  
Green procurement is treated as an 
option rather than an obligation under 
the current EU financial rules and only 
a few EU institutions and bodies used 
it systematically. The Court found in 
160 relevant procedures examined 
that more than half of them either did 
not include any environmental cri ‑
teria or only used weak criteria which 
were unlikely to have any impact on 
the outcome of the procedure. The 
Commission’s voluntary GreenBuilding 
standards for energy performance are 
not systematically used for new build ‑
ings and major renovation projects.114  
At the time of the audit none of the 
EU institutions and bodies had signed 
up to the voluntary European Code 
of Conduct on Data Centre Energy 
Efficiency.
Recommendations  
Full implementation 
of EMAS and green 
procurement
6.  All EU institutions and bodies should 
register with the European eco‑  
management and audit scheme 
EMAS and implement it while pro ‑
gressively reducing any scope limita ‑
tions. They should also consider 
signing up to the European Code on 
Data Centre Energy Efficiency.
7.  Green procurement should be used 
by the EU institutions and bodies, 
wherever possible. The financial 
rules and/or the procurement rules 
applicable to the EU institutions and 
bodies should provide the tools for 
contributing to the protection of the 
environment and sustainable devel ‑
opment, while ensuring that they 
can obtain best value for money for 
their contracts.
This report was adopted by Chamber IV, headed by Mr Milan Martin CVIKL, 
Member of the Court of Auditors, in Luxembourg at its meeting of 24 June 2014.
 For the Court of Auditors
 Vítor Manuel da SILVA CALDEIRA  
 President
40
 Annex
Audit approach for assessing green public procurement
The audit assessed 160 procurement procedures above the threshold of 60 000 euro which were relevant for 
green procurement to see whether the documents relating to the calls for tenders included environmental 
 criteria. Offers received or award decisions made in connection with these procedures were not assessed.
Criteria for assessing tender documents
Green public procurement (GPP) is defined by the Commission as ‘a process whereby public authorities seek to 
procure goods, services and works with a reduced environmental impact throughout their life cycle when com ‑
pared to goods, services and works with the same primary function that would otherwise be procured’1.
The Commission has provided guidance on GPP2 and developed a toolkit for preparing calls for tenders which, 
at the time of the audit, covered 19 different product/service groups3. Two types of criteria are proposed for 
each of these groups: ‘core’ criteria and more ambitious ‘comprehensive’ criteria. According to DG Environment:
(a) the core criteria  are those suitable for use by any contracting authority and address key environmental 
impacts; they are designed to be used with minimum additional verification effort or cost increases to allow 
easy application of GPP;
(b) the comprehensive criteria  are for those who wish to purchase the best environmental products available 
on the market; these may require additional verification effort and/or increase cost compared to other prod ‑
ucts with the same functionality.
Example of core criteria vs comprehensive criteria for copying and graphic paper
Purchase of recycled office paper made from 100 % recovered paper fibres
Core criteria Comprehensive criteria
Paper must be made from 100 % recovered paper fibres. 
Recovered paper fibres include both post-consumer recycled fibres and 
pre-consumer recycled fibres from paper mills, also known as broke. 
Post-consumer recycled fibres may come from consumers, offices, printing 
houses, bookbinders or similar.Paper must be made from 100 % recovered paper fibres, with a minimum of 
65 % post-consumer recycled fibres. 
Recovered paper fibres include both post-consumer recycled fibres and 
pre-consumer recycled fibres from paper mills, also known as broke. 
Post-consumer recycled fibres may come from consumers, offices, printing 
houses, bookbinders or similar.
The paper must be at least elementary chlorine free (ECF). Totally chlorine 
free (TCF) will also be accepted.The ecological criteria of the EU Ecolabel, or other type I national ecolabels 
directly related to paper production (and not the management practices of 
the factory), must be met. Full criteria documents available at: 
EU Ecolabel: http://ec.europa.eu/environment/ecolabel/product/
pg_copyingpaper_en.htm
Source:  ‘Copying & graphic paper — Green public procurement (GPP) product sheet’, European Commission GPP training toolkit — Module 3: 
Purchasing recommendations, Brussels, 2008 ( http://ec.europa.eu/environment/gpp/pdf/toolkit/paper_GPP_product_sheet.pdf ).
1 COM(2008) 400 final, p. 4.
2 Buying green! A handbook on green public procurement , second edition, 2011.
3 1. Copying and graphic paper; 2. Cleaning products and services; 3. Office IT equipment; 4. Construction; 5. Transport; 6. Furniture; 7. Electricity; 
8. Food and catering services; 9. Textiles; 10. Gardening products and services; 11. Windows, glazed doors and skylights; 12. Thermal insulation; 
13. Hard floor coverings; 14. Wall panels; 15. Combined heat and power (CHP); 16. Road construction and traffic signs; 17. Street lighting and traffic 
signals; 18. Mobile phones; 19. Indoor lighting.Annex
41 Annex
Wherever possible, the audit assessed tender documents against the recommendations in the toolkit. Where the 
toolkit did not cover the relevant area, the audit team applied toolkit criteria for other product/service groups 
by analogy. Examples: there were no toolkit criteria for photocopiers but some toolkit criteria for IT equipment 
could be applied by analogy; there were no toolkit criteria for renting or leasing a building but certain criteria 
from the toolkit product sheet on construction could be used.
Five categories to classify procedures
The following five categories were used to classify the procedures examined.
Not green
Tender documents do not include any reference to environmental considerations or only clauses without 
impact on the purchasing approach. Examples: a copy of/reference to the general environmental policy of the 
institution is included or compliance with applicable environmental legislation is required.
Light green
(a) If toolkit available : Only partly compliant with the core criteria. Where the main ‘green’ focus of the procedure 
is on award criteria, the weighting of environmental criteria as a share of the total weighting (for price and 
quality) is below 10 %.
(b) If toolkit not available : Tender documents include some environmental clauses but these clauses concern only 
(a) secondary feature/features of the proposed contract. Where the main ‘green’ focus of the procedure is on 
award criteria, the weighting of environmental criteria as a share of the total weighting (for price and quality) 
is below 10 %.
Green
(a) If toolkit available : Fully or largely compliant with the core criteria and/or partly compliant with the compre ‑
hensive criteria. Where the main ‘green’ focus is on award criteria, the weighting of environmental criteria as 
a share of the total weighting is 10 % or more.
(b) If toolkit not available : Tender documents include significant environmental clauses which concern the 
pri mary function of the goods, services or works to be procured. Where the main ‘green’ focus is on award 
 criteria, the weighting of environmental criteria as a share of the total weighting is 10 % or more.Annex
42 Annex
Very green
(a) If toolkit available : Fully or largely compliant with comprehensive criteria. This means the inclusion of envir ‑
onmental selection criteria, high environmental requirements in the technical specifications and/or a strong 
emphasis on environmental aspects in award criteria (weighting of 25 % or more).
(b) If toolkit not available : Tender documents largely based on best environmental practice. This means the inclu ‑
sion of environmental selection criteria, high environmental requirements in the technical specifications 
and/or a strong emphasis on environmental aspects in award criteria (weighting of 25 % or more).
Green by nature
This is a category where the primary function of the goods, services and works to be procured is green, for 
example the construction of a green roof or the procurement of consultancy services to improve environmental 
performance.
The sample selected
A total of 160 public procurement procedures were examined from all audited EU institutions and bodies with 
the exception of the European External Action Service4.
The sample included procedures launched and/or finalised over the period from January 2012 to February 2013. 
Some procedures launched before or after this period were also included in order to obtain a more complete 
picture, notably for smaller EU institutions and bodies with a few procurement procedures.
4 The EEAS has informed the Court that it does not yet apply the green public procurement procedures promoted by the Commission.Annex
43
The European Commission
Executive summary
I
The European Union leads in proactive climate pol ‑
icy and implementation at international level. In the 
view of the Commission, EMAS is the appropriate 
policy instrument to reduce the carbon footprint of 
EU institutions and bodies. Furthermore, there are 
many examples of where policies implemented in 
relation to the achieving the 20 % emissions reduc ‑
tion goal for 2020 also apply to public administra ‑
tions, including EU institutions and their personnel. 
This will continue to be the case regarding the new 
goals for 2030 (including the proposed 40 % green ‑
house gas emissions reduction target).
The Commission has an environmental policy for its 
own activities that prioritises pollution prevention, 
natural resource efficiency, CO2 emissions reduc ‑
tion, lower waste generation, promotion of recy ‑
cling, inclusion of environmental criteria in calls for 
tender, respect of environmental legislation, more 
sustainable behaviour in staff and stakeholders, etc.
It is therefore the Commission’s strategy to reduce 
the real environmental impact of its daily and 
administrative activities through the EMAS environ ‑
mental management system.
The Commission seeks, through EMAS, to achieve 
real reductions in impact, rather than through miti ‑
gating (particularly offsetting) CO2 emissions.
Given the Commission’s size and organisation, 
the EMAS system was first implemented in a small 
number of its buildings in Brussels and its scope has 
been gradually expanded. In 2013 the EMAS regis ‑
tration covered 89 % of staff and 57 % of floor space 
across all sites.The European Council and 
the Council of the European 
Union 
The General Secretariat of the Council (GSC) is 
aware of the growing importance of environmen ‑
tal issues and has been taking steps to improve 
the environmental performance of its activities 
for many years. Recognising the positive contribu ‑
tion it can make to the sustainable development of 
society, the GSC aims to enshrine the principles of 
sound environmental management in its day ‑to‑
day work. The GSC is developing an environmental 
management programme to enable the Commu ‑
nity eco ‑management and audit scheme (EMAS), 
as defined in Regulation (EC) No 1221/2009 of the 
European Parliament and of the Council, to be 
implemented.
Finally, the GSC notes that the objectives of its 
envir onmental management programme are in line 
with the recommendations made by the Court.Replies of the audited EU 
institutions and bodies
Replies of the audited EU institutions and bodies 44
VII
The Commission partially accepts this recommen ‑
dation. In the view of the Commission, EMAS is the 
appropriate policy instrument to reduce the carbon 
footprint of EU institutions and bodies. The Com ‑
mission will therefore consider this recommenda ‑
tion through the further deployment of EMAS. 
However, setting a quantified overall reduction tar ‑
get for greenhouse gas emissions for the year 2030 
does not take account of wider considerations, such 
as cost effectiveness and specificities across EU 
institutions and bodies. 
Furthermore, the Commission will continue to 
develop appropriate policies to reduce greenhouse 
gas emissions in a cost ‑effective and, as far as possi ‑
ble, holistic way, including in relation to 2030, based 
on thorough impact assessments providing a full 
evaluation of the costs and benefits involved, where 
appropriate.
Reducing emissions where least costly is a key 
aspect of current policy, which is why binding 
reduction targets only tend to be set on a European 
and Member State rather than an organisational 
basis. This retains flexibility to meet targets in the 
best way possible.
Although EU legislation does not impose specific 
emission reduction targets on public administra ‑
tions further action can still be taken at this level, 
including through the continued deployment 
of EMAS which constitutes a common policy for 
reducing the carbon footprint of the administrative 
operations of the EU institutions and bodies.
VII (a)
The Commission accepts the recommendation sub ‑
ject to the successful development of the organisa ‑
tion environmental footprint method in relation to 
public administrations. Furthermore, the Commis ‑
sion considers that, through the implementation of 
EMAS, it has established a proper way of identify ‑
ing, measuring and reporting on the most signifi ‑
cant direct and indirect environmental impacts, 
including its GHG emissions.In the current budgetary climate, the Commission 
extends its system progressively with the avail ‑
able resources. The Commission leads by example, 
encouraging other institutions and bodies to imple ‑
ment EMAS by chairing the GIME (Groupe inter ‑
institutionnel de management environnemental).
II
The Commission is continuously expanding the 
scope of the EMAS and its reports on emissions. 
The huge progression of the EMAS’s scope indi ‑
cates clearly the commitment of the Commission to 
reducing its environmental impacts. Full reporting 
is still the objective for the Commission when the 
EMAS is fully implemented.
IV
The Commission has achieved an important reduc ‑
tion in CO2 emissions in Brussels since 2005 per 
square metre without assuming that electricity 
generated from renewable sources generates zero 
emissions (– 46,2 % between 2005 and 2012 in the 
EMAS office buildings).
V
In the Commission, the implementation of EMAS 
and its continuous extension has progressed well 
taking into account the requirements of the regu ‑
lation and budgetary limitations. In addition, the 
extension of EMAS has to be considered as import ‑
ant related to its size, the geographical distribution 
and organisation pattern.
Introducing environmental criteria into public 
procurement is one of the objectives of the environ ‑
mental policy of the Commission.
VI
The Commission intends to continue the deploy ‑
ment of EMAS, which constitutes a common policy 
for reducing the carbon footprint of the administra ‑
tive operations of the EU institutions and bodies.
Replies of the audited EU institutions and bodies 45
Introduction
01
The classical definition of sustainable development 
is development that meets the needs of the present 
without compromising the ability of future gener ‑
ations to meet their needs. It therefore embraces 
the concept of ‘limitations’ to ensure that the envir ‑
onment can meet both present and future needs.
04
The European Union leads in proactive climate 
policy and implementation at an international level. 
There are many examples of where policies imple ‑
mented in relation to achieving the 20 % emis ‑
sions reduction goal for 2020 also apply to public 
administrations, including EU institutions and their 
personnel. This will continue to be the case regard ‑
ing the new goals for 2030 (including the proposed 
40 % greenhouse gas emissions reduction target).
06
The Commission plans to continue in its proactive 
approach to climate policy and implementation 
and will continue to develop appropriate policies to 
reduce greenhouse gas emissions in a cost ‑effective 
and, as far as possible, holistic way. Although EU 
le gislation does not impose specific emission reduc ‑
tion targets on public administrations further action 
can still be taken at this level, including through the 
continued deployment of EMAS. The huge progres ‑
sion of the EMAS scope indicates clearly the com ‑
mitment of the Commission to reducing its environ ‑
mental impacts.
07
The Commission will continue to seek real reduc ‑
tions in emissions via existing policies, including 
EMAS, while also considering other options such as 
offsetting.VII (b)
The Commission accepts this recommendation 
whilst underlining the voluntary approach and the 
autonomy of each EU institution and body to decide 
the appropriateness of such possible offsetting.
Furthermore, the Commission will continue to seek 
real reductions in emissions via existing policies, 
including EMAS.
Such a common approach will also have to take into 
account:
(i) the need to avoid discouragement of further ef ‑
forts to achieve real reductions in emissions;
(ii) the existing mechanisms including emissions 
trading; and
(iii) the availability of reporting regimes and suffi ‑
ciently high‑standard offsetting schemes. It will 
also require an assessment of the effects on EU 
resources and use of public money.
VII (c)
The Commission accepts this recommendation and 
fully supports the promotion of the EMAS. Scope 
limitations are part of the EMAS itself in order to 
allow each organisation to address the most signifi ‑
cant environmental aspects.
The Commission will consider signing the European 
Code on Data Centre Energy Efficiency after fur ‑
ther evaluating if it is compatible with the financial 
perspectives, and especially for administrative 
appropriation.
The current revision of the FR/RAP sets in place the 
regulatory framework encouraging further green 
public procurement, including life ‑cycle costing, in 
line with Directive 2014/24/EU. 
The Commission will further develop guidance 
documents for GPP and promote those documents 
at the GIME group.
Replies of the audited EU institutions and bodies 46
21
Increasing the scope of activities covered is already 
tackled in the 2014 EMAS action plan and will lead 
to a more complete report for 2013 and further 
results.
29
The OEF method, as recommended by the Commis ‑
sion, is currently subject to extensive pilot testing 
until the end of 2016. 
The objectives of the pilot phase include the defin ‑
ition of certain technical requirements which will 
be key to the wide implementation of the method 
in an administration organised like the Commission. 
Moreover, the results of the pilot phase will prob ‑
ably lead to the revision/improvement of the OEF 
method. During this exercise, the Commission has 
given priority to the development of OEF sectorial 
rules (OEFSRs) for those sectors representing the 
highest share of environmental impacts. The public 
administration sector is not one of these. After 
reviewing the results of the pilot phase, once the 
revised OEF method is available, the Commission 
will consider the possibility of launching an internal 
pilot phase to develop specific sectorial rules for 
the calculation and reporting of the environmen ‑
tal footprint of the Commission or similar public 
administrations.
31
Emissions used in 1990 are unknown for the major ‑
ity of organisations. Assessing their current per ‑
formance against actual emissions in 1990 is usually 
done through estimations.
35
The Commission considers that reporting emis ‑
sions as zero based on use of green electricity 
might hide the real decrease (or increase) in energy 
consumption.
37
By buying green electricity the institutions encour ‑
age electricity producers to opt for renewable 
generation facilities.Such consideration will also have to take into 
account: 
(i) the need to avoid discouragement of further ef ‑
forts to achieve real reductions in emissions;
(ii) the existing mechanisms, including emissions 
trading; and
(iii) the availability of reporting regimes and suffi ‑
ciently high‑standard offsetting schemes. It will 
also require an assessment of the effects on EU 
resources and use of public money.
Observations
12
The reliable and comprehensive information on the 
carbon footprint is not a precondition to draw and 
implement mitigation strategies. At the Commis ‑
sion, mitigations are in place, with clear environ ‑
mental impact reductions evident. 
16
The Commission considers that the use of the com ‑
mon method (OEF) to measure and communicate 
the life ‑cycle environmental performance of organi ‑
sations in accordance with its recommendation of 
9 April  2013 should be encouraged, including by 
EMAS ‑registered organisations. After reviewing 
the results of the pilot phase, once the revised OEF 
method is available, the Commission will consider 
the possibility of launching an internal pilot phase 
to develop specific sectorial rules for the calculation 
and reporting of the environmental footprint of the 
Commission or similar public administrations.
18
As regards the reference to EU institutions and bod ‑
ies not reporting all elements of their GHG emis ‑
sions, the EMAS regulation indicates that organisa ‑
tions must report on emissions where appropriate 
and where significant. Organisations are allowed to 
report partially their direct and indirect emissions 
depending, amongst other on the scope of their 
EMAS registration. If organisations do not report at 
all on one of the EMAS core indicators, an explana ‑
tion has to be given.
Replies of the audited EU institutions and bodies 47
Although EU legislation does not impose specific 
emission reduction targets on public administrations, 
further action can still be taken at this level, including 
through the continued deployment of EMAS.
52
A very wide range of possible offset credits exist, of 
very variable quality.
Rules exist governing the use of offsets for compli ‑
ance under EU climate legislation, which, for rea ‑
sons of consistency, should be reflected in any use 
of offsetting by EU institutions. These rules relate 
to both the quantity relative to own action and the 
type considered of sufficient quality. It is essential, 
for example, to ensure that actions used for offset ‑
ting are additional, subject to sound monitoring, 
reporting and verification to minimise the opportu ‑
nities for fraud and subject to accounting rules that 
avoid the possibility of double counting.
The Commission will continue to give first priority 
to seeking real reductions in emissions via existing 
policies, including EMAS, while also considering 
other options such as offsetting.
Such consideration also needs to take into account: 
(i) requirements to avoid discouragement of further 
efforts to achieve real reductions in emissions;
(ii) the existing mechanisms, including emissions 
trading; and
(iii) the availability of reporting regimes and suffi ‑
ciently high‑standard offsetting schemes. It will 
also require an assessment of the effects on EU 
resources and use of public money.
61 — Last indent
The Commission will continue to seek real reduc ‑
tions in emissions via existing policies, including 
EMAS, while considering the recommendation to 
develop a common approach to offsetting for the 
EU institutions.
It is important to bear in mind that, since 2012, 
CO2 emissions from all flights within and between 
European Economic Area (EEA) countries have been 
covered by the EU emissions trading system (this 
has applied to Croatia from 1 January 2014). 39 (c)
Most visitors and external participants may report 
on their travel emissions through their own organ ‑
isation which might lead to double counting.
44
Although EU legislation does not impose specific 
emission reduction targets on public administra ‑
tions, further action can still be taken at this level, 
including through the continued deployment of 
EMAS.
Reducing emissions where least costly is a key 
aspect of current policy, which is why binding 
reduction targets only tend to be set at European 
and Member State level rather than on an organi ‑
sational basis. This retains the flexibility to meet 
targets in the best way possible.
46
In the EMAS Steering Committee of January 2014, 
the Commission decided to establish long term tar ‑
gets in addition to the annual targets already exist ‑
ing. This was decided to give better guidance to its 
services in establishing annual targets and actions.
47
Since the Commission staff is decreasing (– 5 % 
under the current financial perspectives), and since 
its EMAS scope is continuously evolving, it will con ‑
tinue to report in both absolute and relative terms.
51
The Commission will continue to develop appropri ‑
ate policies to reduce greenhouse gas emissions in 
a cost ‑effective and, as far as possible, holistic way, 
including in relation to 2030, based on thorough 
impact assessments providing a full evaluation of the 
costs and benefits involved, where appropriate.
Reducing emissions where least costly is a key 
aspect of current policy, which is why reduction tar ‑
gets only tend to be set at European and Member 
State level rather than on an organisational basis. 
This retains the flexibility to meet targets in the 
best way possible.
Replies of the audited EU institutions and bodies 48
76
It should be emphasised that the decrease by 15 % 
between 2005 and 2012 in energy consumption in 
Brussels buildings was achieved when, in relation to 
enlargement, Commission staff increased by 25 %. 
79
The financial regulation (FR) and its rules of applica ‑
tion (RAP) provide the same principles as those con ‑
tained in the directives so that EU rules are coherent 
with those applied by the Member States.
The new FR and RAP that are under the approval 
procedure should encourage further the use of 
environmental considerations, including life ‑cycle 
costing as an award method in line with Directive 
2014/24/EU.
80
The FR/RAP is a horizontal regulation not meant to 
list sectorial obligations per policy, but to provide 
general rules for the implementation of the budget.
The FR/RAP currently under the approval procedure 
should foresee that, when using life ‑cycle costing, 
the EU institutions shall use methods adopted at 
EU level whenever available. The implementation 
of this possibility should be carried out by relevant 
services within the EMAS policy.
81
The Commission considers appropriate to use the 
vade ‑mecum and specific guidance to promote 
green public procurement on a voluntary basis 
while ensuring the dissemination of good practices 
also serving as reference to the Member States.This means air operators must acquire and surren ‑
der allowances to cover all such emissions. Flights 
within the EEA are thus subject to the EU ETS car ‑
bon price, and this can be considered equivalent to 
offsetting.
See comment on point 52.
65
The Commission would like to point out that Table 6  
does not reflect the actual square metres covered 
but only the percentage of building surface areas. 
67
One should not underestimate the efforts to com ‑
ply with the EMAS requirements. The Commission is 
by far the biggest institution. The Commission has 
a very clear policy of progressively expanding EMAS 
to all its sites and activities within the available 
budget (see Decision C(2013) 7708).
68
The extension of the EMAS to Brussels and Luxem ‑
burg started immediately after the 2009 decision, 
with full activities registered in 2010 for Brussels 
and in 2012 for Luxembourg. Full buildings registra ‑
tion will be done in 2015 in Brussels and progres ‑
sively at the other sites.
69
The decision to certify under ISO 14001 the five 
sites of the Joint Research Centre was taken before 
the Commission decided to expand the EMAS in 
2009. EMAS registration for these sites is currently 
ongoing.
70
The Commission has decided that the extension of 
the EMAS has to be monitored at senior level by the 
EMAS Steering Committee. Extension is progres ‑
sively done with the most significant sites first. In 
terms of surfaces, the Commission’s representations 
in Member States represent about 2 % of the total 
Commission buildings; some of them are operated 
by other institutions. 
Replies of the audited EU institutions and bodies 49
87
It is a very resource ‑intensive process to update 
criteria. The Commission is endeavouring to close 
existing gaps and revise product groups in the 
framework of existing resources. The mobile phone 
criteria have been taken off the website because 
they were indeed not ambitious anymore and 
moreover, they have not been identified as a higher 
priority by the GPP Advisory Group.
89
Using a life ‑cycle costing (LCC) approach does not 
necessarily make sense for all product groups. For 
example, if procurers want to buy environment ‑
friendly paper, it would be enough to specify that 
the paper should be ‘recycled’ or ‘originating from 
sustainable sources’, because with this product 
group, the procurer would not have maintenance or 
operating costs.
The Commission is preparing the transposition of 
this directive in the financial regulation. However, it 
does not make the use of LCC mandatory.
89 — Last indent
The Commission is currently looking into providing 
guidance documents for LCC.
90
The Commission has targets for buildings energy 
and achieves positives results under the EMAS 
scheme. In Brussels, for instance, where the energy 
efficiency directive (Directive 2012/27/EU) result in 
0,13 % of annual energy savings, the Commission 
drafted in its plan 1 % annual energy savings, eight 
times higher.
1 ‘The uptake of green public procurement in the EU ‑27’, Centre 
of European Policy Studies, http://ec.europa.eu/environment/gpp/
pdf/CEPS ‑CoE ‑GPP%20MAIN%20REPORT.pdf
2 Council conclusions of 22  September  2008 ( http://register.
consilium.europa.eu/doc/srv?l=EN&f=ST%2013067%202008%20INIT ).84
Overall, some kind of GPP is used in the majority of 
cases, although many processes are not fully green. 
Only about a quarter of contracts did not include 
green criteria. With this result, the institutions are 
faring better than the average of public authori ‑
ties in Europe. According to a study1, based on an 
EU‑wide survey, on average 54 % of public authori ‑
ties included some kind of green criterion in their 
last purchase in the period 2009–10 for 10 priority 
product groups (Construction; Electricity; Cleaning 
products and services; Textiles; Food and catering 
services; Furniture; Office IT equipment; Paper; Gar ‑
dening products and devices; Transport).
85
In the Commission communication ‘Public procure ‑
ment for a better environment’ (see footnote 43), 
the Commission proposed that, by the year 2010, 
50 % of all tendering procedures should be green, 
where ‘green’ means ‘compliant with endorsed 
common “core” GPP criteria’. The percentage would 
be expressed in both number and value of green 
contracts as compared to the overall number and 
value of contracts concluded in the sectors for 
which common ‘core’ GPP criteria have been identi ‑
fied. This target was later endorsed by the Council2. 
Since the Court also included product groups for 
which no EU GPP criteria exist, the methodologies 
on how to evaluate the achievement of the GPP 
target are not entirely compatible.
86
Together with the Member States represented in 
the informal GPP Advisory Group, DG Environment 
conducted a GPP prioritisation exercise in 2012/13 to 
identify the needs for GPP criteria development. Data 
centres have received a high priority, and it will be 
decided soon if data centre criteria will be developed. 
Building maintenance is expected to be included in 
the upcoming office building criteria. Business travel 
was not considered to have a specific priority.
Replies of the audited EU institutions and bodies 50
101
The requirements of the Code of Conduct for Data 
Centres in the Commission buildings would have 
very important budgetary implications. The deci ‑
sion to go forward would also imply a serious 
revision of the buildings and some requirements 
cannot even be implemented in the Commission 
buildings due to their age. Nevertheless, the inter ‑
nal organisation of the data centres respects the 
recommendations of the code of conduct.
In addition to its own data centres, the Commission 
has rented data centre facilities in Luxemburg and 
Brussels. The owners of these data centre facilities 
have signed the code of conduct.
Commission is currently reflecting on its data centre 
policy, including the use of the ‘Cloud’. 
Conclusions and recommendations
102
The European Union leads in proactive climate 
policy and implementation at international level 
and this approach will continue in relation to the 
new goals for 2030 and the proposed 40 % green ‑
house gas reduction target.
103
In the view of the Commission, EMAS is the appro ‑
priate policy instrument to reduce the carbon 
footprint of EU institutions and bodies. 
Furthermore, there are many examples of where 
policies implemented in relation to achieving the 
20 % emissions reduction goal for 2020 also apply 
to public administrations, including EU institu ‑
tions and their personnel. This will continue to be 
the case regarding the new goals for 2030 (includ ‑
ing the proposed 40 % greenhouse gas emissions 
reduction target). 93
While this programme is still ongoing, OIB, OIL 
and JRC’s priority have been in compliance with 
the applicable national or regional standards. This 
does not preclude the possibility that some of the 
more recent building projects of the Commission, 
and in particular those underway on the JRC’s Ispra 
site, would indeed comply with the GreenBuilding 
programme’s requirements. OIB will join the pro ‑
gramme in the future if there is added value.
94
The ‘Manual of standard building specifications’ 
(MIT) aims at achieving passive building perform‑
ance and establishes the following minimum pro ‑
ject requirements:
 — Directive 2010/31/EU on the energy perfor ‑
mance of buildings;
 — regional legal minimum requirements.
The MIT also requires that energy audits and/or 
energy studies be carried out in order to assess the 
implementation of energy efficiency solutions and 
the introduction of renewable energy.
95
The Commission is committed to the exemplary role 
of public bodies’ through its engagement to apply 
the requirements of the energy efficiency direc ‑
tive (Directive 2012/27/EU, Articles 4 and 5) and OIB 
(Brussels) has assessed the technical impact of the 
directive on its buildings.
In any case (for both new buildings and renovations), 
the ambitions of future projects and the associated 
financial impact should respect the available annual 
budget appropriation under the MFF 2014–20.
100
The Commission does not limit its approach to 
energy efficiency of a building and considers that 
BREEAM or similar schemes are more comprehen ‑
sive and better in line with its policies and the 
global environmental impact of its activities. 
Replies of the audited EU institutions and bodies 51
Although EU legislation does not impose specific 
emission reduction targets on public administra ‑
tions, further action can still be taken at this level, 
including through the continued deployment of 
EMAS, which constitutes a common policy for 
reducing the carbon footprint of the administrative 
operations of the EU institutions and bodies.
(a) and (b)  
The Commission does not accept this part of the 
recommendation, since it does not take account of 
wider considerations, such as cost effectiveness and 
specificities across EU institutions and bodies. Such 
an approach would require evidence of the benefits 
claimed. 
107
The Commission intends to increase the monitoring 
of its GHG emissions under the EMAS scheme.
108
The Commission has focused its efforts on the 
energy consumption of its buildings because it was 
the biggest GHG emission source where return on 
investment was the best. The Commission is cur ‑
rently addressing the issue of mobility that is the 
second major source of its emissions.
109
The Commission has not historically used a zero ‑
footprint approach for calculating the emissions 
of its electricity consumption from renewable 
sources in Brussels. In the EMAS office buildings 
energy consumption diminished by 40,5 % between 
2005 and 2012 (Brussels, kWh/m2).104
Commission policy aims at the reduction of GHG 
emissions in a cost ‑effective and, as far as possible, 
holistic way, in particular through the climate and 
energy package. In view of the limited proportion 
of emissions from administrative activities of EU 
institutions, the Commission has not considered 
it appropriate to set binding rules for this scale of 
activities. Emissions are in any case covered by the 
reduction targets set at EU or national levels.
105
There is no indication that binding rules for all the 
EU institutions and bodies would have led to better 
results.
106
The Commission intends to continue the deploy ‑
ment of EMAS, which constitutes a common policy 
for reducing the carbon footprint of the administra ‑
tive operations of the EU institutions and bodies.
Recommendation — Common policy to 
reduce greenhouse gas emissions
1.  
The Commission partially accepts this recommen ‑
dation. In the view of the Commission, EMAS is the 
appropriate policy instrument to reduce the carbon 
footprint of EU institutions and bodies. The Com ‑
mission will therefore consider this recommenda ‑
tion through the further deployment of EMAS.
Furthermore, the Commission will continue to 
develop appropriate policies to reduce greenhouse 
gas emissions in a cost ‑effective and, as far as pos ‑
sible, holistic way, including in relation to 2030, based 
on thorough impact assessments providing a full 
evaluation of the costs and benefits involved, where 
appropriate.
Reducing emissions where least costly is a key 
aspect of current policy, which is why binding 
reduction targets only tend to be set at European 
and Member State level rather than on an organisa ‑
tional basis. This retains flexibility to meet targets in 
the best way possible.
Replies of the audited EU institutions and bodies 52
Recommendations — Common 
approach to voluntary offsetting
3.  
The Commission accepts this recommendation 
whilst underlining the voluntary approach and the 
autonomy of each EU institution and body to decide 
the appropriateness of such possible offsetting.
Furthermore, the EU climate policy or legislation 
does not indeed foresee obligatory schemes to 
compensate for emissions. The Commission will 
continue to seek real reductions in emissions via 
existing policies, including EMAS.
A common approach to compensate for emissions 
will also have to take into account: 
(i) the need to avoid discouragement of further ef ‑
forts to achieve real reductions in emissions;
(ii) the existing mechanisms, including emissions 
trading; and
(iii) the availability of reporting regimes and suffi ‑
ciently high‑standard offsetting schemes. It will 
also require an assessment of the effects on EU 
resources and use of public money. 
4.  
The Commission accepts this recommendation. 
There is a very wide range of possible offset credits 
exist of very variable quality.
Rules exist governing the use of offsets for compli ‑
ance under EU climate legislation, which, for rea ‑
sons of consistency, should be reflected in any use 
of offsetting by EU institutions. These rules relate to 
both the quantity relative to own action and to the 
type considered of sufficient quality. It is essential, 
for example, to ensure that actions used for offset ‑
ting are additional, subject to sound monitoring, 
reporting and verification to minimise the opportu ‑
nities for fraud and subject to accounting rules that 
avoid the possibility of double counting.
The Commission will continue to give first priority 
to seeking real reductions in emissions via existing 
policies, including EMAS, while also considering 
other options such as offsetting.Recommendation — Harmonised 
calculating and reporting of emissions
2.  
The Commission accepts the recommendation 
subject to the successful development of the OEF 
methodology for public administrations. It consid ‑
ers that, through the implementation of EMAS, it 
has established a proper way of identifying, meas ‑
uring and reporting on its most significant direct 
and indirect environmental impacts, including its 
GHG emissions. Through EMAS and further inter ‑
institutional cooperation, institutions will be in 
position to have a harmonised approach in calculat ‑
ing their GHG emissions.
(a) 
The OEF method, as recommended by the Commis ‑
sion, is currently subject to extensive pilot testing 
until the end of 2016. The objectives of the pilot 
phase include the definition of certain technical 
requirements which will be key to the wide imple ‑
mentation of the method in a complex administra ‑
tion like the Commission. Moreover, the results of 
the pilot phase will probably lead to a revision/
improvement of the OEF method. During this 
exercise, the Commission has privileged the devel ‑
opment of OEF sectorial rules (OEFSRs) for those 
sectors representing the highest share of environ ‑
mental impacts. Obviously, the public administra ‑
tion sector is not part of these. After reviewing the 
results of the pilot phase, once the revised OEF 
method is available, the Commission will consider 
the possibility of launching an internal pilot phase 
to develop specific sectorial rules for the calculation 
and reporting of the environmental footprint of the 
Commission or similar public administrations.
110
The EU climate policy or legislation does not indeed 
foresee obligatory schemes to compensate for emis ‑
sions. The Commission has sought real reductions in 
emissions via existing policies, including EMAS.
Replies of the audited EU institutions and bodies 53
114
The Commission is considering further evaluating 
whether participation in the European Code on 
Data Centre Energy Efficiency is compatible with 
the financial perspectives, and especially adminis ‑
trative appropriation.
Recommendations — Full 
implementation of EMAS and green 
procurement
6.  
The Commission accepts this recommendation and 
fully supports the promotion of the EMAS scheme. 
Scope limitations are part of the EMAS scheme itself 
in order to allow each organisation to address the 
most significant environmental aspects.
The Commission will consider signing the European 
Code on Data Centre Energy Efficiency after fur ‑
ther evaluating if it is compatible with the finan ‑
cial perspectives, and especially administrative 
appropriation.
7.  
The Commission accepts this recommendation. 
The current revision of the FR/RAP sets in place the 
regulatory framework encouraging further green 
public procurement, including life ‑cycle costing, in 
line with Directive 2014/24/EU. 
The Commission will further develop guidance 
documents for GPP and promote those documents 
at the GIME group.5.  
The Commission accepts this recommendation, 
whilst recognising that the benefit for the local 
population is only one consideration that should be 
taken into account in the evaluation of the quality 
of offsets.
111
The Commission shares the observation of the 
Court that the institutions should adopt and/or bet ‑
ter use the EMAS scheme.
112
EMAS is a strong and demanding management tool 
and a quick implementation is not compatible with 
the financial limitations of most of the EU institu ‑
tions. The limitations of the EMAS scope are part 
of the EMAS system itself. EMAS has to be imple ‑
mented in a cost ‑effective and, as far as possible, 
holistic way.
113
Overall, some kind of GPP is used in the majority of 
cases, although many processes are not fully green. 
Only about a quarter of contracts did not include 
green criteria. With this result, the institutions are 
faring better than the average of public authorities 
in Europe. According to a study (see footnote 1 of 
the Commission’s reply), based on an EU ‑wide sur ‑
vey, on average 54 % of public authorities included 
some kind of green criterion in their last purchase 
for 10 priority product groups (Construction; Elec ‑
tricity; Cleaning products and services; Textiles; 
Food and catering services; Furniture; Office IT 
equipment; Paper; Gardening products and devices; 
Transport) in the period 2009–10.
For most of its building renovation and/or new con ‑
structions, the Commission uses generally BREEAM 
excellent standard, which is not only limited to 
energy performance.
Replies of the audited EU institutions and bodies 54
This allows a fairer assessment of the scale of the 
progress made so far, such as, in particular:
 — the setting in motion of the EMAS project;
 — the completion of a very comprehensive diag ‑
nostic report of GHG emissions resulting from 
the Court of Justice’s activities in 2010 and the 
updating of the carbon balance’s key items for 
2011  and  2012;
 — the significant reduction of GHG emissions 
since 2010 through the implementation of sev ‑
eral mitigation initiatives;
 — the increased consideration of environmental 
criteria in calls for tender;
 — the application of the BREEAM standard to the 
proposed fifth extension of the Court buildings.
The comprehensiveness of the Court 
of Justice’s carbon balance and the 
notable mitigation of its carbon 
footprint (12–61)
In an effort to take tangible measures in order to 
reduce its GHG emissions, the Court of Justice’s 
administration drew up, as early as 2010, an initial 
diagnostic report of the GHG emissions generated 
by its activities, the key items of the carbon bal ‑
ance having been updated in 2013 in relation to 
2011  and  2012.
In that context, it is important to note that the 
Court of Justice chose to make the scope of the 
diagnostic report very comprehensive; the item 
‘Travel’ incorporates not only commuting, but also 
travel for professional purposes and travel by visi ‑
tors. Moreover, efforts designed to mitigate the 
Court of Justice’s carbon footprint are not solely 
focused on ‘Energy’ alone.The Court of Justice of the 
European Union
Introduction (01–11)
As always in respect of annual reports or any other 
special report, the Court of Justice’s administration 
welcomes and takes very careful note of the obser ‑
vations of the Court of Auditors, and always endeav ‑
ours to take the necessary measures to implement 
any recommendations which may be made.
As shown by the present special report, the Court of 
Justice attaches great importance to the protection 
of the environment and, despite the restrictions on 
human and financial resources imposed in recent 
years, has made a firm commitment in this field, in 
particular by way of the comprehensive and struc ‑
tured EMAS (eco ‑management and audit scheme) 
framework. That commitment has already yielded 
noticeable results, as shown by the reduction of 
greenhouse gas (GHG) emissions achieved.
Accordingly, the purpose of the following replies is 
essentially to add useful information with regard to 
some of the observations and recommendations of 
the Court of Auditors.
Observations (12–101)
In general, the progress on environmental policy 
of the various European institutions would also 
benefit from being assessed in the light of the 
resources those institutions were in a position to 
allocate to it. It is thus worth noting that the Court 
of Justice undertook the efforts and initiatives that 
are mentioned in the present special report whilst 
being as efficient as possible in its use of resources 
(in particular by creating a single new post, granted 
by the budgetary authority and filled in 2012). 
Replies of the audited EU institutions and bodies 55
Concerning the failure to implement a system for 
offsetting GHG emissions, the Court’s administra ‑
tion considers that the financing of offsetting pro ‑
jects should be considered only when all other prior 
options for the elimination and reduction of exist ‑
ing emissions have been exhausted, in particular in 
order to maintain a substantial deployment of all 
players within the institution and better to encour ‑
age the taking of necessary initiatives in that field. 
Moreover, the Court’s administration is of the opin ‑
ion that the financing of offsetting projects requires 
the prior adoption of a common interinstitutional 
approach, particularly with regard to the definition 
of an appropriate budgetary framework, the criteria 
and types of eligible projects and the budget which 
could be allocated thereto.
The Court of Justice’s strong 
commitment to the implementation 
of the EMAS project (62–75)
It should be noted that the Court of Justice became 
very active in implementing the EMAS project in 
2012, in particular as a result of the appointment of 
the EMAS coordinator.
At first, the Court of Justice’s administration placed 
particular emphasis on the importance of regular 
communication with departments and staff and 
raising awareness in relation to environmental 
issues.
A two ‑tier operational structure was then 
established in order to steer the EMAS project 
sustainably.
In 2013, a scoping study was carried out in order to 
draw up the roadmap for the EMAS project within 
the institution. Besides a review of the institution’s 
current position from an environmental perspective 
in the light of the EMAS regulation requirements, 
the main objective of that study was to determine 
the stages to be reached in order to obtain regis ‑
tration, which should, according to the proposed 
schedule, be obtained in 2016.The diagnostic reports successively carried out 
made it possible objectively to record a reduction in 
the Court of Justice’s emissions since 2010, particu ‑
larly in the following areas:
 — from 2011 to 2012, GHG emissions from ‘travel 
by visitors’ were reduced by 14 %;
 — from 2010 to 2011 and from 2011 to 2012, GHG 
emissions linked to electricity consumption 
decreased respectively by 98 % and 6 %;
 — from 2011 to 2013, the cost of waste treatment 
was reduced by 25 % and the amount of domes ‑
tic waste decreased by 10 % during the same 
period.
Those reductions were in particular achieved as 
a result of the following projects:
 — the establishment of a green energy contract 
concluded with the electricity supplier;
 — the introduction of measures for the improve ‑
ment of building insulation;
 — the optimisation of the energy programming of 
certain buildings;
 — the reduction of organic waste and improve ‑
ments in waste sorting.
In addition, a more precise assessment of the emis ‑
sions linked to ‘commuting’ and ‘leakage of refriger ‑
ant gases’ has made it possible to improve the qual ‑
ity of the data relating to those two items of the 
carbon balance, thereby reducing the uncertainties 
inherent in those items.
In the interests of transparency, the reports relating 
to the Court of Justice’s carbon balance have been 
published on its Curia website and are thus avail ‑
able to European citizens.
Replies of the audited EU institutions and bodies 56
Relevance of the BREEAM standard 
for the purpose of better reducing the 
environmental impact of the Court’s 
buildings (90–101)
In order to minimise the environmental impact of 
its buildings, the Court of Justice’s administration 
preferred, for the proposed fifth extension of the 
Court of Justice’s buildings, the BREEAM standard 
to the GBP standard used by the Court of Audi ‑
tors as a benchmark. The BREEAM standard is not 
confined to ‘energy ‑saving’ matters; it also includes 
others that are at least as important (such as water 
consumption, waste management and sustain ‑
able mobility), which is certainly the reason why 
that standard is the most widely applied within the 
European institutions.
Conclusions and recommendations 
(102–114)
Overall, the Court of Justice welcomes the observa ‑
tions and recommendations set out in the present 
report of the Court of Auditors.
Concurring with the Court of Auditors’ conclusions, 
the Court of Justice recognises the importance 
of adhering to the EMAS scheme and has been 
actively committed thereto since 2012, in particular 
as a result of the appointment of the EMAS coordin ‑
ator, made possible as a result of the post granted 
by the budgetary authority. Notwithstanding the 
requirement for savings on resources which it must 
meet in the context of the current budget crisis, 
the Court of Justice’s objective is to obtain EMAS 
registration by 2016.
At the same time, the Court of Justice intends to 
continue mitigating its carbon footprint and to 
promote the use of environmental criteria in public 
procurement procedures for which it is responsible 
with due regard to the applicable regulations. In 
addition, the forthcoming fifth extension of the 
Court of Justice’s buildings will fully contribute to 
the reduction of the environmental impact of the 
Court’s building stock thanks to maximum compli ‑
ance with BREEAM requirements in that field.With regard to the environmental objectives, in 
particular the reduction of GHG emissions, the 
Court of Justice’s administration is more in favour of 
setting relative targets (for example, concerning the 
area of buildings and/or the number of people) that 
are measurable through indicators presented in the 
EMAS regulation (Regulation (EC) No 1221/2009). 
Indeed, the determination of absolute quantified 
targets recommended by the Court of Auditors is 
relevant only if the underlying database is suffi ‑
ciently reliable and if the evolution of the chosen 
indicator is likely to provide consistent information 
over time. However, while the conditions necessary 
for the establishment of a sufficiently reliable quan ‑
tified indicator are not satisfied at this stage, they 
should be in the near future as progress is made on 
the EMAS project.
Promoting the integration of 
environmental criteria in public 
procurement (green procurement) 
(77–89)
The Court of Justice’s administration shares the 
concern of the Court of Auditors to promote the 
integration of environmental criteria in public 
procurement and thereby to contribute to more 
sustainable development, including through the 
use of the ‘Green public procurement toolkit’ dis ‑
tributed by the Commission. That is why the Court 
of Justice’s ‘Vade ‑mecum on public procurement’ 
includes a specific section on green public procure ‑
ment, which indeed provides a direct link to the 
European Commission’s corresponding information. 
However, the Court of Justice’s administration is of 
the opinion that the authorising departments of 
each institution should be able to retain sufficient 
discretion with respect to environmental criteria so 
as to be able to weigh carefully the various assess ‑
ment criteria according to the specific features of 
the calls for tender issued.
Replies of the audited EU institutions and bodies 57
The European Central Bank
The European Central Bank (ECB) expresses its 
appreciation for the European Court of Auditors’ 
audit on how the EU institutions and bodies calcu ‑
late, reduce and offset their greenhouse gas emis ‑
sions and welcomes the Court’s special report. The 
ECB strongly believes in the importance of sustain ‑
able policies and in the power of concerted efforts 
to address the challenges that our economy and 
natural environments currently face. Therefore the 
ECB is particularly grateful for the Court’s general 
observations regarding the opportunities to be had 
from establishing a common approach for EU insti ‑
tutions in order to contribute to the achievement 
of the European Union’s long ‑term goal of reducing 
emissions. 
In this context, the ECB also notes the Court’s 
acknowledgement that it has taken steps to reduce 
the negative impact of its administrative operations 
on the environment, as reflected in the ‘Report on 
the audit of the management by the ECB of its car ‑
bon footprint’, published on 28 April 2014. Further 
to the ECB’s replies to this specific report, please 
find below the ECB’s comments to the observations 
and recommendations of the special report: 
Paragraph 08 — Table 1
The increase in the ECB’s headcount ceiling from 
1 448,5 full ‑time equivalent positions in 2012 to 
2 602 full ‑time equivalent positions in 2014 is 
mainly due to the establishment of the Single 
Supervisory Mechanism.
Paragraph 23
With regard to the emissions caused by staff com ‑
muting between home and work, the ECB is cur ‑
rently developing a calculation method with the 
aim of including them in the reporting of its next 
carbon footprint.Finally, the Court of Justice particularly supports 
the recommendations of the Court of Auditors in 
favour of greater harmonisation of approaches 
and strengthened interinstitutional cooperation in 
the audited field, in particular through initiatives 
launched or to be launched by the Commission. In 
that context, the Court’s administration is prepared 
to participate in any work that is necessary to define 
better common approaches.
Replies of the audited EU institutions and bodies 58
The European Court 
of Auditors
The Secretariat General (SG) of the European 
Court of Auditors welcomes the observations of 
the European Court of Auditors and expresses its 
appreciation for the Court’s recommendations for 
improvement.
Recommendation 2
The SG accepts the recommendation and will intro ‑
duce measuring and reporting of the Court’s direct 
and indirect GHG emissions, and will also set up 
reduction targets. The carbon footprint exercise and 
implementation of the GHG methodology will be 
set up as a prior objective in the environmental pro ‑
gramme at the end of the ongoing EMAS project.
Recommendation 3–5
The SG accepts the recommendations, will define a 
policy to compensate for the Court’s residual GHG 
emissions and will introduce high ‑quality offset ‑
ting. These actions will be undertaken immediately 
after completing the action described under recom ‑
mendation No  2.
Recommendation 6
The SG accepts the recommendation and the Court 
will register with the European Eco ‑Management 
and Audit Scheme. The implementation of the 
EMAS ‑type environmental management system is 
currently ongoing. The initial environmental review 
and the audit on the regulatory conformity of the 
Court’s buildings started on 10 April 2014.
The SG also supports the general concept and goals 
of the voluntary European Code of Conduct on Data 
Centre Energy Efficiency ‘to reduce energy con ‑
sumption in data centres throughout Europe, thus 
reducing emissions, limiting global warming and 
saving money’. Therefore, the SG will consider sign ‑
ing up to the code after cost–benefit analysis of the 
implications and risks involved. Many good prac ‑
tices, such as for instance virtualisation or green 
procurement of IT hardware, have been already 
applied by the Court’s services. Paragraphs 83 and 88
The ECB appreciates the Court’s acknowledge ‑
ment that it has made green procurement de facto  
mandatory in all relevant cases by way of internal 
instructions and systematic monitoring, and plans 
to begin reporting on its achievements in terms of 
implementing its sustainable procurement guide ‑
line in its annual environmental statements.
Recommendations 1 to 7
The ECB welcomes and supports the Court’s rec ‑
ommendations on developing common policies 
to reduce greenhouse gas emissions, harmonise 
the calculation and reporting of emissions and 
undertake the offsetting of remaining emissions. 
Furthermore, the ECB fully supports the objective 
of the voluntary European Code of Conduct for 
Energy Efficiency in Data Centres ‘to reduce energy 
consumption in data centres throughout Europe, 
thus reducing emissions, limiting global warming 
and saving money’, and will consider applying for 
participant status.
Replies of the audited EU institutions and bodies 59
The European External 
Action Service
The EEAS was created on 1 January 2011 and moved 
the majority of its staff at headquarters into a new, 
modern building which meets the best standards 
in terms of energy consumption and environmen ‑
tal protection. The EEAS also inherited three older 
buildings from the Council. Their lease expires in 
2018 and the EEAS is currently reflecting on how 
best to improve their efficiency and what alterna ‑
tive the real estate market in Brussels may offer.
The property management of the EEAS in Brussels is 
entrusted to the OIB via a service ‑level agreement, 
and the EEAS expects the OIB to implement best 
practices in terms of facility management. 
In 2012, the EEAS signed a contract for supplies of 
high ‑voltage electric power green energy for the 
headquarters buildings (contract EEAS ‑106 ‑DIVA4 ‑
SUP ‑DIR). It supplies 100 % green electricity (LGO) 
and also complies with supply licences at Belgian 
federal and regional level. 
Regarding the voluntary participation in EMAS, the 
EEAS is interested in learning more about the man ‑
agement of this program and the scope to imple ‑
ment it on a resource ‑neutral basis. Similarly, the 
EEAS is open to introducing ‘green procurement’ 
principles whenever this can be achieved (however, 
this is unfortunately not always the case for EU 
dele  gations in third countries).
We have nevertheless some good examples in 
delegations: installation of solar panels is at present 
being studied or implemented for delegations in 
Cambodia, Cape Verde, Kosovo and Samoa. Recommendation 7
The SG accepts the recommendation and will con ‑
tinue using green procurement in a more system ‑
atic manner by integrating GPP into the Court’s 
environmental management system — in particular, 
by development of internal procedures and by sys ‑
tematic monitoring.
Replies of the audited EU institutions and bodies 60
The European Economic and 
Social Committee and the 
Committee of the Regions of 
the European Union
65 — Table 6
Five of the Committees’ six buildings are an integral 
part of the scope of EMAS. The sixth building is 
shared with the Commission, which owns it. There ‑
fore the building was not included in the scope of 
the Committees’ environmental management sys ‑
tem, although the Committees’ staff working in this 
building must apply the relevant EMAS procedures.
The Committees are currently considering also 
including this building into their scope.
72 
The EESC and the CoR consider that all legal 
requirements (investments) and controls as a result 
of EMAS, which are important should be taken into 
account.
83 
In 2014 the Committees have decided that in the 
future all their directorates shall make compulsory 
consultations on green procurement with the EMAS 
team when the contract value exceeds € 60 000.
91
The EESC and the CoR agree that EU institutions 
and bodies would need to strive for buildings which 
meet the comprehensive criteria for construction of 
the GPP  toolkit.
However, in the urban area of Brussels where the 
Committee buildings are located, the possibilities of 
using localised renewable energy resources within 
the building site itself are limited. Therefore the 
Committees cannot implement option (b) of the 
GPP  toolkit for their buildings.In new construction projects in Burundi, Mexico 
and Niger we asked the architects in charge of the 
project to develop environmental solutions with 
the goal of reducing greenhouse gas emissions and 
devoting attention to the environmental aspects of 
the projects (i.e. sustainable materials, bioclimatic 
solutions, use of alternative energies, etc.). Other 
property markets are more difficult.
The EEAS is committed to doing more to limit its 
greenhouse gas emissions within the operational 
constraints it has to work with.
Replies of the audited EU institutions and bodies 61
Recommendation 3
The EESC and the CoR agree with the recommen ‑
dation that the EU institutions and bodies should 
develop a common approach to this topic.
However, spending on offsetting should only take 
place after all possible investments on reducing 
the environmental impact of the Committees have 
been made.
111
The Committees would like to stress that they make 
full use of the environmental management tools 
promoted by the Commission.
114
See reply to paragraph 101.
Recommendation 6
See replies to paragraphs 65 and 101.
Recommendation 7
The EESC and the CoR agree with the recommenda ‑
tion. In 2014 the Committees have decided that all 
directorates shall make compulsory consultations 
on green procurement with the EMAS team when 
the contract value exceeds € 60 000.Even if the Committees would increase substantially 
the number of solar panels on their buildings, this 
would account for a very low percentage of total 
electricity consumption. The Committees are study ‑
ing the option of a cogeneration installation in 
order to reduce their environmental footprint.
101 
The EESC and the CoR have analysed the code 
of conduct and note that this code is especially 
focused on data centres created after 2011, while 
the Committees’ data centres date from 2004.
Signing up to the code of conduct would impose 
an unnecessary burden on the Committees as they 
have already implemented many of the good  
‘IT equipment and services’ practices promoted 
by the code.
105
Despite the absence of binding rules for all insti ‑
tutions, the Committees have achieved tangible 
results in reducing their emissions through EMAS.
In 2013 per capita consumption of natural gas was 
51 % lower than in 2008, and per capita consump ‑
tion of electricity was 21 % lower than in 2008.
109
The Committees would like to stress that not only 
do they purchase green electricity, but they have 
also succeeded in reducing their energy consump ‑
tion thanks to technical investments (see also 
paragraph 105).
Recommendation 2
The EESC and the CoR agree with the recommen ‑
dation. Once there is a harmonised standard the 
Committees will consider calculating their direct 
and indirect greenhouse gas emissions and setting 
up a specific action plan. As long there is no har ‑
monised methodology for calculating the carbon 
footprint the Committees will invest their resources 
in the mitigation of the carbon footprint.
Replies of the audited EU institutions and bodies 62
Recommendation 1
The EIB would welcome a common policy for 
reducing the carbon footprint of the administrative 
operations of EU institutions and bodies, as sug ‑
gested in the recommendation.
Recommendation 2
A harmonised approach for calculating and report ‑
ing the direct and indirect greenhouse gas emis ‑
sions for EU institutions and bodies would be 
welcomed by the EIB.
Recommendations 3–5
The EIB is, as of 2013, offsetting its residual carbon 
emissions through carbon credits generated by 
a REDD+ project that is validated under the Verified 
Carbon Standard (VCS) and Climate, Community 
and Biodiversity Alliance (CCBA), gold level, and 
which does not only contribute to reducing emis ‑
sions but also to sustainable development in terms 
of benefits for the local population concerned.
Recommendation 6
The EIB takes note of the ECA recommendation and 
will give it close consideration in the context of its 
implementation of an environmental management 
system.
1 Reducing emissions from deforestation and degradation (REDD) 
was originated by the United Nations to help stop the destruction 
of the world’s forests. REDD+ goes beyond avoiding deforestation 
to include the roles of wildlife conservation, community 
development and job creation, and enhancement of forest carbon 
stocks, among other social development benefits.The European Investment 
Bank
General remark
The European Investment Bank (EIB) should like 
to thank the European Court of Auditors (ECA) for 
inviting the EIB to participate on a voluntary basis 
in the audit ‘How do the EU institutions and bodies 
calculate, reduce and offset their greenhouse gas 
emissions?’.
As the Bank of the European Union, the EIB puts 
corporate responsibility at the heart of its activities 
and has a proven record in identifying and man ‑
aging its environmental impacts. The EIB appreci ‑
ates the findings of the Court of Auditors, reflecting 
the strong performance of the Bank in this matter, 
and is pleased to further comment on the observa ‑
tions as follows:
19 and 24
The EIB is continually reviewing the emissions 
sources of its GHG inventory and will adjust the 
reporting scope as appropriate and practicable.
42
The EIB reduced per capita mobility emissions from 
11.10 tCO2e in 2007 to 7.10 tCO2e in 2012, a decrease 
of 36 %.
45, 48 and 50
The EIB believes reporting carbon emissions also in 
per capita terms better reflects the effects of oper ‑
ational factors such as business volumes and staff 
numbers on its carbon emissions. 
58
After having implemented long ‑term carbon 
reduction measures, which have largely come into 
effect, the EIB has decided to offset/compensate 
the residual carbon emissions starting with the 
2013 emissions, and has selected a REDD+1 project 
against which to compensate.
Replies of the audited EU institutions and bodies 63
18 and 19
Project GREEN is looking at ways to measure and 
report EASA’s environmental performance, includ ‑
ing its emissions for 2014 and beyond using 2013 as 
the baseline. It will take into account the European 
Parliament’s carbon footprint report when consid ‑
ering how best to measure and report its emissions.
45
Project GREEN will establish targets for reducing 
EASA’s GHG emissions, likely using 2013 as the 
benchmark.
59
Regarding carbon offsetting, in 2012 EASA intro ‑
duced carbon offsetting for business travel by train. 
In addition, project GREEN will encourage ‘climate ‑
friendly’ means of transport for commuting, busi ‑
ness and visitor travel. It will consider offsetting its 
business air travel, budget constraints permitting.
65
Project GREEN will review a possible step ‑by‑step 
implementation of selected elements of EMAS, 
taking into account its move to new premises in 
2016. EASA will consider seeking recognition of its 
environmental improvements through less formal 
schemes than EMAS. 
Recommendation 1
EASA welcomes a common policy for reducing 
greenhouse gas emissions. Such a policy should 
take into account the diverse range of activities 
that the institutions and bodies undertake. The 
Commission should consult with the institutions 
and bodies when drafting a common policy, and 
should consider subsidising in whole or in part the 
costs associated with implementation. Note that it 
is expected that Project GREEN will establish targets 
for reducing GHG emissions.The European Aviation 
Safety Agency
EASA fully recognises the importance of minimising 
the impact of its activities on the environment and 
greenhouse gas emissions. Indeed environmental 
protection in the field of civil aviation is a part of its 
legal mandate as a regulator.
During its establishment phase from 2003 EASA 
has not been in a position to dedicate itself to 
comprehensive measures to reduce its greenhouse 
gas (GHG) emissions. EASA has now reached a 
stable phase in its development and several recent 
management decisions will enable EASA to focus its 
attention on this issue:
(1) the launch in 2014 of a corporate environmental 
initiative, Project GREEN, promoted by the execu ‑
tive director;
(2) the relocation of EASA to new single ‑tenant head ‑
quarters in 2016, which will offer more opportuni ‑
ties to reduce EASA’s carbon footprint; and
(3) the centralisation of key operational activities 
(e.g. procurement, and business travel and confer ‑
ence management), all of which are represented 
in Project GREEN.
The ambition for Project GREEN is to raise the 
awareness of EASA’s obligations to the environment 
and its commitment to being a considerate neigh ‑
bour. The project’s immediate tasks will be:
(1) to define EASA’s environmental policy taking into 
account the nature and impact of its activities;
(2) to define key environmental performance indica ‑
tors and progressive targets;
(3) to establish green procurement procedures; and
(4) to engage with the local community on green 
projects.
Replies of the audited EU institutions and bodies 64
Recommendation 7
EASA welcomes the proposed amendment of 
financial and/or procurement rules to promote 
and facilitate ‘green procurement’. Project GREEN 
is supporting the development of standard ‘green 
consideration’ provisions into EASA’s procurement 
procedures, and once developed will monitor their 
implementation. The provisions of the GPP toolkits 
will be used and integrated into the specifica ‑
tions (technical, selection/award criteria) where 
appropriate.Recommendation 2
Project GREEN will consider how best to implement 
the Commission’s organisation environmental foot ‑
print method within the context of EASA’s activities. 
Recommendations 3, 4 and 5
EASA welcomes the opportunity to work with the 
institutions and bodies to develop a common vol ‑
untary offsetting approach based on a register of 
recognised schemes to deliver high ‑quality offsets.
EASA recognises that the development of a com ‑
mon approach to offsetting should contribute not 
only to emissions reductions but also to sustainable 
development for the benefit of the local population 
affected by the project. Economies of scale could 
be envisaged if an offsetting scheme were to be 
organised at EU institution level and made available 
to all agencies and bodies.
Recommendation 6
Project GREEN will review a possible step ‑by‑step 
implementation of selected elements of EMAS tak ‑
ing into account its move to new premises in 2016. 
EASA will consider the benefits of seeking recogni ‑
tion of its environmental improvements through 
less formal schemes than EMAS. 
Project GREEN will also consider the benefits of 
 registering EASA with the European Code of Con ‑
duct on Data Centre Energy Efficiency, especially in 
the context of its move to new premises in 2016. 
It should be noted that through Project GREEN EASA 
is committed to being a considerate neighbour 
through engagement with the local community.
Replies of the audited EU institutions and bodies 65
The European Medicines 
Agency
12 and 13
The European Medicines Agency has taken initial 
steps towards reducing its carbon footprint, the 
most important one being purchasing of electri ‑
city generated from renewable sources. Electricity 
would be the highest source of carbon emissions 
for the Agency, and by purchasing electricity from 
100 % renewable sources it has been brought down 
to zero emissions.
Furthermore, the Agency does not have any other 
fuel combustion or owned vehicles.
To further prepare for the introduction of a harmo ‑
nised approach to measuring the carbon footprint, 
the Agency is also tracking emissions from business 
travel and travel by visitors to the Agency when the 
travel is arranged by the Agency. Commuting with ‑
out a car is promoted by the Agency’s decision to 
not lease car parking from 2015 onwards, and Green 
criteria will be brought in to the EMA procurement 
guidelines as further preparation.
18
Following the adoption of the EMA environmen ‑
tal strategy in December 2013, where the Agency 
commits to comply with the UK Climate Change Act 
2008 and the UK environmental reporting guide ‑
lines that were adopted in June 2013, the EMA will 
include environmental information in its future 
annual reports.
19
Until there is a harmonised instruction of reporting 
environmental information the EMA may choose 
to include a limited amount of relevant key per ‑
formance indicators in its non ‑financial informa ‑
tion related to energy consumption, transport and 
waste. The European Environment 
Agency
19 — Table 2
In 2012, as in the preceding years, EEA bought 
electricity from renewable sources only. Emissions 
stemming from the heating of our main building at 
Kongens Nytorv 6 in 2012 amounted to 71 tonnes 
of CO2. These emissions have been offset together 
with the emissions stemming from heating in 2010 
and 2011 (see paragraph 54 of the report).
Recommendations
EEA fully agrees with the recommendations made 
by the Court.
Replies of the audited EU institutions and bodies 66
The Office for Harmonization 
in the Internal Market (Trade 
Marks and Designs)
With respect to the observations of the audit ‘ How 
do the EU institutions and bodies calculate, reduce 
and offset their greenhouse gas emissions? ’, after 
the analysis of their content carried out by the 
relevant services of the Office for Harmonization in 
the Internal Market (OHIM), those observations do 
not give rise to any particular comment from the 
side of the OHIM.
The observations specifically concerning the OHIM 
reflect correctly the reality of the environmental 
management of the OHIM, as it existed at the time 
of the elaboration of the audit.
The general observations referring to all the institu ‑
tions and agencies analysed, correspond to the 
objective data contained in the audit.
The conclusions and the recommendations result ‑
ing from the audit are well founded and reasonable. 
They point the way forward to strengthen by means 
of the example the credibility of the environmental 
policy promoted by the European Union.45
Setting targets for GHG emissions will be part of 
the action plan that EMA will prepare as part of the 
environmental management system.
65
As part of EMA’s environmental commitment the 
Agency has initiated the environmental review. 
This will be followed by the environmental policy 
and establishment of an environmental manage ‑
ment system. Final registration in the EU EMAS is 
expected during 2015.
99 and 100
The European Medicines Agency has brought to the 
landlord’s attention the EU green building certifica ‑
tion, and has been informed that the landlord has 
initiated registration in the programme.
101
The Agency has prepared for registration to the 
European Code of Conduct on Data Centre Energy 
Efficiency.
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QJ‑AB‑140‑14‑EN‑C ISSN  1831 ‑0834
For the European Union’s climate policy to be 
credible, the EU institutions and bodies need 
to be at the cutting edge in designing and 
implementing policies to reduce their own 
greenhouse gas emissions. This special report 
examines how the EU institutions and bodies 
are tackling the challenge to contribute to the 
Union’s 2020 goal of at least a 20 % reduction 
in its emissions compared to 1990 by 
mitigating the impact of their administrative 
operations on the environment. 
EUROPEAN
COURT
OF AUDITORS