EU GPP criteria for food procurement, catering services and vending machines.
Date: 2019-11-04
Institutions: Joint Research Centre
Subjects: automatic vending machine, catering industry, food safety, food standard, foodstuff, research report

EU GPP criteria for food 
procurement, catering services 
and vending machines 

Final Technical Report 

Boyano, A., Espinosa, N., Rodriguez Quintero, R., 
Neto, B., Gama Caldas, M., Wolf, O.  

2019 

EUR 29884 EN 

This publication is a Technical report by the Joint Research Centre (JRC), the European Commission’s science 
and knowledge service. It aims to provide evidence-based scientific support to the European policymaking 
process. The scientific output expressed does not imply a policy position of the European Commission. Neither 
the European Commission nor any person acting on behalf of the Commission is responsible for the use that 
might be made of this publication. For information on the methodology and quality underlying the data used in 
this publication for which the source is neither Eurostat nor other Commission services, users should contact 
the referenced source. The designations employed and the presentation of material on the maps do not imply 
the expression of any opinion whatsoever on the part of the European Union concerning the legal status of any 
country, territory, city or area or of its authorities, or concerning the delimitation of its frontiers or boundaries. 

Contact information  
Name: ALICIA BOYANO LARRIBA 
Address: DIRECTORATE B5 GROWTH AND INNOVATION, c/ INCA GARCILASO 3, 41092 SEVILLE, SPAIN 
Email: JRC-CATERING-SERVICES@ec.europa.eu 
Tel.: +34 954488363 

EU Science Hub 
https://ec.europa.eu/jrc 

JRC 118360 

EUR 29884 EN

PDF 

ISBN 978-92-76-12119-0 

ISSN 1831-9424 

doi:10.2760/748165 

Luxembourg: Publications Office of the European Union, 2019 

© European Union, 2019  

The reuse policy of the European Commission is implemented by the Commission Decision 2011/833/EU of 12 
December 2011 on the reuse of Commission documents (OJ L 330, 14.12.2011, p. 39). Except otherwise 
noted, the reuse of this document is authorised under the Creative Commons Attribution 4.0 International (CC 
BY 4.0) licence (https://creativecommons.org/licenses/by/4.0/). This means that reuse is allowed provided 
appropriate credit is given and any changes are indicated. For any use or reproduction of photos or other 
material that is not owned by the EU, permission must be sought directly from the copyright holders. 

All content © European Union, 2019 

How to cite this report: Boyano Larriba, A. Espinosa Martinez M. N., Rodriguez Quintero R., Neto B., Gama 
Caldas, M., Wolf O., EU GPP criteria for Food procurement, Catering Services and Vending machines, EUR 
29884, ISBN 978-92-76-12119-0, doi:10.2760/748165, JRC 118360. 

CONTENTS 

1 

INTRODUCTION ................................................................................................................6 

1.1 Summary of the preliminary report ..............................................................................8 
1.1.1  Market analysis ....................................................................................9 
Technical analysis ..............................................................................10 
1.1.2 
1.2  Changes from Technical Report v1 to v2 ........................................................12 
1.3  Changes from Technical Report v2 to v3 ........................................................13 
1.4  Changes from Technical Report v3 to v4 ........................................................14 
1.5  Changes from Technical Report v4 to final version ........................................15 

2  DRAFT EU GPP CRITERIA PROPOSAL FOR FOOD ..........................................16 

Procurement management practices ................................................................17 
2.2  Technical Specifications (TS) and Award Criteria (AC) .................................19 
  Organic food products ........................................................................19 
  Marine and aquaculture food products required. ...............................23 
Seasonal produces (removal) .............................................................28 
Integrated production (removal) ........................................................30 
  Animal welfare ...................................................................................32 
Fair and ethical trade products (BEFORE: Fairly traded products)...35 
Packaging (removal) ..........................................................................38 
  More environmentally responsible vegetable fats .............................39 
  Agricultural products labelled with geographical indications ...........42 
2.3  Contract performance clauses (CPC) ...............................................................43 
Procurement management practices...................................................43 

3 

DRAFT EU GPP CRITERIA PROPOSAL FOR CATERING SERVICES ............................................44 

Selection criteria (SC) ................................................................................................46 
  Competences of the tenderer ..............................................................46 
3.2  Technical Specifications (TS) and Award Criteria (AC) .................................48 
Food procurement ..............................................................................48 
Plant-based  menus  (BEFORE:  Menu  planning  or  promotion  of 
vegetarian menus) ..............................................................................49 
Food and beverage waste prevention .................................................51 

  Other  waste:  prevention,  sorting  and  disposal  (BEFORE:  Waste 

sorting and disposal) ..........................................................................55 

  Chemical 

products 

and 

consumable 

goods 

(BEFORE: 

consumable goods) .............................................................................59 
Energy  and  water  consumption 
Equipment) .........................................................................................63 

in  kitchens 

(BEFORE: 

2 

 
 
 
 
 
 
 
 
 
 
 
 
 
Food transportation (BEFORE: Vehicle fleet and planning of food 
delivery) .............................................................................................69 
Environmental management measures and practices.........................73 
3.3  Contract performance clauses (CPC) ...............................................................76 
Provision of low impact drinking water .............................................76 
Purchase of new kitchen equipment...................................................77 
Environmental management measures and practices.........................78 
Staff training ......................................................................................79 
Food and beverage redistribution .......................................................80 

4 

DRAFT EU GPP CRITERIA PROPOSAL FOR VENDING MACHINES ............................................82 

4.2  Technical Specifications (TS) and Award Criteria (AC) .................................84 
  Organic food products ........................................................................84 
Fair and ethical trade products ...........................................................86 
  More environmentally responsible vegetable fats .............................88 
Energy consumption and GWP of refrigerants ..................................89 
  Reusable cups .....................................................................................92 
4.3  CPC: Purchase of new vending machines .......................................................93 

5 

LIFE CYCLE COST CONSIDERATIONS .................................................................................94 

5.2 
Introduction to the Life cycle cost ...................................................................94 
5.3  GPP of FOOD and CATERING SERVICES ..................................................94 
5.4  Findings from an LCC analysis of case-studies ...............................................95 
Food procurement ..............................................................................96 
Promotion of vegetarian menus .......................................................100 
  Avoidable food waste ......................................................................102 
Energy and water consumption in the kitchen .................................104 
  Other catering criteria ......................................................................106 
5.5  Main conclusions and remarks .......................................................................106 

6 

REFERENCES ...............................................................................................................109 

ANNEXES ............................................................................................................................114 

LIST OF ABBREVIATIONS AND DEFINITIONS ............................................................................364 

LIST OF FIGURES .................................................................................................................365 

LIST OF TABLES ...................................................................................................................366 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Acknowledgements 

This  report  has  been  developed  in  the  context  of  the  Administrative  Arrangement  "Development  of 
implementation  measures  for  SCP  instruments  (SUSTIM)"  between  DG  Environment  and  DG  Joint  Research 
Centre. The project responsible for DG Environment was: Enrico Degiorgis 

Authors 

Boyano, Alicia 

Espinosa, Nieves 

Rodriguez Quintero, Rocio 

Neto, Belmira 

Gama Caldas, Miguel 

Wolf, Oliver 

4 

 
 
 
 
Abstract 

This  report  summarized  the  discussions  held  during  the  revision  process  of  the  Green  Public  Procurement 
criteria for Food procurement and catering services.  

The  report  includes a  summary  of  the  preliminary  report  that  includes  related  information  such  as  market 
analysis  and  technical  analysis  and  those  changes  in  the  criteria  structure  and  wording  that  have  been 
proposed and discussed during the whole process.  

The  main  part  of  the  report  consists of  the  wording  and  rationale  of  each  of  the  revised  GPP  criteria.  This 
section  is  organized  in  three  main  blocks  including  the  proposed  criteria  on  Food,  catering  services  and 
vending  machines.  Each  criterion  is  classified  as  contractual  performance  clause,  technical  specification, 
selection criteria or award criteria and includes the wording and values proposed (in the explanatory notes) 
for the core and the comprehensive levels.  

The report closes with the life cycle considerations for this product group.  

5 

 
 
 
 
1 

Introduction 

Public  authorities'  expenditures  in  the  purchase  of  goods,  services  and  works  (excluding  utilities  and  defence) 
constitute approximately 14% of the overall Gross Domestic Product (GDP) in Europe, accounting for roughly EUR 
1.8 trillion annually (Buying green, 2016) 

Thus, public procurement has the potential to provide significant leverage in seeking to influence the market and 
to achieve environmental improvements in the public sector. This effect can be particularly significant for goods, 
services  and  works  (referred  to  collectively  as  products)  that  account  for  a  high  share  of  public  purchasing 
combined with the substantial improvement potential for environmental performance. The European Commission 
has identified Food and Catering services as one such product group. 

Green  Public  Procurement  (GPP)  is  defined  in  the  Commission's  Communication  "COM  (2008)  400  -  Public 
procurement for a better environment” as "…a process whereby public authorities seek to procure goods, services and 
works with a reduced environmental impact throughout their life cycle when compared to goods, services and works 
with the same primary function that would otherwise be procured”. 

Therefore,  by choosing to  purchase  products  with  lower environmental impacts,  public  authorities  can make  an 
important  contribution  to  reduce  the  direct  environmental  impact  resulting  from  their  activities.  Moreover,  by 
promoting  and  using  GPP,  public  authorities  can  provide  industry  with  real  incentives  for  developing  green 
technologies and products. In some sectors, public purchasers command a large share of the market (e.g. public 
transport and construction, health services and education) and so their decisions have considerable impact. In fact, 
in  the  above-mentioned  Commission's  communication  the  capability  that  public  procurement  has  to  shape 
production and consumption trends, increase demand for "greener" products and services and provide incentives 
for companies to develop environmental friendly technologies is clearly emphasised. 

GPP is a voluntary instrument, meaning that  Member States and public authorities can determine the extent to 
which they implement it. 

The development of EU GPP criteria aims to help public authorities ensure that the goods, services and works they 
require are procured and executed in a way that reduces their associated environmental impacts. The criteria are 
thus formulated in such a way that they can be integrated, if deemed appropriate by the individual authority, into 
its tender documents with minimal editing. 

GPP criteria are to be understood as being part of  the procurement process and must conform to its standard 
format  and  rules  as  laid  out  by  Public  Procurement  Directive  2014/24/EU  (public  works,  supply  and  service 
contracts).  Hence,  EU  GPP  criteria  must  comply  with  the  guiding  principles  of:  Free  movement  of  goods  and 
services  and  freedom  of  establishment;  Non-discrimination  and  equal  treatment;  Transparency;  Proportionality 
and Mutual recognition. GPP criteria must be verifiable and it should be formulated either as Selection criteria, 
Technical specifications, Award criteria or Contract performance clauses, which can be understood as follows: 

Selection  Criteria  (SC):  Selection criteria refer to the tenderer, i.e., the company tendering for the contract, 
and not to the product being procured. It may relate to suitability to pursue the professional activity, economic 
and financial standing and technical and professional ability and may- for services and works contracts - ask 
specifically about their ability to apply environmental management measures when carrying out the contract. 

Technical  Specifications  (TS):  Technical  specifications  constitute  minimum  compliance  requirements  that 
must be met by all tenders. It must be linked to the contract's subject matter (the ‘subject matter’ of a contract 
is about what good, service or work is intended to be procured. It can consist in a description of the product, but 
can  also  take  the  form  of  a  functional  or  performance  based  definition.)  and  must  not  concern  general 
corporate practices but only characteristics specific to the product being procured. Link to the subject matter 
can  concern  any  stage  of  the  product's  life-cycle,  including  its  supply-chain, even if  not obvious  in  the  final 
product,  i.e.,  not  part  of  the  material  substance  of  the  product.  Offers  not  complying  with  the  technical 
specifications must  be  rejected.  Technical  specifications  are  not  scored  for  award  purposes;  they  are  strictly 
pass/fail requirements. 

Award  Criteria  (AC):  At the award stage, the contracting authority evaluates the quality of the tenders and 
compares costs. Contracts are awarded on the basis of most economically advantageous tender (MEAT). MEAT 

6 

 
 
includes a cost element and a wide range of other factors that may influence the value of a tender from the 
point of view of the contracting authority including environmental aspects (refer to the Buying Green  2016). 
Everything  that  is  evaluated  and  scored  for  award  purposes  is  an  award  criterion.  These  may  refer  to 
characteristics of goods or to the way in which services or works will be performed (in this case they cannot be 
verified  at  the  award  stage  since  they  refer  to  future  events.  Therefore,  in  this  case,  the  criteria  are  to  be 
understood as commitments to carry out services or works in a specific way and should be monitored/verified 
during the execution of the contract via a contract performance clause). As technical specifications, also award 
criteria must be linked to the contract's subject matter and must not concern general corporate practices but 
only characteristics specific to the product being procured. Link to the subject matter can concern any stage of 
the product's life-cycle, including its supply-chain, even if not obvious in the final product, i.e., not part of the 
material  substance  of  the  product.  Award  criteria  can  be  used  to  stimulate  additional  environmental 
performance without being mandatory and, therefore, without foreclosing the market for products not reaching 
the proposed level of performance. 

Contract  Performance  Clauses  (CPC):  Contract  performance  clauses  are  used  to  specify  how  a  contract 
must be carried out. As technical specifications and award criteria, also contract performance clauses must be 
linked to the contract's subject matter and must not concern general corporate practices but only those specific 
to  the  product  being  procured.  Link  to  the  subject  matter  can  concern  any  stage  of  the  product's  life-cycle, 
including its supply-chain, even if not obvious in the final product, i.e., not part of the material substance of the 
product.  The  economic  operator  may  not  be  requested  to  prove  compliance  with  the  contract  performance 
clauses during the procurement procedure. Contract performance clauses are not scored for award purposes. 
Compliance  with  contract  performance  clauses  should  be  monitored  during  the  execution  of  the  contract, 
therefore after it has been awarded. It may be linked to penalties or bonuses under the contract in order to 
ensure compliance. 

For each criterion there is a choice between two levels of environmental ambition, which the contracting authority 
can choose from according to its particular goals and/or constraints: 

The Core criteria are designed to allow easy application of GPP, focussing on the key areas of environmental 
performance of a product and aimed at keeping administrative costs for companies to a minimum. 

The Comprehensive  criteria  take into account more aspects or higher levels of environmental performance, 
for use by authorities that want to go further in supporting environmental and innovation goals. 

As said before, the development of EU GPP criteria aims to help public authorities ensure that the goods, services 
and works they require are procured and executed in a way that reduces their associated environmental impacts 
and is focused on the products' most significant improvement areas, resulting from the cross-check between the 
key environmental hot-spots and market analysis. This development also requires an understanding of commonly 
used  procurement  practices  and  processes  and  the  taking  on  board  of  learnings  from  the  actors  involved  in 
successfully fulfilling contracts. 

For this reason, the European Commission has developed a process aimed at bringing together both technical and 
procurement  experts  to  collate  a  broad  body  of  evidence  and  to  develop,  in  a  consensus  oriented  manner,  a 
proposal  for  precise  and  verifiable  criteria  that  can  be  used  to  procure  products  with  a  reduced  environmental 
impact. 

This report presents the findings resulting from that process up to the second version of the Technical Report. 

A  detailed environmental  and  market  analysis,  as  well  as an  assessment  of  potential  improvement  areas, was 
conducted within the framework of this project and was presented in the Preliminary Report on EU Green Public 
Procurement Criteria for Food and Catering Services. This report can be publicly accessed at the JRC website for 
Food  and  Catering  Services  (http://susproc.jrc.ec.europa.eu/Food_Catering/).  The  main  findings  presented  in  the 
Preliminary Report are summarised in the next chapter. 

7 

 
1.1 Summary of the preliminary report 

Scope  

Food  service  supply  chains  are  extremely  complex  and  diverse  ranging  from  the  traditional  ‘cook  from  scratch’ 
model while others buy the food ‘ready to serve’ and some use a hybrid of the two. Detailed information on the 
stages of the supply chain can be found in the Preliminary Report (JRC 2016a).  

Similarly, the food categories, catering services and food service segments that were revised regarding the market 
analysis and environmental hotspots identification. The food categories included in the current EU GPP (EU GPP 
2008)  were  further  enlarged  to  categories  such  as  bread  and  cereals,  oils  and  fat  and  sugar,  jam,  honey, 
chocolate and confectionery. 

The scope identified for food and catering services reads:  

The direct procurement of food by public authorities and the procurement of catering services, either using 
in-house resources or facilities or out-sourced in full or in-part through contract catering firms. Food can be 
procured directly from producers, manufacturers, wholesalers or importers or can form part of the service 
provided by the contract catering firms. 

In the EU market, there is a common legal framework that sets the food safety requirements that ensure that 
only  safe  food  and  feed  is  placed  on  the  EU  market  or  fed  to  food-producing  animals.  The  main  pieces  of 
legislation  are  the  Regulation  (EC)  No  178/2002  that  requires  food  and  feed  business  operators  to  be  able  to 
identify  any  person  from  whom  they  have been  supplied  with  a  food,  a feed,  a food-producing  animal,  or  any 
substance intended to be, or expected to be, incorporated into a food or feed. Food or feed which is placed on the 
market must be adequately labelled or identified to facilitate its traceability, through relevant documentation or 
information  in  accordance  with  the  relevant  requirements  of  more  specific  provisions.  The  requirements  on 
traceability are mandatory for all food operators including retail and distribution activities, i.e. catering services.  

The  Regulation  (EC)  No  852/2004  establishes  the  obligation  of  food  business  operators,  including  retail  and 
distribution activities, to put in place, implement and maintain a permanent procedure or procedures based on the 
HACCP (Hazard analysis and critical control points) principles. This regulation sets requirements on staff training 
for food hygiene matters and compliance with any requirements of national law concerning training programmes 
for persons working in certain food sectors. 

Apart from the EU legislation which sets mandatory requirements, the ISO 22000 standard sets requirements on 
food  safety  management  systems,  to  be  third-party  certified.  This  standard  covers  all  the  food  supply  chain, 
although  it  is  more  commonly  applied  to  only  one  step  of  the  chain.  Other  private  schemes  focused  on  food 
safety,  as  GlobalGap  are  limited  to  the  primary  production  (FAO,  2008).  Additional  food  safety  standards  are 
Global Food Safety Initiative (GFSI) recognised includes: IFS Food, BRC-global standard food, FSSC and SQF.  

In the view of the EU legislation and controls already in force in the European market, it seems unnecessary to set 
specific  food  safety  criteria  within  the  EU  GPP.  In  case  any  environmental  criterion  might  jeopardize  the  food 
safety  principles,  the  precautionary  approach  to  secure  the  food  safety  should  rule  on  the  decision  making.  In 
conclusion, the inclusion of food safety issues is considered to be out of the scope of this EU GPP revision 

Definitions 

The following definitions for scope and for food service have been amended by stakeholder consultation feedback. 
The list of definitions considered relevant for the revision of the EU GPP criteria is as follows: 

  Catering  service:  The  preparation,  storage  and,  where  appropriate,  delivery  of  food  and  drinks  for 
consumption  by  the  consumer/client/patient  at  the  place  of  preparation,  at  a  satellite  unit  or  at  the 
premises/venue of the client. 

  Contract catering firm: A business engaged in (amongst other activities or services) providing a meals 
service (for example by running a staff restaurant or providing school meals) or providing drinks, snacks 
or vending. 

8 

 
 
 
  Conventional kitchen: A kitchen (at the place of consumption) where all, or a significant part of, food is 

prepared from raw ingredients. 

  Centralised production unit: Central kitchens or central food factories that send out completed dishes or 
pre-processed ingredients/meals to satellites. It can include both ready-prepared services and assembly-
serve services. 

  Ready-prepared:  Preparation  on  site  or  at  a central facility of  large  batches  of  items  for  consumption 

that are then adequately stored frozen or chilled until serving. 

  Assembly-serve: The food is delivered pre-processed and cooked. Then the food is reheated (if necessary) 

and assembled on site. 

  Vending and hot drink machines: Machines that are available at all times with snacks, fruit, drinks and/or 

sandwiches etc. that are ready to eat/drink or that can be reheated. 

  Water dispensers: A device specifically for dispensing drinking water, which might have the possibility of 

heating and/or cooling the drinking water. 

A more extensive definitions list can be found at the end of this document. 

1.1.1  Market analysis 

Key findings from the market analysis include:  

 

 

The total expenditure on food and catering services in Europe for the 28 Member States is 206.3 euro 
billion (2011 data from Eurostat). The sector (in total) includes 1.5 million enterprises, has a turnover of 
354 euro billion, and employs 8 million people (2012 data from Eurostat).  

The turnover of the total EU contract catering industry in 2008 was 24.6 euro billion and around 600000 
people were employed (EIRO, 2010). 

  Self-operating  public  bodies  and  contract  caterers  on  average  share  the  food  and  catering  market 
around 50/50, but the difference is large between Member States (FERCO, 2012). The market penetration 
of  contract  catering  organisations  varies  significantly  across  Member  States  and  across  public  sector 
segments. For example, in Ireland contract caterers account for 61.9% of the market and in Sweden they 
account for only 15% 

 

 

The most important sectors (in terms of purchase volume and value) in Europe that procure food and 
catering  services  are:  health/welfare  (42.7%  of  the total  meals  served),  education  (31.4%  of  the  total 
meals served) and business & industry (17.8% of the total meals served) 

The EU-28 is a large producer of dairy, cereals (e.g. wheat), fruit and vegetables, meat, potatoes, bread 
and  cold  beverages.  But  the  EU  is  also  dependent  on  imports  of  fish,  fruit,  vegetables,  animal  feed, 
coffee, tea and cocoa (Eurostat Statistics in focus, 2011).  

The consumption of organic production in the EU has been steadily rising since 2004 (FiBL and IFOAM, 2014). Only 
5.7% of the arable land in the EU-28 was used for organic production. It should be noted, though, that the area 
under organic agriculture has increased significantly in the last years (+6% per year between 2002 and 2011) and 
it is still expected to grow in the coming years. Germany (31%), France (18%), UK (8%) and Italy (8%) are the 
countries that buy most organic products. Combined these four countries accounted for nearly two thirds (65%) of 
the  overall  EU  organic  food  sales  in  2012.  Conversely,  countries  such  as  Bulgaria,  Cyprus,  Estonia,  Greece, 
Hungary,  Latvia,  Lithuania  and  Slovakia  represent  very  underdeveloped  markets  (Thünen  Institute  of  Farm 
Economics, 2013). In 2013 only 5.7% of the arable land in the EU-28 was used for organic production.  

 

 

The most popular organic food products that are bought by consumers are: eggs, dairy, fruit, vegetables, 
hot beverages, meat (mainly in Northern Europe) and bread and bakery.  

There  is  a  rising  demand  for  healthy  food  and  drink  products  both  from  private  consumers  and 
governments, especially in the education and health sectors.  

9 

 
 
 

 

Labour cost and food purchase cost, are the two most important factors that influences the price per 
meal 

In  terms  of  corporate  engagement  in  sustainability  issues  there  is  a  significant  focus  in  the  catering 
industry on energy savings, packaging reduction and food waste prevention.  

1.1.2  Technical analysis 

The  key  environmental  hotspots  and  their  relation  to  the  proposed  criteria  are  explained  here  in  detail.  The 
majority  of  the  environmental  impacts  from  food  products  (including  catering  service  activities)  arise  at  the 
primary  production  stage  and  in  some  cases  also  at  the  processing  stage.  At  the  catering  service  stage  in  the 
foodservice supply chain, energy and water use are important contributors to environmental impact, as well as 
waste generation and management.  

Table 1 summarises the main impacts and causes identified from the review of LCA studies (Preliminary Report, 
JRC 2016a) and shows the link to the proposed GPP criteria.  

Table  1:  Main  environmental  hotspots  and  causes  from  food  procurement  (the  name  of  the  criteria 
are the ones proposed in the present report) 
Product category 

Criteria (improvements) 

Fish and 
seafood 

Meat 
Milk and cheese  
Eggs 

t
n
e
m
e
r
u
c
o
r
p

d
o
o
F

Fruit and 
vegetables 
Bread and 
cereals 

Environmental hotspot or  
potential improvement areas 
Depleting fish stocks 
Production of feed for fish and the use of 
antifouling treatment in fish cages 
Combustion of fossil fuels and the use of 
antifouling treatments in fishing vessels 
for wild caught species and equipment for 
aquaculture 
Land use and land use change (e.g. 
destruction of natural habitats, particularly 
forests and related CO2 emissions 
associated to the production of feed, in 
particular soy) 
Production and use of pesticides 
Misuse of overuse of antimicrobials 
Methane emissions from ruminants 
Ammonia/nitrate emissions from rearing 
houses and manure storage 
Water use and water pollution 
Energy use (heating and cooling 
birdhouses)  
Energy use in slaughtering (not for daily 
products and eggs) 
Production and use of chemical fertilisers 
and pesticides 
Soil degradation and potential run-off of 
excessive nitrogen in monoculture 
Energy and water use for irrigation  
Energy use when cultivating in GH 

Marine and aquaculture food products:  
- Avoid pressure on depleting fish stocks 
- Lower environmental impact feed used in 
aquaculture 

Organic food products 
- Higher animal welfare standards 
Animal welfare 
- Some evidence was found on better meat 
quality 
- Ethical consideration  

Organic food products 
- Lower eco-toxicity and lower GWP (in 
some cases) 
- Containing more oxidants, less pesticides 
and heavy metals 
- Natural resources are expected to be 
better protected under organic production: 
air, biodiversity, soil and water. 
Plant-based menus 
- Shifting away from meat. 
- Weekly vegetarian day(s). 

10 

 
 
 
 
 
 
Product category 

Environmental hotspot or  
potential improvement areas 

Oils and fats 

Land  use  and  land  use  change  (e.g. 
destruction of natural habitats, particularly 
forests, and related CO2 emissions) 

Production  and  use  of  chemical  fertilisers 
and pesticides 
Energy use in field work 
Methane  release  (anaerobic  digestion  of 
effluent in open pounds)  
Disposal  of  empty  fruit  bunch  in  landfills 
lead to GHG emissions 
Production  and  use  of  chemical  fertilisers 
and pesticides 
Drying of tea leaves 
Energy use for water boiling 
Production  and  use  of  chemical  fertilisers 
and pesticides 
Energy and water use for irrigation  
Energy use in the bottling process 
Water use 
Long transport emissions 

Hot drinks 

Cold drinks 

Transportation 

Criteria (improvements) 

- Plant-based sourced proteins 
Organic food products See above 

Environmentally responsible vegetable fats 
-  Better  management  systems  used  in  the 
palm and soy oil production and extraction: 
- Avoid deforestation 
- Use of fertilisers 
- Lower emissions in oil mills 

Organic food products See above 

Organic food products See above 

Table 2: Main environmental hotspots and causes from catering services 
Product category 

Criteria  

Environmental hotspot or  
potential improvement areas 
See above 

Lighting,  HVAC,  water  use,  supplies 
(cleaning, toilets, disposable products:  
Use of energy and partially use of cleaning 
products  have  a 
impact  on 
carcinogens, eco-toxicity and fossil fuels 

large 

Food 
procurement 
Operational 
support 

s
e
c
i
v
r
e
s

g
n
i
r
e
t
a
C

See above 

impact 

lower  environmental 

Competences of the tenderer  
- Prevention of food waste and other waste 
-  Use  of  products  and  consumables  with 
lower environmental impact 
- Energy use in catering services 
Chemical products and consumable goods 
-  Use  of 
consumable goods, including:  
- Paper products 
- Tableware 
- Disposable items (such as cutlery) only for 
take-away  (as  a  general  rule  allowing  for 
certain exceptions)  
- Rubbish bags and gloves  
-  Cleaning  products 
cleaning 
detergents) 
Energy  and  water  consumption  in  kitchens 
see below 
Environmental  management  measures  and 
practices 
-  Use  of  products  and  consumable  goods 
with lower environmental impact 

(as  hand  soaps, 
dishwasher 
and 

products 

11 

Food storage 
and food 
preparation 

Cook  chill  systems  show  a  comparatively 
larger impact when compared to the cook-
warm.  
Cook  chill  requires  chill,  cool  storage  and 
reheating. Cook warm is ready to eat. But 
since  the  cook  chill  system  has  less  food 

 
 
 
 
 
 
 
 
 
waste  than  cook  warm  it  has  a  lower 
impact  in  total  (if  including  the  effect  of 
food waste)  

Waste 
management 

Transportation 

Production and disposal of organic waste 
Use  and  disposal  of  packaging 
landfill) 
Long  distances  imply  larger  amounts  of 
transport emissions 

(e.g. 

Processing of 
products 

Energy use in processing  
Wastewater treatment  
Energy  and  refrigerants  used  for  cold 
storage 

- Water and energy use in catering services 
- Solid waste management 
Food  and  beverage  waste  prevention  and 
food  and  beverage  redistribution-  Lower 
generation of food waste 
-  Better  food  stock  management,  portion 
size  of  meals  and  adequacy  to  of  meals 
consumer tastes  

Plant-based menus 
- Shifting away from meat. 
- Weekly vegetarian day(s). 
- Plant-based sourced proteins 
Other  waste:  prevention,  sorting  and 
disposal 
- Liquid and solid waste management 
Food transportation 
-  Lower  combustion  emissions  from  the 
vehicle fleet 
- Better planning the transportation of food 
(raw and ready prepared meals) 
Energy and water consumption in kitchens 
- Use of energy efficient kitchen equipment 
of 
and 
consumption 
Energy 
refrigerants (vending machines) 
- Use of energy efficient vending machines 

GWP 

1.2  Changes from Technical Report v1 to v2  

a) Criteria Format in the FOOD procurement criteria set 

The  wording  and  the  structure  of  all  the  criteria  have  been  modified.  The  new  format  of  the  wording  includes 
recommended values. An "X" value is followed by explanatory notes where the ranges of the recommended values 
for that criterion are included. The highest value could be considered as the "best practice" value while the lowest 
could be considered as a feasible value to be applied across EU-28. 

In  this  way  the  criteria  aim  at  providing  an  example  on  the  types  of  requirements  to  be  included  but  giving 
flexibility  to  the  procurers  to  adapt  these  requirements  to  the  specific  situations  they  are  facing  (e.g.  local 
situation, characteristics of the clients to be served such as students, employees, patients, clerical staff, etc.). 

b) Removal / addition of criteria 

The criterion on "seasonal produce" has been removed from the Food procurement criteria. Eating more seasonal 
food is only one element of a sustainable diet. However, it should be kept in mind that seasonal produce could 
also be referred to the production place and therefore little changes in the diet can be observed. It should not 
overshadow  some  of  the  potentially  more  difficult-to-change  dietary  behaviours  that  could  have  greater 
environmental and health benefits (e.g. reducing overconsumption or meat consumption). 

“Packaging”  is  another  criterion  that  has  been  removed  in  the  present  technical  report.  Several  reasons  were 
considered for this proposal such as the difficulties to assess the distance for returning the reusable packaging 
(e.g. to wash and refill the bottles), the lack of infrastructure for sorting, collecting and composting biodegradable 
and compostable packaging or the trade-offs in the use of single unit packaging.  

12 

 
 
 
 
 
 
c) Changes in the Catering services criteria set 

Several changes have been introduced in the catering service criteria set especially concerning the reclassification 
of the criteria as either technical specification criteria, award criteria or selection criteria and the content of the 
criteria. The newly proposed criteria are mostly focused on the promotion of vegetables and the prevention and 
management of the food waste and other waste.  

More in detail, the criterion proposed as menu planning in the TR1.0 has been removed and a criterion aiming to 
increase  the  consumption  of  vegetables  has  been  introduced.  This  criterion  includes  several  measures  that  the 
tender can implement depending on the type of food services offered.  

Two important criteria have been significantly modified in this report. The first one is the inclusion of a criterion 
concentrated on the prevention of food waste and its redistribution once generated. The food waste has negative 
effects on the economy and the environment and it is not justifiable from an ethical point of view. The second one 
focuses  on  other  waste  and  includes  the  prevention  and  management  of  the  generated  waste,  apart  from 
avoidable food waste.  

The selection criteria have also been revised. Only aspects related to the competences of the tenderer have been 
included in this area. The competences required should be focused on aspects such as the training provided to the 
staff, the ability to prepare tasty vegetarian dishes or the implementation of policies and procedures that aim to 
reduce the environmental impact caused by the activity. 

Finally, those criteria proposed as contractual performance clause have been modified. Four criteria are proposed 
dealing  with  aspects  such  as  the  provision  of  tap  drinking  water,  purchase  of  high  energy  efficient  kitchen 
equipment, environmental management measures and practices or the training of the staff. In those criteria the 
tender must demonstrate s/he performance in the contracts held during the last 5 years.  

Annex 3 includes the feedback received after the 1st AHWG meeting on sections such as the scope and definitions 
and environmental hotspots. The comments accepted were included in TR 2.0. 
.  

1.3  Changes from Technical Report v2 to v3  

a) Removal / addition of criteria 

The criterion on "Integrated production" has been removed from the Food procurement criteria. Rules on integrated 
production have been developed in most of the Member States at national or regional level. Therefore, there are 
different rules and integrated production guidelines for specific crops, fruits and vegetables, both developed by 
public or private schemes. 

The criterion on "Environmentally responsible palm oil" has been modified to "Environmentally responsible fats", to 
incorporate  other  oils  or  fats  from  commodities  as  soy.  A  study  carried  out  by  the  EU  on  the  impact  of 
commodities  on  deforestation  highlights  the  embodied  deforestation  in  EU27  imports  is  mainly  caused  by  oil 
crops (soybean and palm) and their derived products. 

b) Renaming/ rewordings 
"Marine and aquaculture food products" criterion has been modified to reflect the objective of marine sustainability 
yield (MSY) which is part of the implementation of the Common Fisheries Policy (CFP). For commercial fish stocks, 
this means "that they are exploited within safe biological limits, exhibiting a population age and size distribution 
that is indicative of a healthy stock". The species purchased must be marked as green in the list coming from the 
yearly fishing quotas and allowable catches of the European Commission. 

The second part of the criterion on Animal welfare requested before that X% of eggs in shell were labelled with 
code  1  or  2.  It  has  been  edited  to  only  code  1  since  this  is  an  award  criterion  and  according  to  the  technical 
specification (asking for none of the eggs in shell are 3) all eggs purchased might be labelled code 1 or 2. This 
criterion includes as well dairy products. Not only meat but dairy products have been pointed out as one of the 

13 

 
 
 
 
food  categories  with  the  highest  environmental  impacts.  The  production  of  dairy  products  and  meat  is  linked. 
Thus, it is important to consider animal welfare since it is a measure to reduce the impacts on the livestock. 

"Fair and ethical products" criterion has been recommended by stakeholders as a better name to align with other 
EU  trade  policies  policy  is  based  on  a  definition  of  "fair  and  ethical  trade"  that  encompass  all  voluntary 
sustainability standards. Similarly has been changed in the Vending machines section. 

The former criterion "Promotion of vegetarian menus" has been renamed to "Plant-based menus". 

The  criterion  on "Avoidable  food  waste: prevention  and  redistribution",  has  been  renamed  to  "Food  and  beverage 
waste prevention and food and beverage redistribution" to better reflect the food redistribution. There is as well a 
new clause on "Food and beverage redistribution that at encouraging the food donation as a way to prevent food 
waste  in  catering  services,  whenever  and  wherever  possible,  i.e.  those  locations  where  it  is  under  national 
regulation  possible  without  excessive  additional  cost  burden  and  of  sufficient  quantity  to  be  of  interest  of  the 
redistribution organizations or other organizations. 

"Tap water for drinking" renamed to "Provision of low impact drinking water". 

Annex 4 includes the feedback received after the 2nd AHWG meeting on sections such as the scope and definitions 
and environmental hotspots. The comments accepted were included in TR 3.0. 

1.4  Changes from Technical Report v3 to v4  
Energy thresholds of appliances have been modified in accordance with the recent Top ten report update.  

The life cycle cost section has been complemented with recent information provided by stakeholders.  

The  options  given  in  the  organic  food  products  criterion  have  been  reworded.  To  make  easier  the  verification 
during the contract execution, the text has been changed now and in Option A the public procurer would specify 
the list of products to be supplied that should be organically grown. This option can be practical for the cases 
where  they  are  directly  purchasing  the food.  Option  B  requests  a  percentage  of  the  products  to be  supplied  to 
comply with the criterion. This option can be interesting  for public procurers that procure a catering service and 
therefore they do not have the control on the specific products to be supplied, so they may request that at least a 
percentage of them is organically grown. 

Specific mention is done now in all criteria for food for the contracting authorities on the way the percentage of 
purchase taking into account availability and costs  is set and whether it has been calculated, either in volume, 
weight or value. 

“Marime and aquaculture food product” criterion has also been reworded. The requirements included in the criterion 
drafted  for  the  comprehensive  level  request  the  compliance  with  safe  biological  limits  and  requirements  that 
address environmental impacts, including over-fishing or depletion, biodiversity and responsible and sustainable 
use of the resources. 

The name of the criterion "Environmentally responsible fats" has been edited to better capture the essence of the 
criterion, to "More environmentally responsible vegetable fats" 

In  the  criterion  "Plant-based menus",  a  sentence  has been added:  "Menus  offered  must  include  choices  with  the 
goal  of  increasing  the  consumption  of  pulses,  vegetables,  fruits,  wholegrains  and  nuts  whilst  having  the  same 
recommended  nutrient  intake  for  the  clients"  and  as  a  recommended  value,  half  of  the  dishes  offered  daily 
vegetarian or plant-based*, instead of one dish offered daily has to be vegetarian/plant based. The exact number 
or percentage of dishes offered daily based on vegetarian or plant-based dishes to be decided by the contracting 
authority. 

14 

 
 
 
 
 
 
 
 
 
 
 
An  extra  best  practice  in  the  criterion  “Food  and  beverage  waste  prevention”  has  been  included:  "Select  the 
appropriate  packaging  (format,  protection,  preservation,  serving  portions,  etc.)  able  to  minimize  the  generation  of 
food waste" 

Annex  5  includes  the  feedback  received  after  the  written  consultation  on  general  issues  and  the  wording  and 
rationale of the criteria. The comments accepted have been already integrated in this report, TR4.0.  

For the rest, no major changes from v3 to v4. 

1.5  Changes from Technical Report v4 to final version 
The criterion "More environmental responsible vegetable fats" has been reworded in order to open its scope to all 
types of vegetable fats. In this sense, the wording of the criterion has been changed to reflect this point and the 
non-discrimination of any vegetable fats. 

For the rest, no major changes from v4 to this final version. 

15 

 
 
 
 
 
 
 
2  Draft EU GPP Criteria proposal for Food 

Table 3 indicates the criteria included in the Food procurement criteria set 

Table  3.  Criteria  set  for  Food  procurement  Award  Criteria  (AC)  and  Technical  Specification  (TS). 
Thresholds in TS are included as minimum values (i.e. at least x%) and thresholds in AC are included 
as the starting point to get points awarded (i.e. points awarded from x%). 
Level of ambition 
Criteria 
Core 
Option A 
Products included: fruit, vegetables, 
legumes, rice and pasta 

Type of 
criteria 
TS1.1  

Organic food 
products 

Option B 
20-60% in mass 
30-70% in value 
Option A 
Products apart from those in TS1 
Option B 
>20-60% in mass 
>30-70% in value 
List to avoid 

AC1.1  

Marine and 
aquaculture 
food products 

TS2.1 
TS2.2 

TS2.3 

AC2.1 

AC2.2 

TS3 
AC3.1 
AC3.2 

AC4 

Animal welfare 

Fair and ethical 
trade products 

Environmentally 

TS4.1 

Option A 
Products apart from those in TS2.2 
Option B 
For fish products: 
>0-20% in mass 
>0-10% in value 
Option A 
Products apart from those in TS2.2 
Option B 
For aquaculture products:  
>0-20% in mass 
>0-10% in value 
None of the eggs labelled 3 
>80% of the eggs in shells code 1  
>0-25% of the meat and dairy 
(excluding organic) in mass/value 
Option A 
100% from List of products  
Option B 
>40-60% in mass/value 
>10-50% items pre-packed food 

Comprehensive 
Option A 
Products included: fruit, vegetables, 
legumes, rice, pasta, bread and bakery 
products, eggs, daily products, etc. 
Option B 
>50% in mass 
>60% in value 
Option A 
Products apart from those in TS1  
Option B 
>50% in mass 
>60% in value 
List to avoid 
Option A 
List of products  
Option B 
20-50% in mass 
10-40% in value 
Option A 
List of products  
Option B 
20-50% in mass 
10-40% in value 
Option A 
Products apart from those in TS2.2 
Option B 
For fish products: 
>20-50% in mass 
>10-40% in value 
Option A 
Products apart from those in TS2.2 
Option B 
For aquaculture products: 
>20-50% in mass 
>10-40% in value 
None of the eggs labelled 3 
>80% of the eggs in shells code 1  
>0-25% of the meat and dairy (excluding 
organic) in mass/value 
Option A 
100% from List of products  
Option B 
>70-100% in mass/value 
>50-100% items pre-packed food 

16 

 
 
 
 
 
 
 
 
 
 
TS4.2 

CPC1 

>10-50 % in mass 
>10-50% items pre-packed food 
>10-50 % in mass 
See section 2.3.2 

>50-100 % in mass  
>10-50% items pre-packed food 
>10-50 % in mass 

responsible 
vegetal fats 

Procurement 
management 
practices 

Figure  1 shows the relation between the Technical Specification and the Award Criteria that address the same 
environmental hotspot. The blue dark bars indicate the minimum threshold proposed in this report for each of the 
criteria.  These  thresholds  are  associated  with  the  technical  specification  criteria  and  means  that  those  tenders 
that do not comply with these thresholds are excluded from the selection process.  

The gradient bars indicate the points that can be awarded depending on the level reached in each criterion. The 
minimum level to start awarding points is equal to the minimum required by the Technical Specification criteria 
and  the  higher  the  offer  of  the  tender  more  points  should  be  awarded.  The  maximum  percentage  that  can  be 
offered for each of the award criteria is 100%.  

Figure  1.  Relation  between  the  technical  specification  and  the  award  criteria  for  food  procurement.  Core 
level above, comprehensive level below.  

17 

 
 
 
 
Additionally, there are three sections that provide information on three removed criteria in comparison to previous 
TRs. The three sections are named "Seasonal produces" (section 2.2.3), "Integrated production" (section 2.2.4) and 
"Packaging" (section 2.2.7). 
A reference to a new criterion on “Agricultural products labelled with geographical indications” (section 2.2.9) has 
also been added.  

18 

 
 
 
 
 
2.2 

Technical Specifications (TS) and Award Criteria (AC) 

  Organic food products 

Core criteria 
Technical Specification 
TS1. Organic food products 

Comprehensive criteria 

Option A (easier to verify during contract execution) 
TS  1.1  The  following  food  and  drink  products  [to  be  inserted  by  the  contracting  authority,  see  also  explanatory 
notes] must comply with Regulation (EC) No 2018/8481 or its subsequent amendments. 
Verification: 
The  tenderer  must  provide  a  declaration  that  all  food  and  drink  products  listed  above,  that  are  to  be  supplied 
during the execution of the contract, comply with Regulation (EC) No 2018/848 or its subsequent amendments1. In 
addition, the tenderer must provide a description of how it intends to ensure that the products mentioned above 
can  be  sourced  during  contract  execution  from  organic  sources  (e.g.  by  identifying  suppliers  for  the  different 
products). 

Option B (more complex to verify during contract execution) 
TTS  1.1  At  least  X%2 of  the  total  purchases  of  food  and  drink  products  must  comply  with  Regulation  (EC)  No 
2018/8481 or its subsequent amendments. 
Verification: 
The  tenderer must  provide  data  (name  and  amount)  of  food  and  drink  products  that  are  to  be  supplied in  the 
execution of the contract, indicating specifically the products that comply with organic requirements. 
Core criteria 
Award Criteria 
AC1. Additional organic food products 

Comprehensive criteria 

Option A (easier to verify during contract execution) 
Points are to be proportionally awarded to tenders that exceed the list of food and drinks products [listed in TS1 
option A] and comply with the organic products standards. 
Verification: 
See above TS1 option A 

Option B (more complex to verify during contract execution) 
Points are to be proportionally awarded to tenders in which more than the required X%3 of the total purchases of 
food and drink products have been produced in accordance with Regulation (EC) No 2018/848 or its subsequent 
amendments4. 
Verification: 
See above TS1 option B 

1 According to Article 61 of Regulation (EC) No 2018/848, this regulation shall apply from 1 January 2021. 
According to Article 60, products produced in accordance with Regulation (EC) No 834/2007 before 1 January 
2021 may be placed on the market after that date until stocks are exhausted. 
2 X is the threshold to be defined by the contracting authority for the comprehensive and core levels (technical 
specifications and award criteria). Recommendations for its value are given in explanatory notes below. 
3 It is the threshold to be defined by the contracting authority for the comprehensive and core levels (technical 
specifications and award criteria). Recommendations for its value are given in explanatory notes below. 
4 According to Article 61 of Regulation (EC) No 2018/848, this regulation shall apply from 1 January 2021. 
According to Article 60, products produced in accordance with Regulation (EC) No 834/2007 before 1 January 
2021 may be placed on the market after that date until stocks are exhausted. 

19 

 
 
 
 
 
 
 
                                                           
Comprehensive criteria 

Explanatory notes 
Core criteria 
Technical Specification and Award Criteria 
Organic food products  
The contracting authority will have to specify the percentage of purchase taking into account availability and costs 
and  how  the  percentage  of  purchase  has  been  calculated,  either  in  volume,  weight  or  value.  The  contracting 
authorities must decide the inclusion of one or several options in their tenders on individual basis.  
Recommended values for core criteria:  
Option A 
20-60% in mass of the total purchases of food and drinks products or  
30-70% in value of the total purchases of food and drinks products  
Option B 
List of products can include: fruit, vegetables, legumes, rice and pasta2  

Recommended values for comprehensive criteria:  
Option A 
>50% in mass of the total purchases of food and drinks products or  
>60% in value of the total purchases of food and drinks products  
Option B 
List  of  products  can  include:  fruit,  vegetables,  legumes,  rice,  pasta,  bread  and  bakery  products,  eggs,  dairy 
products, etc. 

1) X is the threshold to be defined by the procurer for the comprehensive and core levels (TS and AC). Recommendations for its value are given in explanatory 
notes above. 
2 This list is neither exhaustive nor detailed. Food and drinks products suggested in the comprehensive list or other products not mentioned in these lists can 
also be included in the core list (or in the comprehensive list) if the procurer considers that is suitable.   

Rationale of the proposed criteria wording 

The  inclusion  of  a  criterion  on  organic  food  products  is  proposed  based  on  studies  that  demonstrate  that  the 
possibility  of  achieving  some  environmental  benefits  can  be  brought  under  certain  conditions.  For  example 
benefits regarding biodiversity or the quality of soil. However, it is not yet possible to draw a general conclusion on 
the environmental benefits for all the conditions that are currently present across Europe.  

Several studies compare organic and conventional food products from the environmental perspective with diverse 
conclusions  as  commented  in  the  previous  technical  report  TR1.0  (JRC  2016b)  and  the  preliminary  report. 
Differences stem in the methodologies, and inventories used. The use of different methods, system boundaries, 
functional  units  and  environmental  indicators  among  other  aspects  lead  to  different  conclusions.  Therefore 
comparisons  between  those  kinds  of  products  should  be  carefully  done.  In  particular,  those  studies  based  on 
conventional LCA methodologies do not comprehensively capture aspects related to the biodiversity and therefore, 
they are not fully capturing certain environmental benefits of organic production.  

For example, per unit of area, organic farming has lower impact for most impact areas compared to conventional 
systems. However, per product unit organic systems have lower energy use, but larger land use and hence higher 
eutrophication potential and acidification potential. LCA methods are more product-efficiency driven, which usually 
favours intensive (high input agricultural) systems, even though other types of measures show that those systems 
are  environmentally  unsustainable.  In  this  sense,  for  an  LCA-based  comparison  of  farming  systems,  there  is  a 
need to use distinct functional units to acknowledge multifunctional outputs or to allocate environmental impacts 
to the whole set of agricultural outputs.  

When  looking  at  food  composition  and  contamination  aspects,  organic  crops  (i.e.  cereals,  fruit  and  vegetables) 
contain more antioxidants, less pesticides and less heavy metals (such as cadmium that accumulates in the body) 
than  do  conventional  crops.  In  addition,  from  an  animal  welfare  perspective,  organic  production  has  higher 
standards (Barański, 2014).  

With  respect  to  the  market  availability  the  EU  organic  food  market  has  been  continuously  growing  in  the  last 
years in all the steps of the chain of value. In 2015, it increased by 13% and nearly reached 30 billion euros (FIBL 

20 

 
 
 
 
2017). Almost all the major markets in EU enjoyed between 10 and 15% growth in value. The trend of the market 
growing faster than organic farmland continued in 2015. However, it is also observed that the area of organic 
farmland grew at a faster rate than it had in past years: it increased by 8.2% reaching 12.7 million hectares in 
2015 (6.2% of the total agricultural land). The countries with the largest organic farmland areas are Spain, Italy 
and France.  

In Europe there are more than 350 000 organic producers, 60 000 organic processors and almost 3 700 organic 
importers. The number of agents involved in the chain of value of organic products grew in all the sectors. The 
number of organic producers increased at 3% and the number of organic processors and importers increased by 
12% and 19% respectively.  

Requirements  on  organic  food  products  in  European  tenders  vary  significantly  ranging  from  10  to  100%  of 
organic  meals.  Some  organic  products  such  as  eggs,  dairy,  fruit,  vegetables,  hot  beverages,  meat  (mainly  in 
Northern  Europe)  and  bread  and  bakery  (in  some  Member  States)  are  more  dominant  than  others  (FiBL  and 
IFOAM, 2014). Organic products are often more expensive than conventional products, although the premium to 
pay depends on the type of product, country and season, ranging from 10% to 200%. 

The proposed criterion on organic food products is set up as a technical specification and as an award criterion, 
reflecting the wide-spread inclusion of this criterion in GPP tenders across EU-28 and the high requirements set in 
some  Member  States.  However,  in  other  Member  States  the  organic  product  market  is  not  well  developed  and 
strict requirements could create market distortions and difficulties of supplying. Both proposals are drafted giving 
freedom  to  the  procurers  to  set  thresholds  based  on  mass,  volume  or  monetary  value.  The  suitability  of  each 
accounting system will depend on the type of service, preparation chain, etc. The proposed thresholds are based 
on the information received as well as the benchmarks for excellence for GPP of food and drink products (section 
4.1.1.1 in TR1.0) (JRC 2016b). 

The proposed criterion includes several drafting options. Option A focuses on the type of products. This option is 
based  on  the  consolidation  of  already  established  markets  of  organic  products  such  as  pasta,  rice,  fruits  and 
vegetables,  legumes,  etc.  and  proposed  other  products  with  a  less  consolidated  market  for  the  comprehensive 
level of this criterion.  

Option B does not point out the type of organic product to be purchased but only the recommended minimum 
quantity or value. This option can be an opportunity to boost the market of certain organic products that are not 
widely offered.  

A  third  option  requiring  that  certain  amount  of  orders  comply  with  the  organic  regulation  requirements  was 
suggested by stakeholders. It was taken into account but discarded to ease the verification of public procurers. 

The explanatory notes include ranges of values that can be applied to set up the minimum requirements for the 
core and comprehensive levels. The values for the option B were estimated based on the information provided by 
the  stakeholders  and  included  in  Annex  1.  Among  this  information,  several  examples  of  existing  GPP  in  tender 
were provided. The uptake and levels of ambition vary significantly ranging from 10% to 100% of organic meals. 
The  proposed  values  are  in  line  with  the  benchmarks  of  excellence  for  GPP  of  Food  and  drink  products  in  the 
tourism sector. The reference document (BEMP 2012) states that at least 40% in value of food and drink products 
is certified according to high environmental standards or criteria.    

Further information can be found in Annexes 3.1 and 4.1 

Rationale of the proposed verification 

The verification of the proposed criterion is based on the Regulation (EC) No 834/2007 on organic production and 
labelling of organic products and an accounting document of the expected annual purchases. 

In accordance with Regulation (EC) No 834/2007, organic produce food can be certified and labelled as such being 
easily recognised and making feasible the verification of this criterion. EU organic logo is mandatory for organic 
pre-packed food produced in the EU.  

Procurers can also verify the purchases of organic food and drink products via detailed invoices. This is especially 
indicated for those cases where the tenderer cannot provide in advance the exact organic products to be supplied 
in the execution of the contract because they are not buying them but the orderer, the municipality or the kitchens. 
Invoices of the food and drink products purchased should be detailed enough and include the name of the product, 

21 

 
the quantity in mass or volume and the costs (as requested by the contracting authorities and specified in  the 
Contract Performance Clause, sections 2.3 and 3.2.8).  

22 

 
 
 
  Marine and aquaculture food products required. 

Core criteria 
Technical Specification 
TS2. Marine and aquaculture food products 
TS2.1  No  fish  or  fish  products  are  to  be  used  from  species  and  stocks  identified  in  a  ´fish  to  avoid´  list  that 
reflects the state of fish stocks in different regions.1) 

Comprehensive criteria 

Verification: 
The tenderer must provide a declaration that only fish and fish products that are compliant with the requirement 
mentioned above will be supplied. In addition, the tenderer must provide a description of how it intends to ensure 
compliance during the execution of the contract. (e.g. by identifying suppliers for the different products). 

Option A (easier to verify during contract execution) 
TS 2.2 The following fish and fish products [list of fish 
and  fish  products  to  be  defined  by  the  contracting 
authority]  must  have  been  produced  in  stocks  within 
safe  biological 
limits  addressing  environmental 
impacts, including over-fishing or depletion, biodiversity 
and  responsible  and  sustainable  use  of  the  resources.  
This implies that science indicates that there is a high 
probability that the estimated spawning biomass stock 
is higher than levels at which the stock risks collapsing. 
This must be based on assessments by the independent 
scientific  bodies  who  provide  advice  to  the  EU,  in 
particular  the  International  Council  on  the  Exploration 
of  the  Seas  (ICES),  the  EU's  Scientific,  Technical  and 
Economic  Committee  for  Fisheries  (STECF)  or  by 
Regional  Fisheries  Management  Organizations  around 
the globe2) 
Verification: 
The tenderer must provide a declaration that only fish 
and  fish  products  that  are  compliant  with  the 
requirement  mentioned  above  will  be  supplied.  In 
addition,  the  tenderer  must  provide  a  description  of 
how  it  intends  to  ensure  compliance  during  the 
execution  of  the  contract  (e.g.  by  identifying  suppliers 
for the different products). 

Option  B  (more  complex  to  verify  during  contract 
execution) 
TS 2.2. At least Y%3 of the purchases of fish and fish 
products  must  have  been  produced  in  stocks  within 
limits  addressing  environmental 
safe  biological 
impacts, including over-fishing or depletion, biodiversity 
and  responsible  and  sustainable  use  of  the  resources.  
This implies that science indicates that there is a high 
probability that the estimated spawning biomass stock 
is higher than levels at which the stock risks collapsing. 
This must be based on assessments by the independent 
scientific  bodies  who  provide  advice  to  the  EU,  in 
particular  the  International  Council  on  the  Exploration 
of  the  Seas  (ICES),  the  EU's  Scientific,  Technical  and 
Economic  Committee  for  Fisheries  (STECF)  or  by 

23 

 
 
 
 
the  products 

that  comply  with 

Regional  Fisheries  Management  Organizations  around 
the globe2). 
Verification: 
The tenderer must provide data (name and the amount) 
of marine and aquaculture food products that are to be 
supplied  in  the  execution  of  the  contract,  indicating 
specifically 
the 
requirements. 
Option A (easier to verify during contract execution) 
TS 2.3. The following aquaculture food products [list of 
products  to  be  defined  by  the  contracting  authority] 
must  have  been  produced  in  accordance  with  the 
requirements of a certification scheme for sustainable 
production 
is  based  on  multi-stakeholder 
organisations with a broad membership and addresses 
environmental 
including  biodiversity  and 
responsible and sustainable use of the resources4) 
Verification: 
The  tenderer  must  provide  a  declaration  that  only 
aquaculture food products that are compliant with the 
requirement  mentioned  above  will  be  supplied.  In 
addition the tenderer must provide a description of how 
it intends to ensure compliance during the execution of 
the  contract  (e.g.  by  identifying  suppliers  for  the 
different products).  

impacts, 

that 

that 

in  accordance  with 

Option  B  (more  complex  to  verify  during  contract 
execution) 
TS  2.3.  At  least  Y%3)  of  the  purchases  of  aquaculture 
food  products  (excluding  organic  aquaculture)  must 
have  been  produced 
the 
requirements of a certification scheme for sustainable 
production 
is  based  on  multi-stakeholder 
organisations with a broad membership and addresses 
environmental 
including  biodiversity  and 
responsible  and  sustainable  use  of  the  resources.4) 
Verification: 
The tenderer must provide data (name and the amount) 
of marine and aquaculture food products that are to be 
supplied  in  the  execution  of  the  contract,  indicating 
specifically 
the 
requirements.  Where  certification  schemes  are  based 
on  the  principles  mentioned  above,  they  could  be 
indicated as means of proof4) 

that  comply  with 

the  products 

impacts, 

Core criteria 
Award Criteria 
Option A (easier to verify during contract execution) 
AC 2.1. Points are to be proportionally awarded to tenders that exceed the list of fish and fish products [listed in 
TS2.2. option A] that have been produced in stocks within safe biological limits addressing environmental impacts, 
including over-fishing or depletion, biodiversity and responsible and sustainable use of the resources. 

Comprehensive criteria 

Option B (more complex to verify during contract execution) 
AC 2.1. Points are to be awarded proportionally to tenders in which more than the required Y%3) of the amount of 

24 

 
 
 
 
 
fish and fish products purchases  are coming from  stocks within safe biological limits. This implies  that science 
indicates that there is a high probability that the estimated spawning biomass stock is higher than levels at which 
the stock risks collapsing. This must be based on assessments by the independent scientific bodies who provide 
advice to the EU, in particular the International Council on the Exploration of the Seas (ICES), the EU's Scientific, 
Technical  and  Economic  Committee  for  Fisheries  (STECF)  or  by  Regional  Fisheries  Management  Organizations 
around the globe2 
Verification: 
See above TS2.2. option B 

Option A (easier to verify during contract execution) 
AC 2.2. Points are to be proportionally awarded to tenders that exceed the list of aquaculture food products [listed 
in  TS2.3.  option  A]  that  have been  produced  in  accordance  with  the  requirements  of  a  certification  scheme  for 
sustainable  production.  This  is  a  scheme  that  is  based  on  multi-stakeholder  organisations  with  a  broad 
membership and addresses environmental impacts, including biodiversity and responsible and sustainable use of 
the resources4) 

Option B (more complex to verify during contract execution) 
AC 2.2. Points are to be awarded proportionally to tenders in which more than the required X%3) of the purchases 
of aquaculture food products not complying with the organic produce criterion have been produced in accordance 
with  the  requirements  of  a  certification  scheme  for  sustainable  production  that  is  based  on  multi-stakeholder 
organisations  with  a  broad  membership  and  addresses  environmental  impacts,  including  biodiversity  and 
responsible and sustainable use of the resources.4) 
Verification: 
AC 2.1A. See above TS2.2. option A 
AC2.1B. See above TS2.2. option B 
 AC 2.2A.See above TS2.3. option A 
AC2.2B. See above TS2.3 option B. 

Comprehensive criteria 

Explanatory notes 
Core criteria 
Technical Specification and Award Criteria 
Marine and aquaculture food products  
The contracting authority will have to specify the percentage of purchase taking into account availability and costs 
and how the percentage of purchase has been calculated, either in volume, weight or value.  
Recommended values for core criteria: (X%) 
0-20% in mass of total purchases of fish or aquaculture products (excluding organic fish products)  
0-10% in value of total purchases of fish aquaculture products (excluding organic fish products) 

Recommended values for comprehensive criteria: (Y% or X%) 
20-50% in mass of total purchases of fish or aquaculture products (excluding organic fish products) 
10-40% in value of total purchases of fish or aquaculture products (excluding organic fish products) 

1) A specific list needs to be referenced. The following may be used as a guide: e.g. the Marine Conservation Society ‘fish to avoid’ 
(http://www.fishonline.org/fishfinder?min=5&max=5&fish=&avoid=1), WWF’s sustainable seafood guides, IUCN, Seaweb Europe, CITES, FAO, NOAA, Monterey 
Bay Aquarium Seafood Watch, Greenpeace. For national seafood guides. check Table 34. 
2) This information can normally be obtained through the websites of these organizations, for instance: www.ices.dk or https://stec.jrc.ec.europa.eu/ 
3) X and Y are the thresholds to be defined by the procurer for the core and comprehensive levels (TS and AC). Recommendations for its value are given in 
explanatory notes below. 
4)  At  the  time  of  writing  the  schemes  such  as  the  Aquaculture  Stewardship  Council  (ASC)  or  Globalgap  for  aquaculture  food  products,  are  considered  to 
provide a  sufficient  level  of  assurance.  Other  schemes  at country  level can  be considered  as  equivalent  if they comply  with  the  environmental  principles 
mentioned above. 

Rationale of the proposed criteria wording 

One of the chief consequences of industrial fishing is that some species have been overfished to the point of near 
extinction.  Most  European  landings  of  commercial  fish  and  shellfish  stocks  come  from  the  North-East  Atlantic 

25 

 
 
 
 
 
  
 
Ocean and Baltic Sea (86%). Approximately 60% of commercial fish landings come from stocks that are assessed 
with Good Environmental Status (GES) information (DG ENV, 2018). Strong regional differences exist, where the 
Mediterranean and Black Sea remain poorly assessed. 

Around 58% of the assessed commercial stocks are not in GES. Only 12% are in GES for both the level of fishing 
mortality and reproductive capacity. These percentages also vary considerably between marine waters. 

The use of commercial fish and shellfish stocks in Europe, therefore, remains largely unsustainable. Nevertheless, 
important signs of improvement for certain stocks are being recorded in the North-East Atlantic Ocean and Baltic 
Sea. 

One of the fundamental objectives of the Common Fisheries Policy is that stocks are fished at a level that can 
keep them  at  maximum  sustainable  yield  (MSY).  The  EU  Marine  Strategy  Framework  Directive’s  (MSFD)  overall 
objective is to reach GES of the marine environment by 2020. For commercial fish stocks, this means "Populations 
of all commercially exploited fish and shellfish are within safe biological limits, exhibiting a population age and size 
distribution that is indicative of a healthy stock". Concretely this means: 

  Sustainable  exploitation:  fishing  mortality  (F)  is  at  or  below  levels  that  deliver  Maximum  Sustainable 

Yield (MSY), i.e. F ≤ FMSY. 

  Reproductive capacity intact: (or its proxy) spawning stock biomass (SSB) is above the reference level, i.e. 

SSB ≥ SSBmsy (or above its proxy). 

This criterion aims at reducing the biodiversity loss environmental impacts by purchasing more sustainable fish 
from stocks that are not overfished. Responsible procurement should then avoid the purchase of threatened or 
endangered species and fish from damaging fisheries or farming systems included in red lists such as the Marine 
Conservation Society red list (MCS, 2015a). The Marine Conservation Society provides an up-to-date guideline on 
what fish stocks can be responsibly fished or farmed for wild caught fish and aquaculture respectively. Other lists 
have been included as commented below. Equivalent lists and national seafood guides should be checked as well 
by public authorities (see Table 34).  

The environmental impact is here addressed by requiring that fish products purchases must have been produced 
in stocks within safe biological limits. The marine and aquaculture criterion  are therefore addressed separately, 
since they have different production methods and therefore cause different environmental impacts. The marine 
products are addressed by means of TS2.1 and TS2.2 whereas the aquaculture products are addressed mainly by 
criterion TS2.3The species purchased should not be included in the list of “fish to avoid” and if a higher level of 
ambition is pursued, they must be positively assessed by the independent scientific bodies who provide advice to 
the EU. 

Despite the uptake of EU GPP criteria on fish by public procurers is low up to now (2 out of 7 respondents use it 
within  their  public  tendering),  in  the  1st  AHWG  meeting  the  stakeholders  showed  a  growing  awareness  to  use 
them.  The  stakeholders  in  the  2nd  AHWG  expressed  their  concerns  on  the  use  of  red  lists,  and  the  use  of 
percentages  in  mass  or  volume  since  this  is  a  product  category  that  is  frequently  bought  frozen,  being  more 
difficult to identify the date on which the fish was caught and if it was complying with the criteria at that time. 

There are differences among the Member States as regards the availability and number of suppliers of certified 
sustainable seafood products. In general, for criteria TS2.2 and TS2.3 there was consensus on the ambition levels 
proposed in the 1st AHWG meeting, although some stakeholders thought it lacked ambition. Therefore, the wording 
of  the  criteria  has  been  reformulated  allowing  the  contracting  authorities  to  set  up  the  most  appropriate 
thresholds  that  better  suit  the  diversity  of  the  region  or  country.  The  recommended  values  are  given  in  the 
explanatory  notes.  A  minimum  up  to  20%  in  mass  has  been  proposed  for  the  core  level,  while  for  the 
comprehensive level a figure between 20% and 50% has been proposed of those fish and seafood products that 
do not comply with the requirements of organic food products.   

Further information can be found in Annex 4.2. 

Rationale of the proposed verification 

When procurement includes the purchase of fish and seafood products, first of all s/he must make sure that the 
species are not included in the Red List. There are several recognised red lists that are regularly updated and give 
information about the fish stocks that can be responsibly fished or farmed for fish and aquaculture respectively. 

26 

 
The Marine Conservation Society provides one (MCS, 2015b). Other lists have been included in this revision, upon 
stakeholders  comments,  such  as  those  of  WWF  sustainable  seafood,  IUCN,  Seaweb  Europe,  CITES,  FAO,  NOAA, 
Monterey Bay Aquarium Seafood Watch and Greenpeace. 

Secondly, when the procurement includes the purchase of fish of popular (and often overfished) species such as 
tuna or cod, and fish from aquaculture (e.g. salmon), the verification that the stock is exploited at a rate that is 
consistent with producing the highest catch from the stock in the long term, can be done by using the latest EU 
publication of TACS available in https://ec.europa.eu/fisheries/cfp/fishing_rules/tacs_en. 

Up to now, there is no EU legislation on this topic, therefore third party certified schemes for wild caught fish and 
for  fish  from  aquaculture  are  considered  as  well  as  a  means  to  verify  compliance  with  the  criterion.  Certified 
products are widely available on the market in all Member States, as commented by stakeholders. However, some 
stakeholders expressed their concern for SMEs to acquire products since the chain of custody certification can be 
costly.  

These schemes should address a number of issues of environmental concern associated with the production of 
fish including: habitat alteration (e.g. over-fishing, depletion, loss of biodiversity, etc.), freshwater impacts (e.g. due 
to  the  use  of  nutrients  that  increase  organic  pollution),  escapes  and  impacts  on  associated  dependent  and 
ecologically  related  species),  interactions  with  local  wildlife,  effective  management  of  the  resources  that  is  in 
accordance with and enforces local, national and international regulations.  

The Marine Stewardship Council (MSC) label for wild caught fish and the Aquaculture Stewardship Council (ASC) 
(ASC,  2015)  label  for  fish  from  aquaculture  are  not  the  only  labels  that  public  bodies  could  accept.  GlobalGap 
(GLOBAL  GAP  2017a)  certified  production  standards  for  farmed  species  (aquaculture  but  also  other  animal 
species) are amongst other certification schemes proposed as a possible means of proof. National schemes can 
also be used.  

Further  information  on  third  party  environmental  certification  schemes  operating  among  others  in  EU-28  are 
gathered for consultation in Annex 3.4.2 (Table 34). 

Procurers can also verify the purchases of low environmental impact fish products  via detailed invoices. This is 
especially indicated for those cases where  the tenderer cannot provide in advance the exact fish species to be 
supplied in the execution of the contract.  Invoices of the food and drink products purchased should be detailed 
enough and include the name of the product, the quantity in mass or volume and the costs (as requested by the 
contracting authorities and specified in the Contract performance clause, sections 2.3 and 3.2.8).  

27 

 
 
 
Seasonal produces (removal) 

NOTE:  The  criterion  on  seasonal  produce  has  been  removed  from  the  Food  procurement  criteria  but  this 
explanatory note is proposed to be re-introduced.  

Explanatory notes 

Seasonal produces 

Seasonal produces have different environmental, health, economic and societal impacts depending on the regions 
the  products  are  coming  from  and  consumed  in.  Seasonal  produce  grown  outdoors  and  transported  over  short 
distances might have lower environmental impacts than products grown in greenhouses or transported over long 
distances.  

Seasonal vegetables may be characterized by better taste, quality and prices, which can promote the shift of the 
menu provided towards more vegetarian or plant-based options.  

Contracting authorities might decide the inclusion of seasonal produce criterion in their tenders on individual basis 
by indicating at what time of the year which food and drink products must be delivered/offered.  

Rationale for the proposed explanatory notes 

Eating more seasonal food  might be one proposal for moving towards more sustainable consumption patterns, 
based on the assumption that it could reduce the environmental impact of the diet. Seasonality can be defined as 
either globally seasonal (i.e. produced in the natural production season but consumed anywhere in the world) or 
locally seasonal (i.e. produced in the natural production season and consumed within the same climatic zone) (Mac 
Diarmid et al 2014). The environmental, health, economic and societal impact varies by the definition used. Global 
seasonality  has  the  nutritional  benefit  of  providing  a  more  varied  and  consistent  supply  of  fresh  produce  year 
round, but this increases demand for foods that in turn can have a high environmental burden in the country of 
production (e.g. water stress, land use change with loss of biodiversity, etc.). Greenhouse gas (GHG) emissions of 
globally seasonal food are not necessarily higher than food produced locally as it depends more on the production 
system used than transportation.  

Eating more seasonal and local food, particularly fruit and vegetables, is one of the dietary changes proposed to 
achieve  an  environmentally  friendlier  diet.  This  has  become  a  popular  message  being  advocated  by  non-
governmental organizations, promoted through media campaigns and is being considered as part of sustainable 
eating guidelines (Eat seasonably 2003, DEFRA 2008)  

The perception, awareness and understanding of seasonal food are important if the contracting authorities want 
to  include  this  criterion.  Seasonal  food  is  often  associated  with  locally  produced  food,  better  quality  food  or 
limited  food  choice.  Local  and  seasonal  fruit  and  vegetables  are  often  described  as  tastier,  fresher  and  better 
quality than the equivalent imported produce and those produced out of season. However, it is also often viewed 
as more expensive, less convenient, more time consuming to source and limits the variety of food  on the diet, 
which would inhibit the purchase of only seasonal food; these perceived barriers have been found to be similar 
across socio-economic groups (Chambers et al 2007) 

The environmental impacts of the food system are multidimensional with implications for climate change, water 
use, land use, biodiversity, soil degradation and pollution. There are very few studies that have explored all these 
issues  together  in  relation  to  seasonality,  most  have  focused  on  GHG  emissions.  GHG  emissions  are  produced 
throughout the lifecycle from production to processing, distribution, retail, consumption and waste disposal and 
overall the food system accounts for 20-30% of the total GHG emissions produced in a developed country such as 
UK (Garnett 2008). One of the benefits of eating seasonal food is that it reduces the GHG emissions because it 
does  not  require  the  high-energy  input  from  artificial  heating  or  lighting  needed  to  produce  crops  out  of  the 
natural growing season. There are many case studies in the literature that show that the total GHG emissions of 
some food produced out of season in the UK in the heating glass houses are higher than the same product grown 
naturally  in  season  abroad  and  transported  to  UK  (Webb  et  al  2013).  Even  some  products  grown  abroad  and 
transported  can  have  lower  GHG  emissions  than  the  same  food  produced  in  the  region  and  stored  for 
consumption out of season (Foster et al 2014). In other cases where more efficient production methods are used, 

28 

 
 
 
 
even when including transportation to the region of consumption they can have lower total GHG emissions than 
producing the same food in the region (Sauders and Barber, 2008)  

These examples bring into question the popular view that "food miles" (e.g. distance food travels) have one of the 
greatest  environmental  impacts  in  terms  of  the  diet.  Its  popularity  as  a  concept  and  use  as  an  indicator  of 
environmental impacts has fuelled many of the arguments for eating local and seasonal food. However, this use 
has been taken out of the original context for which it was first devised and been inappropriately used for carbon 
intensity. This concept is not supported by the evidence. In UK and the USA transportation only accounts for about 
10-11% of the food system with the vast majority of emissions coming from production and processing of food. 
Additionally, it is shown that most of the GHG emissions associated to the transportation occurs within the region, 
of  which  more  than  half  come  from  consumers  driving  to  and  from  food  shops  and  in  other  cases  from  the 
producers to the retailers (Weber et al., 2008).  

The studies indicate that focusing only on GHG emissions is likely to be ineffective, as it is only one dimension of 
the environmental impact of our food choices. As others have highlighted demand for food is putting significant 
pressure on many of the finite natural resources in the world such as water, land and minerals and therefore GHG 
emissions may not be the major driver, but other environmental considerations need to be taken into account.  

In  summary,  eating  more  seasonal  food  is  only  one  element  of  a  sustainable  diet.  However,  it  should  not 
overshadow  some  of  the  potentially  more  difficult-to-change  dietary  behaviours  that  could  have  greater 
environmental  and  health  benefits  (e.g.  reducing  overconsumption  or  meat  consumption).  For  drafting  realistic 
guidelines  for  environmentally  friendlier  diets,  the  contracting  authorities  will  need  to  take  into  account  the 
catering service or type of food product they need as well as the cultural and social traditions and expectations in 
the current food environment.  

29 

 
 
 
 
Integrated production (removal) 

NOTE:  The  criterion  on  integrated  production  has  been  removed  from  the  Food  procurement  criteria  but  this 
explanatory note has been re-introduced.  

Explanatory notes 

Integrated production 

Rules on integrated production have been developed in most of the Member States at national or regional level. 
Therefore there are different rules and integrated production guidelines for specific crops, fruits and vegetables, 
both developed by public or private schemes.  

The contracting authorities may decide to include an integrated production criterion in the tenders on an individual 
basis by indicating the percentage of total purchase not complying with organic food products criterion that must 
comply  with  the  rules  in  place  where  the  food  products  are  produced  or  a  specific  private  scheme1).    The 
percentage will be calculated, either in volume, weight or value.  

Rationale 

Scientific  evidence  suggests  that  integrated  production  (IP)  could  be  a  way  to  achieve  lower  environmental 
impacts in comparison to conventional produce from agriculture at no or little additional cost, as it  is based on 
good practices. IP can provide significant environmental benefits compared to conventional farming because of, 
among other good practices, the restricted use of pesticides and synthetic fertilisers.  

However,  and  regarding  the  introduction  of  IP  in  the  GPP  criteria  for  food  procurement  no  criteria  has  been 
proposed due to mainly two major points:  

There  is  no  a  unique  definition  of  ''integrated  production''  across  Europe.  At  present,  at  EU  level  there  is  no  a 
unique definition of IP and most of the Member States that developed regulation on IP chose its own definition. 
However, it should be noted that most of the IP definitions are pretty close in the concept. From the point of view 
of the environment, negligible differences between definitions and regulations are not relevant enough to prevent 
procurers from taking advantage of the benefits of this production method.   

Definitions provided by the existing national and regional regulations are also close to the definition provided by 
International organization of biological and integrated control (IOBIC 2017) that reads "integrated production is a 
farming  system  that  produces  high  quality  feed  and  other  products  by  using  natural  resources  and  regulating 
mechanisms to replace pollution inputs to secure sustainable farming". Additionally, the IOBC provides the principles 
of the integrated production which are listed in the Annex 3.1. 

It should be noted, that best practices to be applied to crops are detailed in the guidelines that come along with 
the  regional  and  national  regulations  or  the  private  schemes.  These  IP  guidelines  transfer  the  IP  concept  into 
methods  and  measures  that  can  be  implemented  on  farm-level.  The  IP  guidelines  consist  of  crop-specific 
measures  that  have  been  thoroughly  tested  in  practise.  For  example,  there  are  IP  guidelines  specific  for  each 
region for stone fruits, soft fruits, citrus, arable crops, each type of vegetables, etc. 

The second point concerns the verification procedure. As there is no common EU certification scheme, there is no a 
common verification procedure. Therefore, the verification procedure should be based on the regulation in place. If 
the Member State does not develop any regulation on IP neither at national nor at regional level, farmers can still 
produce  applying this method  and  get  a  third  party  certification  and  label  that ensures  that  the  food  products 
were produced respecting some standards. Currently there are international certification schemes that are widely 
recognised  and  can  provide  a  certification  on  crops  that  demonstrate  the  good  practices  put  in  place,  such  as 
Global GAP 

There  are  other  systems  such  as  Sustainable  Agriculture  Initiative  Platform  (SAI  2017),  a  platform  farm 
sustainability  assessment  (FSA)  that  follows  a  benchmarking  system.  The  benchmarking  carried  out  by  SAI 
involved a detailed analysis process, in which the score reflects the overall equivalence between the FSA and the 
alternative program at the question level. FSA is general so far and can be applied to most crops and all regions, 
and covers a wide range of issues. A producer that follows the FSA can show compliance with this criterion if the 

30 

 
 
 
equivalence between the FSA and a national or well-recognised scheme proposed for verification achieves at least 
a bronze level.   

In case the contracting authorities nevertheless choose to introduce a criterion on integrated production, procurers 
can also verify the purchases of products under integrated production standards throughout the detailed invoices. 
Invoices of the food and drink products purchased should be detailed enough and include the name of the product, 
the quantity in mass or volume and the costs 

31 

 
 
 
 
  Animal welfare 

Core criteria 
Technical Specification criteria 
TS3. Animal welfare  
None of the eggs in shell coming from conventional farming are labelled code 3 of Regulation (EC) No 589/2008 
or its subsequent amendments. 

Comprehensive criteria 

Verification:  
The tenderer must provide a declaration that none of the eggs in shell coming from conventional farming will be 
labelled code 3 of Regulation (EC) No 589/2008. In addition, the tenderer must provide a description of how it 
intends  to  ensure  compliance  during  the  execution  of  the  contract  (e.g.  by  identifying  suppliers  and  indicating 
specifically the ones that will supply eggs compliant respectively with code 1 or 2 of Annex I, part A to Regulation 
(EC) No 589/2008.). 

Award criteria 
AC3. Additional animal welfare  
3.1. Points are to be proportionally awarded to tenders in which more than X%1) of the eggs in shell (excluding 
organic eggs) are labelled code 1 of Regulation (EC) No 589/2008. 

3.2. Points are to be proportionally awarded to tenders in which more than Y%1) of the total purchases of meat 
and  dairy  (excluding  those  that  are  organic)  have  been  produced  in  accordance  with  the  requirements  of  a 
certification scheme for animal welfare. This is a scheme that is based on multi-stakeholder organisations with a 
broad  membership  and  addresses  general  aspects,  including  low  stress,  minimum  use  of  antibiotics,  stunned 
slaughter, minimum transportation times, and addresses particular aspects such as the grazing season for milk 
cows or no-tail docking on pigs2).  

Verification:  
AC 3.1. See above TS3 
AC 3.2. The tenderer must provide data (name and amount) of the meat products that are to be supplied in the 
execution of the contract indicating specifically the ones that comply with the requirements.  

Explanatory notes 
Core criteria 
Award Criteria 
The  contracting  authority  will  have  to  specify  the  percentage  of  purchase  taking  into  account  availability  and 
costs, and how the percentage of purchase has been calculated, either in volume, weight or value.  
Recommended values for (X%) and (Y%) 
X=80% of the eggs in shells (excluding organic eggs products) are labelled with code 1 
Y=0-25% of meat and dairy products (excluding organic meat products) 

Comprehensive criteria 

1)  X  and  Y  are  the  threshold  to  be  defined  by  the  procurer  for  the  comprehensive  and  core  levels  (AC).  Recommendations  for  its  value  are  given  in 
explanatory notes below. 
2) Products that have been third party certified by widely accepted and recognised standards such as e.g. Label Rouge, GlobalGAP with the add-on of Animal 
welfare, RSPCA Assured are deemed to comply, provided they cover the environmental principles mentioned above. 

Rationale for the proposed criteria wording 

Farm animal welfare involves both the physical and psychological well-being of an animal. How they are raised 
and  treated  can  have  important  repercussions,  not  just  for  animal  welfare,  but  for  the  environmental 
sustainability,  food  security  and  economic  well-being  of  farmers.  Improving  animal  welfare  can  have  positive 
impacts for sustainability and livelihoods in a variety of systems 

32 

 
 
 
 
 
 
 
 
 
Meat  and  dairy  products  have  been  pointed  out  as  one  of  the  food  categories  with  the  highest  environmental 
impacts. Some measures can be implemented to reduce the environmental impacts due to this consumption such 
as a reduction of the overall demand of meat/dairy products or the consumption of meat/dairy produced under 
certain conditions. Thus, it is important to consider animal welfare since it is a measure to reduce the impacts on 
the  livestock.  Additionally,  this  criterion  addresses  an  important  consumer's  demand  and  is  linked  with  animal 
health and well-being.  

Eggs  and  other  products  coming  from  livestock  are  food  categories  with  an  important  attributed  overall 
environmental impact and impacts on the life standards of the animals. Eggs are widely consumed across EU-28 
and therefore it was considered to be included in this criterion as a technical specification criterion. The Regulation 
(EC) No 589/2008, sets minimum requirements for systems of production for the various egg farming methods, 
and distinguishes three types of methods according mainly to the open air access and the stocking density the 
hens have. Eggs with code 0 are organic eggs, eggs with code 1 are free-range eggs, eggs with code 2 have been 
produced within a limited room while eggs coded 3 are coming from caged hens. 

LCA studies have often excluded aspects such as social, economic or ethical matters. This fact makes difficult to 
value the importance of this criterion from an environmental perspective. Scientific evidence shows that higher 
animal welfare standards have pros and cons in the respect to achievable environmental benefits. The longer lives 
and more space (reduced stocking density) would require more resources (per unit of production), hence, from an 
LCA perspective it will increase the total burden of meat production. It is not clear whether better animal welfare 
practices  lead  to  better  food  quality,  but  there  are  evidences  that  free-range  pigs  have  lower  stress  level  and 
therefore at EU level better meat quality than pigs kept indoors on slatted floors. 

The low uptake in the recently launched GPP schemes across EU-28 made that in the TR1.0 (JRC 2016b) only the 
category of eggs was included at the core level. However, voluntary welfare labelling schemes are available and a 
number  of  the  national  GPP  schemes  include  animal  welfare  standards  as  an  ethical  criterion.  This  experience 
demonstrates that the scope of the present criterion on Animal Welfare could be wider, entailing all animal based 
food products on top of free range eggs, in agreement with many stakeholders opinion.  

This revision does not point out thresholds or units to measure the amount of products complying with animal 
welfare standards to be procured. The common stakeholder's opinion about the ambition levels for the criterion 
was  that  a  minimum  up  to  25%  of  the  total  purchases  of  animal  products  must  be  produced  respecting  high 
welfare  standards,  for  the  core  level  or  the  comprehensive,  respectively.  Since  these  thresholds  may  seem 
stringent  and  not  affordable  by  all  Member  States,  this  criterion  is  here  proposed  as  an  award  criterion. 
Additionally,  procurers  are  given  recommended  values  in  the  explanatory  notes,  having  the  freedom  to  fix  the 
most appropriate value attending to the specificity of the place where the tender is launched. 

Further information can be found in Annex 4. 

Rationale for the proposed verification 

The verification of the proposed criterion for cage-free eggs is based on the Regulation (EC) No 589/2008, laying 
down detailed rules for implementing Regulation (EC) No 1234/2007  on marketing standards for eggs, plus an 
accounting document of the expected annual purchases. 

For  the  second  requirement  on  meat  products  there  is  EU  Regulation  although  there  has  been  an  uneven 
implementation level in the different EU countries. In 1998, Directive 98/58/EC on the protection of animals kept 
for farming purposes, gave general rules for animals of all species kept for the production of food, wool, skin or 
fur or for other farming purposes, including fish, reptiles of amphibians. These rules are based on the European 
Convention  for  the  Protection of  Animals  (Council  of  Europe,  1976)  kept  for  Farming  Purposes.  Legislation  has 
been further developed since that time to progressively improve the welfare status of farmed animals and to set 
standards on the farm, for their transport and conditions at the time of stunning and slaughter. 

Due to the low and unequal implementation of the Regulation (EC) No 589/2008, the verification for this criterion 
has to rely on third party certification schemes. The certification schemes considered as valid for verification of 
this criterion on animal welfare standards should cover the following aspects to ensure the equivalency among 
the  standards:  stocking  density,  cleanliness  conditions,  responsible  use  of  antibiotics  and  transport  conditions 
among  others.  Examples  are  given  such  as  GlobalGap  (GLOBAL  GAP  2017b)  with  the  add-on  Animal  welfare. 

33 

 
Organic labels can only be considered to verify the organic produce criterion and cannot be used to be awarded on 
the animal welfare criterion. 

The market availability in EU-28 of these certification schemes has been revised in the EU campaign and gathered 
for consultation in the Annex 4. 

Procurers can also verify the purchases of organic food and drink products via detailed invoices. This is especially 
indicated for those cases where the tenderer cannot provide in advance the exact animal products to be supplied 
in the execution of the contract. Invoices of the food and drink products purchased should be detailed enough and 
include the name of the product, the quantity in mass or volume and the costs (as requested by the contracting 
authorities and specified in the Contract performance clause, sections 2.3 and 3.2.8).  

34 

 
 
 
Fair and ethical trade products (BEFORE: Fairly traded products) 

Core criteria 
Award Criteria 
AC4. Fair and ethical trade products 

Comprehensive criteria 

Option A (easier to verify during contract execution) 
Points  are  to  be  awarded  proportionally  to  tenders  in  which  the  following  products:  [list  of  food  and  drink 
products]  have  been  produced  and  traded  in  accordance  with  the  requirements  of  a  fair  and  ethical  trade  
certification scheme that requires a minimum certified content of 90%. This is a scheme that is based on multi-
stakeholder  organizations  with  a  broad  membership.  The  scheme  addresses  international  fair  trade  standards 
including  working  conditions  for  production  in  accordance  with  the  core  conventions  of  International  Labour 
Organisation (ILO) 1), sustainable trade and pricing3).  

Verification:  
The tenderer must provide data (name and amount) of all products to be supplied in the execution of the contract 
indicating the ones compliant with the criterion. 

Option B (more complex to verify during contract execution) 
Points are to be awarded proportionally to tenders in which more than X%2) of the total purchases of each of the 
following  products  [list  of  food  and  drink  products]  have  been  produced  and  traded  in  accordance  with  the 
requirements of a fair and ethical trade certification scheme that requires a minimum certified content of 90%. 
This  is  a  scheme  that  is  based  on  multi-stakeholder  organizations  with  a  broad  membership.  The  scheme 
addresses international fair and ethical trade standards including working conditions for production in accordance 
with the core conventions of International Labour Organisation (ILO)1), sustainable trade and pricing3).  

Verification: 
The tenderer must provide the list of products to be supplied in the execution of the contract that comply with the 
criterion. 

Explanatory notes 
Core criteria 
Award Criteria 
The  contracting  authority  will  have  to  specify  the  percentage  of  purchase  taking  into  account  availability  and 
costs, and how it has been calculated, either in volume, weight or value spent.  

Comprehensive criteria 

Option A 
The list of products can include: coffee, tea, chocolate (cocoa), sugar, bananas, other fruits and packaged fruits, 
exotic fruit juice, avocados, tomatoes, vanilla, etc. 

Option B 
Recommended values for core criteria:  
X > 40-60% of total purchases of each product included in the list. 
Recommended values for comprehensive criteria:  
X > 70-100% of total purchases of each product: coffee, tea, chocolate (cocoa), sugar and bananas.  
The list of products can include: coffee, tea, chocolate (cocoa), sugar, bananas, packaged fruits, exotic fruit juice, 
etc. 

1) The ILO Core 8 convention requirements are explicitly written into organizational documents: #29-Forced Labour (1930), #87-Freedom of Association and 
Protection  of  the  Right  to  Organize  (1948),  #98-Right  to  Organize  and  Collective  Bargaining  (1949),  #105-Abolition  of  Forced  Labour  (1959),  #138- 
Minimum Age (1973), #182-Worst Forms of Child Labour (1999), #100-Equal Remuneration (1951), and #111-Discrimination (1958).  
2) X is the threshold to be defined by the procurer for the comprehensive and core levels (AC). Recommendations for its value are given in explanatory notes. 
3) Schemes considered to deem with the requirements of this criterion do not need to be part of the Fair Trade movement. Schemes such as Fairtrade®, UTZ, 
Bonsucro, etc. can show compliance with the criterion provided they cover the principles mentioned above. Other schemes at country level can be considered 

35 

 
 
 
 
 
 
 
 
 
 
as equivalent as far as they comply with the principles mentioned above. 

Rationale for the proposed criteria wording 

Products  originating  from  developing  countries  can  have  lower  social/labour  standards  than  the  EU  minimum 
accepted  level.  The  most  common  products  imported  to  the  EU  from  developing  countries  that  are  covered  by 
responsible  or  ethical  labels,  are:  coffee,  tea,  sugar,  chocolate  and  bananas.  From  an  ethical  perspective  it  is 
proposed that these products should be covered by a certification scheme that ensures better trading conditions 
and promotes sustainability.  

These  fair  and  ethical  trade  certification  schemes  and/or  labels  usually  also  include  minimum  environmental 
considerations,  such  as  avoiding  unsustainable  deforestation  and/or  to  restrict  the  use  of  hazardous  pesticides. 
Additionally, as part of these certification schemes farmers are often taught good farming practices which results 
in lower environmental impacts, compared to farmers that are not part of such a scheme. This is an additional 
reason to include this criterion in this revision.  

The name for this criterion has been slightly modified from the TR1.0 (JRC 2016b), due to the similarity with a 
registered trademark, as pointed by stakeholders. A suggested alternative was ‘fairly traded products', which was 
accepted in the second revision. However, a broader definition has been taken to be coherent with other policies 
and the final name of the criterion is 'fair and ethical trade products'. This name does not make a reference to the 
Fair Trade Movement and the certification schemes included in this movement. Other schemes apart from those 
of  the  Fairtrade  movement  can  be  used  to  show  compliance  with  this  criterion  as  long  as  they  fulfil  the 
requirements listed. 

The  uptake  of  this  kind  of  criterion  has  also  been  revised.  Some  stakeholders  argued  that  a  lack  of  market 
availability would impede the consecution of high thresholds, while others stated that the limits should be more 
ambitious and include more types of products. The uptake/inclusion of this criterion in the recently launched GPP 
schemes  across  Europe  was  approx.  30%,  which  allows  the  proposal  to  include  fair  and  ethical  trade  product 
requirement as an award criterion.  

Regarding the level of ambition and the scope of the criterion, stakeholder opinions were much split. Therefore, 
two options are proposed. In the option A the totally of the products must be purchased in accordance with the 
requirements of the criterion, but the procurers decide which those products are.  In the option B,  procurers are 
given  a  range  of  recommended  values  in  the  explanatory  notes  (40-60%  for  the  core  and  70-100%  for  the 
comprehensive  level),  having  the  freedom  to  fix  the  most  appropriate  value  attending  to  the  specificity  of  the 
place where the tender is launched for those products that are considered to be widely available on the EU market 
and listed in the criterion. Some food and drink products are mentioned as examples in the explanatory notes. 

Further information can be found in Annex 3.1. 

Rationale for the proposed verification 

Despite no EU Regulation exists for this criterion, in the context of public purchasing, the Commission in the EC 
Communication EC COM (2009) 215,; underlines the interest of providing guidance to public purchasing authorities 
help realise the full potential contribution to sustainable development from their decisions. In this communication 
the  Commission  also  underlines  that  a  contracting  authority  that  intends  to  purchase  sustainability  assurance 
goods should use only criteria linked to the subject matter of their purchase and comply with the other relevant 
EU public procurement rules. Contracting authorities must always allow bidders to prove compliance with these 
standards by using Fair Trade labels or by other means of proof. 

There is a number of third party certified fair trade schemes for all mentioned products available in Europe. The 
State of Sustainability Initiatives Review (IISD & IIED, 2014) gathers the description of the most relevant schemes 
of sustainable production, together with the market information of the penetration of these schemes within some 
product categories. The World Fair Trade Organisation counts with a guarantee system, which is recognised by the 
EC Communication EC COM (2009) 215 final as a system implementing Fair Trade criteria. 

In  terms  of  market  availability,  the  Fairtrade®  label  is  available  across  all  of  EU-28.  The  Fair  Trade  Labelling 
Organisations International (FLO, 2017) serves also as a coordinating organisation for national labelling initiatives 
and producer networks as well as a certification body. The use of any scheme under FLO indicates that a product 
has  been  certified  by  independent  auditors  to  ensure  that  it  respects  environmental,  labour  and  development 

36 

 
standards. Apart from the schemes identified above, the SSI report (SSI, 2014) also includes others as ProTerra 
Foundation (ProTerra, 2014). 

Some  of  the  third  party  certification  schemes  proposed  to  show  compliance  within  the  requirements  of  the 
criterion have been analysed in more detail. It was found that the amount of certified product required by each 
certification scheme varies widely and  that the labels and messages communicated to the consumers are also 
significantly  different.  Therefore  a  minimum  threshold  in  the  certified  content  that  should  be  required  by  the 
scheme has been set up in this revision. This limit will exclude those certification schemes that provide a label to 
products with lower content of certified ingredient in the overall product.  

This criterion does not exclude those products that are complying with the organic food product requirements for 
two  main  reasons:  there  is  a  wide  availability  of  products  that  are  double  labelled  (in  accordance  to  organic 
produce and fairly trade) and both criteria address aspects completely different. Therefore both criteria cannot be 
considered as alternatives but they should be considered as complementary aspects of those products produced 
in developing countries.  

Procurers  can  also  verify  the  purchases  of  fair  and  ethical  trade  products  throughout  the  detailed  invoices. 
Invoices of the food and drink products purchased should be detailed enough and include the name of the product, 
the quantity in mass or volume and the costs (as requested by the contracting authorities and specified in the 
Contract performance clause, section 3.2.8). 

37 

 
 
 
Packaging (removal)  

Rationale for the proposed criteria 

Packaging is a complex subject area. The use of packaging has, from the environmental point of view, pros and 
cons. Among the advantages are: the extension for the product life or the improvement of the overall integrity of 
products  (e.g.  modified  atmosphere  packaging  and  skin  packaging).  Among  the  disadvantages  are  the 
environmental  impacts  due  to  the  use  of  materials  and  resources  such  as  the  embedded  impacts  in  materials 
from  their  manufacture,  unnecessary  transport  emission  from  too  heavy  or  bulky  packaging  and  the 
environmental impacts associated with the end of life waste management.  

The TR1.0 (JRC 2016b) proposed a criterion that partially tackled (at least partially the first and second impacts 
(not  the  end  of  life  phase  impacts),  including  criteria  on  reusability,  recycled  material  content.,  no  single  units, 
materials coming from sustainable sources or packaging that could be compostable or biodegradable.  

Prior to the writing of this report, stakeholders stressed the greater emphasis should be place on the benefits of 
packaging in terms of improved food safety and reducing food losses. Even the inclusion of a packaging criterion 
as a separate criterion was challenged as packaging could be considered as an integral part of the product and 
hence cannot be assessed in isolation.  

Stakeholders stated that there are too many trade-offs and different situations that should be analysed case by 
case  to  estimate  the  environmental  benefits  of  using  packaging.  Additionally,  it  was  suggested  that  the  GPP 
should not favour/penalise the choice of packaging material since this is dependent on the situation in which they 
are being used. For example, the use of compostable/biodegradable packaging represents the most contentious 
issue  since  the  associated  environmental  benefits  are  heavily  dependent  on  the  local  recycling  infrastructure. 
Another example is the restriction on the single unit use that received large amounts of comments. The single unit 
packaging  can  reduce  food/drink  waste  and  indirectly  improve  water  and  energy  efficiency  at  the  preparation 
stage. The use of reusable packaging such as returnable bottles only brings environmental benefits if the distance 
between the cleaning and re-filling facilities and the catering facilities does not exceed 100km 

Finally,  several  challenges  were  identified  related  to  the  verification  of  the  proposed  requirements  such  as  the 
difficulties to assess the need of single unit packaging, the need to rely on private schemes or self-declarations. 
For example, it was commented that it is difficult to assess if single unit packaging is beneficial without knowing 
the details of the catering service where they are used. 

For all these reasons, the packaging criterion is proposed to be removed in this report.  

38 

 
 
 
 
 
  More environmentally responsible vegetable fats 

Core criteria 
Technical specification 
TS4. More environmentally responsible vegetable fats 

Comprehensive criteria 

TS  4.1.  If  pre-packed  food  and/or  drink  products  containing  vegetable  fats  are  purchased,  at  least  X%5 of  the 
units/items of pre-packed food products containing vegetable oils must have been produced from crops complying 
with environmental criteria regarding  soil, biodiversity, land-use change and organic carbon stocks by meeting the 
requirements of a certification scheme6 covering these issues, of Article 93 of Regulation (EU) No 1306/2013 , or 
by other equivalent means. 

TS 4.2. If vegetable oil is purchased, at least Y%5 of the vegetable oil purchased as raw ingredients must have been 
produced  from  crops  complying  with  environmental  criteria  regarding  soil,  biodiversity,  land-use  change  and 
organic carbon stocks by meeting the requirements of a certification scheme6 covering these issues, of Article 93 
of Regulation (EU) No 1306/2013, or by other equivalent means. 

Verification: 
TS 4.1. The tenderer must provide a declaration that at least X%5 of all the food products containing vegetable fats 
(as units) to be supplied in the execution of the contract are compliant with the requirement mentioned above. The 
tenderer must include a description of the measures that will be taken to ensure compliance (e.g. sources of supply 
that could be used). 

TS 4.2. The tenderer must provide a declaration that at least Y%5 of all vegetable oil or their derivatives (as raw 
ingredient or as margarines) that  it supplies  are compliant with the  requirement mentioned above. The tenderer 
must include a description of the measures that will be taken to ensure compliance (e.g. sources of supply that 
could be used). 

Explanatory notes 
Core criteria 
Technical specification 
Contracting authorities will list which vegetable oils  are relevant for the specific tender and have to satisfy this 
technical specification 
Recommended values for the core criteria:  
X=10-50% of the units/items of pre-packed food and/or drink products 
Y=10-50% in mass of the total vegetable oil (bought as raw ingredient) or margarine 

Comprehensive criteria 

Recommended values for the comprehensive criteria:  
X=50-100% of the units/items of pre-packed food and/or drink products 
Y=50-100% in mass of the total vegetable oil (bought as raw ingredient) or margarine  

Rationale for the proposed criteria wording 

5 It is the threshold to be defined by the contracting authority for the comprehensive and core levels (technical 
specifications and award criteria). Recommendations for its value are given in explanatory notes below. 
6 Schemes based on organisations with a broad multi-stakeholder membership, including NGOs, industry and 
government such as Roundtable on Sustainable Palm Oil - RSPO, Palm Oil Innovation Group - POIG, 
Roundtable on Responsible Soy - RTRS, The Soybean Sustainability Assurance Protocol - SSAP or Pro-Terra 
can show compliance with the criterion provided they cover the environmental principles mentioned. Other 
schemes, including at country level, are to be considered as equivalent if they comply with the environmental 
principles mentioned. 

39 

 
 
 
 
 
 
 
 
 
                                                           
Oil  crops  (soybean  and  palm)  and  their  derived  products  represent  the  largest  share  (63%)  of  deforestation 
embodied traded crop commodities, followed by stimulants (11%) like coffee and tea and fibre crops (8%) like 
cotton and tobacco  

In EU-27 the import of oil crops are heavily associated with deforestation in the country of origin. The embodied 
deforestation was mainly associated with two crops and their derived secondary crop products, namely soybean 
cake  and  soy  beans  (together  82%  but  including  also  the  soybeans  used  for  animal  feed)  and  oil  palm  (17 
%).  Other  important  crop  products  are  stimulates  like  coffee  and  cocoa  (12%)  and  industrial  crops  like  rubber 
(6%), some of them covered in other criteria in the current document. 

The criterion on environmentally responsible vegetable fats has been split into two parts. The first part deals with 
the pre-packed food products that contain  vegetable fats and the second one with the purchases of  vegetable 
fats raw ingredient. This separation was in fact requested by several stakeholders to make easier the accounting 
of the certified vegetable fats used and the verification process (see below for further details).  

The  criterion  scope  is  open  to  all  types  of  vegetable  fats.  In  this  sense,  the  wording  of  the  criterion  has  been 
changed to reflect this point and the non-discrimination of any vegetable fats.  

Currently,  there  are  two  production  standards  working  for  a  more  responsible  production,  RTRS  and  ProTerra, 
which  the  WWF  and  other  organizations  classify  as  comparable.  The  certification  system RTRS  (Round  table  on 
responsible soy) set requirements within five areas: compliance with national and local laws, human rights, social 
responsibility,  environmental  responsibility  and  sustainable  agricultural  practices  ("good  agricultural  practices" 
GAP). The RTRS is a member-based initiative founded in 2006, which works in the sector of responsible soy value 
chains.  The  initiative  develops  and  manages  standards  for  responsible  soy  production  and  operates  across  21 
countries.  The  initiative  operates  business  to  business.  RTRS  units  are  evaluated  for  certification  each  year,  by 
means of third party audits and, accredited auditors. RTRS offers a separate Chain of Custody certification and 
applies  the  segregation  and  mass  balance  models  of  supply  chain  traceability  to  its  products  to  ensure 
accountability of compliance claims in the marketplace (IISD and IIED, 2014). 

The  certification  system  Proterra  sets  requirements  within  the  areas  of  nature  conservation,  protection  of 
minorities, good working conditions, human rights, sustainable agricultural practices and products free from GMOs. 
Pro-terra certification means that, unlike RTRS, the soy is physically traceable and assures the buyer that the soy 
has been verified and can be traced back to the grower.  The ProTerra Foundation is a member-based, not for- 
profit  foundation,  starting  in  2012.  The  ProTerra  Standard  is  applicable  to  any  food  or  agricultural  product, 
although it is currently used mainly for soy production and soy-derived consumer products. The initiative operates 
business to consumer, developing standards and managing and maintaining quality control over certification. The 
validity  period  of  ProTerra  certificates  is  one  year,  with  all  audits  conducted  by  third-party  auditors.  Identity 
preservation and the segregation models of supply chain traceability are applied to all ProTerra soy products to 
ensure accountability of compliance claims in the marketplace. (IISD and IIED, 2014). 

Secondly, palm oil is used extensively in food manufacture and food preparation in Europe. The extensive review 
of LCA studies summarized in the preliminary report (JRC 2016a), found that palm oil has a large environmental 
impact due to its production and extraction, which can be reduced if the palm oil is grown, collected and treated in 
a  sustainable  manner  (i.e.  deforestation-free,  not  grown  on  land  which  has  involved  land-use  change, 
implementing practices on better management of the resources and the lower and better use of fertilisers).  

There  are  other  oils  that  are  also  used  as  raw  ingredient  or  in  the  preparation  of  food  such  as  rapeseed  and 
sunflower  oils.  Procurement  authorities  should  determine  which  are  the  most  relevant  vegetable  fats  to  be 
addressed in their specific contracts. . The substitution of palm oil by other vegetable oils was also proposed by 
several  stakeholders,  but  it  should  be  noted  that  palm  oil  has  much  higher  yield  rates  compared  to  the  main 
alternative  vegetable  oils,  and  therefore  totally  substitute  palm  oil  may  result  in  further  land  use  and 
deforestation. 

Certified palm oil is available on the international market. In 2014 almost 12 million tonnes of palm oil, about a 
fifth of total world production, were produced according to the criteria of the Roundtable on Sustainable Palm Oil 
(RSPO 2015), but only half of that amount was sold as Certified Sustainable Palm Oil (CSPO) – the rest didn't find 
a  buyer  on  the  certified  market  and  was  sold  as  conventional  palm  oil.  The  availability  of  palm  oil  certified 
through the most rigorous certification schemes that offer transparent traceability is currently widely available in 
the  Netherlands,  UK,  Belgium,  Germany,  Austria,  Switzerland,  France  and  progressing  in  the  Scandinavian 

40 

 
countries,  Italy,  Latvia,  Poland,  and  Spain.  However,  there  are  other  schemes  (unbundled  ones)  that  work 
internationally through an on-line platform being available in any Member State without restrictions. 

The criterion was initially proposed as an award criterion due to the little use of palm oil in some Member States. 
However, the stakeholders pointed out that an Award Criterion rewards the efforts made by the tenderers to buy 
palm  oil  or  palm  oil  containing  products  being  in  contradiction  to  some  national  health  recommendations  or 
promoting  the  use  of  this  type  of  oil  over  other  vegetable  oils.  In  this  report,  the  criterion  is  proposed  as  a 
Technical Specification. In this way, it is ensured that whenever used, at least a percentage of the products or the 
raw ingredient will be covered by a certification scheme.  

The  criterion  requires  the  provision  of  vegetable  fats  coming  from  certified  sources,  including  an  example  of 
schemes that could be considered as a proof of compliance. There are several schemes on the market that aim at 
certificate  the  responsible  management  of  the  areas  where  the  vegetable  fat  comes  from.  Among  all  those 
schemes are the Roundtable Sustainable Palm Oil (RSPO 2015, RSPO 2015b) that has the largest market shares. 
Palm Oil Innovation Group (POIG) is a very robust certification scheme that could also be used. All these schemes 
should be independent multi-stakeholders organizations that provide a globally applicable certification system for 
the  sustainability  of  raw  materials  and  products  and  traceability  through  the  supply  chain.  Responsible 
management requirements are part of those schemes.  

Further information can be found in Annex 3.1. 

Rationale for the proposed verification 

As commented before, the criterion was split into two clauses. The first one deals with the palm oil as ingredient 
in  the  pre-packed  food  products  and  the  second  one  deals  with  the  palm  oil  as  raw  ingredient.  Stakeholders 
commented  the  difficulties  that  they  would  face  to  comply  and  verify  this  criterion  in  case  the  threshold  is 
considered as a unique percentage in mass. Vegetable fats, such as palm oil, is a typical ingredient of prepared or 
pre-packed  food  products  such  as  biscuits  or  chocolate  bars  that  the  tenders  buy  and  provide  to  the  clients 
without  further  processing.  Estimating  the  amount  of  vegetable  fat  used  in  the  pre-packed  products  is  rather 
difficult since most of the times the exact information about the vegetable fat content and type in the pre-packed 
food products is missing. Therefore, two separated thresholds have been proposed, on percentage of commodity 
in mass and on percentage of units of pre-packed food containing vegetable fat. 

Currently, there is no regulation at EU-28 level on the environmentally responsible of vegetable fat but there are 
several  international  and  national  certification  schemes  that  ensure  that  vegetable  fat  is  grown  and  dealt  in 
accordance  with  several  sustainability  principles,  which  include  environmental,  social  and  economic  criteria. 
Examples of certification schemes are not provided in the criteria for all vegetable oils but only some examples 
are mentioned for palm and soy oils.   

41 

 
 
 
  Agricultural products labelled with geographical indications 

Explanatory notes 
Agricultural products labelled with geographical indications  
Citizens  and  consumers  increasingly  demand  quality  as  well  as  traditional  products  with  identifiable  specific 
characteristics, in particular those linked to their geographical origin. An agricultural product or foodstuff bearing 
such  a  geographical  indication  should  meet  certain  conditions,  such  as  specific  requirements  aimed  at,  among 
others, protecting the natural resources or landscape of the production area or improving the animal welfare of 
farm animals. Such requirements are set out in the product specification of each geographical indications product. 
The  contracting  authorities  may  decide  to  include  agricultural  products  and  other  foodstuffs  labelled  with 
geographical  indication  criterion  in  their  tenders  on  an  individual  basis  by  indicating  the  list  of  such  products 
bearing a geographical indication label that can be delivered/offered. 

Rationale for the proposed explanatory notes 
An  agricultural  product  or  foodstuff  bearing  a  geographical  indication  should  meet  certain  conditions,  such  as 
specific  requirements  aimed  at,  among  others,  protecting  the  natural  resources  or  landscape  of  the  production 
area or improving the animal welfare of farm animals7. Such requirements are set out in the product specification 
of  each  geographical  indications  product.  This  explanatory  note  is  included  to  allow  the  contracting  authorities 
include agricultural products and other foodstuffs labelled with geographical indication criterion in their tenders on 
an  individual  basis  by  indicating  the  list  of  such  products  bearing  a  geographical  indication  label  that  can  be 
delivered/offered. 

7  Regulation (EU) No 1151/2012 of the European Parliament and of the Council of 21 November 2012 on 
quality schemes for agricultural products and foodstuffs (OJ L 343, 14.12.2012, p. 1–29) 

42 

 
 
 
 
 
 
 
                                                           
2.3 

Contract performance clauses (CPC)  

Procurement management practices 

Core criteria 
Contract Performance Clause 
CPC1. Procurement management practices 
Over the duration of the contract, the service provider must collect and record,. 

Comprehensive criteria 

- 

the invoices and other documents that prove compliance with the criteria in accordance with the 
requirements for verifying the relevant technical specifications and award criteria TSx-y and the ACx-y. 

 These invoices must be made available to the contracting authority for verification purposes. 
The contracting authority may set rules for penalties for non-compliance. 
These invoices must be made available to the contracting authority for verification purposes.  
The contracting authority may set rules for penalties for non-compliance. 

Rationale for the proposed criteria wording 

The aim of this Contract Performance Clause is to  ensure the correct implementation of technical specification 
and award criteria that are part of the Food procurement criteria set. Especially for the procurement of organic, 
marine and aquaculture food and animal welfare products, the tender may not be able to provide in advance data 
of the precise products to be supplied in the execution of the contract. The contractor must commit to carry out 
the purchases according to the requirements for verification of those criteria over the contract duration.  

43 

 
 
 
 
 
 
3  Draft EU GPP Criteria proposal for Catering Services 

Table 4 indicates the criteria included in the Catering service criteria set 

Table 4. Criteria set for Catering services Selection Criteria (SC), Technical Specification (TS), Award 
Criteria (AC) and Contract Performance Clauses (C). Thresholds in TS are included as minimum values 
(i.e.  at least x%)  and  thresholds  in AC  are  included  as  the  starting  point  to  get points awarded  (i.e. 
points awarded from x%). 
Criteria 

Competences of the 
tenderer 
Food procurement 
Plant-based menus  

Food and beverage 
waste prevention  
Other waste: 
prevention, sorting 
and disposal 
Chemical products 
and consumable 
goods 

Energy and water 
consumption in 
kitchens 

Type of 
criteria 
SC 1 

Level of ambition 
Core 
See section 3.2.1 

See section 3.2.1 
See section 3.2.2 

See section 3.2.3 

See section 3.2.4 

Non-disposable items, except from 
some items and events 

0-50% of the purchases of chemical 
products awarding an Ecolabel 
Automating dispensers or dosage 
pumps.  
Actions to reduce the consumption of 
chemical products.  
0-50% of the purchases of kitchen 
paper and kitchen rolls awarding an 
Ecolabel 
Paper dispensersPaper dispensers 
See section 3.2.6 

0-50% of the plug-in cabinets and 
storage cabinets,  
0-50% of chest freezers and wine 
storage appliances with one or multi-
zones 
0-50% of the equipment using 
refrigerants with a GWP below 150 

TS 1  
TS 2 
AC 1 
TS 3. 1 

TS 4.1 
TS 4.2 

TS 5.1 

TS 5.2 

TS 5.3 

AC 1.1 

AC 1.2 

TS 6.1 

AC 2.1a 

AC 2.1b 

AC 2.1c 

AC 2.2 

AC 2.3 

Comprehensive 

No disposable items,  except from 
some items and events 
100% of the purchases of hand 
washing, dishwashing and cleaning 
products awarding an Ecolabel 
100% of the purchases of kitchen 
rolls and kitchen paper awarding an 
Ecolabel 
Automatic dosing systems 
Paper dispensers 

51-100% of the plug-in cabinets and 
storage cabinets 
51-100% of the chest freezers and 
wine storage appliances with one or 
multi-zones 
51-100% of the equipment using 
refrigerants with a GWP below 150 
51-100% of the cooking appliances 

51-100% of the professional 
dishwashers 

 Food transportation 

TS 7.1  

Implementation a reduction plan to minimise GHG and air pollutant emissions  

44 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Food transportation 

 Environmental 
management 
measures and 
practices 

Provision of low 
impact drinking 
water 
Purchase of new 
kitchen equipment 
Staff training 

Food and beverage 
redistribution 

TS 7.2 
AC 3.1 
AC 3.2 

AC 3.3 

AC 3.4 

TS 8 

CPC 3 

CPC 1 

CPC 2 

CPC 4 

CPC 5 

Fleet meet the requirements for Euro V/5 
Fleet meet the requirements for Euro VI/6 

-  LCV  performing  <=  50  g  CO2/km 
(type approval value) 
-  Hybrid,  plug-in  hybrid  or  electric 
HDVs 
- Electric L-category vehicles. 
fleet totally composed by HDVs using 
refrigerants  with  a  GWP  lower  than 
150 
Service  fleet  including  cycles  and 
cycle trailers 

Monitoring and recording of indicators 
Implementation operational procedures to minimise the environmental 
indicators 
Evaluation the deployment and the implementation of the operational 
procedures  
In case of deviations implementation the necessary actions to correct those 
deviations. 
Documenting and reporting, the results of monitoring of indicators and the 
results of the evaluation, correction and prevention actions, where applicable, 

Information and supply of tap water for drinking and reusable glasses for 
drinking at the premises of the catering service  

Commitment to purchase equipment complying with the requirements set by 
the core AC3. 
Annual on-site staff training on the method statements listed in the SC1 to:  
- new staff 
- permanent and temporary staff with contract duration above one year 

Safe redistribution of the surplus of 
the food is ensured. 

45 

 
 
 
 
 
 
 
 
 
Selection criteria (SC) 

  Competences of the tenderer 

Comprehensive criteria 

Core criteria 
Selection Criteria 
SC1. Competences of the tenderer 
The tenderer must have relevant competences and experience in each of the following areas for which s/he would 
be responsible under the contract [select as relevant to the specific contract]:  
- method statements for:  

 

 
 
 

the planning of menus, observing the increasing consumption of plant-based food when appropriate the 
prevention of food waste 
the safe redistribution of surplus food if/where applicable 
the prevention of other waste, how to be sorted out and disposed 
the measurement of the environmental indicators proposed in TS8 of catering services, including at least 
the amount of plant-based food, food waste generated in several points of the chain value, other waste 
generation by waste stream, energy consumption, water consumption and fuel consumption if applicable 
  water and energy savings in equipment and operation and maintenance of the equipment (for the staff 

responsible for this) 
the appropriate dosage and handling of cleaning products and cleaning procedures 

 
  waste management, including hazardous waste, monitoring and traceability documentation 
 

environmentally-conscious driving on a regular basis to increase fuel efficiency for the staff involved in 
food delivery 
staff training on environmental aspects that are to be annually renewed/reviewed policies, and 
supporting management systems to minimise food waste and other waste, maximise the redistribution 
of surplus food as/where appropriate and where safe to do so, maximise the reuse or recycling of 
packaging and/or other waste and ensure their safe disposal. 

 

Verification: 
Evidence in the form of information and references (such as documented feedback from customers) related to the 
relevant  contracts  in  the  previous  5  years  in  which  the  above  elements  have  been  carried  out.  This  must  be 
supported by records of training activities. 

Rationale for the proposed criteria wording 

The competences of the tenderer has been demonstrated to be the most efficient way of reducing environmental 
impacts  in  kitchens  as  long  as  it  includes  aspects  related  to  the  training  staff  and  the  implementation  of 
environmental  policies.  The  best  environmental  management  practices  (BEMP  2012)  for  Tourism  sector  also 
includes staff training in its criteria, as a mean to implement energy saving routines and standards.  

Regarding  the  requirements  related  to  the  staff  training,  a  revision  of  the  uptake  of  EU  GPP  criteria  across 
Member States shows that 20% of the schemes include staff training for environmental purposes as a criterion. 
The  general  consensus  from  stakeholders  indicated  that  a  more  detailed  wording  was  needed  but  that,  at  the 
same time, it should not be too prescriptive leaving room for businesses to customise staff training.  

The currently valid EU GPP scheme includes staff training as a contract performance clause (that remains in this 
proposal for those members of the staff that are new or still inadequately skilled to correctly performed their job), 
but includes other environmental aspects than just waste issues. In this revision, the staff training criterion has 
been  developed  to  complement  the  other  proposed  criteria  and  it  is  proposed to  be  also  part  for  the  selection 
criterion focused on the competences of the tenderer. Including competence of the tenderer as a selection criterion 
will  allow  procurers  to  be  sure  that  tenderers  are  experienced  in  this  field  and  that  provide  a  staff  with 
appropriate skills to deliver more environmentally conscious catering services. 

46 

 
 
 
Due  to  the  high  turnover  of  staff  in  the  foodservice  sector,  staff  training  has  to  be  an  on-going  activity.  The 
training of employees is country-, sector- and company-specific and hence the criterion scope aims to cover these 
specificities  by  being  flexible  in  nature  but  clear  for  the  purpose  of  verification.  The  criterion  proposed  in  this 
revision  is  designed  to  cover  the  different  activities  of  catering  services.  Additionally  the  contract  performance 
clause criterion that deals with staff training will ensure that those new members of the staff also become skilled 
in a short period of time.  

The staff training is a cost-effective measure. The training cost is not significant in comparison to the savings that 
can be achieved. Economic benefits due to the reduced avoidable food waste, reduced energy consumption and 
water usage among other issues outweigh the training costs in most of the catering services.  

Other competences required to the tenderer are the ability to prepare vegetarian dishes and the implementation 
of environmental policies and supporting management systems. The ability to prepare vegetarian dishes is of key 
importance in this criteria set because a promotion of vegetarian dishes is required. Certainly, under this criteria 
set the consumption of vegetables will be higher than in other circumstances being needed that the staff is skilled 
enough to prepare attractive vegetarian menus.  

Finally the implementation of policies and supporting management systems is important to prevent production of 
surplus food and minimise the food waste generation and generation of other waste and maximise redistribution 
of any surplus food where possible and safe to do so. The waste generated can be considered as an indicator of 
underperformance of the catering services. 

Rationale for the proposed verification 

There is no standardized verification system to prove the competences of the tenderers. Therefore the proposed 
verification relies on information and references of previous contracts where the requirements where carried out. 
This evidence must be complemented by the training records. In the records the tenderer will provide the duration 
of the training, the status of the staff (permanent or temporal) and will indicate the duration of the contract as 
well as the content of the training given. 

47 

 
 
 
 
3.2 

Technical Specifications (TS) and Award Criteria (AC) 

Food procurement 

Core criteria 

Comprehensive criteria 

Technical Specification 
TS1. Food procurement 
The food used to fulfil the catering contract has to be purchased according to the EU  GPP Food Procurement 
criteria. 
Verification: 
See above EU Food procurement criteria:  

-  Organic food products (TS1, AC1) 
-  Marine and aquaculture food products (TS2 and AC2) 
-  Animal welfare (TS3, AC3) 
-  Fair and ethical trade products  (AC4)   
-  Environmentally responsible fats (TS4) 

From  the  life  cycle  perspective,  the  primary  production  of  food  stands  for  the  major  environmental  impact 
(Baldwin et  al., 2011;  Calderón  et  al., 2010).  Also  from the  economic point  of  view  the  food  purchase  and  the 
labour costs account, in general, for the highest costs of the catering service.  

For  these  reasons,  all  the  TS  and  AC  proposed  for  the  EU  GPP  Food  procurement  must  be  considered  as  an 
essential part of the EU GPP Catering service procurement.  

The criteria set includes: 

-  Organic food products (TS1, AC1) 
-  Marine and aquaculture food products (TS2 and AC2) 

Animal welfare (TS3, AC3) 

-  Fair and ethical trade products (AC4)  
-  Environmentally responsible fats (TS4) 

48 

 
 
 
 
 
 
 
Plant-based menus (BEFORE: Menu planning or promotion of vegetarian menus) 

Core criteria 

Technical Specification 
TS2. Plant-based menus 

Comprehensive criteria 

Menus offered must include choices with the goal of increasing the consumption of pulses, vegetables, fruits, 
wholegrains and nuts whilst having the same recommended nutrient intake  for the clients, including [to  be 
selected].  

-  X1) vegetarian or plant-based day(s)/per week 
-  X1) vegetarian or plant-based dishes to be offered daily or Z1) days per week. 
- 
-  Y1)  grams  of  plant-based sourced  proteins  or  pulses  per  [week  or  day].A  bulking  up  (V1)  %)  of 

"dish of the day" to be a vegetarian or plant-based dish 

meat dishes with beans, grains or vegetables. 

Verification: 
The tenderer must provide the menu planning with the alternatives that promote the consumption of pulse, 
vegetables and fruits clearly specified, in accordance with the established requirements.  
Explanatory notes 

Technical specification and Award criterion 
The contracting authority must observe the recommendations on nutritional intake for the type of clients they 
are contracting the catering service and set the thresholds accordingly.   

If  there  are  no  thresholds  set  (examples  of  absolute  values  are  not  provided  as  they  depend  on  the  total 
intake to be recommended for the type of client): 
Recommended values for core criteria:  

there should be 1 vegetarian or plant-based day/per week. 

- 
-  half of the dishes offered daily vegetarian or plant-based *.meat  dishes  should  be  bulked  up 

(40 %) of with beans, grains or vegetables. 

Recommended values for comprehensive criteria:  

there should be 2 vegetarian or plant-based day/per week. 

- 
-  more than half of the dishes offered daily should be vegetarian or plant-based dishes . 
- 

the "dish of the day" to be a vegetarian or plant-based dish.meat  dishes  should  be  bulked  up 
(60 %) of with beans, grains or vegetables. 

1) X, Y, V, W, Z are the thresholds to be defined by the procurer for the comprehensive and core levels (TS and AC). Recommendations for its value are  
given in explanatory notes above. 
* Exact number or percentage of vegetarian or plant-based dishes offered daily to be decided by the contracting authority. 

Rationale for the proposed criteria wording 

Meat is responsible for the largest emissions of GHG of all food products. Meat accounts for almost one fifth of 
the world's total GHG emissions. Moreover, meat is the largest contributor to the total environmental impact of all 
food categories and of all impact categories (mainly eutrophication, acidification, global warming and ecotoxicity). 
Red meat in particular was found to have the largest impact on the environment in the current production systems 
due to methane emissions that largely contribute to GWP (15-40 kg of CO2eq/ kg), followed by pork and chicken 
having lower environmental impact (respectively, approximately 5 and 2 kg of CO2eq/ kg). 

Hence, reducing meat content or shifting animal protein sources away of the menu is the most effective measure 
to minimise environmental impact. A shift from meat products towards more vegetables will likely have a positive 
impact in the budget as well as in the consumer's health. Although, this is perhaps one of the potentially more 
difficult  dietary  behaviours  to  change,  this  trend  is  getting  momentum  as  demonstrates  the  one  third  of  the 
recently  launched  public  purchases  schemes  surveyed  where  a  reduced  meat  consumption  criterion  is  used. 

49 

 
 
 
 
 
  
 
Additionally,  recently  a  law  approved  in  the  Portuguese  Parliament  on  3rd  march  2017  ensures  that  all  public 
canteens in that country offer at least one vegetarian meal8. The "strict vegetarian options" refers to vegan food 
which is free from all animal products. The law applied to "canteens at all schools, universities, hospitals, prisons 
and other public buildings" but it also includes a clause that reportedly gives canteens the option to discontinue the 
vegan meals "if there is not enough demand for them".  

Initially, the meat products considered in this revision under the meat category were:  

- 

fresh, chilled or frozen meat from animal origin (bovine and cattle, ovine, porcine, horse, poultry, exotic 
animals etc.), 

-  dried, salted or smoked meat (sausages, salami, bacon, ham, pâté, etc.); 
-  other  preserved  or  processed  meat  and  meat-based  preparations  (canned  meat,  meat  extracts,  meat 

juices, meat pies, etc.).  

The category excludes: land and sea snails, lard and other edible animal fats, soups, broths and stocks containing 
meat. 

Stakeholders  also  pointed  out  that  dairy  products  have  substantial  environmental  impacts  and  that  the  words 
"vegetarian menus" allow for their consumption. The current proposal aims at promoting an increase of vegetables, 
fruits  and  pulses  and  proposes  new  ideas  for  that  in  accordance  with  some  stakeholder's  recommendations. 
Examples are: vegetarian day(s) a week, the increase of vegetarian sourced or plant-based proteins, limiting the 
serving  of  meat  per  week  or  bulk  up  the  meat  dishes  with  vegetables  (i.e.  substituting  part  of  the  meat 
composition in the dish with vegetables). Advanced procurers can limit this criterion to only plant based menus, 
whereas vegetarian dishes are supposed to be easily implemented. 

The criterion was proposed as a technical specification criterion to ensure either a complete avoidance or a much 
substitution of meat in the TR2.0. In TR3.0 the criterion is kept as TS.  

Further information can be found in Annex 4. 

Rationale for the proposed verification 

This  criterion  has  no  standard  or  procedure  available  to  measure  the  promotion  or  higher  consumption  of 
vegetables, fruits and pulses and/or the reduction of meat, meat products and dairy products.  

However,  it  is  proposed  to  monitor  the  number  of  meals  prepared  and  the  overall  amount,  in  mass,  of  each 
ingredient  used  in  the  preparation  of  meals  over  a  defined  representative  period  of  time,  as  part  of  the 
environmental  management  measures  and  practices.  In  addition,  an  indicator  of  (g  of  vegetables,  fruits  and 
pulses/meal)  or  (g  of  meat  and  meat  products/meal)  is  proposed.  The  monitoring  and  recording  of  these  
indicators  will  provide  data  useful  for  the  assessment  of  the  overall  environmental  impact  and  show  the 
continuous improvement of the tenderer on the promotion of vegetables.  

Additionally,  for  the  verification  of  this  criterion,  the  tenderer  must  provide  the  menu  planning  with  the 
alternatives that promote the consumption of vegetables clearly specified. 

8 Assembleia da República, Lei n.º 11/2017de 17 de abril, Estabelece a obrigatoriedade de existência de opção vegetariana nas ementas 
das cantinas e refeitórios públicos, Diário da República, 1.ª série — N.º 75 — 17 de abril de 2017 

50 

 
 
 
                                                           
Food and beverage waste prevention  

Comprehensive criteria 

Core criteria 
 Technical Specification 
TS3. Food and beverage waste prevention  
Note: It may be that the tenderers will not be the ones deciding or offering some of the best practices in criterion 
TS3.1,  because  the  contracting  authorities  could  be  the  ones  requesting  them.  For  example,  the  contracting 
authorities can allow fewer menu options to be available at the beginning and end of the services, preventing the 
tenderers from adopting this measure. 
The  tenderer  must  have  written  procedures  describing  best  practices  for  preventing  the  generation  of  food 
waste, including [to be selected]: 

- establishing an accurate stock inventory and ordering system to avoid over-ordering and spoilage of 
stock. 
- developing a food waste inventory: this means surveying all processes to identify types and sources 
of on-site waste generation including liquid food waste (e.g. beverages) 
- conducting measurement of food waste amounts on continuous or period basis 
-  operating  a  back-to-front  (first-in  first-out)  policy  in  the  storage  of  food  products  and  checking 
periodically the date of expiry. 
- directly using food near its date of expiry (flexible meal planning). 
- Ensure that the food is stored under the proper conditions. 
- avoiding over-trimming of bulk meat, fish or whole vegetables or reusing the over-trimmings 
- performing long-term analysis of meals sold in order to adapt food orders (to weekday, season, and 
external factors such as holidays or major events) and analysis on the use of leftover food or food 
that is approaching its use-by date 
- developing strategies against overproduction (e.g. freezing) 
- preventing  preparation losses and training employees 
- cooling down food quickly to avoid growth of microorganism 
- not preparing meals for presentation purposes only (use photographs instead) 
- adjusting the meal portions and accommodating the quantities to the customers or providing more 
than one-size portions 
-  selecting  packaging  (taking  into  account  aspects  such  as  the  format,  protection,  preservation, 
serving portions, etc.) that minimises the generation of food waste 
- using doggy bags and/or internal routines for staff to eat food not sold as well as to prepare the 
safe redistribution of surplus food if/where applicable 
- not requiring the full range of menu options to be available from the start to the end of the service 
- sensitising customers to food waste and the causes of food waste (e.g. using posters) 
- increasing customer acceptance of sustainability measures through communication 
- implementing a system that allows customers to give feedback on food portions and the quality of 
prepared  meals  (e.g.  survey  the  reasons  for  plate  waste  using  feedback  sheets)  and  subsequently 
implementing appropriate actions. 

The tenderer must communicate to the guests the key parts of the food waste prevention policy. 

Verification: 
The  tenderer  must  provide  evidence  in  the  form  of  standard  operating  procedures  for  purchasing,  storage, 
cooking,  menu  planning  and  serving.  The  evidence  must  be  completed  by  a  description  of  channels  through 
which the food waste prevention policy will be communicated to the guests 

Rationale for the proposed criteria wording 

Reducing food waste will help to reduce the associated costs and environmental impacts of the whole catering 
services. The food, food products or parts thereof that are thrown away are waste of valuable resources. Food has 

51 

 
 
 
 
 
 
a  high  carbon  footprint  due  to  the  energy  used  for  growing  the  food,  harvest,  transportation,  processing, 
packaging, retailing and preparing it. Moreover, food which is wasted in the later stages of the value added chain 
has a greater negative effect than food which is wasted in the agricultural stage, because additional resources 
(e.g. staff, transportation and packaging) have been employed to prepare the food stuff for consumption (Betz et 
al, 2015). This is one main reason why the reduction of food waste at the end of the value added chain is of 
major importance.  

Several studies reported that around 18% of the food purchased will become food waste of which 10% is lost 
during the manufacturing, 4% in storage and preparation and 4% in serving process. The Annex 4.4 provides also 
a summary of root causes of food waste in the food service sector.  

The  importance  of  this  criterion  to  be  considered  as  a  technical  specification  is  supported  by  the  European 
parliament's environment committee that in April 2017 backed a resolution calling on EU governments to halve 
food waste by 2030, with an interim target of a 30% reduction by 2025. The resolution further asks the European 
Commission  to  decide by  2020  whether to  set  legally-binding  food  waste  reduction  targets,  and  to  legislate  if 
necessary. Some 88 million tonnes of food are discarded annually across Europe, with associated costs estimated 
at 143 billion euros, from which 12% comes from catering services (Fusions, 2016). Additionally, it was required 
to devise a "common methodology, including minimum quality requirements, for the uniform measurement of the 
food waste levels" and to agree a concrete legal definition of what constitutes food waste. Finally, they endorsed a 
call for the commission to look into ways to recover and use food that is past its sell-by date but otherwise fit for 
consumption. Prior to this resolution, the UN sustainable development goals adopted in 2015 call for a halving of 
global  food  waste  at  the  retail  and  consumer  levels  by  2030,  and  for  the  reduction  of  food  losses  along 
production and supply chains.  

This  commitment  triggers  the  introduction  of  this  criterion  in  some  of  the  recently  launched  GPP  schemes. 
Therefore, a specific criterion on food waste is thus proposed in this revision to increase the visibility of this issue, 
instead of being a part of the criterion on menu planning. 

Stakeholders welcome this idea and they even requested to prioritize the criterion on food waste prevention over 
the criterion on food redistribution. Several reasons were put forward as for example that food waste prevention 
is beneficial for the catering service in terms of saving costs (cost of production and cost of waste management), 
increasing satisfaction of the customers or reducing the overall environmental impacts of the business  

Several routines have been considered as relevant for preventing the food waste generation along the life cycle of 
the catering services. The type of recovered food products are normally: 

-  canteens,  restaurants,  hotels,  hospitals  and  barracks  donate  surplus  meals  (entrée,  first  course,  main  course, 
vegetables, sauces, desserts) 

- schools donate bread, fruit and desserts with a long-term expiry date 

- bakeries, rotisseries and fruit and vegetables markets donate chiller surplus food 

The suggested routines cover all the food recovered from steps such as purchases, storage, preparation, cooking, 
and menu planning and serving. More in detail some suggested measures are: avoid  inflexible portion sizes,  an 
assortment  that  match  requests,  the  control  of  the  expiration  date  for  food  products  and/or  potential  use  of 
leftovers.  Once  the  food  waste  is  generated,  the  waste  sorting  and  disposal  criterion  will  try  to  minimize  its 
environmental impact.  

Improvements of the tender performance would require separating food waste from other waste streams as well 
as measuring and recording the food waste generated. This would be part of the selection criterion which requires 
the implementation of Environmental management measures and practices criterion.  

Further information can be found in Annex 3.2.  

Rationale for the proposed verification 

This criterion has no standard or procedure available to measure the reduction of food waste. However, this issue 
has been studied by WRAP (2016). This institution developed a protocol for evaluating business food waste.  

According  to  WRAP  (2016)  the  definition  of "food waste"  is  not  commonly  understood  and  not  uniquely  agreed 
even amongst experts, and can mean a whole range of things to business. Confusions arise if material intended to 

52 

 
be  eaten  used  for  other  purposes  (such  as  animal  feed,  pet  food,  composting),  and  whether  inedible  parts 
associated with food also count towards food waste. In this sense, the business should define its own definition 
for 'food waste' and keep it along the years of the contract. For example, a definition could be (Fusions, 2016):  

"Food waste is any food, and inedible parts of food, removed from the food supply chain to be recovered 
and  disposed  (including  composed,  crops  ploughed  in/not  harvested,  anaerobic  digestion,  bio-energy 
production, co-generation, incineration, disposal to sewer, landfill or discarded to sea"  

In addition to reducing food waste, the additional goals are to prevent generation of surplus food and, where this 
occurs, to redistribute it for human consumption where possible and safe to do so. Unsold food which is not suited 
for human consumption (e.g. broken biscuits) may in some instances be utilized for animal feed, in line with the 
EU rules on feed safety and animal health. Overall the aim is to ensure the higher value use of food resources 
produced, in line with the waste prevention hierarchy.   

Food  waste  here  is  defined  as  edible  and  inedible  material  associated  with  food  exiting the  food  supply  chain 
(Fusions, 2016). As a minimum, the combined amount of wasted edible food and associated inedible parts should 
be  measured.  It  is  recommended  that  furthermore,  edible  and  inedible  parts  are  measured  separately,  or 
estimated within the total  arising.  If  sampling  procedures  are  employed,  it  is  important  to  note  what  they  are. 
Random sampling is recommended. To determine how much sampling is required pre- and post-intervention to the 
able to estimate (with a given degree of confidence) the change in food waste (and the best to underestimate this 
change for the purposes of these calculations). This may require the input of someone with statistical expertise.  

An important issue is not to include material surrounding food waste (e.g. packaging, waste that is used to dilute 
food waste, etc.) in the food waste figures.   

To measure the food waste there are different food waste quantification methods, some of them are listed below 

-  direct  weighting  involves  a  measuring  device  to  determine  the  weight  of  food  waste.  It  is  the  most 
commonly used method to measure food waste, sometimes in combination with other techniques such 
as waste composition analysis 
scanning/counting  assessing  the  number  of  items  that  make  up  food  waste  and  using  the  result  to 
determine  the  weight.  useful  when  whole  items  are  discarded.  Usually  a  conversation  form  fanatical 
value (euro) is required.  

- 

-  volumetric assessment is assessing the volume that food waste takes up, and combining that information 
with density factors to determine the weight. Usually used for liquid material, but can also be used for 
solid  and  semi-solid  material.  It  may  be  more  practical  than  using  weighting,  but  can  introduce 
inaccuracies through the use of incorrect density factors.  

-  waste composition analysis is a physical separation of food waste in order to determine the weight. It is 
commonly used to separate food waste from a waste stream that includes other material which is not 
food waste (e.g. packaging). It may also be used to understand the different components that make up 
food  waste  (e.g.  inedible  vs  edible  food  waste,  food  types).  It  provides  an  opportunity  to  collect  very 
detailed  and  useful  information  about  food  waste,  but  is  generally  expensive  and  organisationally 
difficult. A composition analysis might be done on a sample of waste, and then applied to the total waste 
stream determined by other methods. Consent might be needed if the producer of food waste and the 
entity measuring the waste are not one and the same. This can also influence results, for example high 
wasters may be less inclined to give consent.  

-  mass  balance an  organization measures inputs (e.g. ingredients) and outputs (e.g. products made) and 
uses  a  mass-balance  method  to  infer  food  waste.  Account  is  taken  of  changes  in  stocks  and  due  to 
processing (e.g. evaporation of water during cooking). In theory this can be a cheap and reliable way of 
determining waste, but in practice, it is often obscured by the inventory-maker, for example, stolen items 
or evaporation 

-  use of proxy data that can be employed when direct measurement of food waste or specific attribute of 
interests are not possible but we have information about those from a similar entity or another waste 
stream 
surveys  is  another  method  to  gather  information  form  a  large  amount  of  individuals  or  entities  on 
attitudes, beliefs and self-reported behaviours thorough a set of structured questions. Also used when 
the entity gathering data is not in control of the waste stream. Relying on recall is prone to error and as 

- 

53 

 
such,  the  uncertainty  associated  with  this  data  should  be  clearly  explained.  Generally  surveys  are  not 
reliable enough to produce quantification of waste, but can be used to gather insights about the attitudes, 
values and behaviours associated with specific amounts and types of food waste.  

In addition, it may be useful to report food waste data compared to a relevant denominator for example per meal 
served  in  a  restaurant  or  per  portion.  The  best  normalization  factors  (denominators)  are  meaningful  for  the 
intended audience, strongly correlated with the level of food waste, and have themselves good data reliability.  

Finally, while impossible to completely remove uncertainty within the waste measurement, it is important that the 
uncertainty is identified, minimised as much as possible and appropriately communicated.  

Considering all the points above, it is proposed that each tender proposed the most suitable indicator and method 
for his/her business as part of the environmental management measures and practices: examples could be the 
amount  of  food  waste/meal  served  and  the  method  weighting.  The  monitoring  and  recording  of  this  indicator 
keeping the first year as baseline, will show the continuous improvement of the tenderer on this aspect. 

Additionally, for the verification of this criterion, the tenderer must provide the routines to be in place for each life 
cycle stage of the catering service. 

54 

 
 
 
 
  Other waste: prevention, sorting and disposal (BEFORE: Waste sorting and disposal) 

Core criteria 
Technical Specification 
TS 4. Other waste: prevention, sorting and disposal 
TS 4.1. Waste prevention 

Comprehensive criteria 

The  tenderer  must  implement  a  plan  for  reducing  the  generation  of  waste  in  accordance  with  the  waste 
hierarchy of Waste Framework Directive 2008/98/EC. The plan must at least include: 

-  developing  a  waste  inventory:  this  means  surveying  all  areas  and  processes  to  identify  types  and 

- 

sources of on-site waste generation including beverages. 
reducing  waste  in  the  procurement  of  food,  beverages,  disposable  and  consumable  goods  [to  be 
selected}. This means: 

 
 
 
 
 

efficient ordering and storage: order perishable products frequently in the quantities required 
storing perishable products in appropriate conditions (e.g. correctly adjusted refrigeration units) 
ordering non-perishable products in bulk, when possible and environmentally relevant 
selecting the appropriate packaging (format, protection, preservation, serving portions, etc.) 
selecting  recyclable  packaging  where  possible  provided  the  packaging  guarantees  for  food 
safety and hygiene. Recyclable packaging includes compostable packaging 
returning packaging for reuse when possible. 
reducing of waste in the catering [to be selected}:. This means:  

 

- 

  avoiding items with unnecessary or excessive secondary packaging according to the needs of 

the catering service 
putting  condiments  and  food  servings  in  refillable  containers,  where  food  waste  prevention, 
food hygiene, consumer safety and public health considerations allow their use. 
identify reuse possibilities 
return packaging for reuse when possible and environmentally relevant 

 

 
 

TS 4.2. Waste sorting and disposal  

Note: this criterion only applies where sorted waste is separately collected 

The tender must implement a plan for sorting and disposing of waste limited to locally available treatments 
of waste streams.  

If the waste is to be collected by an authorised collector, the tenderer must sort into the fractions stipulated 
by  the  collector  (e.g.  municipality).  When  the  collection  by  an  authorised  collector  allows  for  bio-waste 
collection and/or the collection of fats, oils and greasers (FOGs), the tenderer must sort bio-waste and wasted 
FOGs produced in the kitchen and other facilities used by the staff separately and dispose of them into the 
authorised collection and recycling system.  

If  a  collection  system  for  FOGS  is  not  in  place,  the  tenderer  must  put  FOGs  into  a  suitable  container  and 
dispose of them in the residual wasted. FOGs must not be discharged into the sewage system. 

If the waste will be treated on-site, the tenderer must provide the waste management procedures included in 
the  waste  management  plan of  the  waste  streams  in  accordance  with  the waste  hierarchy  of  Art  4  of  the 
Waste Framework Directive 2008/98/EC 

Dry clean-up methods must be used for the first clean of a greasy or oily area/equipment before washing the 
equipment.  

If guests sort waste themselves, clear sorting instructions must be provided 

55 

 
 
 
 
 
Verification  
TS 4.1. The tenderer must supply the waste prevention plan. The tender must supply a list of disposable and 
non-disposable items that will be used in the execution of the contract. The tender must provide information 
about  the  material  the  disposable  items  are  made  of,  indicating  specifically  if  those  are  recyclable  or 
compostable in accordance with EN13432 
TS 4.2. The tenderer must supply a description of the waste stream categories to be sorted and the disposal 
procedures to be followed during the execution of the contract. 
If the guests will sort waste themselves, a sample of the sorting instructions must be provided. 

Explanatory notes 
Core criteria 
Technical Specification 
TS 4.2. Waste sorting and disposal  
If the waste is to be collected by an authorised collector, the tenderer must sort into the fractions stipulated 
by the collector (e.g. municipality). At least 4 fractions must be used: paper/cardboard, glass, plastic, metal. 
Residual waste must also be sorted in addition to any environmentally dangerous waste. 

Comprehensive criteria 

If the collection by an authorised collector allows for more waste stream categories such as porcelain, liquid 
packaging board, metal, textiles, organic material*, grease/cooking oil and combustible waste, the contracting 
authority may require that these additional categories are sorted.   
When  a  collection  system  for  FOGs  is  in  place,  the  tenderer  must  separate  the  wasted  fats  and  oils  and 
dispose  of  them  in  the  authorised  collection  and  recycling  systems.  Waste  categories  should  be  identified 
according to the European waste codes. 

Dry clean-up methods include scraping as much of the leftovers on the dish into a food waste container, using 
rubber scrapers and squeegees and paper towels to remove fats, oils and grease from cookware utensils or 
work areas, using brooms or vacuum to sweep up spills of the dry ingredients.  

* Organic material includes those fractions described as bio-waste in the Waste Framework Directive 2008/98/EC, Article 3(4)". 

Rationale for the proposed criteria wording 

The most sustainable waste is the one not generated in first place. But once the  waste is generated, if properly 
managed, its environmental impacts can be reduced. Therefore this criterion aims at:  

reducing the amount of waste generated 

- 
-  encouraging tenderers to properly manage the waste generated.  

The preliminary report shows that the end-of-life of the waste can be more or less relevant depending on the way 
it is carried out. Landfilling of organic waste is responsible for large GHG emissions and the non-organic waste for 
other  environmental  impacts  (e.g.  leaching).  This  can  be  avoided,  or  partially  avoided,  by  more  adequate 
procedures for waste management.  

Waste prevention plan 

An aspect that is covered in the technical specification part is a waste reduction plan. This plan should include 
information and objectives  on actions to be taken to minimise waste at all stages of the catering service. This 
includes aspects such as the: specific tasks to be undertaken, allocation of responsibilities,  best practices to be 
implemented, etc. Finding the right balance between being practical and making it easy for the business (to ensure 
better quality data) and being ambitious (to collect the right kind of data an enough of it) is the most important 
challenge.  

The waste prevention plan should focus on those streams that have been identified as important and that have 
the potential to be reduced. In the catering services packaging alone can account for a large part of the waste 
stream. Selecting the most suitable packaging for each type of food and drink product and where it is going to be 
consumed  or  prepared  can  prevent  a  considerable  quantity  of  waste.  The  quantity  of  packaging  is  a  relevant 

56 

 
 
 
 
criterion for green procurement decisions. For example, it may be negotiated to return packaging to local suppliers 
for reuse, if they are not already offering this possibility. Procurement of concentrated products (e.g. chemicals) 
can  also  reduce  packaging  requirements  as  well  as,  when  appropriate,  buying  food  in  bulk  and  avoiding  over-
ordering of perishable products. Similarly, there is often scope to reduce waste by providing access to tap-water 
as  it  can  reduce  the  purchase  of  bottle  water  and  its  respective  packaging.  This  measure  was  included  in  the 
clause performance criteria (BEMP 2012).  

The total quantity of waste generated per client or meal served is the most appropriate indicator of the intensity 
of  waste  generation  and  the  effectiveness  of  management  measurements  to  reduce  it.  The  first  year 
measurement will present the baseline. Even if the discussion of the indicators is provided in more detail in the 
section 3.2.8 it is worth mentioning that to specifically reflect waste avoidance; sorted fractions sent for recycling 
should also be included in the total waste generation. The density of waste varies considerably depending on the 
type  and  the  degree  of  compaction.  Therefore,  the  weight  of  waste  generated  is  a  more  reliable  indicator  of 
performance in waste avoidance that the volume of waste generated. Therefore, it is proposed as best practice is 
to monitor and record all waste generation by weighting single waste fractions. In the absence of weighting, waste 
quantities may be expressed by volume, easily estimated from the number of waste receptacles (e.g. bins, skips) 
filled every day, week or month.  In those cases, the weight of waste may be estimated from (non-compacted) 
volumes according to estimated densities.  

Neither a specific level of ambition of this technical specification criterion not a rate of improvement have been 
introduced in this criterion.  

Waste sorting and disposal 

As  the  correct  sorting  and  disposal  of  solid  waste  represents  high  potential  improvement  for  environmental 
impact reduction at much reduced cost, it was proposed to be covered as a Technical Specification. This is also 
important  if  it  is  kept  in  mind  that  waste  disposal  costs  are  likely  to  increase  steadily  in  the  future  due  to 
diminishing landfill space and increasing collection and disposal costs. Poor waste management has implications 
for hygiene and health, environmental quality, resource and economic sustainability.  

Experience in the inclusion of this criterion can be found in the recently launched GPP schemes across Europe. A 
criterion dealing with waste management is applied in approximately halve of the revised schemes at both core 
and comprehensive level. 

It is important to notice that to some extent tenders are limited by the waste management infrastructure in their 
locality, often owned and operated by the local authority, especially if they are not able to find other takers for 
waste  fractions  that  the  local  system  does  not  accept  (BEMP  2012).  In  some  catering  services  available  floor 
space may constrain the storage of multiple bins for separated waste fractions. However, experience shows that 
there are many innovative means of sorting waste in the processes reducing disposal costs. Among them are:  

- 
identify waste recycling  and packaging return options available locally 
-  select products and packaging made from recycled and recyclable material 
- 
-  separate waste during room cleaning into fractions collected separately from catering premises 
-  separate waste arising in public areas, maintenance of outdoor and indoor facilities, and other back-of-

install separated waste collection bins in all the rooms/spaces 

- 

- 

house areas into appropriate fractions for recycling and correct disposal 
consider  packaging  volume,  production  impact  and  recyclability  when  assessing  products  for 
procurement 
install and train staff to use conveniently located bins for separate collection of glass, plastics and paper 
and cardboard in kitchen and dining areas 

The details of the wording of the criteria as well as the revised ambition levels are discussed here: 

-  Categories of waste to be collected separately: Several categories of waste are proposed to be collected 
separately. These include paper/cupboard, glass, plastic, cans and general waste and others if possible 
such as biowaste or used FOGs. The separation and appropriate disposal of other types of waste is also 
encouraged. In this regard, it should be ensured that catering services companies separate and dispose 
of  solid  waste  into  the  correct  streams  as  required  by  the  local  or  national  waste  facilities  or  an 
appropriate waste collector.  

57 

 
-  Fats, oils and greasers: Especial attention should be paid to the treatment of fatty, oily or greasy waste 
due to the large environmental impacts that it causes. Therefore, a new requirement has been included in 
this criterion that requires at least the collection into a suitable container and its disposal in the residual 
waste and the use of a dry cleaning of the fat, oil or greasy for the first cleaning. This measure  must 
prevent  that  a  large  amount  of  the  fatty,  oily  or  greasy  waste  generated  reaches  the  wastewater 
treatment plants or the rivers.  

-  Responsibility for sorting out the waste: It has been identified that waste is generated at different stages 
of the catering service, being the responsibility of different actors to sort it out. The criterion on staff 
training  ensures  that  these  persons  received  the  appropriate  information  to  sort  out  and  correctly 
dispose  the  waste  that  is  generated  during  their  work.  Once  the  food  is  served,  there  are  catering 
services  where the  guests  are  responsible for  disposing  the  waste.  If  so, in  this  type  of services  clear 
information should be given to the guests to help then to sort out and correctly dispose the generated 
waste.  

Rationale for the proposed verification 

This criterion has no standard or procedure available to measure the reduction of waste, its sorting and disposal.  

However, it is proposed to be monitored and recorded by means of an indicator such as the grams of waste/meal 
as part of the environmental management measures and practices. The monitoring and recording of this indicator 
will show the continuous improvement of the tenderer on this aspect. 

Additionally, for the verification of this criterion, the tenderer must provide the routines to be in place for each life 
cycle stage of the catering service included in the waste reduction plan, as well as the description of the  waste 
stream categories to be sorted and the disposal procedures. 

58 

 
 
 
  Chemical products and consumable goods (BEFORE: consumable goods) 

Core criteria 
Technical specifications  
TS 5. Chemical products and consumable goods 
TS 5.1 Disposable items 
Non-disposable items9 must be used on a general 
basis. See exceptions in Explanatory notes 

If disposable items are used, they must be recyclable, 
made  of  either  recyclable  plastic  or  compostable 
material.  Compostable  items  are  to  be  preferred  for 
those uses leading to contamination of items by food 
(e.g. cutlery and dishware) disposable items are used, 
they  must  be  recyclable,  made  of  either  recyclable 
plastic  or  compostable  material.  Compostable  items 
are  to  be  preferred  for  those  uses  leading  to 
contamination  of  items  by  food  (e.g.  cutlery  and 
dishware). 

Comprehensive criteria 

TS 5. Chemical products and consumable goods 
TS 5.1 Disposable items 
Non-disposable items1) must be used. Exceptions: 
- tableware for take-away and fast-food catering 
 - rubbish bags and cleaning gloves 
-  paper  tablecloths  which  can  be  wiped  and  used  for 
extended  periods  (disposable  tablecloths  used  for  only 
one sitting are not allowed) 
- tableware for big events catering  

All  disposable  items  used  must  be  recyclable,  made  of 
either  recyclable  plastic  or  compostable  material. 
Compostable  items  are  to  be  preferred  for  those  uses 
leading to  contamination  of  items by  food  (e.g.  cutlery 
and dishware) 

Verification: 
TS  5.1.  The  tender  must  supply  a  list  of  disposable 
and  non-disposable  items  that  will  be  used  in  the 
execution of the contract, indicating specifically those 
that are disposable items.  

TS 5.2. Chemical products for hand washing, 
dishwashing and routine cleaning3) 
All products to be used for hand washing, dishwashing 
the 
routine  cleaning  products  must  meet 
and 
requirements of an EU Ecolabel for the specific product 
or equivalent.  

TS 5.3. Kitchen roll and kitchen paper 
All  kitchen  rolls  and  kitchen  paper  must  meet  the 
requirements of an EU Ecolabel for the specific product 
or equivalent.  

Verification: 
TS 5.1. The tender must supply a list of disposable and 
non-disposable items that will be used in the execution 
of  the  contract,  indicating  specifically  if  those  that  are 
disposable items.  
The  tenderer  must  provide  information  about  the 
material  the  disposable  items  are  made  of,  indicating 
specifically if the items are recyclable or compostable in 
accordance with EN13432. 

TS  5.2.  The  tenderer  must  supply  a  list  of  chemical 
products for hand dishwashing, dishwashing and routine 
cleaning  that  will  be  used  in  the  execution  of  the 
contract,  indicating  specifically  which  products  comply 
with the criterion. 

9 Disposable items include tableware such as plates, mugs, glasses, cutlery, tablecloths, napkins, etc. 
and other items such as gloves, bin bags, etc. 

59 

 
                                                           
  
 
 
 
 
 
 
 
 
TS  5.3.  The  tenderer  must  supply  a  list  of  paper 
products  that  will  be  used  in  the  execution  of  the 
contract,  indicating  specifically  the  ones  which  comply 
with the criterion. 

Comprehensive criteria 

AC1.  Chemical products and consumable goods 
AC1.1. Chemical products for hand washing, 
dishwashing and  routine cleaning 
Additional points are to be awarded to tenders in which:  
-  cleaning  agents  and  hand  soaps  are  dispensed 
accurately by an automating dispenser or dosage pump 
-  other  actions  are  taken  to  reduce  significantly  the 
consumption  of  chemical  products,  such  as  steam 
cleaning.  

AC1.2. Kitchen roll, kitchen paper 
Additional points are to be awarded to tenders in which 
the kitchen is equipped with dispensers that dispense 
paper towels or fabric hand towel rolls. 

Verification: 
AC1.1. The tenderer must supply information about the 
dosing  systems  to  be  used  and  their  maintenance  (if 
needed) in the execution of the contract. 

AC1.2. The tenderer must supply information about the 
dispensers to be used in the execution of the contract. 

Core criteria 
Award criteria  
AC1. Chemical products and consumable goods 
AC1.1. Chemical products for hand washing, 
dishwashing and routine cleaning 
Points are to be awarded proportionally to tenders in 
which more than the required X%2)  of the purchases 
for hand washing, dishwashing and cleaning have met 
the  requirements    of  an  EU  Ecolabel  for  the  specific 
product or equivalent  
Additional  points  must  be  awarded  to  tenders  in 
which:  
-  cleaning  agents  and  hand  soaps  are  dispensed 
accurately  by  an  automating  dispenser  or  dosage 
pump 
-  other  actions  are  taken  to  reduce  significantly  the 
consumption  of  chemical  products,  such  as  steam 
cleaning.  

AC1.2. Kitchen roll, kitchen paper 
Points are to be awarded proportionally to tenders in 
which more than the required Y%2) of kitchen rolls and 
kitchen  paper  have  met  the  requirements    of  an  EU 
Ecolabel for the specific product or equivalent  
Additional  points  are  to  be  awarded  to  tenders  in 
which  the  kitchen  is  equipped  with  dispensers  that 
dispense paper towels or fabric hand towel rolls. 

Verification: 
AC1.1. See TS 5.2.  
The  tenderer  must  supply  information  about  the 
dosing systems to be used and their maintenance (if 
needed) in the execution of the contract. 

AC1.2. See TS 5.3  
The  tenderer  must  supply  information  about  the 
dispensers to be used in the execution of the contract. 

Comprehensive criteria 

Explanatory notes 
Core criteria 
Technical specifications and Award criteria 
The contracting authority will have to specify how the percentage will be judged, either in volume, weight or value 
spent.  
TS 5.1 Disposable items 
Contracting authorities may allow disposable item in the following cases: 
-  tableware  for  take-away  and  fast-food  catering  in  those  cases  where  reverse  logistics  (i.e.  collection)  is 
extremely hard or impossible due to. the nature of the event, 

60 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
  
- rubbish bags and cleaning gloves 
- paper tablecloths which can be wiped and used for extended periods (disposable tablecloths used for only one 
sitting are not allowed) 

TS 5.2 and AC1.1. Chemical products for hand washing, dishwashing and routine cleaning 
Exception  can  be  made  if  the  authorities  have  especial  requirements  for  cleaning.  Exemption  from  the 
requirement may be granted on the condition that there are no ecolabelled products available on the market. 
Certification schemes equivalent to the EU Ecolabel that are based on the same principles must be decided by the 
contracting authorities.   

Recommended values for core criteria (X%) 
50-100% in volume of the purchases of the hand washing, dishwashing or routine cleaning products are awarded 
by an EU Ecolabel for the specific product or equivalent 

TS 5.3 and AC1.2. Kitchen roll, kitchen paper  
Exemption  from  the  requirement  may  be  granted  on  the  condition  that  there  are  no  ecolabelled  products 
available on the market.  

Recommended values for core criteria (Y%) 
0-50% in volume of the purchases of the kitchen rolls and kitchen paper are awarded  by an EU Ecolabel for the 
specific product or equivalent 

1) Disposable items includes tableware items such as plates, mugs, glasses, cutlery, tablecloths, napkins, etc and other items such as gloves, bin bags, etc  
2) U and Y are the thresholds to be defined by the procurer for the core levels (AC). Recommendations for its value are given in explanatory notes below 
3) Routine refers to regular activities that are performed at least once a month. With regard to the present project, any cleaning activity, with the exception 
of window cleaning, that is performed less frequently than once a month is considered to be out of scope. 

Rationale for the proposed criteria wording 

This criterion aims at: 

- 
- 

reducing the use of chemical products and consumable goods and 
reducing the environmental impacts of both chemical products and consumable goods whenever used.  

Regarding the  first  purpose,  requirements  on  non-use  of  the  products  or  requirements  on  dosing systems,  that 
avoid  overdosing,  have  been  included.  This  requirement  is  also  linked  to  other  criteria  such  as  Other  waste: 
prevention,  sorting  and  disposal.  Regarding  the  second  purpose  of  the  criterion  (reducing  the  environmental 
impacts of the products whenever used) several alternatives have been included that are commented below.  

The  production,  use  and  end-of-life  of  the  chemical  products  for  washing  and  routine  cleaning  cause  several 
environmental impacts such as aquatoxicity, eutrophication or acidification of the water streams. The magnitude 
of the environmental impacts largely depends on the formulation of the chemical products as well as the dosing. 
More information can be found at (Boyano et al 2016) 

(Packer 2009) carried out an impact analysis of the consumable goods used in the catering service sector. One of 
the major findings was that overall environmental impact is context specific. Each product feature has different 
environmental impact weighting of importance to different users.  

The inclusion of these requirements are observed in other policy tools such as the Nordic Swan for several types 
of detergents and cleaners, for disposable goods, for restaurants or for coffee services and the EU Ecolabel for 
several types of detergents and for Tourist and accommodation services. The inclusion of these requirements in 
the recently launched GPP schemes is not very popular, only some of them include some requirements on these 
points.  

This  criterion  is  relevant  for  those  catering  services  that  procure  consumables  (sometimes  the  catering  service 
contract does not include cleaning or provision of consumables). Therefore it is proposed to be included partially 
as  a  technical  specification  and  partially  as  an  awarded  criterion.  The  non-use  of  disposable  items  has  been 

61 

 
 
 
 
 
 
 
considered  of  key  importance  and  left  as  a  technical  specification  criterion.  The  use  of  cleaning  products  and 
paper  products  is  widely  spread,  being  a  reason  for  setting  these  requirements  as  a  technical  specification  at 
comprehensive level as well as an award criterion and for the modification of the name of the criterion.   

Three main areas have been identified to be included in the criteria: 

-  Chemical products for hand washing, dishwashing and routine cleaning products. This section includes 
several types of the chemical products such as hand soaps, dishwasher detergents, flooring cleaners, 
window  cleaners,  kitchen  cleaner  or  sanitary  cleaners.  The  feedback  provided  by  the  stakeholders 
pointed out the need of including requirements to reduce the consumption of this kind of products as 
well as to increase the level of ambition of the thresholds. Stakeholders confirmed the large availability 
of ecolabelled products on most markets at an affordable price.  

-  Paper products but specifically kitchen rolls and kitchen paper have also been identified as widely used 
products in the catering services. Like the feedback for previous sub-criterion, stakeholders suggested 
the  need  of  facilitating  a  lower  consumption  of  these  products  and  to  increase  the  amount  of 
environmentally  friendlier  purchases  (e.g.  products  covered  by  a  type  I  ecolabel).  Ecolabel  paper 
products are also widely available on the market at reasonable prices. Even so, an exemption can be 
granted wherever a lack of availability is identified.  
Another exception is granted to the use of tablecloths made of paper that can be reused. This type of 
tablecloths has shown to be environmental-friendlier than the only one use.  

-  Disposable  items  and  consumable  goods  are  the  third  type  of  products  included  in  this  criterion.  The 
sub-criterion  focuses  on  the  non-use  of  these  consumables  with  the  only  exception  of  take  away 
catering, big events and other specific cases like the use of rubbish bags or cleaning gloves. In those 
cases, requirements on the degradability and/or composability of the materials have been introduced. 
Further explanations can be found in Annex 4.6.  

The comments on the ambition levels were in general split with problems in the market availability being cited as 
an issue in some Member States and the large availability at affordable prices in other Member States. Therefore, 
the recommended values have been increased in comparison to values previously proposed, but an exemption has 
been considered for inclusion if needed. Wherever a lack of availability of these types of products is identified, the 
criterion must not be introduced.  

Rationale for the proposed verification 

-  Paper products: The current criteria states that paper products, such as, kitchen paper or paper napkins 
must  be  made  from  recycled  or  sustainably  managed  virgin  fibre.  This  is  to  avoid  (in  particular)  the 
negative  impacts  from  deforestation.  However,  this  requirement  is  only  a  part  of  the  requirements 
included in an Ecolabel scheme. The EU Ecolabel scheme is a comprehensive tool that informs about the 
best environmental performing products. Therefore, it can be said that the old requirement has been kept 
but that the verification of paper products throughout this ecolabel allows the simultaneous verification 
of some other requirements. Other ecolabel schemes can be used as proof of verification as long as they 
are considered as equivalent by the contracting authorities.  

-  Chemical products requirements should be verified based on the award of an EU ecolabel. This ecolabel 
ensures  that  the  best  environmental  performing  products  on  the  market  are  being  used.  Equivalent 
schemes can be also used as proof of verification.  The proper dosage of these products is proved by a 
description of the dosing systems.  

-  Disposable items are restricted in this criterion. However, if need they must fulfil some requirements and 

must be verified throughout the compliance with the international standards (e.g. EN13432) 

62 

 
 
 
 
 
Energy and water consumption in kitchens (BEFORE: Equipment) 

Core criteria 

Comprehensive criteria 

Technical specifications 
TS6 Energy and water consumption in the kitchens 
TS6.1. Best practices to minimise energy and water consumption 
The  tenderer  must  have  written  procedures  describing  best  practices  for  the  use  of  kitchen  equipment  to 
minimise energy and water consumption, including procedures for [to be selected depending on the contracting 
authority's infrastructure]: 
General remarks 
- If feasible, equip kitchen areas with their own meters for water and electricity/gas 
- Avoid switching on all electrical equipment at the same time to avoid peak electrical power. 
- In the consumer rooms, equipment and lighting must be switched on only during the hours of service 
to the public. 
Ovens: 
- Switch on only those ovens required to meet the demand.  
- Switch ovens off when not in use for over 20 minutes  
-  Use  spare  oven  capacity  to  perform  other  cooking  operations  and  avoid  switching  on  other 
equipment, or allow it to be switched off.  
- Avoid using electric ovens for holding food, use a well-insulated hot cupboard instead and switch the 
ovens off as soon as possible.  
- Avoid frequent opening of the oven door during cooking 
Hobs: 
- Switch on hob rings when needed, switch off after use.  
- Avoid leaving pilot lights on over night  
- Where possible use open hobs in preference to flat-tops.  
- Avoid extended cooking times on hobs, use them intensively for shorter periods and switch off.  
- Use spare oven capacity to perform some hob operations (e.g. cooking pasta).  
Other cookers: 
- Switch on equipment when needed; switch off after use, e.g. grills, fryers.  
- Use reduced settings to reduce warm-up times: grills, fryers.  
- Use spare oven capacity to perform some grill and fryer operations (roasting, browning, frying).  
Extraction 
- Where extraction is manually controlled ensure a staff member has responsibility for switching it off.  
-  Where  extraction  is  timer/BMS  controlled  ensure  the  settings  match  the  operating  hours  of  the 
kitchen.  
- Where the operating hours are variable put control measures in place to vary the extraction hours 
accordingly.  
- Where the extractor/air supply has variable speed control determine the setting that gives adequate 
air flow and use that setting. Use a reduced setting at times of lower activity.  
- Ensure filters and vents are cleaned regularly to reduce system resistance.  

Dishwasher 
- Ensure dishwashers are switched off whenever possible to minimise standby energy consumption  
- Wherever possible ensure that racks are full to minimise the amount of energy used per plate.  
- Use cold-water for pre-rinse to minimise the use of hot water. 
- Avoid manual rinsing of the place settings and kitchenware, throwing food left on plates in the 
biowaste bin.  
Refrigeration 
- Efficient use – least amount of door-openings possible.  
- Do not place refrigerated appliances near sources of heat. 
- Maintenance – Ensure seals are maintained and heat exchangers cleaned.  
- Ensure refrigerators have sufficient ventilation for their heat exchangers.  
- Right capacity – decommission units if poorly utilised. Choose the right capacity of each unit, instead 

63 

 
 
of purchasing multiple smaller units. 

The best practices are aimed at the staff working in the kitchen/s providing the contracted catering service.  

Verification 
The tenderer must provide the written procedures describing the best practices for using kitchen equipment. 
Award criteria 
Core criteria 
AC2.  Energy  and  water  consumption  in  the 
kitchens10 

Comprehensive criteria 
AC2.    Energy  and  water  consumption  in  the 
kitchens 

This  criterion  is  applicable  only  where  the  caterer  is 
responsible for providing the equipment 

This  criterion  is  applicable  only  where  the  caterer  is 
responsible for providing the equipment 

AC2.1a. Refrigeration 
Points are to be awarded proportionally to tenders in 
which  more  than  A%1)  of  the  plug-in  cabinets*  and 
storage  cabinets  have  lower  energy  efficiency  index 
(EEI) than the values in the following table: 
Category 
Storage counter refrig 
Storage refrig 1-door 
Storage refrig 2-doors 
Storage counter freezers 
Storage freezers 1-door 
Storage freezers 2-doors 
Storage refrig-freezers 

EEI  Min. energy class 
<25 
<25 
<50 
<35 
<50 
<50 
<75 

A 
A 
C 
B 
C 
C 
D 

Min. energy class 

EEI 
< 22  A+++ 
< 42  A+ 

AC2.1b.  Refrigeration 
Points  are to be awarded proportionally to tenders in 
which  more  than  C%1)  of  the  household  appliances 
have  lower  energy  efficiency  index  (EEI)  than  the 
values in the following table: 
Category 
Storage chest freezers 
Wine  storage  appliances 
with one temperature zone  
Wine  storage  appliances 
with  multi 
temperature 
zones 
Note:  Regulation 
(EC)  No  1060/2010  on  energy 
labelling of household refrigerating appliances and the 
refrigerants  of  the  equipment 
is  currently  under 
revision 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?qid=1562161019863&uri=PI_COM:Are
s(2018)5145999 ) 

< 55  A 

AC2.1a. Refrigeration 
Points are to be awarded proportionally to tenders in 
which  more  than  B%1)  the  plug-in  cabinets*  and 
storage cabinets have an energy efficiency index (EEI) 
lower than 25 (Energy Class A). 

AC2.1b.  Refrigeration 
Points  are to be awarded proportionally to tenders in 
which more than D%1)  of the household refrigerating 
appliances  have  an  energy  efficiency  index  (EEI)  of 
lower than 22  

AC2.1c.  Refrigeration 
Points  are to be awarded proportionally to tenders in 
which  more  than  F%1)  of  the  equipment  uses 
refrigerants  with  a  global  warming  potential  (GWP) 
below 3.  

10 These criteria are without prejudice to situations where public authorities are obliged to purchase only 
products or services with high energy-efficiency performance in accordance with Article 6 of Directive 
2012/27/EU on energy efficiency 

64 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
AC2.1c.  Refrigeration 
Points  are to be awarded proportionally to tenders in 
which  more  than  E%1)  of  the  equipment  uses 
refrigerants  with  a    global  warming  potential  (GWP) 
below 5.  
Verification: 
The tenderer must supply a list of the equipment that 
will be used in the execution of the contract, indicating 
specifically  which  items  of  equipment  comply  with 
this criterion. 
The tenderer must supply information about the EEI in 
accordance  with  Regulation  (EC)  No  2015/1094  on 
energy  labelling  of  professional  refrigerated  storage 
cabinets or Regulation (EC) No 1060/2010 on energy 
labelling  of  household  refrigerating  appliances  and 
the refrigerants of the equipment3) or its subsequent 
revision or amendment. 
In case of new acquisitions, the tenderer must provide 
a  signed  commitment  to  purchase  or  lease  the 
equipment within the first 6 months of the contract. 

AC2.2 Cooking appliances 
Points  are to be awarded proportionally to tenders in 
which more  than  G%1)  of  the  cooking  appliances  are 
equipped with:  
- an induction hob or gas hob with optimised burners 
and controlled by pot sensors. 
- insulated food heating or 
- a convection oven, combi oven or pressure cooker. 
- a hood equipped with detection devices that would 
detect  its  operation  and  activate  the  corresponding 
part of the hood, avoiding to operate the whole hood 
at the same time . 

AC2.3. Professional dishwashers 
Points are to be awarded proportionally to tenders in 
which more than H%1) of the dishwashers are 
equipped with: 
- heat recovery systems from exhaust air heat, waste 
water heat recovery or dried dishes 
- a double wall 
- optimised filter systems: centrifugal systems 
(cyclone filter) or integrated pre-scouring system 
- multi-zone rinsing. 

Verification: 
AC2.1.  
The tenderer must supply a list of the equipment that 
will be used in the execution of the contract, indicating 
specifically  which  items  of  equipment  comply  with 
this criterion. 
The tenderer must supply information about the EEI in 

65 

 
 
 
 
 
 
 
accordance  with  Regulation  (EC)  No  2015/1094  on 
energy  labelling  of  professional  refrigerated  storage 
cabinets or Regulation (EC) No 1060/2010 on energy 
labelling  of  household  refrigerating  appliances  and 
the refrigerants of the equipment3), or its subsequent 
revision or amendment. 
In case of new acquisitions, the tenderer must provide 
a  signed  commitment  to  purchase  or  lease  the 
equipment within the first 6 months of the contract. 

AC2.2.  The  tenderer  must  supply  a  list  of  the 
equipment  that  will  be  used  in  the  execution  of  the 
items  of 
indicating  specifically  which 
contract, 
equipment comply with this criterion.  
The  tenderer  must  supply  information  about  the 
technology of the equipment3). 
In case of new acquisitions the tenderer must provide 
a  signed  commitment  to  purchase  the  equipment  
within the first 6 months of the contract. 

AC2.3.  The  tenderer  must  supply  a  list  of  the 
equipment  that  will  be  used  in  the  execution  of  the 
contract, 
items  of 
indicating  specifically  which 
equipment comply with this criterion.  
The  tenderer  must  supply  information  about  the 
technology of the equipment3). 
In case of new acquisitions the tenderer must provide 
a  signed  commitment  to  purchase  the  equipment 
within the first 6 months of the contract. 

Explanatory notes 
Core criteria 
Award criteria 
AC2 Energy and water consumption in the kitchens 
Recommendation for scaling up the percentages from small to large number of kitchen appliances 
of each type 
The following table is recommended for kitchens with few appliances of each type: 

Comprehensive criteria 

Number of kitchen appliances of each type  Minimum number of  compliant appliances 

1 - 3 
4 - 6 
7 - 9 
 10 

1 
2 
3 
50% 

E.g. In a kitchen with 2 ovens and 3 refrigerators, 1 of the ovens and 1 of the refrigerators have to comply with 
the criteria set above to be awarded with the points. 

AC2.1 Refrigeration 
Recommended values for core criteria:  
A = 0-50% of the plug-in cabinets (remote cabinets are not considered) and storage cabinets 
C = 0-50% of the storage chest freezers and wine storage appliances with one or multi temperature zones.  
E= 100% of the equipment using refrigerants with a GWP below 5. 
Recommended values for comprehensive criteria:  
B = 0-50% of the plug-in cabinets (remote cabinets are not considered) and storage cabinets 
D = 0-50% of the storage chest freezers and wine storage appliances with one or multi temperature zones.  

66 

 
 
 
 
 
F = 100% of the equipment using refrigerants with a GWP below 3 

AC2.2. Cooking appliances 
Recommended values for comprehensive criteria:  
G=51-100% of the cooking appliances are equipped with the listed technologies 

AC2.3. Professional Dishwashers 
Recommended values for comprehensive criteria:  
H=51-100% of the dishwashers are equipped with the listed technologies 

* remote cabinets are not considered 
1)  A,…I  are  the  thresholds  to  be  defined  by  the  procurer  for  the  core  and  comprehensive  levels  (AC).  Recommendations  for  its  value  are  given  in 
explanatory notes below 
2) Energy label of the appliances, test reports or any other technical documentation), and if applicable a signed commitment to purchase the equipment 
over the first 6 months of the contract  
3)  Technical  sheet  or  Technical  documentation  of  the  equipment,  and  if  applicable  a  signed  commitment  to  purchase  the  equipment  over  the  first  6 
months of the contract. 

Rationale for the proposed criteria wording 

The energy use in kitchen operations has an impact on fossil fuels, carcinogens and eco-toxicity, and it plays an 
important  part  once  the  catering  service  is  analysed  isolated  from  the  primary  production  of  food.  The  study 
carried out by IEEA (2012) showed that almost 40% of the energy consumption of the kitchen is used for cooking, 
28% for refrigeration, 17% at extraction and dishwashing at 5%. In carbon terms, cooking accounts for 27% and 
refrigeration for 34%. This is due to the lower carbon impact of gas which accounts for 68% of cooking energy.  

The  measures  proposed  in  this  criterion  are  cost-effective.  The  requirement  of  this  criterion  are  especially 
important to reduce the environmental impacts of the kitchen if it is noted that in many occasions, the caterer 
does not pay the energy bill and s/he does not have not economic incentives to reduce the energy consumption. 
Hence, this criterion is proposed as a technical specification including the best practices for using the equipment. 
The study by IEEA (2012) also showed that there is considerable potential for improvements based on how staff 
uses the kitchen equipment. The study estimated that the energy savings could reach 40% in cooking and 25% in 
dishwashing, with very affordable investments. Therefore, it is proposed that the GPP criteria include a technical 
specification requiring the implementation of best practices for the use of kitchen equipment, aimed at the staff 
working  in  the  kitchen/s  providing  the  contracted  catering  service.  Recommendations  from  the  study  by  IEEA 
(2012) are provided in the criteria text as a guidance for the caterers to include in their procedures. 

An  award  criterion  including  the  use  of  kitchen  equipment  with  best  available  technologies  (BAT).  Further 
information  about  the  current  BATs  can  be  found  in  Annex  4.7.  The  requirements  of  the  performance  of  the 
appliances are based on 

-  There  is  a  lack  of  regulation on  the  performance  of cooking  equipment  and  professional  dishwashers. 
The  requirements  for  this  type  of  appliances  could  have  been  based  on  the  US  Energy  Star,  those 
requirements are not representative for the EU market. The BATs for cooking equipment and dishwashers 
are proposed as requirements in this criterion at comprehensive level, in order to keep the core level as 
simple as possible. 

-  Energy Label regulations for professional and household refrigeration are considered (Regulation (EU) No 
2015/1995  and  Regulation  (EU)  No  1060/2010).  The  thresholds  for  these  requirements  are  based  on 
Topten criteria (Topten 2019) 
Another policy ruling the refrigeration appliances in Europe is the so called F-Gas Regulation (Regulation 
(EU) No 517/2014 on fluorinated greenhouse gases and repealing Regulation (EC) No 842/2006). This 
regulation  aims  at  the  phase  out  of  HFC  refrigerants  with  high  global  warming  potential  (GWP), 
particularly for commercial and professional refrigeration; it sets deadlines to ban high and medium GWP 
refrigerants. Hydrocarbons are commonly used in professional refrigeration, and perform GWP below 5. 
Therefore there is no need of additional drivers to promote the use of refrigerants with GWP below 150, 
but those ones with much lower GWP. 

67 

 
 
 
 
 
 
- 

In the case of extraction, the main parameters affecting the energy consumption are related to the type 
of cooking appliances and dishwashers. Other parameters, as the speed variable fans, are usually part of 
the kitchen design which is out of the control of the catering service operator. Therefore, no requirements 
on the energy performance have been included. 

The percentages proposed are set taking into account the number of appliances of each type in the kitchen. It is 
recommended to progressively scale up the percentages from small to large number of kitchen appliances of each 
type. This is meant to balance the burden that these award criteria might entail for SMEs. 

Rationale for the proposed verification 

In the case of the technical specification there is not a standard or procedure available to measure the reduction 
of energy and water consumption in the kitchens. However, indicators such as KWh/meal or l/meal are proposed 
as part of the “Environmental management measures and practices” criterion. The monitoring and recording of this 
indicator will show the continuous improvement of the tenderer on this aspect. 

Additionally, for the verification of this criterion, the tenderer must provide the written procedures describing the 
best practices for using of kitchen equipment. 

For refrigeration appliances, the energy label of the appliances and the technical sheets indicating the GWP of the 
refrigerants would act as proof of compliance. For the rest of appliances, the technical information describing the 
technologies requested would constitute the documentation for verification. 

In case that new acquisitions are needed, there is a provision to allow tenderers to provide a signed commitment 
to purchase the compliant equipment over the first 6 months of the contract (see also section 3.3.2). The aim of 
this clause is to avoid tenderers investments prior to the award of the contract. For some companies, the incoming 
cash-flows from the contract may be crucial to ensure reasonable payback periods for those investments. 

68 

 
 
  
 
Food transportation (BEFORE: Vehicle fleet and planning of food delivery) 

Core criteria 
Technical Specification 
TS.7 Food transportation 
These criteria only apply where the food delivery is part of the service contracted and the fleet is under the control 
of the tenderer. 'Food delivery' covers the transportation of food to and from service kitchen, and to the place where 
the service is provided, if it is elsewhere. 

Comprehensive criteria 

TS7.1. Reduction of fuel consumption 
The  tenderer  must  implement  a  reduction  plan  to  minimise  greenhouse  gas  and  air  pollutant  emissions  of  the 
vehicles used in the service, taking into account route optimisation, the load transported, the last mile  problem, 
and, if economically feasible, the technologies listed in the AC3.2, AC3.3 and AC3.4 award criteria. 

TS7.2. Air pollutant emissions 
All heavy duty vehicles (HDV) used in carrying out the service must meet at least Euro V standard1).  
All light commercial vehicles (LCV) used in carrying out the service must meet at least Euro 5 standard2).  

Verification:  
TS7.1. The tenderer must supply the transport plan to minimise GHG and air pollutant emissions.  
TS7.2. The tenderer must present the list of vehicles of the service fleet and their certificates of conformity. For 
those vehicles having achieved the standard mentioned above following a technical upgrade, the measures must 
be documented and included in the tender, and this must be verified by an independent third party 
In case of new acquisitions the tenderer must provide a signed commitment to purchase the vehicles within the 
first 6 months of the contract 

Core criteria 
Award criteria 
AC.3 Food transportation  
Note: These criteria only apply where the food delivery is part of the service contracted and the fleet is under the 
control of the tenderer. 'Food delivery' covers the transportation of food to and from service kitchen, and to the place 
where the service is provided, if it is elsewhere. 

Comprehensive criteria 

AC.3.1. Air pollutant emissions 
Points will be awarded to tenderers offering a service delivery fleet totally composed of Euro 6/VI3) vehicles 

Verification:  
AC.3.1. The tenderer must present the list of vehicles of the service fleet and their certificates of conformity. For 
those vehicles having achieved the standard mentioned above following a technical upgrade, the measures must 
be documented and included in the tender, and this must be verified by an independent third party. In case of new 
acquisitions, the tenderer must provide a signed commitment to purchase or lease the vehicles within the first 6 
months of the contract. 

AC.3.2. GHG emissions 
Points  will  be  awarded  to  tenders  offering  a  service 
delivery fleet totally composed of: 
- LCV performing <= 45 g CO2/km (type approval value) 
-  Hybrid,  original  equipment  manufacturer  OEM 
(meaning  new,  no  aftermarket  conversions)  dual-fuel 
natural  gas  with  substitution  ratios  of  at  least  45%, 
high  pressure  direct  injection  natural  gas,  plug-in 
hybrid, electric  or hydrogen HDVs 
- Electric L-category vehicles. 

69 

 
 
 
 
  
 
 
 
 
 
AC.3.3. Refrigerants  
Points  will  be  awarded  to  tenders  offering  a  service 
delivery  fleet 
totally  composed  of  HDVs  using 
refrigerants with a global warming potential lower than 
150. 

Verification:  
AC.3.2. The tenderer must provide the technical sheets 
of the vehicles to be used to provide the service where 
the type approval CO2 emissions per km is stated 
In case of new acquisitions the tenderer must provide a 
signed  commitment  to  purchase  or  lease  the  vehicles 
within the first 6 months of the contract. 

AC.3.3. The tenderer must provide the technical sheets 
of the vehicles to be used to provide the service where 
the global warming potential of the refrigerant used in 
the HDVs is stated  
In case of new acquisitions the tenderer must provide a 
signed  commitment  to  purchase  or  lease  the  vehicles 
within the first 6 months of the contract. 

AC.4.4. Cyclelogistics 
Note: In those cities where the topography and the urban 
infrastructure  are  suitable,  and  for  services  that  consist 
of small volumes of food delivery, e.g. services for small 
meetings.  

Points  will  be  awarded  to  tenders  offering  a  service 
fleet that includes cycles and cycle trailers, which may 
be  electrically  power  assisted  cycles.  The  cycles  and 
cycle  trailers  will  be  aimed  at  addressing  last  mile 
problem,  according  to  the  reduction  plan  to  minimise 
greenhouse gas and air pollutant emissions set by the 
TS7.1. 

Verification:  
The  tenderer  must  provide  the  technical  sheets  and 
serial numbers of the cycles to be used to provide the 
service. 
In case of new acquisitions the tenderer must provide a 
signed commitment to purchase or lease the equipment 
within the first 6 months of the contract. 

1)  Directive  2005/55/EC  of  the  European  Parliament  and  of  the  Council  of  28  September  2005  on  the approximation  of  the  laws  of  the  Member  States 
relating to the measures to be taken against the emission of gaseous and particulate pollutants from compression-ignition engines for use in vehicles, and 
the emission of gaseous pollutants from positive-ignition engines fuelled with natural gas or liquefied petroleum gas for use in vehicles 
2)  Regulation  (EC)  No  715/2007  of  the  European  Parliament  and  of  the  Council  of  20  June  2007  on  type  approval  of  motor  vehicles  with  respect  to 
emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on access to vehicle repair and maintenance information. 
3)  Regulation  (EC)  No  715/2007  of  the  European  Parliament  and  of  the  Council  of  20  June  2007  on  type  approval  of  motor  vehicles  with  respect  to 
emissions from light passenger and commercial vehicles (Euro 5 and Euro 6) and on access to vehicle repair and maintenance information and Regulation 
(EC) No 595/2009 of the European Parliament and of the Council of 18 June 2009 on type-approval of motor vehicles and engines with respect to emissions 
from heavy duty vehicles (Euro VI) and on access to vehicle repair and maintenance information and amending Regulation (EC) No 715/2007 and Directive 
2007/46/EC and repealing Directives 80/1269/EEC, 2005/55/EC and 2005/78/EC 

70 

 
 
 
 
 
 
 
 
 
Rationale for the proposed criteria wording 

Cerutti et al. (2016) found that the GHG emission share of urban food distribution in the carbon footprint (CF) of 
the school catering service is relevant (24–28% of the total CF) and highlighted the possibilities for GHG emission 
reductions. The grade of contribution of transport activities on the overall environmental impacts of the catering 
services depends on food category and on situation.  

The use of fossil fuels leads to global warming, abiotic resource depletion, ozone depletion and acidification By 
requesting vehicles to be more fuel efficient or have lower emissions will also minimise the burdens on the other 
impact categories.  

Three main actions have been identified as mostly effective to reduce these environmental impacts:  

-  Reduction plan for fuel consumption: this is the most cost-effective measure to reduce the emissions and 
other  environmental  impacts  coming  from  the  food  delivery.  The  BEMP  for  Food  and  Beverage 
Manufacturing (European Commission, 2015b) had recommendations on logistics and route optimisation 
such  as  to  avoid  empty  loads  or  to  use  back-haul.  The  reviewed  GPP  schemes  also  apply  these 
requirements  as  for  example:  deliveries  to  be  made  once  a  week  and  on  a  more  regular  basis  when 
needed and a contractual delivery that stops on orders with a value below EUR 100 
Eco-driving  has  also  an  important  potential  of  fuel  reduction,  which  could  be  reinforced  by  additional 
measures other than the training, for example, the drivers could  receive regularly information on their 
fuel efficiency performance, so they could improve their driving behaviour continuously. 

-  Air pollutants emissions: In the view of the set of improvements that EURO VI/6 standards introduce (see 
annex 4.7 for more details), new vehicles on the market need to make important efforts to comply with 
their requirements, and therefore, it is proposed these new standards to be promoted within the EU GPP 
criteria.  The  total  replacement  of  a  fleet  to  EURO  VI/6  may  entail  significant  costs,  therefore  it  is 
proposed  an  award  criterion  for  fleets  totally  composed  by  EURO  VI/6  vehicles.  However,  it  is  also 
proposed a technical specification requiring a minimum EURO standard of the fleet, in order to exclude 
low  performance  vehicles.  The  technical  specification  sets  EURO  V/5  as  minimum  requirement,  which 
would  exclude  vehicles  older  than  9  years  for  heavy  duty  vehicles  and  7  years  for  light  commercial 
vehicles. 

-  CO2  emissions:  the  most  fuel  efficient  internal  combustion  engine  vehicles  are  cost-effective.  The 
additional cost of the vehicle is outweighed by the fuel saving over its lifetime. Conversely, electric and 
semi-electric vehicles are still at a lower production scale which makes their prices not as competitive as 
ICEVs. For this reason, the comprehensive award criterion is meant to promote the use of plug-in hybrids 
and electric vehicles, which are the only ones able to perform 45 g CO2/km (type approval CO2 value). In 
the case of heavy duty vehicles, other technologies than electric and semi-electric are also covered by 
the  award  criterion,  since  the  duty  cycles  might  require  larger  ranges.  These  technologies  are 
hybridisation,  OEM  dual-fuel  natural  gas  with  substitution  ratios  of  at  least  45%,  high  pressure  direct 
injection natural gas and hydrogen.  

-  Cycle logistics has demonstrated its capability to operate in urban deliveries, which makes it suitable for 
deliveries within catering services for small volumes of food transported. According to CIVITAS (CIVITAS, 
2012) 42% of all motorized trips in urban areas could be shifted to logistics by bicycle (this corresponds 
to 25% of all trips).  

-  HFC refrigerants: From 2017 onwards the global warming potential (GWP) of air conditioning gases used 
in  cars  and  vans should be  below 150,  according to  the  European  directive  on  mobile  air  conditioning 
systems  (MACs  Directive)  (Directive  2006/40/EC).  The  only currently  available  alternatives  to  meet  the 
legal limit already perform very low GWP (1- 4), therefore an award criterion for lower GWP beyond that 
limit  would  be  easily  complied  by  all  the  vehicles  and  wouldn’t  bring  any  added  value.  Trucks  are 
excluded from the MAC Directive, however, the HFCs used in these systems are affected by the phase-
down put in place by the F-gas Regulation (EU) No 517/2014, which will exert a strong pressure on prices 
of these gases as the supply will become more restricted. Therefore, there is a strong regulatory driver in 
place that favours the use of low GWP in this sector. It is proposed to set an award criterion for those 
refrigerants with GWP below 150 at comprehensive level. 

71 

 
 
 
Rationale for the proposed verification 

In the case of the technical specification there is not a standard or procedure available to measure the reduction 
of fuel consumption in food delivery. However, an indicator of fuel consumption per meal is proposed as part of 
the environmental management measures and practices. The monitoring and recording of this indicator will show 
the continuous improvement of the tenderer on this aspect. 

For  the  award  criteria,  the  technical  sheets  of  the  vehicles  would  suffice  to  verify  the  criteria  on  air  pollutant 
emissions, CO2 type approval and GWP of refrigerants. In case of upgrades of vehicles to Euro VI, there need to be 
a document issued by a third party verification entity. For cyclelogistics, the serial numbers of cycles to be used in 
the service are also requested.  

In case that new acquisitions are needed, there is provision to allow tenderers to provide a signed commitment to 
purchase the compliant equipment the over the first 6 months of the contract. This is to avoid that tenderers have 
to invest in new vehicles before the contract is awarded. For some companies, the incoming cash-flows from the 
contract may be crucial to ensure reasonable payback periods for those investments. 

72 

 
 
 
 
Environmental management measures and practices 

Core criteria 
Technical Specification 
TS8. Environmental management measures and practices 
The tenderer must have operational procedures to: 
1. monitor and record at least twice a year, for representative weeks, the following indicators:  

Comprehensive criteria 

-  Number of meals prepared and overall amount, in mass, of each ingredient used in the preparation of 

meals (with a threshold above 1 kg/week) 

-  Consumption of vegetables, fruits and pulses (g of vegetables, fruits and pulses/meal or g of meat and 

meat products/meal) (this indicator is not required if the amount of vegetables, fruits and pulses/meal or g 
of meat and meat products/meal is fixed in the contract) 

-  The number of annual environmental staff training hours thought per type of employee (e.g. type of 

- 

function and experience in the company) 
If food waste is sorted out, food waste (g/meal) measured as: kitchen food waste, serving food waste 
and plate food waste 

-  Other waste (g/meal) at least sorted out into : paper/cardboard, glass, plastic, metal and residual waste 
-  Energy consumption (kWh/meal) 11 
- 
-  Water consumption (l/meal) 
- 

In case the service includes the delivery of food and the fleet is under the tenderer's control, the fuel 
consumption of the vehicles used for the food delivery (l/km.meal) 

-  The satisfaction of the clients with the food and the services provided (a business to client indicator)  
-  The satisfaction of the contract authority with the tenderer's performance (a business to business 

indicator) 

2. optimise* the environmental indicators monitored and recorded in 1.  The procedures must be at least the ones 
covered by the following criteria: 

-  Staff training  
-  Plant-based menus 
-  Food waste prevention  
-  Other waste prevention, sorting and disposal 
-  Energy and water consumption in kitchens 
- 

In case the service includes the delivery of food and the fleet is under the tenderer's control, food 
transportation. 

The service staff must be aware of the operational procedures. 

3. evaluate the deployment of points 1 and 2 by tracking both any changes in the environmental indicators and 
the implementation of the procedures. 

4. in case of deviations, implement the necessary actions to correct those deviations, and if possible prevent them 
in the future. 

Verification:  
The tenderer must provide the procedure:  
1. for monitoring and recording the indicators pointed out in section 1) at least twice yearly 
2. to ensure the implementation of the operational procedures 
3. to correct the deviations found in the evaluation, and if possible prevent them in the future. 

11 Waste categories should be identified according to the European waste codes. 

73 

 
 
 
 
                                                           
Environmental management systems that are certified against ISO 14001 or EMAS, and services holding a Type 1 
ecolabel  are  deemed  to  comply,  if  they  fulfil  the  following  environmental  objectives:  increase  in  vegetable 
consumption, minimisation of food waste, other waste, energy and water and if applicable, minimisation of fuel 
consumption. 
The  tenderer  must  show  an  environmental  policy  committed  to  achieving  these  objectives,  together  with  the 
certificate issued by the certification body. 

Explanatory notes 
Technical Specification 

TS8. Environmental management measures and practices 

A representative week means a week where the level of business / activity is approximately the average over a 
year (a week where there is a higher number of functions, higher number of bank holidays or special occasions 
e.g. Valentine's day or Christmas is not representative) 

The  concept  of  meals,  if  not  defined  by  the  contracting  authorities,  can  differ  from  one  tender  to  another.. 
Therefore,  if  the  proposed  indicators  are  expected  to  be  served  for  comparing  the  offers,  the  contracting 
authorities must clearly define the indicators to be used.  

* meaning improve or keep at the minimum feasible level 

Rationale for the proposed criteria wording 

An  Environmental  Management  System  (EMS)  is  a  systematic  and  documented  mean  of  demonstrating  an 
organisation's  commitment  to  managing  and  reducing  its  environmental  impacts.  It  is  particularly  helpful  to 
ensure  the  environmental  performance  of  services,  where  an  important  part  of  the  criteria  must  rely  on  best 
practices, staff training and other operational requirements. 

This  criterion  is  included  within  the  current  EU  GPP  (EU  GPP  2008)  criteria  as  a  selection  criterion  at 
comprehensive level. . Even if EMS is a very useful tool to develop systematic improvement processes, the leeway 
offered by the ISO standards may hinder their application in real practice. Their requirements are so general that 
their interpretation may be difficult for the non-expert users. In addition, EMSs are not very common among the 
catering service operators and particularly difficult to be achieved by SMEs which may lead to their exclusion of 
the tendering process. For these reasons, under this revision a full and comprehensive EMS is not required. The 
present  revision  proposes  a  technical  specification  criterion  that  is  inspired  on  the  plan-do-check-act  (PDCA) 
principles which constitute the basis of the management systems  

The criterion is structured on the pillars of the PDCA applied to EMS: 

-  Monitoring the environmental issues by means of environmental indicators: The set of indicators proposed 
to be monitored is based on the environmental hotspots identified for this sector: energy consumption 
(including  fuel  if  food  delivery  is  included  in  the  service),  water  consumption  and  waste  generation, 
particularly food waste, relative to the number of meals which is the functional unit of the service. 
Implementation  of  the  operational  procedures  to  minimise  the  environmental  aspects:  The  operational 
procedures  are  aimed  at minimising  the environmental  indicators  and  should  gather  at  least the  ones 
required by the criteria proposed in this revision. In this way, the environmental management is not an 
isolated criterion but encompasses the rest of the GPP criteria. 

- 

-  Evaluation of  the implementation of the procedures and correction of the deviations found: There must be 
a  systematic  way  to  ensure  the  proper  implementation  of  the  operational  procedures  and  the 
minimisation  of  indicators.  For  this  purpose,  it  is  necessary  to  carry  out  a  regular  evaluation  of  both 
indicators and procedures, and to set corrective and preventive actions where needed. This is proposed to 
be  done  by  tracking  the  evolution  of  the  indicators  over  the  contract  duration,  and  checking  how  the 
procedures function in real practice. 

74 

 
 
 
 
 
 
 
Rationale for the proposed verification 

Stakeholder consultation brought up an obstacle for the inclusion of certified environmental management systems 
as  proof  of  verification  of  this  criterion.  They  are  not  very  common  among  the  catering  service  operators  and 
particularly  difficult  to  be  achieved  by  SMEs  which  may  lead  to  their  exclusion  of  the  tendering  process.  The 
requirement on certified systems is considered unaffordable for most catering service operators. 

For  these  reasons,  the  verification  is  now  proposed  to  be  based  on  the  provision  of  the  following  written 
documents:  

1) the procedure for monitoring and recording the indicators  
2)  the  operational  procedures  describing  the  measures  to  be  deployed  to  minimise  the  environmental 
indicators  
3) the evaluation procedures to ensure the implementation of the operational procedures 
4) the correction procedures to correct the deviations and to prevent them in the future  

However, if the catering service operator has a certified environmental management system, EMAS or the service 
holds a type 1 Ecolabel that cover the environmental objectives listed in the criterion, this will deem to comply  

75 

 
 
 
3.3 

Contract performance clauses (CPC)  

Provision of low impact drinking water 

Comprehensive criteria 

Core criteria 
Contract Performance Clause 
CPC1. Provision of low impact drinking water 
Note: This criterion only applies to those cases where it is possible to supply or get access to tap drinking water 
The contractor must supply free tap water for drinking at the premises of the catering service (either providing 
direct access to the water tap or providing the tap water in a jug or other dispenser) and provide reusable glasses 
for drinking. 
The contractor must inform the customers about the provision of tap drinking water at the premises. 
The contracting authority may set rules for penalties for non-compliance. 

Rationale for the proposed criteria wording 

The long-term environmental impacts of bottling and transporting water across countries have severe implications 
due to the attributed emissions and waste generated (mainly plastic and glass) in a very short lifecycle of the 
product. With an EU average consumption of 110 litres per person per year, bottled water is the first most popular 
liquid  refreshment  before  carbonated  drinks  (Canadean,  2016).  The  mineral  water  sold  in  the  EU  represented  in 
2012  half  of  the  total  volume  of  soft  drink  cold  beverages  in  EU-28  (41881  million  litres  in  accordance  with 
Eurostat – PRODCOM NACE Rev. 2).  

On the other hand, drinking water directly from the tap hold or throughout a dispenser to become sparkling water 
is safe in the vast majority of EU-28 as ensured by the Drinking Water Directive (Council Directive 98/83/EC of 3 
November  1998  on  the  quality  of  water  intended  for  human  consumption).  The  Commission  published  last 
October 2016 the Synthesis Report on the quality of drinking water in the Union. A complete list national drinking 
water portals across the EU is offered by European Environmental Agency (EEA 2016). 

Although industry’s big players are all pursuing efforts to increase recycled content in polyethylene terephthalate 
(PET)  bottles,  progress  is  slow  and  the  environmental  impact  associated  still  remains.  Therefore,  this  criterion 
proposed to support effort towards facilitating healthy and low environmental impacting hydration and increasing 
access to water for all clients.  

TR1.0  proposed  a  ban  on  in-bought  water.  This  proposal  was  not  welcome  by  a  number  of  stakeholders.  They 
commented that a reduction of bottled water choice may go against public health interest since studies show that 
people do not drink enough and thus not meeting EFSA guidelines for water intake. Additionally, it was pointed out 
that bottle water has  the lowest environmental footprint amongst all beverages (single ingredient, no chemical 
treatment, very high recycling rate including in close loop) and that consumers have to have the right to choice the 
water they prefer.  

Finally, it was mentioned that in Europe, bottled water refers to Natural Mineral Water (84%) and Spring Water 
(13%) which means purity at source, no chemical treatment and unique mineral water composition as stated on 
label  (consumer  information)  being  according  to  Directive  2009/54/EC  distinguishable  from  ordinary  drinking 
water. Consumers appreciate the naturalness of this product and the possibility to make a choice based on taste 
and mineral composition. Having in mind these comments, the ban on in-bought bottle water has been removed 
but the criterion has been kept to ensure that clients have access to low-impacting environmental water if this is 
their selection. 

76 

 
 
 
 
 
 
Purchase of new kitchen equipment 

Comprehensive criteria 

Core criteria 
Contract Performance Clause 
CPC2.  Purchase of new kitchen equipment 
If a kitchen equipment or vehicle of the service fleet is replaced, the new one must help in keeping or improving 
the composition and technologies as offered in the tender to comply with the award criteria AC2 and AC3. 
In case new kitchen equipment has to be purchased partially or wholly to provide the service contracted, the 
contractor must purchase equipment complying with the highest energy class available in the market. 
The contractor must report the purchase of new equipment to the contracting authority. 

Explanatory note 

The award criteria AC2 reflect the best technologies in terms of energy efficiency available in the market at the 
moment of publication of the EU GPP criteria, and they can be used as guidance to determine the highest energy 
class requested to the purchase of new kitchen equipment during the contract period. 

Rationale for the proposed criteria wording 

The  Energy  Efficiency  Directive  (Directive  2012/27/EU)  sets  energy  efficiency  requirements  for  purchasing 
products, services and buildings by central government. It specifically sets that central governments must require 
in their tenders for service contracts that the new products purchased for the purpose of providing the service in 
question must comply with:  

(a).  where  a  product  is  covered  by  a  delegated  act  adopted  under  Directive  2010/30/EU  or  by  a  related 
Commission implementing directive (Energy Labelling Directive), products must comply with the criterion 
of belonging to the highest energy efficiency class possible; 

(b).  where  a  product  not  covered  under  point  (a),  but  by  an  implementing  measure  under  Directive 
2009/125/EC  (Ecodesign  Directive)  adopted  after  the  entry  into  force  of  this  Directive,  purchase  only 
products that comply with energy efficiency benchmarks specified in that implementing measure; 

Therefore, this contract performance clause is proposed to harmonise the GPP criteria with the provisions of the 
Energy Efficiency Directive. 

77 

 
 
 
 
 
 
 
 
 
Environmental management measures and practices 

Core criteria 
Contract Performance Clause 
CPC3. Environmental management measures and practices 
The contractor must document and report, over the duration of the contract. 

Comprehensive criteria 

- 
- 

the results of the monitoring of indicators and 
the results of the evaluation and the correction and prevention actions, where applicable, according to 
the written procedures provided for to the verify TS8 Environmental management measures and 
practices  

These reports must be made available to the contracting authority for verification purposes.  
The contracting authority may set rules for penalties for non-compliance. 

Rationale for the proposed criteria wording 

The aim of this Contract Performance Clause is to ensure the correct implementation of the technical specification 
of  technical  specification  criterion  Environmental  management  measures  and  practices.  The  contractor  must 
commit to carry out the written procedures provided for the verification of technical specification over the contract 
duration. 

This requirement is newly proposed under this revision. 

78 

 
 
 
 
 
 
 
 
 
 
Staff training 

Comprehensive criteria 

Core criteria 
Contract Performance Clause 
CPC4. Staff training 
In the case of new hired staff, the contractor must provide on-site staff training on the method statements listed 
in the selection criteria (SC1) 
For permanent and temporary staff whose contract is for more than one year, the contractor must provide update 
on-site training on the method statements listed in the selection criteria (SC1) at least once per year. 
The contractor must report the training provided to the contractor authority.  
The contracting authority may set rules for penalties for non-compliance. 

Comprehensive criteria 

Explanatory notes 
Core criteria 
Contract Performance Clause 
Recommended values 
For permanent staff and temporary staff whose contract is for more than one year, 16 h per year of on-site 
formation is a recommended value for the duration of the formation while for other temporary and short term 
staff must be proportional to the duration of the contract. Duration of the formation can be adjusted to the needs 
and conditions of the tenders.  
Staff in charge of the preparation of the menus, particularly vegan menus, must receive some guidelines on how 
to prepare them whilst observing the recommended nutritional intake and decreasing the overall environmental 
impact attributed to the dishes.  

Rationale for the proposed criteria wording 
The  contract  performance  clause  criterion  focuses  on  the  new  members  of  the  staff  or  those  that  have  been 
relocated.  Even  if  the  tenderer  have  the  method  statements,  staff  should  be  aware  of  the  techniques  and 
methods that can make their activity environmentally-friendlier.   
Due to the importance of the role of the personnel in the outcome of the activity and the high turnover rate of the 
sector, this clause is of great importance.  

The duration of the training is a debated issue among stakeholders, being too short for some and too ambitious 
for others. Here it is proposed a middle ground: the duration of the training proposed is  16 hours  per year for 
permanent  staff  while  for  temporary  and  short  term  personnel  duration  must  be  proportional  to  the  contract 
period.  

79 

 
 
 
 
 
 
 
Food and beverage redistribution 

Core 
Contract Performance Clause 

Comprehensive criteria 

CPC5. Food and beverage redistribution 
Note: applicable in those locations where hygiene rules allow and where the surplus of food to 
be donated is of interest for the redistribution organizations.   

The contractor must redistribute the food by [to be selected]:  

-  contacting  the  organizations  that  collect  food  products  that  are  donated  to  food 
distribution organizations  
- implementing the procedures for the collection of chilled and cooked food products that 
the  organization  establishes  with  the  catering  providers  (if  the  necessary  equipment  is 
available) 
- monitoring and maintaining the cold chain of cooked products by the organization1). 

The contractor must keep records of the redistribution of food. 
The contracting authority may set rules for penalties for non-compliance. 
The contacting authority is invited to see EU guidelines relevant for food donation (https://eur-
lex.europa.eu/legal-content/GA/TXT/?uri=CELEX:52017XC1025(01)) as well as EFSA opinion on 
hazards related to food donation (new food safety management approach 

1) The procurer may fix the temperature that has to be maintained to ensure the cold chain for cooked products according to local specificities. 

Rationale  
The  clause  on  food  redistribution  was  also  welcomed  by  the  stakeholders.  Food  redistribution  is    a  process 
whereby  surplus  food  that  might  be  otherwise  be  wasted  is  recovered,  collected  and  provided  to  people,  in 
particular to those in need. Food donation encompasses the recovery and redistribution of food by food business 
operators  which  are  provided,  the  holder,  free  of  charge.  EU  guidelines  on  food  donation  are  available  at: 
https://ec.europa.eu/food/sites/food/files/safety/docs/fw_eu-actions_food-donation_eu-guidelines_en.pdf. The main 
goal  of  a  catering  service  must  be  to  use  resources  as  efficient  as  possible  and  therefore  to  generate  low 
amounts of surplus food and prevent food waste. 

The identified barriers for implementing the criterion on food redistribution were:  

1. Legislative requirements: there are two main barriers the VAT on the products to be donated and the liability 
on the donor with regard safety issues. 

In  order  to  overcome  these  barriers,  in  May  2017  the  EU  Parliament's  environmental  committee  adopted  a 
resolution the initiative on resource efficiency: reducing food waste and improving food safety12. This resolution 
is  called  to  propose  a  change  to  the  VAT  Directive  that  would  "explicitly  authorise  tax  exemptions  on  food 
donations". It urges among other measures national governments to "set a VAT rate that is close to zero if a food 
donation is made close to the recommended expiry date or if the food is unsellable".  

Some  countries  such  as  Italy  and  France  have  recently  modified  their  legislation.  In  Italy  in  2016  a  new 
regulation came into force aiming to drastically reduce the amount of food wasted in the country easing  for 
farms and supermarkets the donation of unsold food. Thanks to this law, today in Italy it is possible that:  

- 

catering companies can propose the food donation to their new customers, as an added value to their 
services 

-  public calls for tenders can request food donation e.g. catering services in hospitals, schools, etc. 

In  France  all  supermarkets  are  obliged  since  2016  to  donate  the  food  before  entering  in  the  waste  stream. 
Conditions are specified for the food banks and charities with regard hygiene and distribution. Many initiatives 
have emerged since then to connect food donors and charities, such as web platforms. 

12 http://www.europarl.europa.eu/oeil/popups/summary.do?id=1490347&t=e&l=en 

80 

 
 
 
                                                           
  
 
The procedures for the recovery of chilled and cooked food products are established with the donors, thanks to 
the competence and expertise of the voluntary organizations (e.g. Siticibo in Italy). However, these procedures 
have been perceived as a possible technical barrier by some stakeholders. 

In addition to ensure that legal clarity the European Commission will publish by the end of 2017 EU guidelines 
on food donation. The guidelines aim to clarify relevant provisions in EU legislation and help to lift barriers to 
food redistribution within the current EU regulatory framework. More specifically, these guidelines will seek to 
facilitate compliance of providers and recipients of surplus food with relevant requirements laid down in the EU 
regulatory  framework  (e.g.  food  safety,  food  hygiene,  traceability,  liability,  VAT,  etc…)  and  promote  common 
interpretation  by  regulatory  authorities  in  the  EU  Member States  of  EU  rules  applying  to  the  redistribution  of 
surplus food. 

2. Lack of proper kitchen equipment: Chilled and cooked food products must be monitored to maintain the cold 
chain,  cooked  products  are  maintained  at  a  constant  temperature  of  4C  (blast  chiller)  thanks  to  refrigerated 
vans or thermo box that the volunteers have. For this, the tenderer must prepare the food under the collecting 
conditions.  

This clause aims at encouraging the food donation whenever and wherever possible, i.e. those locations where it is 
under national regulation possible without excessive additional cost burden and of sufficient quantity to be of 
interest of the redistribution organizations or other organizations. 

Further information can be found in Annex 3.2. 

81 

 
 
4  Draft EU GPP Criteria proposal for Vending machines 
Table 5 indicates the criteria included in the Vending machines criteria set 

Table  5.  Criteria  set  for  Vending  machines  Award  Criteria  (AC)  and  Technical  Specification  (TS). 
Thresholds in TS are included as minimum values (i.e. at least x%) and thresholds in AC are included 
as the starting point to get points awarded (i.e. points awarded from x%). 

Criteria 

Organic food 
products 

Type of 
criteria 
TS 1   

 AC 1 

Fair and ethical trade 
products 

AC 2 

More 
Environmentally 
responsible 
vegetable fats 
Smart controls 

Annual energy 
consumption 
GWP of refrigerants 

Reusable cups 

Purchase of new 
vending machines 

TS 2 

TS 3 

AC 3 

AC 4 

TS 4 

CPC1 

Level of ambition 
Core 
Option A 
List of items  
Option B  
20-50% of the items to be supplied  
Option A 
List of items  
Option B  
>20-50% of the items to be supplied  
Option A 
List of items  
Option B 
10-30% of the coffee, tea, chocolate 
(cocoa), sugar and bananas items  
List of products 
10-30% of the items of pre-packed food 
products  

Comprehensive 
Option A 
List of items  
Option B  
>50% of the items to be supplied  
Option A 
List of items  
Option B  
>50% of the items to be supplied  
Option A 
List of items  
Option B 
30-70%  of the coffee, tea, chocolate 
(cocoa), sugar and bananas items   
List of products 
30-50%  of  the  items  of  pre-packed 
food products  

Vending machines equipped with integrated smart controls, which are programmed 
to work during the operating hours of the place where they are located and put the 
cabinet  into  sleep-mode  or  the  minimum  energy  consumption  mode  for  the  food 
and drink products in the off-hours.  
Vending machine/s with lower annual energy consumption of the machines. 

Refrigerated  vending  machines  using 
refrigerant gases with a GWP < 150. 

Drink machines dispensing hot and/or cold drinks  that enable the use of reusable 
cups instead of disposable cups.  
Commitment  to  purchase  equipment  complying  with  the  requirements  set  by  the 
TS3 on Energy Consumption. 

Vending machines are a ubiquitous part of our food environments.  Vending machines are found in many public 
settings including, but no limited to worksites, schools, health care facilities, municipal buildings and other public 
spaces such as sport centres, cultural centres or libraries. In Europe there are approximately 3.8 million of vending 
machines, 2.36 million of those dispense hot drinks, either as table-top or freestanding coffee machines and are 
mainly located in the workplaces (80%).  

Every day, over 90 million food and drink items are dispensed from European vending machines and the 6 biggest 
markets are Italy, France, UK, Germany, Spain and the Netherlands, which in total make up around 75% of the 
total European market.  

The consumer behaviour was studied in Europe in 2015 and covered 10 Member states (AT, FR, DE, IT, NE, PL, RO, 
RU, SP, SE and UK). The study revealed the drivers for and barriers against using chilled vending machines, which 
results being clear that consumers would like to see more diverse products in glass fronted  vending machines, 
which could help them, make a better choice. Indeed, 30% of respondents said that they wanted to see more low 

82 

 
 
 
 
 
 
 
calorie food and snacks (31% of the respondents), fruit and vegetables (29%), salads (20%) and organic products 
(16%) and 22% of the respondents said a barrier to why they don’t use vending machines is that options tend to 
be unhealthy (EVA 2017) 

The purpose of this review is not to describe vending products to be offered but to list those criteria ensure that 
the vending machines/services perform environmentally friendlier, therefore in this section we don’t mention any 
health  proposal  related  to  the  vending  products.  If  the  contracting  authorities  are  interested  in  this  aspect, the 
literature presents several studies on how to promote healthier vending purchases by consumers, which measures 
are the most effective ones and which effects can have on the sales and revenues.  

This paragraph is a brief literature review limited to some studies conducted mainly in United States and Australia 
within  the  past  two  decades.  Measures  such  as  price  changes  increase  in  healthier  items,  changes  to  the 
advertisements  wrapped  around  vending  machines  and  promotional  signs  such  as  stoplight  system  to  indicate 
healthfulness of items and to remind consumers to make healthy choices were part of the studies.  Most of them 
concluded  that  applying  these  measures  to  the  vending  machines  resulted  in  statistically  significant  positive 
changes  in  purchasing behaviour  and  that  although  there was  no  intervention  pattern  that  ensured  changes  in 
purchasing,  price  reductions  were  the  most  effective  overall.  Revenue  from  vending  sales  did  not  change 
substantially  regardless  of  measures  applied,  which  will  be  important  to  foster  initiation  and  sustainability  of 
healthier vending. Contracting authorities should identify price changes that would balance healthier choices and 
revenue as well as better marketing to promote purchase of healthier items.  

83 

 
 
 
 
 
 
4.2 

Technical Specifications (TS) and Award Criteria (AC) 

  Organic food products  

Core criteria 
Technical Specification 
TS1. Organic food products 
Option A 
The following food and drink items to be supplied in the vending machine must comply with the organic products 
standards [list of food and drink items to be inserted by the contracting authority, see also explanatory notes] 

Comprehensive criteria 

Verification: 
The tenderer must provide a declaration that all food and drink items listed above, to be supplied in the execution 
of the contract will comply with Regulation (EC) No 2018/848 or its subsequent amendments13. In addition, the 
tenderer must provide a description of how it intends to ensure that the products mentioned above can be sourced 
during contract execution from organic sources (e.g. by identifying suppliers for the different products). 

Option B (more complex to verify during contract execution) 
At least X%1) of the food and/or drink items to be supplied in the vending machine must comply with the organic 
products standards. 

Verification:  
The tenderer must provide data (name and amount) of the food and/or drink items to be supplied in the vending 
machine in the execution of the contract, indicating specifically the products that comply with Regulation (EC) No 
834/2007. 

Comprehensive criteria 

Core criteria 
Award Criteria 
AC1. Additional organic food products 
Option A 
Points  are to be proportionally awarded to tenders that exceed the list of food and drink items to be supplied in 
the vending machine [listed in TS1 option B]  and that comply with the organic products standards 
Verification: 
See above TS1 option A 

Option B 
Points are to be proportionally awarded to tenders in which more than the required X%1) of the food and/or drink 
items  to  be  supplied  in  the  vending  machine  have  been  produced  in  accordance  with  Regulation  (EC)  No 
2018/84814. 
Verification:  
See TS1 option B 

13 According to Article 61 of Regulation (EC) No 2018/848, this regulation shall apply from 1 January 2021. 
According to Article 60, products produced in accordance with Regulation (EC) No 834/2007 before 1 January 
2021 may be placed on the market after that date until stocks are exhausted. 
14 According to Article 61 of Regulation (EC) No 2018/848, this regulation shall apply from 1 January 2021. 
According to Article 60, products produced in accordance with Regulation (EC) No 834/2007 before 1 January 
2021 may be placed on the market after that date until stocks are exhausted. 

84 

 
 
 
 
 
 
 
 
 
 
 
                                                           
Comprehensive criteria 

Explanatory notes 
Core criteria 
Technical Specification and Award Criteria 
Organic food products  
The contracting authority will have to specify how the percentage of purchase will be calculated, either in volume, 
weight or value  
Option A 
List of items: unpackaged fresh fruit (e.g. bananas, oranges), packaged fruits, cookies and bakery products, milk 
and dairy products,  
Option B 
Recommended values for core criteria:  
Up to 20% of the food and/or drink items to be supplied in the vending machines  
Recommended values for comprehensive criteria:  
>20% of the food and/or drink items to be supplied in the vending machines  

1) X is the threshold to be defined by the procurer for the comprehensive and core levels (TS and AC). Recommendations for its value are given in explanatory 
notes above. 

Rationale for the proposed criteria wording and verification 
See section 2.12 for the rationale of the criterion on Organic food products in the Food procurement criteria set.  

85 

 
 
 
 
Fair and ethical trade products  

Core criteria 
Award Criteria 
AC2. Fair and ethical trade products 

Comprehensive criteria 

Option A 
Points are to be awarded proportionally to tenders in which  the following food and drink items  [list of food and 
drink  products   to  be  inserted by  the  contracting authority,  see  also explanatory  notes] have been produced and 
traded in accordance with the requirements of a fair and ethical trade certification scheme and that requires a 
minimum  certified  content  of  90%.  This  is  a  scheme  that  is  based  on  multi-stakeholder  organizations  with  a 
broad  membership.  The  scheme  addresses  international  fair  trade  standards  including  working  conditions  for 
production in accordance with ILO core conventions2), sustainable trade and pricing3).  

Verification:  
The tenderer must provide   the list of items that are to be supplied in the vending machines in the execution of 
the contract that comply with the criterion. 

Option B 
Points  are  to  be  awarded  proportionally  to  tenders  in  which  more  than X%1) of  the  total  items  of  each  of  the 
following products:[list of food and drink products   to be inserted by the contracting authority, see also explanatory 
notes]    have  been  produced  and  traded  in  accordance  with  the  requirements  of    fair  and  ethical  trade  
certification scheme that requires a minimum certified content of 90%.  This is a scheme  that is based on multi-
stakeholder organizations with a broad membership. The scheme addresses international fair and ethical trade 
standards including working conditions for production in accordance with ILO core conventions2), sustainable trade 
and pricing3).  

Verification:  
The  tenderer  must  provide    data  (name  and  amount)  of  all  products  that  are  to  be  supplied  in  the  vending 
machines in the execution of the contract, indicating specifically the products compliant with the criterion. 

Explanatory notes 
Core criteria 
Award Criteria 
The contracting authority will have to specify how the percentage will be calculated, either in volume, weight or 
value spent.  

Comprehensive criteria 

Option A 
List  of  items  that  can  include:  bananas,  coffee,  tea,  chocolate  (cocoa),  sugar,  bananas,  packaged  fruits,  exotic 
fruit juice, etc. 
Option B 
The list of products can include: coffee, tea, chocolate (cocoa), sugar, bananas, packaged fruits, exotic fruit juice, 
etc. 
Recommended values for (X) core criteria:  
X=10-30% of total purchases of each product: coffee, tea, chocolate (cocoa), sugar and bananas. 
Recommended values for (X) comprehensive criteria:  
X=30-70% of total purchases of each product: coffee, tea, chocolate (cocoa), sugar and bananas.  

1) X is the thresholds to be defined by the procurer for the comprehensive and core levels (AC).  Recommendations for its value are given in explanatory 
notes below. 
2)  The ILO Core 8 convention requirements are explicitly written into organizational documents: #29-Forced Labour (1930), #87-Freedom of Association and 
Protection  of  the  Right  to  Organize  (1948),  #98-Right  to  Organize  and  Collective  Bargaining  (1949),  #105-Abolition  of  Forced  Labour  (1959),  #138- 
Minimum Age (1973), #182-Worst Forms of Child Labour (1999), #100-Equal Remuneration (1951), and #111-Discrimination (1958). 
3)  Schemes  such  as  Fairtrade®,  UTZ,  Bonsucro,  etc.  can  show  compliance  with  the  criterion  provided  they  cover  the  environmental  principles  mentioned 
above. Other schemes at country level can be considered as equivalent as far as they comply with the environmental principles mentioned above. 

86 

 
 
 
 
 
 
 
 
 
Rationale for the proposed criteria wording and verification  
See  section  2.1.7  for  the  rationale  of  the  criterion  on  Fair  and  ethical  trade  products  in the  Food  procurement 
criteria set. 

87 

 
 
 
  More environmentally responsible vegetable fats 

Core criteria 
Technical specification 
TS2. More environmentally responsible vegetable fats 

Comprehensive criteria 

TS 2.1. If pre-packed food and/or drink products containing vegetable oil or their derivatives are purchased, at least 
X%1 of the units/items of pre-packed food products containing vegetable oils must have been produced from crops 
complying  with environmental  criteria  regarding  soil,  biodiversity,  land-use change  and  organic  carbon  stocks  by 
meeting  the  requirements  of  a  certification  scheme15 covering  these  issues,  of  Article  93  of  Regulation  (EU)  No 
1306/2013, or by other equivalent means. 

Verification:  
TS 2.1. The tenderer must provide a declaration that at least X% of all food products containing vegetable oils (as 
units/items of pre-packed food products) that it supplies are compliant with the requirement mentioned above. The 
tenderer must include a description of the measures that will be taken to ensure compliance (e.g. sources of supply 
that could be used). 

Explanatory notes 
Core criteria 
Technical specification 
TS2. More environmentally responsible vegetable fats 
The contracting authority will have to specify how the percentage will be  calculated, either in volume, weight or 
value 
Contracting authorities will list which vegetable oils are relevant for the specific tender and have to satisfy this 
technical specification 

Comprehensive criteria 

Recommended values for the core criteria:  
X=10-30% of the units/items of pre-packed food products 
Recommended values for the comprehensive criteria:  
X=30-50% of the units/items of pre-packed food products 

1) X is the thresholds to be defined by the procurer for the core and comprehensive levels (AC). Recommendations for its value are given in explanatory notes 
below 

Rationale for the proposed criteria wording and verification  
See section 2.1.9 for the rationale of the criterion on more environmentally responsible vegetable fats in the Food 
procurement criteria set.  

15 Schemes based on organisations with a broad multi-stakeholder membership, including NGOs, industry and 
government such as Roundtable on Sustainable Palm Oil - RSPO, Palm Oil Innovation Group - POIG, 
Roundtable on Responsible Soy -– RTRS, The Soybean Sustainability Assurance Protocol - SSAP or Pro-Terra 
can show compliance with the criterion provided they cover the environmental principles mentioned. Other 
schemes, including at country level, are to be considered as equivalent, if they comply with the environmental 
principles mentioned. 

88 

 
 
 
 
 
 
 
 
 
                                                           
Energy consumption and GWP of refrigerants 

Core Criteria 

Comprehensive Criteria 

Technical specification 
TS3. Smart controls  
This criterion covers the following types of vending machines  provided they do not contain perishable food:: 
1)  Refrigerated closed fronted can and bottle machines where the products are held in stacks  
2)  Refrigerated glass fronted can and bottle, confectionery and snack machines  
3)  Refrigerated multi-temperature glass fronted machines  
4) 

 Drink machines dispensing cold drinks 

Perishable  food  is  defined  as  food  and  beverages  subject  to  degradation,  decay  or  destruction,  which  relies  on 
refrigerated storage in order to reduce the rate of decay and loss of quality (Codex Alimentarius).  

The  tenderer  must  provide  vending  machines  equipped  with  integrated  smart  controls,  also  called  energy 
management  systems  or  devices.  These  machines  are  programmed  to  work  during  the  operating  hours  of  the 
place where they are located, and the cabinet is put into sleep-mode or the minimum energy consumption mode 
for the food and drink products in the off-hours. 

Verification 
The  tenderer  must  provide  the  technical  sheet  of  the  vending  machine  to  be  used  for  the  service  where  the 
compliance with this requirement is stated. 

Core Criteria 

Award criteria 

Comprehensive Criteria 

AC3. Annual energy consumption  
This criterion covers the following types of vending machines: 

1)  Refrigerated closed fronted can and bottle machines where the products are held in stacks  
2)  Refrigerated glass fronted can and bottle, confectionery and snack machines  
3)  Refrigerated glass fronted machines entirely for perishable foodstuffs  
4)  Refrigerated multi-temperature glass fronted machines  
5)  Drink machines dispensing hot and/or cold drinks; 

The call for tenders will specify the type of vending machine to be supplied and its volume. This award criterion must 
only be used to compare vending machines of the same type and volume. 

Points will be awarded to tenders of vending machine/s in a proportionally inversed manner to the annual energy 
consumption of the machines. 

Verification:  
The tenderer must provide a list of the vending machines that will be used in the execution of the contract. The 
tenderer must also provide the technical sheets of these vending machines together with the copies of the test 
reports  of  the  machines  according  to  the  EN  50597,  for  vending  machines  from  1  to  4,  and  according  to  the 
Energy  Measurement  Protocol  Part  B  developed  by  the  European  Vending  Association,  for  drink  machines 
dispensing hot and/or cold drinks. 

89 

 
 
 
 
 
 
 
 
 
 
AC4. GWP of refrigerants 
This criterion covers the following vending machines: 

1)  Refrigerated  closed  fronted  can  and  bottle 
machines where the products are held in stacks  

2)  Refrigerated  glass 

fronted  can  and  bottle, 

confectionery and snack machines  

3)  Refrigerated  glass  fronted  machines  entirely  for 

perishable foodstuffs  

4)  Refrigerated  multi-temperature  glass  fronted 

machines  

The  call  for  tenders  will  specify  the  type  of  vending 
machine  to  be  purchased.  This  award  criterion  must  only  
be used to compare vending machines of the same type. 

Points  will  be  awarded  to  tenders  proportionally  to  the 
number  of 
refrigerated  vending  machines  using 
refrigerant gases with a GWP lower than 150. 

Verification:  
The tenderer must provide a list of the vending machines 
that  will  be  used  in  the  execution  of  the  contract, 
indicating  specifically  which  machines  comply  with  this 
criterion.  
The  tenderer  must  supply  copies  of  the  technical  sheets 
where the GWP of the refrigerant is stated. 

Rationale for the proposed criteria wording 

The  energy  consumption  of  the  vending  machines  has  been  recognized  as  an  important  environmental  aspect. 
Proof of this is the development of regulations such as Ecodesign and Energy label at EU level. In addition and 
according to EVA market statistics) there are over 10 000 companies across Europe,  providing circa 3.8 million 
vending machines. The inclusion of this criterion is also important since the majority of vending services suppliers 
does not manufacture their own vending machines, being a lack of stimulus to improve their energy consumption. 

According  to  the  Preparatory  study  for  the  Ecodesign  of  Commercial  Refrigeration  (JRC,  2014b),  smart 
sensors/energy management devices are currently available. They can reduce the energy consumption by allowing 
the temperature inside the cooler to rise (between 7°C to 14°C) during periods when the machine is rarely used, 
and  by  maintaining  the  working  temperature  (between  0°C  and  7°C)  during  the  active  hours.  It  is  therefore 
proposed to require  smart sensors/energy management devices as technical specification for vending machines 
that do not contain perishable food. Perishable food is defined as food subject to decay or destruction, that has 
been,  for  example,  minimally processed  or  not  otherwise  preserved  and  which  relies  on  refrigerated  storage  in 
order to reduce the rate of decay and loss of quality (Codex Alimentarius).. 

Vending  machines  have  different  energy  consumption  depending  on  the  type  and  volume.  Refrigerated  closed 
fronted  machines  generally  consume  less  energy  than  refrigerated  glass  fronted,  but  their  functions  are  also 
different. For this reason, the award criterion proposal includes a provision setting that only vending machines of 
the same type and volume can be compared.  

For the time being, there is no EU Regulation on these machines, being difficult to set up a maximum threshold of 
energy consumption. The contract authority must award the points by comparing the energy consumption of the 
vending machines provided that they are of the same type and volume. 

Another policy ruling the refrigeration appliances in Europe is the so called F-Gas which aims at the phase out of 
HFC refrigerants with high GWP. Particularly for commercial refrigeration; it sets the deadlines to ban high and 
medium GWP refrigerants In line with this phase-out timeline, it is proposed an award criterion to promote the use 

90 

 
 
 
 
 
 
of refrigerants with GWP below 150 in vending machines, which can be achieved by means of unsaturated HFCs 
(HFOs),. Contrary to fridges and freezers, in vending machines the use of hydrocarbons raises some safety issues 
due  to  the  sources  of  ignition  coming  from  the  moving  parts.  Carbon  dioxide  is  being  used  in  closed  fronted 
machines, but it is not so spread in glass fronted machines. With regards of unsaturated HFCs (HFOs), the industry 
is concerned about their cost and availability. For these reasons, the award criterion on low GWP refrigerants is 
proposed to be set at comprehensive level. 

Rationale for the proposed verification 

Ecodesign  and  Energy  Labelling  regulations  have  not  reached  a  common  position  on  energy  consumption 
thresholds  and  energy  classes  yet.  However,  the  standard  developed  for  the  measurement  of  the  energy 
consumption  of  vending  machines  (EN  50597),  is  almost  finalised,  and  its  publication  is  expected  by  2017. 
Therefore, this standard is proposed for verification purposes. . 

There is not an EN standard to measure the energy consumption of  drink machines dispensing hot and/or cold 
drinks, but it is part of the Energy Measurement Protocol developed by the European Vending Association. This 
protocol is proposed to be used for verification 

The tests are not requested to be carried out by an accredited or independent laboratory, to be aligned with the 
Ecodesign  and  Energy  Labelling  regulations  which  allow  the  manufacturers  to  declare  the  performance  of  the 
appliance based on in-house testing. 

For  refrigeration  gases,  the  technical  sheets  indicating  the  GWP  of  the  refrigerants  would  act  as  proof  of 
compliance. 

91 

 
 
 
  Reusable cups 

Core Criteria 

Comprehensive Criteria 

Technical specification 
TS4. Reusable cups 
Note: This criterion covers drink machines dispensing hot and/or cold drinks. This requirement only applies when it is 
appropriate  on  grounds of  food  hygiene,  consumer  safety  and  public  health,  under  those  conditions  the  tenderers 
must be excluded of liability if the provided beverage is contaminated by the reused cup.  

The tenderer must provide drink machines dispensing non-prepacked hot and/or cold drinks that enable the use of 
reusable cups (e.g. porcelain cups, glass cups) instead of disposable cups. If disposable cups are not avoidable  on 
grounds of food hygiene, consumer safety and public health (see note above), they must be recyclable, made of 
either recyclable plastic or compostable material 

Verification 
The tenderer must provide the technical sheet of the vending machine to be used to provide the service where 
compliance with this requirement is stated. 

Rationale for the proposed criteria wording 
The  use  of  disposable  cups  in  drink  machines  dispensing  non-prepacked  hot  and/or  cold  drinks  entails  the 
generation  of  plastic  and  paper  waste,  which  can  be  minimise  replacing  them  by  reusable  cups.  There  are 
machines available in the market equipped with a device that enables the user to choose between disposable or 
reusable cups. It is therefore proposed to set a technical specification to require drink machines dispensing hot 
and/or cold drinks to enable the use of reusable cups instead of disposable. 

Rationale for the proposed verification 
The technical sheet of the machine where this device is described would suffice to verify this criterion. 

92 

 
 
 
 
 
 
 
 
4.3  CPC: Purchase of new vending machines 

Comprehensive criteria 

Core criteria 
Contract Performance Clause 
CPC1. Purchase of new vending machines 
In case new vending machines have to be purchased partially or wholly to provide the contracted service by the 
contractor, the contractor must purchase equipment complying with the requirements set by the technical 
specification TS3. 
The tender must report the purchase of new vending machines to the contractor authority 
The contracting authority may set rules for penalties for non-compliance. 

Rationale for the proposed criteria wording 

In line with the contract performance clause AC 3 of the catering services criteria, this criterion aims at ensuring 
that the new equipment to be purchase will comply with the strictest regulation at that time.  

93 

 
 
 
 
 
 
5 

Life cycle cost considerations 

5.2 

Introduction to the Life cycle cost 

Life cycle cost (LCC) is a method for assessing the total costs of the product group or service under study. It takes 
into  account  all  cost  of  purchasing,  preparation  and  cooking,  serving  and  disposing  the  generated  waste.  The 
purpose of the LCC is to estimate the overall costs of project alternatives and to select the option that ensures the 
purchase or the service or both that will provide the lowest overall costs consistent with its quality and function. 
The LCC should be performed early in the purchase process.  

The LCC use in GPP procedures can determine the lowest costs in evaluating offers. By using LCC in GPP, in fact, 
the authorities are able to consider not only the acquisition costs of a product or service (e.g. they include the raw 
materials and the manufacturing costs), but also other costs that usually have to be identified and calculated by 
the purchaser (e.g. maintenance costs, running costs, disposal recycling costs, etc.). These kinds of costs should be 
added to the selling price to have a comprehensive estimation of the LCC of the product or service.  

In  addition, the LCC  can  consider  the  environmental externalities  of  a  product  or  a  service  during its  life  cycle, 
when it is possible to determine a monetary value.  

The Directive 2014/24/EU on Public procurement identifies the costs to be considered in an economic analysis of 
the purchase to be performed. Some of these costs are:  

"- costs, borne by the contracting authority or other users, such as: 

i. costs relating to the acquisition 
ii. costs of use, such as consumption of energy and other resources, 
iii. maintenance costs 
iv. end of life costs, such as collection and recycling costs 

- costs imputed to environmental externalities linked to the product, service or works during its life cycle 
provided their monetary value can be determined and verified; such costs may include the cost of emission 
of GHGs and of other pollutant emissions and other climate change mitigation costs" 

The directive indicates that both direct costs and indirect costs must be included in LCC calculation, however, this 
can  raise  some  methodological  problems  since  direct  costs  can  be  calculated  by  applying  LCC  from  user 
perspectives, whereas externalities effect he entire humanity and can be assessed only if LCC is applied from the 
society perspective. These costs are e.g. all the costs induced by the consumption of the product related to the 
ecosystem conservation, to human health, to social aspects and so on.  

Although  the  directive  provides  the  definition  of  the  LCC  and  the  list  of  cost  items  to  be  included,  it  does  not 
provide a clear explanation on how to do it (no methods are mentioned). Several methods have been developed to 
account for the internal and external costs, but all of them account for methodological problems, uncertainties 
and heterogeneities of the monetisation factors used, connected with the application of LCC being identified as 
the main barriers to tis application by the public authorities 

In this section, firstly a base case is presented. The aim of this example is to present a possible breakdown of the 
costs that catering services could face out and to weight the additional costs or benefits that the proposed EU 
GPP criteria can bring. The main conclusion section summaries all the economic benefits and drawbacks triggered 
by the EU GPP criterion whenever possible.  

5.3  GPP of FOOD and CATERING SERVICES 

Food and catering services are procured by a range of public sector bodies. There is a large range of types of food 
procured as well as a large range of catering services contracted. However, in most of the food purchases, and 
from the purchase perspective, the costs usually fall into the following categories:  

-  purchase cost or cost of the raw materials:  it is the purchase of items that went into inventory regardless 

of whether they are sold during the year or not. 

-  delivery cost is the amount of money it takes for a company to manufacture and deliver a product.  
- 

inventory and storage cost: Inventory costs are the costs related to storing and maintaining its inventory 
over a certain period of time. Typically, inventory costs are described as a percentage of the inventory 

94 

 
value on an annualized basis. They vary strongly depending on the business field, but they are always 
quite high. It is commonly accepted that the carrying costs alone represent generally 25% of inventory 
value on hand. 

-  end-of-life costs are the attributed costs of handling with the waste generated.  

The  catering  services  are  even  more  spread.  This  means  that  there  are  more  categories  in  which  the  catering 
services costs may fall into. Some examples are;  

-  purchase costs of raw materials (food purchase) and other purchases (eg consumable goods, chemicals, 

other products): see above 
Inventory and storage costs: see above 

- 
-  Labour cost is the total expenditure borne by employers in order to employ workers. The cost of labor is 
the sum of all wages paid to employees, as well as the cost of employee benefits and payroll taxes paid 
by  an  employer.  The  cost  of  labour  is  broken  into  direct  (wages  for  the  employees  that  produce  a 
product) and indirect costs (overheads or wages of staff associated with support labor).  

-  Utilities cost is the cost of usage of utilities such as lighting, water, and heat.  
-  Maintenance and insurance costs. the insurance costs is optional and could be defined as the specified 
amount of payment required periodically by an insurer to provide coverage under a given insurance plan 
for  a  defined  period  of  time.  The  premium  compensates  the  insurer  for  bearing  the  risk of  a  pay-out 
should an event occur that triggers coverage.  

-  Taxes: A fee charged ("levied") by a government on a product, income, or activity. If tax is levied directly 
on personal or corporate income, then it is a direct tax. If tax is levied on the price of a good or service, 
then it is called an indirect tax.  

-  Financial cost is the cost and interest and other charges involved in the borrowing of money to build or 

purchase assets. This cost is optional and depends on the financial structure of the company 

-  End of life costs are the attributed costs of handling with the waste generated. 

5.4 

Findings from an LCC analysis of case-studies 

Studies  on  life  cycle  cost  assessments  carried  out  for  food  procurement  and  especially  for  catering  services 
demonstrated that it is important not to consider the purchase costs in isolation, but instead the LCC including the 
operation, maintenance and even financial charges that can be involved in providing the service. In this way, the 
LCC  approach  allows  public  bodies  to  explore  the  costs  and  benefits  of  different  catering  services  not  just 
according to their investment costs but also their operational cost. 

The following example shows some of the costs that a catering service, such as a restaurant, can face during its 
duration. The calculations below show that food purchase and labour costs are the most important ones.  

Table 6. Breakdown of the costs per serving of a catering service (example) 
Costs 
Direct 

3.66 euro 

33.2 % 

Value 

Indirect 

7.36 euro 

66.8 % 

Served raw material 
Security margin 
Labour 
Utilities 
Amortizations 
Purchases 
Marketing  
Insurance 
Taxes 
Financial costs 

3.18 euro 
0.48 euro 
6.39 euro 
0.12 euro 
0.60 euro 
0.13 euro 
0.03 euro 
0.04 euro 
0.04 euro 
0.02 euro 

Percentage 
28.9 % 
4.3 % 
58.0 % 
1.1 % 
5.5 % 
1.2 % 
0.3 % 
0.4 % 
0.3 % 
0.2 % 

Total 

11.02 euro 

100 % 

Another stakeholder sent a breakdown of the costs per serving of a catering service in a school in Madrid (Spain). 
The average total cost of the menu without organic products reaches 4.88euros.  

95 

 
 
 
Table 7. Breakdown of the costs per serving of a catering service (example) 

Costs 
Labour cost of the kitchen staff 
Labour  cost  of  the  monitors  and  children 
carers 
Served raw material and security margin 
Utilities and insurances 
Logistics 
Amortizations 
Profits 
Utilities (energy) 
Purchases of tableware and kitchenware 
TOTAL 

% of the total 
31,39% 
28,24% 

26,53% 
4,44% 
2,13% 
1,70% 
1,77% 
1,90% 
1,90% 
100,00% 

The breakdown of this example is in line with the information published by PwC 2009 about the breakdown of the 
costs in the catering services of 7 Member States, as shown in Table 8 

Table 8. Cost structure for catering services in 7 Member stares 

LCC relevant costs (%) 
Labour cots 
Food procurement costs 
Other costs 
Management fees 

AT  DK 
43 
48 
6 
4 

39  44 
50  47 
6 
6 
4 
4 

FI  DE  NE 
50 
43 
40 
47 
6 
6 
4 
4 

SE  UK  Average 
44.1 % 
44 
46.1 % 
47 
5.9 % 
6 
4 % 
4 

47 
44 
5 
4 

The breakdown of the costs provided in Table 6 can be modified if some of the criteria considered and presented 
in this revision are taken into board.  

Food procurement 

The  breakdown  of  the  costs  showed  in  Table  6,  Table  7  or  Table  8  would  remain  unchanged  for  most  of  the 
categories  when  comparing  the  LCC  associated  with  food  products  complying  with  the  EU  Food  procurement 
criteria and the conventional food products. Only the cost of procuring the food in  Table 6 and Table 7 (or the 
served raw material cost in Table 8) can be subject of change. 

Organic food products 

The literature reports that the differences in cost of organic and conventional products are large and that they 
depend  on  multiple  factors  such  as  the  type  of  product,  the  location,  the  season,  etc.  Certified  organic  food 
products are in general more expensive than their conventional counterparts. Some of the reasons stated are that 
the organic food supply is limited as compared to demand, that the production costs are typically higher because 
of  greater  labour  inputs  per  unit  of  output  and  because  greater  diversity  of  enterprises  means  economies  of 
scales  cannot  be  achieved,  that  post-harvest  handling  of  relatively  small  quantities  of  organic  food  results  in 
higher costs because of the mandatory segregation of organic and conventional produce, especially for processing 
and transportation and that the marketing and the distribution chain of organic products is relatively inefficient 
due to the smaller volumes.  

The increase in the prices of organic foods claims that it does not only include the costs of production itself, but 
also  a  range  of  other  factors  that  are  not  captured in  the prices  of  conventional  food.  In  this  sense,  it  can  be 
understood as a way to already account for possible externalities of the food production. Some of these issues 
are the environmental aspects related to the biodiversity and land use (as the organic production needs rotational 
periods which are necessary to build soil fertility), higher standards for animal welfare, avoidance of health risks 
to  farmers  due  to  inappropriate  handling  of  pesticides,  rural  development  by  generating  additional  farm 
employment, etc. 

Some studies quantify the cost difference in purchasing organic food products vs non-organic food products. The 
difference found by PwC 2009 for the 7 Member states are shown in Table 9  

96 

 
 
 
LCC relevant costs (%) 
Increase  in  procurement  costs  if  organic  food  products  are 
bought 

Table 9. Cost structure for catering services in 7 Member stares 
UK 
DE 
1.03  1.02  0.11  3.80  1.13  0.41  2.55 

DK 

NE 

AT 

SE 

FI 

This shows that the impact in the overall LCC of the catering services varies from a very modest 0.11% increase 
in Finland to a more significant 3.80% increase in Germany. Other studies report differences in prices per kg of 
food purchase of different product groups, as showed in Table 10 

Table 10. Wholesale increase in price of organic products in comparison to conventional products of 
different products in different member states. 
CR 
FI 
40 
166 
151 
80 
46 
113 
-- 
15 

% increase of euro/kg 
Coffee 
Tomatoes 
Potatoes 
Chicken 

ES 
66 
54.4 
254 
230 

DE 
60 
80 
113 
139 

122 

UK 

A case study details the cost impacts of applying GPP criterion for 20% organic food products in school catering 
services in Lens, France. Organic menus proposed by the winning bidder were priced at 1.5 euro/meal, 8% higher 
than the 1.40 euro/meal for the equivalent non-organic option.  

Finally,  stakeholders  communicated  that  there  are  additional  costs  due  to  the  preparation  of  organic  meals 
separately from conventional dishes. This cost increase depends on the infrastructure and the space available in 
the  kitchen.  If  it  is  a  modern kitchen  with enough  space  to  stare  products in  the  fridge or  else  separately  and 
enough for handling, the extra labour costs are only depending on the menu type or complexity. If the kitchen is 
small, or with old or no modern cooking infrastructure and not enough space for preparing in advance, it is needed 
more extra cleaning time not to have a cross contamination risk.  

In the case of complex methods or manipulations, it can be an extra of half an hour to 2 hours/day for one person 
(also depending on the quantities to be prepared).  

Marine and aquaculture food products 

Economists expect a continuing strong growth in fisheries that will result both in higher supply and higher prices. 
World per capita consumption (round weight) is expected to increase 8% over the next decade, from 19 kg to 20.6 
kg / person. Most of this growth will be supplied by aquaculture (by 2022 aquaculture is expected to increase by 
35%)  (undercurrentnews,  2013)  surpassing  capture  fisheries  and  becoming  the  main  source  for  human 
consumption by 2015.  

In the latter half of the next decade, increases in fish and seafood prices are expected and consequently a slower 
growth rate of in seafood consumption. Fish product prices are projected to rise strongly over the coming decade 
as a result of strong demand, rising production costs and slowing production growth.  

Today, and according to the study (Agrifoods 2014), the cost of certified frozen cod fillets are in average 12% 
more expensive that the non-certified products, i.e. 4.20 euros vs 3.75 euros per fillet (in SE). Due to the above 
described tendencies this difference is expected to be even higher in the coming future.  

Some other sources of information provided an estimation of the price increase due to the certification that is 
approximately in line with the example reported some lines above. The certification considered in the Table 11 is 
MSC.  

Table 11. Cost differences per 1kg of white wild caught fish as standard product or certified product.  
NO 
10% 

Country 
% difference 

BE 
20-30% 

FR 
0-20% 

UK 
1-2% 

DE 
15% 

DK 
13% 

SE 
23% 

The influence that an increase in price in the aquaculture and marine food products have in the catering services 
in general depends on the amount of fish provided. According to information provided by some stakeholders, for 
example in a school menu, the amount of fish and meat served accounts for approximately 37% of the total cost 

97 

 
 
 
 
 
of the meal (noted that meat products are in general more expensive than fish products). The overall influence of 
certified fish products is thus expected to be lower very low 

Animal welfare 

The prices of the food commodities are not expected to increase in constant prices. Exceptions to this forecast are 
the prices of  beef (3%), pork (2%) and fish products (1%). Additionally, it has been shown that the cost of the 
meat and fish products in comparison to other ingredients is quite relevant and that this share can reach 37% of 
the total cost for a school menu. This means that the cost of the meat products is significant in the overall cost of 
the food procurement.  

A study published in "A compassion in world farming" (2011) provides a breakdown of the additional farm-level 
production costs associated with higher welfare standards. the examples given pointed out that producing a free 
range  egg  cost 0.023  euro/egg  more  than  a  battery  egg,  adding  straw  and  additional  space  for  fattening  pigs 
costs approximately an extra of 0.058 euro/kg of pork produced and that housing sows in groups rather than in 
sow stalls adds at most 0.022 euro/kg of pork produced.  

Other  sources  of  information  reported  that  the  costs  differences  between  standard  eggs  and  free  range  eggs 
depends on the location and the type of eggs provided. Some ranges are showed in Table 12.  

Table 12. Costs differences between standard eggs and free range eggs 
Country   % difference per egg in shell  % difference per egg in liquid 
Belgium 
Spain 
UK 
France 
Norway 
Denmark 
Sweden 
Germany 
Hungary 

30-50% 
54% 
35% 
50% - 100% 
32% 
57% 
76% 
21% 
173% 

12% 
64% 
245% 

35% 
35% 

These  examples  suggest  that  only  the  case  of  the  eggs,  the  criterion  will  raise  the  overall  food  procurement 
expenses of a catering service. Indeed the prices of the meat products are expected to increase due to mainly 
other reasons. It should also be noted that the share of expenses in eggs is in most of the cases no very relevant.  

Additionally,  the  percentage  of  difference  between  1kg  of  meat  of  chicken  and/or  pork  when  a  certification 
scheme is provided was also reported as showed in Table  13. The information provided by this source suggests 
that  the  certification  of  meat  products  have  a  higher  impact  of  the  food  procurement  than  the  previous 
estimation.   

20-30% 

30-40% 
120% 
3% 
50%-150% 

Table 13. Costs differences between standard chicken or pork and certified one 
Country   % difference per kg of chicken  % difference per kg of pork 
Belgium 
Spain 
UK 
France 
Norway 
Denmark 
Sweden 
Germany 
Italy 
Hungary 

104% 
18% 
30% 
133% 

20% 
18% 
30% 

3% 
10% 

143% 

98 

 
 
 
 
 
 
   
   
 
 
 
 
 
Fairly trade 

The  fairly  trade  minimum  prices  act  as  safety  net  if  the  prices  of  the  commodity  fall  below  the  costs  of 
sustainable production. In light of high production costs and the depreciation of its value in real terms, the fairly 
trade minimum price needed to be adjusted.  

Some of the products under the fairly trade schemes are also organic products. These products require an organic 
differential to account or the higher costs of organic production and to provide an incentive for converting to and 
maintaining certified organic production. As prices for many commodities have risen, fewer farmers see value in 
seeking and maintaining organic certification even as demand is increasing. Therefore, most of the fairly trade 
schemes also include an organic differential 

Finally the fairly trade premium is additional money above the selling price paid to organizations for use in social 
and business development projects that benefit the entire communities. To strengthen producer organizations and 
provide greater value to the members, the fairly trade premium was introduced. 

As an example the additional fairly trade prices or premiums of the Fairtrade for coffee are shown in Table 14 

Table 14. Fairtrade minimum prices or premium for coffee (Fairtrade, 2011) 

Fairtrade minimum price 
Fairtrade organic price 
Fairtrade premium 

+ 1.40 USD/lb to provide a stronger safety net and increase access to pre-financing 
+ 0.30 USD/lb to incentivize increased organic production 
+ 0.20 USD/lb including a 0.05USD/lb earmark for productivity/quality improvements 

Considering  the  prices  of  conventional  coffee  in  some  member  states  in  Europe  in  2009  and  the  conversion 
factors between USD/lb to Euro/kg the percentage of increase due to these schemes can be estimated.  

The results are shown in Table 15. These differences would have an impact in the vending machine services and 
especially in those that are focused in vending coffee. The prices increase is expected between 25 and 75% of the 
price of the conventional coffee and between 30 and 85% if the product is not only fairly trade but also organic 
certified.  

Table 15. Surplus in the prices of conventional coffee due to the fairly trade (FT) schemes 
certifications (USD/lb to euro/kg factor = 2.11). All the units in euro/kg of coffee 

Member 
state 
Finland 
Germany 
Spain 
Czech Republic 

Price 
coffee 
13.80 
10.36 
9.36 
4.72 

FT minimum 
price 

FT 
premium 

2.96 

0.63 

% increase 
FT schemes 
26% 
35% 
38% 
76% 

FT organic 
addition 

0.42 

% increase 
FT organic 
29% 
38% 
43% 
85% 

Other sources of information provide the additional increase in costs depending on the country where the products 
are traded and the kind of products. Some examples are given in Table 16 

20% 

Table 16. Costs differences between standard and fairly trade products 
Country   % difference/ kg coffee  % difference/ kg banana  % difference/ kg other products 
Belgium 
Spain 
UK 
France 
Norway 
Denmark 
Sweden 
Germany 
Hungary 

2% 
35% 
44% 
15% 
16% 
57% 
128% 

25% 
2% 
81% 
22% 
139% 

30-35% 
20% 

Integrated production  

The European Commission (2014b) undertook a study on precision agriculture which reported that the potential 
benefits mainly focus on crop yield improvements, optimisation of inputs and improvement of the management 

99 

 
 
 
 
 
 
 
 
 
 
 
 
 
and quality of the work. For example, the economic benefit of guiding systems in the UK to minimise the level of 
overlapping for a 500ha farm were at least 2.24 euro/ha. Benefits grow if more complex systems are adopted, 
which would lead to additional returns of 18-45euro/ha. In Germany, the economic savings of nitrogen fertilisation 
were calculated in the range of 10-25euro/ha.  

From the context of the GPP criteria, the question is whether these savings are passed on to the foodservice 
sector but it can be concluded that integrated production is more likely to reduce food procurement costs rather 
than add costs.Conclusions 

The results of the analysis presented here shows that in general the organic products are more expensive than the 
non-organic products. This difference is also observed when an LCC approach is used to compare organic products 
vs conventional products since a higher expenditure in food procurement costs (or served raw materials) have an 
effect on the overall expenditure of the service. For some products the absolute price differences per cup or per 
serving are quite low and the share of the purchasing costs of the raw product at the total costs or selling prices 
of the end product (cup or serving) are far below 10%, for the organic and the non-organic versions. It should also 
be  noted  that  some  externality  costs  of  non-organic  products  are  already  included  in  the  higher  price  of  the 
organic food products.   

The  increase  in  the  prices  of  fairly  trade  certified  food  products  can  be  significant.  It  depends  on  the  member 
state where the service is provided and the surplus suggested by the scheme. In a catering service for a cantine or 
restaurant, the increase due to the provision of fairly trade products does not seem to be relevant as the products 
covered  by  the  criterion  are  not  an  essential  part  of  the  menu.  In  vending  machines  services,  however,  this 
criterion would have serious implications.  

Promotion of vegetarian menus 

The expenditure on meat represents an average of 28% of the food basket in EU-28 (Safefood, 2015), being by 
far  the  category  with  the  largest  contribution  to  the  expenditure.  Therefore  the  potential  saving  is  high  when 
implementing a reduction of meat consumption.  

A study conducted by Tukker et al. in 2009, compared the environmental impact and the expenditure on food for 
four  diets  (scenarios).  Scenario  0  represents  the  status  quo  in  2003  in  EU-27.  In  the  other  scenarios,  the  food 
basket  has  been  slightly  changed.  From  scenario  1  to  3  they  enhance  fruit  and  vegetables  intake,  and  reduce 
progressively the intake of meat and animal fat; being the scenario 3 the most stringent in these reductions. 

The expenditure for meat can be reduced about 3.5% if the scenario 2 is implemented. When implementing a total 
reduction of all meat from the diet, the savings can reach up to 10%.  

Table 17. Food expenditures on food products for 3 scenarios studied. 

100 

 
 
 
101 

 
 
 
 
 
Food prices in real terms are projected to rise strongly over the coming decade as a result of strong demand. Beef 
price will do an average of 13% higher, pork 16% higher and poultry meat 21% higher in 2013-22. When making 
the  comparison  with  the  average  level  of  prices in  a base period  (2010-12),  real  price  increases  over the  next 
decade will be 3% for beef, 2% for pork and 11% for poultry. Therefore, the savings before calculated could be 
higher if a reduction of meat consumption is implemented. 

  Avoidable food waste 

The  production  of  food  waste  occurs  in  all  the  stages  of  the  food  production  and  catering  services.  There  are 
several studies reporting data on the amount of food waste, avoidable food waste and their costs. However, most 
of the studies remark the high uncertainties they are working with. 

According to the study called "Estimates of EU food waste levels" (Stenmarck 2016) and their data provided at EU-
28 level, the amount produced in each of the stages of a catering service including the food procurement and 
therefore its production is approximately that of showed in Table 18.  

This study also estimates the cost of the food waste produced. The costs associated with food waste for EU-28 in 
2012  are estimated  at  around  143  billion  euros.  Two-thirds  of  the  costs  are  associated with  food  waste  from 
households (around 98 billion euros) and then approximately 45 billion euros are associated with the food waste 
generated in the food production, distribution and service. 

Food waste 
(kg/pers year)* 

Table 18. Estimated food waste (in mass and cost) at EU-28 level. 
% food waste 
excl households 
22.2 % 
41 % 
11 % 
26 % 
100 % 

Food waste 
(mTon/year)* 
9.1 ± 1.5 
16.9 ± 12.7 
4.6 ± 1.2 
10.5 ± 1.5 

18 ± 3 
33 ± 25 
9 ± 2 
21 ± 3 

46.5 ± 4.4 
87.6 ±13.7 

92 ± 9 
173 ± 27 

Sector 

Primary production 
Processing 
Wholesale and retail 
Food service 
Total food waste excl household 
Household 
Total food waste 
*with 95%CI 

Cost edible 
food waste  
0.399 €/kg 
1.490 €/kg 
2.738 €/kg 
3.148 €/kg 

3.529 €/kg 

Other studies also provide data and estimations on both the amount and the cost of food waste. For example the 
Credon et al (2010) associates the quantity and importance of each of the costs of the food waste generated with 
the policy and the type of service that the caterer wants to follow. If the caterer seeks the total and immediate 
satisfaction of the customers, the tenderer will have a tendency to over-buying, to increase the security margins 
of  the  stock,  to  overcooking  and  to  serve  larger  quantities  per  portion  and  with  a  large  variety.  This  strategic 
decision implies that the quantities of food products treated will be higher and consequently the associated costs. 
The only benefit from the economic point of view is that it triggers a lower price per food product unit thanks to a 
better position in the negations with the suppliers due to the scale economy.  

This study provides a comparison of two catering services that have different policies. The first one does not have 
a food waste prevention policy while the second one does. If the  first catering service is generating more than 
3000 kg of food waste, a prevention policy will trigger a reduction of the amount of food waste generated. This 
reduction will have a positive effect in the total reduction of the food waste cost. The difference between both 
catering services is the approximately 4200 euro/year. 

Table 19. Possible savings if a food waste prevention policy is applied 
Without food waste prevention policy  With a food waste prevention policy 
Euro/kg  Total euro 
Kg waste 
3014 

Kg waste 
2162 

Euro/kg 
3.06 
6.15 
9.21 

Total euro 
9223 
18548 
27771 

3.06 
7.83 
10.90 

6615 
16928 
23577 

Costs 

Direct 
Indirect 
Total  

Some local governments estimated the costs of food waste as the Ministerio de Agricultura in Spain did. According 
to these data the average cost of the solid food in Spain is close to 3.06 euro/kg. If a catering service provides 

102 

 
 
 
 
 
 
 
800 g/meal, it needs to buy approximately 1200 g of food/meal. From this purchase, and as average 84 g will 
become  avoidable  food  waste  and  316  g  will  become  unavoidable  losses  during  the  preparation,  cooking  and 
serving processes.  

Therefore, it can be estimated that under the conditions of this example, if the catering service has a capacity of 
120 meal/day, around 10 kg/day will become food waste at a cost of 31 euro/day. This means that the catering 
service generates approximately 3000 kg/year at a cost of 9200 euros/year.  

From the social point of view, the food that is going to be wasted could be donated to collectives that cannot 
afford buying it. To do so, it is needed that the food is preserved from the preparation steps. The 'aprovecha la 
comida'  (Universidad  de  Barcelona  2013)  estimated  the  costs  associated  with  the  management  of  the  food 
donation. This cost was calculated based on the costs incur by charitable organizations. They reported that the 
food  waste  due  to  the  societal  aspects  could  be  considered  as  0.13  euro/kg  or  0.30  euro/kg.  The  first  one  is 
reported when the food is provided directly by the companies and the second one when the food provides from a 
European programme.  

From the environmental point of view, the food waste triggers also additional costs. This cost could be estimated 
based  on  the  emissions  to  the  air  and  water  that  are  produced  when  preparing,  storing,  serving  and  finally 
managing the waste of 1 kg of food. The study reports that as an average 1.98 t CO2 equivalent is produced per 
ton of food. If an average ETS price of 13.9 euro / tCO2eq is considered, the food waste generation of 3000 kg will 
generate an extra environmental cost of approx. 83 euro/year (the extra environmental cost per kg will be 0.03 
euro).  

Table 20 shows the total costs of the food waste generation according to the example showed in  Table 6 and 
Table 8. The figures of the example indicate the importance of the food waste. The cost of food waste (as raw 
material) is lower than half of the indirect costs and does not reach one third of the total processing costs.  

Table 20. Total estimated cost of food waste generation 

Internal 

External 

Total 

Direct 
Indirect 
Societal 
Environmental 

3.06 euro 
6.15 euro 
0.13 euro 
0.03 euro 

9.21 euro 

0.16 euro 

9.37euro 

Finally, a study undertaken by WRAP (2013) provided a breakdown of the total waste and highlighted the fact that 
many catering business simply focus on the cost of waste disposal when assessing the cost of the food waste 
being generated.  
Table 21 provides a summary of the findings from the study and highlights that, when an LCC approach is taken, 
it is the costs associated with food purchase and labour that are the most significant and the costs associated 
with waste management are quite modest in comparison; equating circa 4% of the total cost of avoidable food 
waste.  

Table 21: The cost of avoidable waste in the UK foodservice sector (Source: WRAP 2013) 

(€ cents /meal) in 2012 
Food purchase 
Energy 
Water 
Labour 
Transport 
Administration 
Waste management 
Consumable 
Total 
2012 £ to € av exch: 1.233263 (Ref: UKForex) 

Private staff catering 
3.12 
0.36 
0.01 
2.58 
0.01 
0.11 
0.28 
0.01 
6.47c€/meal 

Healthcare 
12.58 
0.30 
0.04 
12.49 
0.07 
0.46 
1.48 
0.04 

Education 
11.17 
0.44 
0.06 
14.19 
0.04 
0.41 
1.23 
0.05 
27.45c€/meal  27.60c€/meal  52.99c€/meal 

Services 
24.91 
4.14 
0.97 
18.86 
0.02 
0.90 
3.17 
0.02 

103 

 
 
 
 
 
These  costs  are  closely  related  to  the  sorting  out  and  the  monitoring  of  the  waste  generated.  Stakeholders 
provided information on the cost of the waste monitoring.  
The increase in costs due to the sorting activities largely depends on the infrastructure and legal obligations that 
the  catering  services  have.  In  the  case  of  sorting  of  the  plate  waste  after  lunch  made  by  the  consumers,  the 
additional  cost  is  zero.  But  they  pointed  out  that  this  is  not  the  case  in  most  of  the  kitchens.  Today  in  many 
kitchens there is no sorting of plate food waste because the infrastructure is too small and the handling is not 
possible. If the sorting is done by the kitchen personnel, 1 to 3 people are necessary during the start of the belt 
until the end of the service (average 1h).  
The monitoring of food waste form production can be done at the end of the service by one trained person during 
10-15 calendar days/year. Depending on the total quantities, the reporting time, etc this requires 15 to 20 hours 
of labour/weighting period. Only the weighting can be done by a trained person, this means, that if the trained 
person has to travel to the kitchen facilities, prepare the waste streams, weight and report the data, it is needed 4 
hours  for  the  monitoring  activity  per  day.  (if  the  labour  cost  is  supposed  to  be  40euros/hour,  a  total  of 
2400euros/year are needed for monitoring the waste streams). 

Conclusions 

There is a large variation in the estimated food waste production and food waste costs across Europe. Not only 
does it depend on the country but also in the type of catering service provided (e.g. size, intended guests, etc).  

The  estimation  of  the  benefits  of  the  Avoidable  food  waste  prevention  criterion  included  in  this  revision  is 
therefore challenging. Summarizing the data collected and reported in this section, the following conclusion can be 
drawn:  a  reduction  of  food  waste  generation  will  always  bring  economic  benefits  to  the  catering  provider.  The 
amount of these economic benefits depends on the costs that are attributed to the food waste, in particular to the 
avoidable food waste. In all the cases, the cost of the food waste is significant when a LCC approach is used, 
going well beyond the waste management costs which in most cases are very modest when compared with the 
food purchase and the labour costs associated with the generation of the food waste.  

Energy and water consumption in the kitchen 

There are several studies in the literature that confirm that significant opportunities for energy efficiency exist in 
the  contract  catering  sector.  Defra  (2013)  identifies  potential  for  energy  savings  of  43%  from  the  behaviour 
change in cooking, 27% for behaviour change in dishwashing and 55% from improving control of extraction, 42% 
cost saving from replacing electric combies with gas combis, 19% from purchasing more efficient ovens, and 25% 
form  purchasing  more  efficient  refrigeration  cabinets.  Taken  together  these  measures  could  reduce  carbon 
emissions by around 33% and save the industry approximately 32% of the current energy costs.  

Typically the catering tenderer pays for the equipment and invests in new equipment. This means that the caterer 
obtains no financial benefit from improved energy efficiency. Therefore either a new business model or additional 
incentives  are  needed  for  the  sector  that  provides  caterers  with  incentives  to  specify  and  use  equipment 
efficiently, while providing clients with incentives to invest in the most efficient equipment.  

Even  if  the  biggest  saving  identified  above  is  from  the  behaviour  change,  implementing  widespread  behaviour 
change in contract catering will be a challenge due to the large number of staff, the turnover of staff members, 
the focus on the core business of cooking and the indirect link to energy bills. As the behavioural measures are 
difficult  to  implement,  the  full  potential  of  these  measures  is  dismissed  and  the  saving  costs  due  to  the 
replacement of the equipment becomes more relevant.  

Table 22 provides the results of the Defra (2013) about the cost and benefits of implemented different measures 
in the catering services.  

Table 22. Summary of the cost-effective business cases for an average site in the catering sector 
Measure (average site) 

Behaviour change for cooking 
Behaviour change for dishwashing 
Good practice – gas combi's ovens as preplacement 

Implementation 
cost 
600 
200 
3000 

Cost Reduction 
per annum 
1800 
300 
1000  

Payback 
time 
4 months 
8 months 
 3 years 

104 

 
 
 
for electric ovens 
Good practice - more efficient ovens 
Good practice – improving control of extractors, with 
existing control 
Good practice – improving control of extractors 
without existing control; 
Good practice – refrigerator replacement with ETL 
standard 
Innovation – installation of sub-metering /transfer 
energy costs to caterer 

2000 
0 

4500 

1100 

3000 

500 
1300 

2400 

4 years 
immediate 

2 years 

700 

1.5 years 

3500 

1 year 

Regarding the saving potentials due to the behavioural changes the following measures are named depending on 
the kitchen equipment under study:  

- cooking equipment:  

-  equipment  choices  that  could  reduce  energy  use  include:  correct  sizing  of  capacity,  operational 
flexibility, low idle energy, high food energy efficiency and design features that facilitate good energy 
behaviour.  

-  aspects  that  drive  energy  use  include:  avoiding  switching  on  equipment  that  is  not  immediately 
required,  ensuring  equipment  is  switched  off  when  not  immediately  required, ensuring  that  equipment 
that is on is effectively utilised, especially ovens and the choice of cooking method.  

-  extractors 

- the key factors driving the specified power of the extraction system include the choice of cooking fuel, 
the layout of the appliances, the fan efficiency and the system resistance to the overcome including any 
filtration requirements 

- dishwashers 

- optimize the time the dishwasher is on compared to the time it is operational. Long idle periods lead to 
increased electricity consumption by the electric heater.  

-  the  impact  of  water  quality  on  dishwashing  energy  consumption  is  also  to  be  considered.  Units 
performing in hard water areas might be proved to increase energy consumption through the fouling of 
the heater, as well as increased chemicals consumption 

- refrigeration 

- some points are reduce as much as possible the number of times that the door is opened, ensuring 
seals are maintained and heat exchangers cleaned, ensuring refrigerators have sufficient ventilation for 
their heat exchangers and decommissioning units if poorly utilised.  

In more detail, the Defra (2013) provides comparisons and LCC for specific equipment used in the kitchen.  

Cooking equipment: ovens 

Cooking accounts for 40% of the energy use. The study showed that the cooking equipment is not closely matched 
to the number of meals served. Most of the caterers have spare capacity for occasional large functions. Improving 
this aspect can save significant energy.  

The study also provides the LCC for Combi steamers (a particular type of oven widely used in the catering sector). 
Table 23 shows the comparative costs over a 10 year life cycle for electric and gas combi ovens taken from the 
EuP  study  on  ovens.  The  energy  cost  for  an  electric  combi  equals  the  purchase  price  over  10  years,  while  the 
energy costs for the gas combi are 42% lower. Based on this table, the additional purchase and install cost of the 
gas  combi  is  paid  back  in  lower  running  costs  in  less  than  3  years,  being  significantly  lower  than  the  lifetime 
expected for the machines. This indicates that the investment is worth doing.  

EuP study:  

Table 23. LCC for combi-steamers 
Commercial electric 

Commercial gas combi-

105 

 
LCC over 10 years 
Product price 
Installation/acquisition costs 
Gas 
Electricity 
Water 
Repair and maintenance costs 

combi-steamer 
48 % 
1 % 
0 % 
17 % 
2 % 
2 % 

Cooking equipment: hobs 

steamer 
62% 
1% 
24% 
8% 
2% 
3% 

The ovens associated with the hobs were generally not used, the kitchen having adequate combi oven capacity. 
The  number  of  hour's  use  and  duty  cycle  for  the  hobs  is  very  variable,  with  most  of  them  very  lightly  used. 
Therefore, the analysis of this equipment is not detailed in this section.  

Dishwashers 

The  information  provided  about  the  LCC  of  professional  dishwashers  is  scarce.  The  EuP  preparatory  study 
identifies potential energy savings of 12-36% for dishwashers with the LLCC compared to the base case.  

Refrigeration  

An average site has 70% of its refrigerated volume as fridges and 30% as freezers. The EuP preparatory study 
identifies potential energy savings of 52-62% fir refrigeration units with the LLCC compared to the base case. 
Advanced technologies such as magnetic refrigeration are probably some way from market.  

  Other catering criteria 

Chemicals and consumables 

Stakeholders commented that the increase in the purchase price of certified cleaning products can be between 
10% and 18%. Depending on the infrastructure (old or lower quality steel) the required amount can be 8% to 20% 
more.  

Staff training 

Staff  training  is  a  must  and  is  necessary  on  site  for  employees  in  their  environment.  The  first  year  the  staff 
training  is  more  costly.  The  training  could  include  the  following  subjects:  menu  planning  (2x6hr),  sustainability 
(2hr), team coaching on health, safety and environment (7hr) and training time for the manager/chef (20hr).  

The cost of providing training by specialists/experts in the tenderer facilities has been estimated to approximately 
600-750 euros/day. This means, that the total average labour costs depends on the size of the kitchen (number of 
employees) but can be around 3000 eur/year for the first year and around 1000 euro/year for the following ones 
for a kitchen that supplies approximately 250 meals/day.  

Food donation 

The cost of food donation depends mainly on the country and the control and regulations stablished. The time/cost 
for  this  comes  from  recipients,  food  preparation  especially  if  cold  or  warm  temperatures  are  required,  HACCP 
follow-up and registration, labelling the product for traceability, administration and internal logistic for hand over 
to the social organizations. This time depends on the product quantities and because of the extra handlings. It is 
not possible to start cleaning/disinfecting the preparation area until things are done.  

Estimations  provided  by  the  stakeholders  account  for  an  extra  time  required  between 1  and  2  hours/day  (only 
possible when the installation and infrastructure is in conformity) or an average of 3 hours of extra labour costs 
per 100 meals donated, excluding packaging items.  

5.5  Main conclusions and remarks  

The data should be carefully considered due to the likely high uncertainties of the data sources and differences in 
the sources they are coming from. Additionally, the implementations of different policy tools such as the reduction 
of meat consumption in the Italian schools to a minimum or the additional cost for preparing the food left-overs 

106 

 
for distribution might distort the estimations in the Table. Therefore, the savings and additional costs cannot be 
added  at  the  catering  level  column.  Moreover,  there  are  other  potential  cost  savings  that  rely  on  the  proper 
implementation  of  the  energy  and  water  consumption  criterion  (TS),  the  staff  training  criterion  and  the 
environmental management measures and practices.   

Table  24  provides  a  summary  of  the LCC  analysis  and  shows  the  level  of  trade-offs  between  the  criteria that 
result in a reduction in LCC, such as meat reduction, food waste prevention or energy and water consumption in 
the kitchens and those that could incur in additional cost, such as those related to the food purchase. There are 
some criteria which effects could not be estimated due to the lack of data.    

The data should be carefully considered due to the likely high uncertainties of the data sources and differences in 
the sources they are coming from. Additionally, the implementations of different policy tools such as the reduction 
of meat consumption in the Italian schools to a minimum or the additional cost for preparing the food left-overs 
for distribution might distort the estimations in the Table. Therefore, the savings and additional costs cannot be 
added  at  the  catering  level  column.  Moreover,  there  are  other  potential  cost  savings  that  rely  on  the  proper 
implementation  of  the  energy  and  water  consumption  criterion  (TS),  the  staff  training  criterion  and  the 
environmental management measures and practices.   

Newly proposed  
GPP criteria 

% difference applying 
criteria vs standard 

Estimated significance at LCC 
level 

% difference at 
catering level 

Table 24: Concluding summary table 

Organic food products 

+ 2% to +200% 

Marine and aquaculture  
food products 
Animal welfare 

 +5% to +20% 

+15% to + 50% 

61% of the food 
procurement 
15% of the food 
procurement 
22% of the food 
procurement 

33.2%  of  the 
overall catering 
cost  due 
to 
food 
procurement 

+ 0.4% to + 40% 

+ 0.2% to + 0.9% 

+ 1.0% to + 3.6% 

Fair and ethical trade 
products 
Plant-based menus 
Food and beverage waste 
prevention 
Other waste: prevention, 
sorting and disposal 
Chemical products and 
consumable goods 
Staff training  
Energy and water 
consumption in the 
kitchen 

+2% to + 120% 

-- 

0 to -10% 

- 42% replacing combi 
-19% efficient ovens 
- 25% efficient refriger. 

1.1% of the overall 
catering cost  
5.5% of the overall 
catering cost 

due  to utilities 
cost 
due to 
amortizations  

+ 0% to – 1.3% 
 Approx.. - 5.5% 

+1.56% 

+0.07% 

+ 0.25% 
 - 0.01% better 
equipment* 

Note:  
This  estimation  is  based  on  the  data  that  the  authors  collected.  The  robustness  and  most  of  the 
particular details of the data sources are unknown. Therefore the uncertainty of this estimation is also 
unknown but it is expected to be very high and relevant.  
The data collected have been used without making difference of the type of catering services they are 
coming from. There are catering services that have a similar distribution of the costs as presented here 
but  there  might  be  others  that  do  not.  These  differences  can  be  even  more  relevant  if  the  catering 
service is provided under other conditions/assumptions.  
Most  of  the  criteria  proposed  have  a  component  that  falls  under  staff  training  or  environmental  management 
measures and practices. Two particular cases are the criteria of energy and water consumption in the kitchens and 

107 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
the  avoidable  food  waste  criteria.  A  proper  implementation  of  both  the  staff  training  and  the  environmental 
management measures and practices can bring additional economic benefits (even exceeding the cost of the training 
itself). Especially in the energy and water consumption criterion, a behavioural change of the staff can bring a cost 
reduction of up to 43% in cooking, 27% in dishwashing and 55% in the control of the extraction. 
The fourth column has been calculated by multiplying the column 2 by the column 3 (contribution of that specific 
cost to the overall catering cost) 
* in some cases there is no central food production and the fresh food is cooked on the client's premises.  

108 

 
 
 
6 

REFERENCES 

"A compassion in world farming", 2011 https://www.ciwf.org.uk/about-us/our-story/ accessed on 26th January 
2017 

Agrifoods 2014, http://www.agrifood.se/Files/AgriFood_WP20144.pdf, accessed on 26th January 2017 

ASC (Aquaculture Stewardship Council) (2015) Fact sheets Aquaculture Stewardship Council (ASC) available 
at: http://www.asc-aqua.org/upload/150506_Factsheet%20ASC%20press_Final.pdf, (accessed 1th December 
2015). 

Baldwin, C., Wilberforce, N. and Kapur, A. (2011), Restaurant and food service life cycle assessment and 
development of sustainability standard, The International Journal of Life Cycle Assessment, 16, p. 40-49. 

Barański, Huntr. (2014) Higher antioxidant and lower cadmium concentrations and lower incidence 
of pesticide residues in organically grown crops: a systematic literature review and meta-analyses. 
British Journal of Nutrition, British Journal of Nutrition 112, pp 794-811 
doi:10.1017/S0007114514001366.  

Boyano, A.; Kaps, R.; Medyna, G.; Wolf, O, 2016, Revision of six EU Ecolabel criteria for detergents and cleaning 
products, available at: http://susproc.jrc.ec.europa.eu/detergents/stakeholders.html 

Buying green, (2016),. Buying green. A handbook on green public procurement, 2nd Edition.2011 available at: 
http://ec.europa.eu/environment/gpp/pdf/handbook.pdf, (accessed 4th February 2016). 

BMPE, 2013 Best environmental management practice in the tourism sector, 2012 available at: 
https://ec.europa.eu/jrc/en/publication/eur-scientific-and-technical-research-reports/best-environmental-
management-practice-tourism-sector 

CEAP, 2017, Food waste platform, MS specific laws – see annex 4.6, p. 34 
https://ec.europa.eu/food/safety/food_waste/eu_actions_en (accessed on 26th January 2017) 

Calderón LA,  Iglesias L,  Laca A,  Herrero M,  Díaz M, 2010, The utility of Life Cycle Assessment in the ready meal 
food industry, http://dx.doi.org/10.1016/j.resconrec.2010.03.015 

Canadean, 2015. Global Beverage Forecasts March 2015. 

Cerutti et al. (2016). Carbon footprint in green public procurement: Policy evaluation from a case study in the 
food sector. Food Policy 58 (2016) 82–93 

CIVITAS (2012). Cycle Logistics- Moving goods by cycle : e-update . Retrieved 2016, from 
http://www.civitas.eu/sites/default/files/1212_epomm_enews_cyclelogistics.pdf 

Commission of the European Communities, (2008), Communication from the Commission to the European 
Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions - on 
Public procurement for a better environment,  COM/2008/400 final, available at: http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:52008DC0400, (accessed 17th Feb 2015). 

COM Recommendation (EU) 2016/336, On the application of Council Directive 2008/120/EC laying down 
minimum standards for the protection of pigs as regards measures to reduce the need for tail-docking  

Commission Regulation No 589/2008. COMMISSION REGULATION (EC) No 589/2008 of 23 June 2008, laying 
down detailed rules for implementing Council Regulation (EC) No 1234/2007 as regards marketing standards for 
eggs. 

Council of Europe (1976). European Convention for the Protection of Animals kept for Farming Purposes. Treaty 
open for signature by the member States and by the European Union and for accession by non-member States. 

Credon et al (2010) Less Food Waste More Profit - A Guide to Minimising Food Waste in the Catering Sector 
available at: http://www.epa.ie/pubs/reports/waste/wpp/Less_Food_Waste_More_Profit_Booklet_2010.pdf 

109 

 
 
DEFRA 2008, Department of environment, food and rural affairs (2008) A framework for pro-environmental 
behaviours, London: HMSO; available at 
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/69277/pb13574-behaviours-report-
080110.pdf 

DG ENV 2018. Our oceans, seas and coasts. Achieve good environmental status. available at: 
http://ec.europa.eu/environment/marine/good-environmental-status/index_en.htm 

Eat seasonably 2003, www.eastseasonably.co.uk 

EEA 2016 European environmental agency http://ec.europa.eu/environment/water/water-
drink/national_info_en.html (accessed on 26th January 2017) 

EIRO (European Foundation for the Improvement of Living and Working Conditions), (2010). Representativeness of 
the European social partner organisations: Catering sector, available at: 
http://www.eurofound.europa.eu/sites/default/files/ef_files/docs/eiro/tn0909017s/tn0909017s.pdf, (accessed 13th 
May 2015). 

EU GPP (2008), Current EU GPP criteria refers to those criteria that are valid at the time of drafting this report. 
they are available at: http://ec.europa.eu/environment/gpp/pdf/toolkit/food_GPP_product_sheet.pdf 

European Commission (2015), Public Procurement Indicators 2013. European Commission DG Growth, May 
2015, May 2015. 

European Commission, (2015a), Labelling related to animal welfare, available at: 
http://ec.europa.eu/food/animals/welfare/other_aspects/labelling/index_en.htm, (accessed 4th Nov 2015). 

European Commission, (2015b), Best Environmental Management Practice for the Food and Beverage 
Manufacturing Sector, (Final Draft), available at:  

http://susproc.jrc.ec.europa.eu/activities/emas/documents/FoodBeverageBEMP.pdf, (26th Aug 2015). 

European Commission, (2015c), EU actions against food waste, available at: 
http://ec.europa.eu/food/safety/food_waste/eu_actions/index_en.htm, (accessed 5th Oct 2015). 

European Commission, (2014), Animal Welfare, available at:  

http://ec.europa.eu/agriculture/organic/consumer-trust/animal-welfare/index_en.htm, (accessed 29th Jul 2015).  

European Commission, (2013a), Expert Group for Technical Advice on Organic Production (EGTOP) - Final Report 
On Greenhouse Production (Protected Cropping), available at: http://ec.europa.eu/agriculture/organic/eu-
policy/expert-advice/documents/final-reports/final_report_egtop_on_greenhouse_production_en.pdf 

European Commission, (2010), Preparatory study on food waste across EU 27, Bio Intelligence Service, a report 
commissioned by the European Commission, October 2010, available at: 
http://ec.europa.eu/environment/archives/eussd/pdf/bio_foodwaste_report.pdf, (accessed 14th May 2015). 

EP European Parliament News 2017 available at http://www.europarl.europa.eu/news/en/news-
room/20170411IPR71007/proposals-for-cutting-food-waste 

Eurostat Statistics in focus (2011), From farm to fork – a statistical journey along the EU’s food chain, available 
at: http://ec.europa.eu/eurostat/documents/3433488/5578964/KS-SF-11-027-EN.PDF/ff7df84c-b8f9-4b73-9959-
e0853ab109ca?version=1.0, (accessed 22nd May 2015) 

EVA 2017, European initiatives to encourage a wider choice of products in vending machines. Available at: 
http://www.vending-europe.eu/en/subject-areas/hygiene--nutrition/eu-platform.html 

Fairtrade, (2011), http://www.fairtrade.net/fileadmin/user_upload/content/2009/news/releases_statements/2011-
03-09_FLO_coffee_factsheet_final-EN.pdf accessed on 26th January 2017 

FAO, (2008), Certification in the value chain for fresh fruits, available at: http://www.fao.org/3/a-i0529e.pdf, 
(accessed 20th Nov 2015). 

110 

 
 
FERCO (European Federation of Contract Catering Organisations) (2012), The European Contract Catering Sector 
and the future of the VAT Regime, available at:  

http://www.foodserviceeurope.org/gallery/58/Briefing%20Paper%20on%20VAT%20and%20Catering%20(August%
202012).pdf, (accessed 26th Mar 2015). 

FiBL and IFOAM (2014), The world of organic agriculture: Statistics and emerging trends 2014, available at: 
https://www.fibl.org/fileadmin/documents/shop/1636-organic-world-2014.pdf, (accessed 14th May 2015). 

FiBL 2017, The world of organic agriculture: Statistics and emerging trends 2017, available at:  
http://www.fibl.org/en/media/media-archive/media-release/article/biomarkt-waechst-zweistellig-bioflaeche-steigt-
auf-fast-13-millionen-hektar-an.html 

FLO, 2017 https://www.fairtrade.net/  (accessed 26th January 2017) 

Foster et al 2014, C. Foster, C. Guében, M.Holmes, J.Wiltshire, S. Wynnb (2014) The environmental effects of 
seasonal food purchase: a raspberry case study. J of cleaner production 73 (2014) 269 
http://dx.doi.org/10.1016/j.jclepro.2013.12.077 

Fusions, 2016, Stenmarck et at 2016, Estimates of EU food waste levels, 2016, ISBN-978-91-88319-01-2, part 
of the project H2020: FUSIONS, Reducing food waste through social innovation. 

Garnett T (2008) Cooking up a storm: food, GHG emissions and our changing climate. University of Surrey, food 
climate research network, centre for environmental strategy.  

GLOBAL GAP (2017a) Global gap: friends of the sea http://www.globalgap.org/uk_en/what-we-do/globalg.a.p.-
certification/globalg.a.p.-00001/friend-of-the-sea/ 

GLOBAL GAP (2017b) Global gap: animal welfare http://www.globalgap.org/uk_en/what-we-do/globalg.a.p.-
certification/globalg.a.p.-00001/Animal-Welfare/ 

GLOBAL GAP (2017c) Global gap: general rules http://www.globalgap.org/uk_en/for-producers/NURTURE-Module/ 

ICCT, (2014). EU CO2 emission standards for passenger cars and light-commercial vehicles. Available at: 
http://www.theicct.org/sites/default/files/publications/ICCTupdate_EU-95gram_jan2014.pdf [Accessed 03 July 
2015]  

ICCT (2015). Accelerating progress from Euro 4/IV to Euro 6/VI vehicle emissions standards 

Innocat, (2015). Sustainable Public Procurement of School Catering Services, A good practice report. 

IISD and IIED (2014). The State of Sustainability Initiatives Review 2014 Standards and the Green Economy 
available at: https://www.iisd.org/pdf/2014/ssi_2014_chapter_1.pdf, (accessed 4th January 2016) 

ISCC plus (2017) http://www.iscc-system.org/en/iscc-system/iscc-plus/ (access on the 26th January 2017) 

IOBIC (2017) https://www.iobc-wprs.org/ip_ipm/index.html (access on the 26th January 2017) 

IEEA (2012), Industrial Energy Efficiency Accelerator Sector Guide. Contract Catering Sector. Report for DEFRA and 
the Carbon Trust, available at: https://www.carbontrust.com/media/163491/contract-catering-sector-guide-
industrial-energy-efficiency-accelerator.pdf 

JRC (2014b). Ecodesign for Commercial Refrigeration. Preparatory study update Final report, available at: 
http://susproc.jrc.ec.europa.eu/comrefrig/docs/COMM_REFRIG_PUBLISHED_BKG_DOC%20-
%202014%20August%2026.pdf (accessed 25th January 2017) 

JRC (2016a) Revision of European Green Public Procurement criteria for Food and Catering Services available at 
http://susproc.jrc.ec.europa.eu/Food_Catering/docs/EU%20GPP%20Food%20Catering%20services_Preliminary%20r
eport.pdf (accessed 1st December 2016) 

JRC  (2016b)  Revision  of  European  Green  Public  Procurement  criteria  for  Food  and  Catering  Services  TR1.0 
available at http://susproc.jrc.ec.europa.eu/Food_Catering/docs/  (accessed 21st December 2016) 

111 

 
MCS (Marine Conservation Society), 2015a. Good fish guide. Fish to avoid. , available at: 
http://www.fishonline.org/information/Fish+ratings, (accessed 1th December 2015). 

MSC (Marine Stewardship Council), 2015b. MSC Annual Report 2014-2015,  available at: 
https://www.msc.org/documents/msc-brochures/annual-report-archive/annual-report-2014-15-english/view, 
(accessed 1th December 2015). 

Ministerio de Agricultura Spain, 
http://www.fiab.es/es/zonadescargas/sesion_1/Guia%20alimentaria%20contra%20el%20desperdicio%20alimentari
o%20de%20Unilever_ANA%20PALENCIA.pdf 

ProCold (2016) Selection Criteria Storage Refrigerators and Freezers, available at: http://www.pro-
cold.eu/english/criteria/professional-storage-refrigerators.html#h20 (accessed on 5th Feb 2016) 

ProTerra (2014) ProTerra Standard Social Responsibility and Environmental Sustainability VERSION 3.0. 

RSB, Roundtable on Sustainable Biofuels Certification (2017) http://www.sgs.com/en/agriculture-
food/commodities/audit-certification-and-verification/certification/roundtable-on-sustainable-biofuels-rsb-
certification (accessed 26th January 2017) 

RSPO (Round Table of Sustainable Palm Oil) (2015). Trademark products gallery, available at:  
http://www.rspo.org/trademark/trademark-products-gallery, (accessed 5th October 2015) 

RSPO (Round Table of Sustainable Palm Oil) (2015a). RPSP next, available at: http://www.rspo.org/news-and-
events/news/rspo-next-taking-the-principles-and-criteria-to-the-next-level, (accessed 15th October 2015) 

Safefood, (2015). The cost of a healthy food basket Study of six household types in the Republic of Ireland. 

SAI, Sustainable Agriculture Initiative Platform (2017), http://www.fsatool.com/). 

Sauders C & Barber A (2008) Carbon foodprints, life cycle analysis, food miles: global trade trends and market 
issues. Polit Sci 60, 73-88 

SSI (2014). The State of Sustainability Initiatives Review Standards and the Green Economy  

The good Samaritan law (2017), http://ec.europa.eu/dgs/health_food-
safety/dgs_consultations/docs/ag/summary_ahac_05102012_3_feba_en.pdf (accessed on 26th January 2017) 

TopTen (2016a) Recommendations for professional refrigerated storage cabinets and blast cabinets, available at: 
http://www.topten.eu/uploads/Storage_Refrigerators_Freezers_Procurement_Guide_August_2016.pdf (accessed on 
11th October 2016) 

TopTen (2016b) Recommendations Refrigerated Display Cabinets, available at: 
http://www.topten.eu/?page=commercial-display-cabinets&fromid= (accessed on 5th Feb 2016) 

TopTen (2017) Selection Criteria Storage Refrigerators and Freezers, available at: 
http://www.topten.eu/english/criteria/professional-storage-refrigerators.html&fromid== (accessed on 20th Oct 
2017) 

Thünen Institute of Farm Economics (2013) Evaluation of the EU legislation on organic farming Final report. 
Available at http://ec.europa.eu/agriculture/evaluation/market-and-income-reports/organic-farming-2013_en.htm 
(accessed 8th October 2015) 

Tukker, Sandra Bausch-Goldbohm, Marieke Verheijden, Arjan de Koning, René Kleijn, Oliver Wolf, Ignacio Pérez 
Domínguez, 2009, Environmental Impacts of Diet Changes in the EU, 23783 EN, 6/2009 available at; 
http://ipts.jrc.ec.europa.eu/publications/pub.cfm?id=2359 

Universidad de Barcelona marzo 2013 Una guía para reducir el despilfarro alimentario en el sector de la 
hostelería, la restauración y el catering, Universidad autónoma de Barcelona,  

Webb et al, 2013 J, Williams AG, Hope E et al, Do foods imported into the UK have a greater environmental 
impact than the same foods produced within the UK? Int J Lifecycle assessment 18, 1325-1343 

112 

 
Weber et al. 2008 Food miles and the relative climate impacts of food choices in the United States. Env. Sc. 
Technol. 42, 3508-3513. 

WRAP 2016 Protocol for evaluation business food waste, available at http://eu-refresh.org/protocol-evaluating-
business-food-waste 

113 

 
 
Annexes 

Annex 1. 

Example of the GPP for FOOD PROCUREMENT: criteria and verification documents 

This section provides several examples of GPP food procurement tenders and of accounting documents or similar ones that the tenderers  must provide to demonstrate the 
compliance with the proposed criteria.  

1.1.  Food procurement criteria  

The  Table  25  includes  some  of  the  proposed  GPP  criteria  that  can  be  included  into  a  call  for  tenders  for  purchasing  FOOD.  This  exercise  does  not  aim  at  providing  a 
comprehensive call for tenders for any particular collective. Indeed, the quantities and  list  of food  and drink  products  are  not  nutritionally  balanced. The only purpose of this 
section is to show how the compliance within the minimum percentages of each criterion can be calculated. 

Threshold 

  Table 25 Example of GPP criteria that could be included in a comprehensive call for tenders for FOOD procurement  
Criteria 
Technical specifications 
Organic food 
products 

At  least  30%  in  mass  of  the  total  purchases  of  food  and  drink  products  must  comply  with  the 
organic products standards 

Verification 

Marine and 
aquaculture 
food products 

All  fish  and  fish  products  must  not  contain  species  and  stocks  identified  in  Marine  Conservation 
Society: a ´fish to avoid´ list that reflects the local varieties of fish.  
2. At least 20% in mass of the amount of marine food products purchases not complying with the 
organic  food  products  criterion  must  have  been  produced  meeting  the  requirements  of  a 
certification  scheme  for  sustainable  production  that  is  based  on  multi-stakeholder  organizations 
with a broad membership and addresses environmental impacts including over-fishing or depletion, 
biodiversity and responsible and sustainable use of the resources2). 
3. At least 10% in mass of the amount of aquaculture food products purchases not complying with 
the  organic  food  products  criterion  must  have  been  produced  meeting  the  requirements  of  a 
certification  scheme  for  sustainable  production  that  is  based  on  multi-stakeholder  organizations 
with a broad membership and addresses environmental impacts including over-fishing or depletion, 

The tenderer must provide data (name and amount) 
of food and drink products planned to be supplied in 
the  execution  of  the  contract  indicating  specifically 
the products that comply with organic requirements. 
Organic products that have been third party certified 
in  accordance  with  Regulation  (EC)  No  834/2007  on 
organic  production  and  labelling  of  organic  products 
will be deemed to comply.  
The  tenderer  must  provide  data  (name  and  the 
amount)  of  marine  and  aquaculture  food  products 
planned  to  be  supplied  in  the  execution  of  the 
contract  indicating  specifically  the  products  that 
comply with the requirements.  

114 

 
 
 
 
 
 
 
 
 
Integrated 
production 

Animal welfare 

biodiversity and responsible and sustainable use of the resources2) 
At least 30% in mass of the purchases not complying with the organic food products criterion must 
be compliant with the integrated production standards and/or guidelines of a certification scheme 
for  integrated  production  that  is  based  on  multi-stakeholder  organizations  with  a  broad 
membership, including producers and retailers and that addresses environmental impacts including 
pest, crop and waste management and conservation3)  
None of the eggs in shell are labelled code 3 of Regulation (EC) No 589/2008 or equivalent. 

The tenderer must provide data (name and amount) 
of  all  food  products  planned  to  be  supplied  in  the 
execution  of  the  contract  indicating  specifically  the 
ones compliant with the requirements. 

The tenderer must provide the amount of the eggs in 
shell  planned  to  be  supplied  in  the  execution  of  the 
contract  indicating  specifically  the  ones  compliant 
with code 1 or 2 of Annex I part A to Regulation (EC) 
No 589/2008. 

Awarded criteria  
Organic food 
products 
TP: 25 

Marine and 
aquaculture 
food products 
TP: 10 

Integrated 
production 
TP: 25 

Animal welfare 

Points  shall  be  proportionally  awarded  to  tenders  in  which  more  than  30% in  mass  of  the  total 
purchases of food and drink products have been produced in accordance with Regulation (EC) No 
834/2007.  

See verification above 

See verification above 

Points shall be awarded proportionally to tenders in which more than 20% in mass of the amount 
of  marine  food  products  purchases  not  complying  with  the  organic  produce  criterion  have  been 
produced  meeting  the  requirements  of  a  certification  scheme  for  sustainable  production  that  is 
based on multi-stakeholder organizations with a broad membership and addresses environmental 
impacts including biodiversity and responsible and sustainable use of the resources2).  
Points  shall be awarded proportionally to tenders in which more than 10% in mass of the amount 
of  aquaculture  food  products  purchases  not  complying  with  the  organic  produce  criterion  have 
been produced meeting the requirements of a certification scheme for sustainable production that 
is  based  on  multi-stakeholder  organizations  with  a  broad  membership  and  addresses 
environmental  impacts  including  biodiversity  and  responsible  and  sustainable  use  of  the 
resources2).  
Points    shall  be  awarded  proportionally  to  tenders  in  which  more  than  30%  in  mass  of  the 
purchases  not  complying  with  the  organic  food  products  criterion  have  been  produced  in 
accordance  with  integrated  production  standards  and/or  guidelines  of  a  certification  scheme  for 
integrated production that is based on multi-stakeholder organizations with a broad membership, 
including  producers  and  retailers  and  that  addresses  environmental  impacts  including  pest,  crop 
and waste management and conservation3) 
Points  shall be proportionally awarded to tenders in which more than 80% of the eggs in shell not  See verification above 

See verification above 

See verification above 

115 

 
 
 
 
 
TP: 5 (part 1) 
and 13 (part 2) 

Fair and ethical 
trade products 
TP: 2 

Environmentally 
responsible fats 
(each 
1 
TP: 
part) 

complying  with  the  organic  food  products  criterion  are  labelled  code  1  of  Regulation  (EC)  No 
589/2008. 
Points  shall be proportionally awarded to tenders in which more than 25% in mass of the total 
purchases  of  meat  not  complying  with  the  organic  food  products  criterion  have  been  produced 
meeting  the  requirements  of  a  certification  scheme  for  animal  welfare  that  is  based  on  multi-
stakeholder  organizations  with  a  broad  membership  and  addresses  aspects  including  the  use  of 
antibiotics, stunned slaughter, transportation times, grazing season for milk cows or no tail docking 
on pigs4). 
Points  shall be awarded proportionally to tenders in which more than 80% in mass of the total 
purchases  of  each  of  the  following  products:  coffee,  tea,  chocolate  (cocoa),  sugar  and  bananas, 
have been produced and traded meeting the requirements of a certification scheme for fair trade 
that  requires  a  minimum  content  of  certified  product  of  90%  and  that  is  based  on  multi-
stakeholder  organizations  and  addresses  international  fairtrade  standards  including  working 
conditions for production in accordance with ILO, sustainable trade and pricing5).    
Points  shall be awarded proportionally to tenders in which more than 30% of the units/items of 
pre-packed food products containing palm oil have been sourced from plantations that meet the 
requirements  of  a  certification  scheme  for  sustainable  production  that  is  based  on  multi-
stakeholder organizations that has a broad membership, including NGOs, industry and government 
and that addresses environmental impacts including on soil, biodiversity, organic carbon stocks and 
conservation of natural resources6). 
Points  shall be awarded proportionally to tenders in which more than 50% in mass of the palm oil 
purchased as raw ingredient have been sourced from plantations that meet the requirements of a 
certification  scheme  for  sustainable  production  that  is  based  on  multi-stakeholder  organizations 
that  has  a  broad  membership,  including  NGOs,  industry  and  government  and  that  addresses 
environmental  impacts  including  on  soil,  biodiversity,  organic  carbon  stocks  and  conservation  of 
natural resources6). 

The tenderer must provide data (name and amount) 
of  the  meat  products  planned  to  be  supplied  in  the 
execution  of  the  contract  indicating  specifically  the 
ones that comply with the requirements  

The tenderer must provide data (name and amount) 
of  all  coffee,  tea,  chocolate  (cocoa),  sugar  and 
bananas  planned  to  be  supplied  in  the  execution  of 
the contract indicating specifically the ones compliant 
with the criterion. 

The tenderer must provide data (name and amount) 
of  all  food  products  containing  palm  oil  (as  units) 
planned  to  be  supplied  in  the  execution  of  the 
contract  indicating  specifically  the  ones  compliant 
with the criterion. 

The tenderer must provide data (name and amount) 
of  all  palm  oil  (as  raw  ingredient)  planned  to  be 
supplied  in  the  execution  of  the  contract  indicating 
specifically 
the 
criterion. 

the  purchases  compliant  with 

1) The "fish to avoid" list is available on the MCS website: http://www.fishonline.org/fishfinder?min=5&max=5&fish=&avoid=1. Equivalent lists could be found from: WWF’s Sustainable Seafood guides, IUCN, Seaweb Europe, CITES, FAO, NOAA, 
Monterey Bay Aquarium Seafood Watch, Greenpeace, etc. 
2) Such as, e.g., the Marine Stewardship Council (MSC) for marine food products and the Aquaculture Stewardship Council (ASC) or Globalgap for aquaculture food products, provided they cover the environmental principles mentioned above. 
Other schemes at country level can be considered as equivalent as far as they comply with the environmental principles mentioned above. 
3)  Food  products  that  have been  certified  in  accordance with  integrated  production  national  or  regional  regulation  will  be  deemed  to  comply.  Other  schemes  such  as  Global GAP, IOBC,  FSA  with  at  least  bronze equivalence,  etc  can  show 
compliance with the criterion provided they cover the environmental principles mentioned above. Other schemes at country level can be considered as equivalent as far as they comply with the environmental principles mentioned above. 
4) Products that have been third party certified by widely accepted and recognised standards such as e.g. Label Rouge, GlobalGAP with the add-on of Animal welfare, RSPCA Assured, Red Tractor Farm Assurance are deemed to comply. 
5) Schemes such as Fairtrade®, UTZ, Bonsucro, etc. can show compliance with the criterion provided they cover the environmental principles mentioned above. Other schemes at country level can be considered as equivalent as far as they 
comply with the environmental principles mentioned above. 
6) Schemes such as RSPO, ICCTS plus or RSB can show compliance with the criterion provided they cover the environmental principles mentioned above. Other schemes at country level can be considered as equivalent as far as they comply with 
the environmental principles mentioned above.  

116 

 
 
 
 
 
 
 
 
1.1.1. Accounting documents and compliance with the required criteria 

An example of the accounting documents are shown in Table 26 and Table 27. Table 26 includes the list of food products that the tenderer expects to purchase during one year. 
Information about the expected number of kg and expected costs is also provided in the columns 6 and 7. Table 28 shows the minimum thresholds required in this call for 
tenders as well as the percentages expected to be provided by the tenderer. Points have been distributed among the criteria based on possible costs and points awarded have be 
given proportionally.  

Table 26. Example of the expected purchases indicating those products that are expected to comply with some of the above criteria 
Name 

Euro/unit  Total kg  Total cost 

Classification 

Organic food 
products kg 

Other products 
label 
MSC 

Units/ 
kg 

total 
units 
200 
200 
500 

COD FILLETS (24) 
GOLDEN TIDDLERS 
SALMON FILLET SKINLESS 
(30) 
SCAMPI  
BACON UNSMOKED BACK  
BURGERS 4OZ  
CHICKEN DOUBLE BREAST  
HAM SLICED 
LAMB LEG STEAK  
LAMB CUTLET 
SAUSAGE BREAKFAST 
SAUSAGE IRISH 
SAUSAGE MINI PORK 
STEAK GAMMON 
STEAK RUM 
STEAK SIRLOIN 
APPLE&BLACKBERRY (12) 

BAKED CHEESECAKE (12) 
CHOCOLATE (cocoa) 

Fish 
Fish 
Fish 

Fish 
Meat 
Meat 
Meat 
Meat 
Meat 
Meat 
Meat 
Meat 
Meat 
Meat 
Meat 
Meat 
Sweets & Desserts 

Sweets & Desserts 
Sweets & Desserts 

kg 
kg 
kg 

kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 

kg 
kg 

100 
200 
400 
100 
200 
100 
100 
100 
100 
100 
200 
200 
200 
200 

50 
200 

10 
6 
9 

15 
5 
5 
3 
4 
6 
7 
5 
5 
5 
8 
8 
8 
10 

10 
12 

200 
200 
500 

100 
200 
400 
100 
200 
100 
100 
100 
100 
100 
200 
200 
200 
200 

50 
200 

2000 
1200 
4500 

1500 
1000 
2000 
300 
800 
600 
700 
500 
500 
500 
1600 
1600 
1600 
2000 

500 
2400 

ASC 

GlobalGAP 
Label Rouge 

GlobalGAP 

Label Rouge 

GlobalGAP 

Label Rouge 
GlobalGAP 

Fair trade 

117 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Name 

Classification 

Units/ 
kg 

ICE CREAM MOVEN ALL 
PROFITEROLES 1X5 
STICKY TOFFEE PUDDING 
(12) 
WAFFLES BELGIAN 
X MANS PUDDING 1X12 
APPLES GREEN 
BANANAS 
BROCCOLI 2KG 
CARROT 2KG 
CAULIFLOWER 
CUCUMBER 
FZ MUSHROOMS  
FZ PEAS GARDEN (6) 
FZ POTATO MASHED 
FZ POTATO ROAST 
FZ POTATO SMILES 
MUSHROOMS BUTTON (2) 
MUSHROOMS FLAT FIELD 
ONIONS 
PEARS 
POTATOES NEW 
SALAD MIX (12) 
TOMATOES 
BUTTER PORTION (100) 
CHEESE BRIE (4) 
CHEESE CHEDAR 

Sweets & Desserts 
Sweets & Desserts 
Sweets & Desserts 

Sweets & Desserts 
Sweets & Desserts 
Fruit & Veg 
Fruit & Veg 
Fruit & Veg 
Fruit & Veg 
Fruit & Veg 
Fruit & Veg 
Fruit & Veg 
Fruit & Veg 
Fruit & Veg 
Fruit & Veg 
Fruit & Veg 
Fruit & Veg 
Fruit & Veg 
Fruit & Veg 
Fruit & Veg 
Fruit & Veg 
Fruit & Veg 
Fruit & Veg 
Dairy 
Dairy 
Dairy 

kg 
kg 
kg 

kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
unit 
kg 
kg 

total 
units 
50 
200 
200 

400 
50 
500 
500 
300 
1000 
300 
200 
300 
500 
800 
800 
800 
200 
200 
600 
500 
800 
2000 
1000 
500 
150 
150 

Euro/unit  Total kg  Total cost 

Organic food 
products kg 

Other products 
label 

12 
6 
5 

4 
4 
1.5 
1.2 
1 
0.4 
1.2 
1 
1.6 
1.3 
0.6 
0.6 
0.7 
1 
1 
0.8 
1.5 
1 
1 
1.5 
0.1 
12 
12 

50 
200 
200 

400 
50 
500 
500 
300 
1000 
300 
200 
300 
500 
800 
800 
800 
200 
200 
600 
500 
800 
2000 
1000 
5 
150 
150 

600 
1200 
1000 

1600 
200 
750 
600 
300 
400 
360 
200 
480 
650 
480 
480 
560 
200 
200 
480 
750 
800 
2000 
1500 
50 
1800 
1800 

500 
500 
300 

300 

300 
500 
800 
800 

600 

2000 
1500 

Fair trade 

produccion integrada andalucia 

produccion integrada andalucia 

produca integrada 
produca integrada 

produccion integrada andalucia 
produccion integrada andalucia 

see justification 

global Gap 

118 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Name 

Classification 

Units/ 
kg 

CHEESE MOZ (10) 
CHEESE STILTON 
CREAM AEROSOL SPRAY 
EGGS (15) 
EGGS LIQUID (12) 
MILK SEMI SKIMMED/FULL 
YOGHURT ALL 
BAGUETTE TEAR 
BLOOMER BREAD (6) 
BREAD LOAF 
CROISSANTS (32) 
MINI MUFFINS 
TORTILLAS 6INCH 
GARLIC GRANULES 
MOROCAN SEASONING 
PEPPER GROUNDS BLACK 
PEPPER GROUNDS WHITE 
PEPPERCORNS WHOLE 
SALT TABLE 
AMB. MAYONNAISE (2) 

OLIVE OIL 

TOMATO SAUCE 

AMD. TARTARE SAUCE 

SACHET BROWN SAUCE 

Dairy 
Dairy 
Dairy 
Dairy 
Dairy 
Dairy 
Dairy 
Bakery 
Bakery 
Bakery 
Bakery 
Bakery 
Bakery 
Herbs & Spices 
Herbs & Spices 
Herbs & Spices 
Herbs & Spices 
Herbs & Spices 
Herbs & Spices 
Sauces & 
Dressings 
Sauces & 
Dressings 
Sauces & 
Dressings 
Sauces & 
Dressings 
Sauces & 

kg 
kg 
kg 
unit 
kg 
kg 
unit 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 

kg 

kg 

kg 

unit 

total 
units 
150 
150 
100 
500 
200 
1000 
3000 
400 
400 
400 
200 
200 
400 
200 
50 
20 
20 
20 
300 
50 

300 

1500 

20 

500 

Euro/unit  Total kg  Total cost 

Organic food 
products kg 

Other products 
label 

12 
12 
5 
0.12 
0.8 
0.8 
0.2 
1 
1 
1 
1.2 
1.2 
0.9 
1 
1 
1 
1 
1 
0.1 
10 

3 

0.6 

10 

0.2 

150 
150 
100 
40 
200 
1000 
360 
400 
400 
400 
200 
200 
400 
200 
50 
20 
20 
20 
300 
50 

300 

1500 

20 

7.5 

1800 
1800 
500 
60 
160 
800 
600 
400 
400 
400 
240 
240 
360 
200 
50 
20 
20 
20 
30 
500 

900 

900 

200 

100 

400 

400 

200 

20 
20 
20 

Code 1 

Global gap 
see justification 

Integrated production Andalucía 

Integrated production 

see justification 

119 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Name 

Classification 

Units/ 
kg 

total 
units 

Euro/unit  Total kg  Total cost 

Organic food 
products kg 

Other products 
label 

SACHET MUSTARD 

SACHET TOMATO KETCHUP 

BEV COSTA MOCHA ITALIAN 
BEV COFFEE TI BLEND 
BEV CON GOLD SACHETS 
BEV. DOUWE EGGBERTS 
BEV. TEA BAGS 
BISCUITS FOR CHEESE 
BISTO GRANULES 
CEREAL KELLOGS (32) 
CEREAL MUSELI (50) 
CEREAL WEETABIX (50) 
HONEY PORTION (100) 
JAM PORTION (100) 
JUICE APPLE 
JUICE ORANGE 
MARMALADE (100) 
OIL SUMMER HARVEST 
OIL PALM 
PASTA RIGATONI 
PASTA SPAGHETTI 
RICE COCONUT 

RICE GOLDEN 

Dressings 
Sauces & 
Dressings 
Sauces & 
Dressings 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 

Dry Food 

unit 

unit 

kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
unit 
unit 
kg 
kg 
kg 
kg 
kg 
kg 
kg 
kg 

kg 

500 

500 

1000 
1000 
1000 
1000 
2000 
100 
100 
300 
300 
100 
1000 
1000 
2000 
2000 
100 
200 
100 
1500 
1500 
1500 

1500 

0.2 

0.2 

6 
6 
6 
6 
3 
4 
4 
4 
3 
1 
0.3 
0.3 
10 
10 
5 
1 
0.8 
0.8 
0.4 
0.5 

1 

7.5 

7.5 

1000 
1000 
1000 
1000 
2000 
100 
100 
300 
300 
100 
15 
15 
2000 
2000 
100 
200 
100 
1500 
1500 
1500 

100 

100 

6000 
6000 
6000 
6000 
6000 
400 
400 
1200 
900 
100 
300 
300 
20000 
20000 
500 
200 
80 
1200 
600 
750 

100 

300 

2000 
2000 

1500 

1500 

1500 

1500 

see justification 

see justification 

Fairtrade 
Fairtrade 
Fairtrade 
Fairtrade 
Rainforest alliance 

see justification 
see justification 

RSPO 

Integrated production Comunidad 
Valenciana 

120 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Name 

RICE TILDA 

SUGAR (15) 
SUGAR ICING 
TIN PINEAPPLE RINGS 
VINEGAR BALSAMIC 
VINEGAR MALT 
W NUTS DRY ROASTED 

W NUTS SALTED 

TOTAL 

Classification 

Units/ 
kg 

Dry Food 

Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 
Dry Food 

Dry Food 

kg 

kg 
kg 
kg 
kg 
kg 
kg 

kg 

total 
units 

1500 

500 
100 
300 
50 
50 
300 

300 

Euro/unit  Total kg  Total cost 

0.5 

1 
1.2 
0.8 
1 
1 
3 

5 

1500 

500 
100 
300 
50 
50 
300 

300 

750 

500 
120 
240 
50 
50 
900 

1500 

43430 

138680 

Organic food 
products kg 

500 

Other products 
label 
Integrated production Comunidad 
Valenciana 
Fairtrade 

Integrated production Comunidad 
Valenciana 

300 

17360 

Table 27. Calculations to demonstrate compliance with the technical specification criteria 
Criteria 

Total kg within compliance 

Threshold 

Total kg in that category 

Organic food products 
M&A Red list 
M&A maritime 
M%A aquaculture 
Integrated production 

30% 
100% 
20% 
10% 
30% 

17360 
- 
200 
500 
8000 

43430 
- 
1000 
1000 
12060 

Tenderer 
proposal  
40% 
- 
20% 
50% 
66% 

compliance 

YES 
YES 
YES 
YES 
YES 

Table 28. Calculation related to the awarded points of the awarded criteria 
Total kg within compliance 
Awarded criteria  

Threshold 

Total kg in that category 

Organic food products 
M&A maritime 
M%A aquaculture 
Integrated production 
Animal welfare (eggs) 

30% 
20% 
10% 
30% 
80% 

17360 
200 
500 
8000 
400 

43430 
1000 
1000 
12060 
500 

Tenderer 
proposal  
40% 
20% 
50% 
66% 
80% 

Total points  Points  awarded 

25 
5 
5 
25 
5 

3.56 
0.00 
2.22 
12.98 
0.00 

121 

 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
Animal welfare (meat) 
Fair  and  ethical  trade  products- 
chocolate 
Fair  and  ethical  trade  products- 
coffee 
Fair and ethical trade products- tea 
Fair  and  ethical  trade  products- 
sugar 
Fair  and  ethical  trade  products- 
bananas 
Palm oil (units) 
Palm oil (ingredient) 
Total points 

25% 
80% 

80% 

80% 
80% 

80% 

80% 
80% 

1300 
200 

4000 

40 
500 

500 

100 

2000 
200 

4000 

40 
600 

500 

100 

65% 
100% 

100% 

100% 
83% 

100% 

100% 

13 

6.93 

2 

1.18 

1 
1 
82 

0.00 
1.00 
27.87 

As shown in the previous tables, the tenderer fulfils all the technical specifications criteria and achieves a score of 27.82 points out of 82. If the selection criteria requirements 
and the contractual performance criteria are met, the offer of this tenderer can be considered as a candidate.

122 

 
 
 
 
 
 
 
 
 
Annex 2. 

Table of stakeholder's comments on general aspects of the Technical Report v1 

2.1.  Table of stakeholder's comments on the scope and definitions, environmental hotspots 

This section presents the comments received through BATIS and personal communication from the 1st AHWG meeting to the 2nd AHWG meeting.  

Table 29. Feedback from the stakeholders on the TR1.0:  
Topic 

of 
Reflection 
environmental 
impact  in  the 
criteria 

as 

GPP 
working tool  

a 

Criteria 
drafting 
and 
scientific  and 
other grounds 

Feedback from stakeholders 
As stated also in the previous position paper, ETL considers it important that the progress made on 
the knowledge  on  food  sector  and  environmental  impacts  since the  first  GPP  criteria  set for  food 
was established should be better taken into account while setting the stage for the new criteria. 
ETL believes that a constructive way forward with remarkable improvement and impacts is to create 
criteria that take into account all kinds of products and production methods. 
There is a detailed analysis on the key sustainability aspects related to foodstuffs included in the 
report. However, the results of this analysis are not properly reflected to the chosen set of criteria 
presented in the report.  
In all, the criteria should be based on objective and scientific basis that takes into account the whole 
life cycle of the product(s) in question. In this respect, also the difficulties related to the assessment 
of environmental impacts of foodstuffs should be recognized.  
The criteria definition should be based on the principles of relevance and impact, i.e. what are the 
most useful criteria in order to reach the overall goal (improved environmental performance). If the 
focus is on marginal solutions, they rule the majority of food chain players and the corresponding 
volumes – as well as the related environmental improvement potential – out. 

Discrepancy between the proposed criteria and the scientific analysis they should be based on. In the 
Preliminary  and  Technical  report,  the  JRC  conducts  a  thorough  scientific  analysis  of  sustainability 
hotspots  in  the  lifecycles  of  food  and  drink  products.  Surprisingly,  this  analysis  is  only  weakly 
reflected  in  the  new  GPP-criteria  the  JRC  proposes.  For  example,  despite  scientific  evidence 
indicating  advantages  and  disadvantages  to  both  organic  and  conventional  agriculture,  thereby 
underlining the importance of industry and science backed sustainable agriculture standards, GPP-
criteria point to organic production as the best option because of availability and the fact that it is 
central to existing GPP-schemes. While it is possible that other considerations may be of relevance 
in the drafting of GPP-criteria in addition to scientific analysis, such as market availability, feasibility 

JRC-Directorate B5 assessment 
Acknowledged 

Acknowledged 
It  would  be  appreciated  if  the  specific  aspects  would 
have been pointed out 
Acknowledged 
It was the intention of this revision.  

Comment rejected 
The scope of the GPP revision is to update the criteria 
that  can  be  used  by  the  procurer  when  drafting  the 
specific calls for tenders. Procurers have the last word 
on which criteria should be included or should not and 
how  many  points  should  be  awarded  to  each  award 
criteria  
Acknowledged 
The aim of the GPP revision is to propose GPP criteria 
based  on  the  scientific  analyses  of  the  sustainability 
hotspurs in the lifecycles of food and drink products.  
However,  several  additional  aspects  should  be 
considered  when  proposing  the  final  wording  of  the 
criteria. some of these aspects are:  
-  the  criteria should  be  verified  by the  procurers,  that 
sometimes  lack  the  expertise  for  carrying  out  self-

123 

 
 
 
 
and societal demands, the main foundation of GPP-criteria should be objective and factual. We call 
upon the JRC to focus on the science, and leave societal or political considerations to governments 
implementing the GPP-criteria. 

Nutritional  and 
sustainability 
aspects 

Besides  environmental  impacts,  nutrition  and  other  broader  sustainability  issues  are  of  relevance 
when talking about foodstuffs. A wider sustainability approach than limited focus on environmental 
aspects might serve this product group better. In that case, a clear definition on which dimensions of 
sustainability are addressed and when is needed. 

Verification  

Private 
sustainable 
schemes 

Private 
sustainable 

The GPP criteria should provide guidance more on the ends than a limited set of means. The overall 
goal of decreased environmental burden can be achieved in various ways, which should be reflected 
also in the chosen criteria. This approach would also encourage various actors to innovate new ways 
to improve the sustainability of food chain rather than adhering to a fairly narrow set of recognized 
means. 
Private sustainability schemes are overlooked in both criteria and verification. Since the first design 
of GPP policy and criteria, many private, public, public-private, national, European and international 
initiatives have been taken for sustainable food production and consumption. Some major initiatives 
are completely overlooked in both the Preliminary and the Technical report, such as the SAI Platform 
Farm Sustainability Assessment. This scheme is backed by major food manufacturers and retailers, 
builds upon the Integrated Production principles included in the GPP-criteria, and aligns with strong 
international  sustainability  standards.  These  and  other  privately-owned  initiatives  should  be 
Acknowledged  in  addition  to  public  IP-schemes,  as  means  to  operationalise  the  sustainable 
agriculture principles central to GPP, as it is within these initiatives real sustainability impact is made 
within international supply chains.  
Product certification can be a bottleneck for both SMEs and large-scale production. A large number 
of  Dutch  food  and  drink  companies  are  SMEs.  When  developing  the  new  GPP  requirements  it  is 

evaluation. Therefore, the proposed criteria should rely 
on third party certifications that ensure the compliance 
with the criterion.  
-  the  procurers  should  assess  the  most  suitable  the 
limits/thresholds for each of the proposed criteria that 
are  selected  to  be  included  in  their  call  for  tenders. 
Therefore  the  information  included  in  the  explanatory 
notes should be considered as a guidance 
-  the  revision  of  the  GPP  takes  into  account  other  EC 
policy  tools.  Criteria  are  suggesting  trying  to  enhance 
the  harmonization  among  policy  tools  but  especially 
trying to avoid contradictions among them.  
Comment rejected 
The  aim  of  the  GPP  policy  tool  is  to  focus  on  the 
environmental  aspects.  Other  aspects  related  to  the 
sustainability  can  be  considered 
the  criteria 
whenever possible.  
Comment accepted 
Several  means  of  compliance  have  been  suggested 
whenever possible.  

in 

Comment rejected 
Major  initiatives  are  considered  as  long  as  they  fulfil 
the needed requirements to be used in this policy tool. 
To  be  included  in  the  GPP  schemes,  the  initiatives 
should, among other aspects count for:  
-  thresholds  that  clearly  address  the  environmental 
aspects identified as hotspots in this revision 
- means of verification that rely on third party schemes 
or that can be easily performed by the procurers even 
if they are lacking of expertise in the field.  
Comment accepted 
There  are  several  criteria  which  verification  has  been 

124 

 
schemes  and 
SME 

Continuous 
improvement 
of GPP criteria 

Ambition levels 

essential to consider the SME perspective. In the proposed GPP-criteria, the JRC focuses exclusively 
on  product  certification  as  verification  means,  which  can  be  very  challenging  for  SMEs.  This  also 
goes for companies operating in large-scale and high-volume supply chains, in which certification of 
individual products is simply not feasible or adequate sustainable agriculture certification schemes 
are lacking. In order to allow for and encourage continuous improvement throughout the mainstream 
food  and  drink  sector,  credible  industry-owned  standards  and  verification  methods  other  than 
product  certification  should  be  permitted  to  prove  compliance  with  GPP-criteria,  such  as  system 
verification or process certification. 
Green Public Procurement should spur continuous improvement. The sustainable production of food 
is a process of continuous improvement of environmental performance, social/ethical circumstances 
and economic welfare, throughout the food manufacturing process and throughout the food supply 
chain.  GPP-criteria  should  reflect  this  improvement-driven  approach  and  take  into  account  overall 
environmental  performance  rather  than  prescribing  specific  techniques  or  labels.  Moreover,  the 
criteria setting should address improvements in the main environmental, welfare and social issues 
relevant to each product category. 
We welcome the breadth of the proposals and the broader range of products and services covered 
by the draft criteria. 
It would be useful to align the ambition of certain categories such as vehicles and cleaning products 
with  the  relevant  criteria  sets  for  those  products.  There  is  no  reason  why  they  should  be  less 
ambitious here. 
It  would  be  useful  if  the  ambition  levels  could  be  rationalised  (e.g.  why  is  the  ambition  level  for 
integrated farming lower than that for organic farming? why is long distance transport included for 
fruit and not vegetables or fruit?) 

Ambition levels  The supporting technical document needs to be completely reviewed to be any use in formulating 
GPP  principles.  We  have  already  seen  how  "ambitious"  public  procurement  managers  in  cities  like 
Hamburg strictly apply the GPP rules and although well intentioned, effectively significantly increase 
the  city's  environmental  impact  AND  reduce  consumer  choice.  Please  see  the  comments  in  the 
Technical  report  in  attachments.  I  am  also  happy  to  supply  LCA  studies  to  substantiate  the 
comments made. 

Other 

Ambition levels 
Links  between 

This  needs  to be  more  specific  by  identifying  products  with  a  lower  environmental  impact.  Please 
add to the first bullet of the potential improvement area: “…including more plant-based foods.” 
In the public sector, catering services can be contracted to external providers (contract caterers) or 
can be provided in-house. Green public procurement (GPP) criteria should be applied equally among 

enlarged  including  private  schemes  in  addition  to  the 
national regulations. This is the case of the criterion on 
integrated production.  
Additionally,  most  of the  criteria  that  are  proposed  to 
be verify throughout a third party certification scheme 
include  the  wording  "or  equivalent",  so  that  procurers 
feel  free  to  include  other  schemes  that  they  consider 
are suitable for this purpose.    
Comment rejected 
The goal for continuous improvement of the companies 
is not part of the scope of the GPP tool. This is included 
in other policy tools such as EMAS.  

Acknowledged 

Acknowledged 

Comment rejected 
Proposed  thresholds  are  based  on  the  available 
information.  
Comment accepted 
The  shape  of  the  criteria  has  been  significantly 
modified.  The  last  proposal  let  procurers  make  the 
decision  on  the  most  suitable  threshold  for  their  area 
or  service.  Recommended  values  are  included  in  the 
explanatory  notes  of  each  criterion  but  they  are  not 
mandatory to be applied.  
Acknowledged 

Comment accepted 
- See above concerning the thresholds included in each 

125 

 
 
 
 
 
 
criteria 

TS vs AC 

third-parties 

certification.   

in-house catering and out-sourced contract catering providers to ensure a level playing field. 
Setting  GPP  criteria  will  not  be  environmentally  beneficial  unless  there  is  adequate  market 
availability of the products specified at a price that is affordable within the budget of the tender.  
Many of the sourcing requirements proposed will create a price premium because these are niche 
products for which there is limited market availability. The reliance on third-party certified products 
to prove verification is another factor that contributes to the price premium  since producers must 
pay 
for 
When  establishing  GPP  criteria,  it  must  be  borne  in  mind  that  while  the  EU  states  that  GPP  is 
voluntary for public authorities, it has been made mandatory for public authorities in at least one EU 
Member State. When a public authority includes GPP criteria in the tender, it is mandatory for the 
contract  caterer  to  comply  and  contract  caterers  can  face  fines  if  they  are  not  able  to  fulfil  the 
criteria in the contract. Such fines are perceived as being disproportionate when non-compliance is 
due  to  a  lack  of  market  availability.  Setting  criteria  for  which  the  ambition  is  beyond  the  market 
availability and affordability only results in non-compliance, and there is no environmental benefit. 
We urge the Commission to set criteria that is realistic and achievable for all EU countries. 
Question: How much do public authorities spend on procurement of food? 
The EEB has consulted the draft criteria set for food and catering services together with its member 
organisations and other environmental NGOs. We recommend that the proposal should be improved 
with regard to the following points of concerns which are outlined in further detail in the attached 
position paper. 
Although in general the EEB welcomes the scope and contents of the proposed GPP criteria set for 
food and catering services, we would like to point out that there is a need to highlight those criteria 
with the biggest potential to reduce the environmental impact and to avoid trade-offs with less 
relevant requirements for the procurement process. Environmental NGOs clearly prioritize ambitious 
criteria on food procurement, menu planning and training for catering services, including measures 
to reduce food waste. 
Additional requirements e.g. on environmental management measures and practices, equipment and 
vehicle fleets should be considered in general only as award criteria. This should be done in a 
balanced way that does not penalize or even discriminate against small and medium size companies 
(SMEs) that have an outstanding performance on the above mentioned key criteria for food and 
catering services but cannot afford certain investments, monitoring and certification procedures to 
fulfil the tender specifications. 
Finally, the EEB would like to request clarification on a possible gap between the two criteria sets 
proposed. We need to ensure that a public procurer for food products who does not contract a 
catering service (but e.g. runs an in-house canteen or cafeteria) also has to meet certain 

criterion 
-  Some  criteria  have  been  included  in  the  Catering 
service  that  allow  for  balancing  the  premium  price  to 
be paid for the compliance of some other criteria. For 
example,  the  purchase  of  organic  products  or  fairly 
traded products can be balanced by a reduction of red 
meat,  substitution  of  animal  proteins  by  bop-based 
proteins, etc….  

Not known 
Comment partially accepted 
The selection of the criteria and ambition levels to be 
included  in  the  call  for  tenders  is  eventually  in  the 
hands of the procurers.  
The classification of a criterion as TS or AC is based on 
several aspects in addition to the effectiveness of the 
criterion  to  address  the  corresponding  hotspot.  These 
aspects  can  be  found  in  the  guidance  for  developing 
GPP schemes.  
Not only have procurers the freedom to choose those 
criteria and ambition levels that fit their purposes but 
they should be also award of the type of service that 
they want to purchase. It is not the same the purchase 
of  the  food  products  than  the  purchase  of  catering 
services. It should be also kept in mind that there are 
multiple types of catering services.  

126 

 
  
 
LCA, scientific 
evidence 

Green vs 
sustainable  

Voluntary vs 
mandatory 
tools 
Selection 
criteria 

GMO 

requirements that are only listed for catering services such as menu planning and prevention of food 
waste for example. If this topic has not been addressed yet e.g. in the scope definitions, the JRC 
should definitely consider it for the updated version of the technical report. 
To  be  sure  that  the  defined  criteria  EFFECTIVELY  helps  public  authorities  to  reduce  their 
environmental impacts, the criteria must be designed based on robust scientific assessment (i.e life 
cycle assessment) and not on believes/assumptions/perceptions. Indeed a product might have higher 
environmental  impacts  during  its  production  stage,  but  designed  in  a  way  to  reduce  the  impacts 
occurring during the use phase, including avoiding food wastage 
Using  the  term  Sustainable  Production  Policy  (SPP)  and  SPP  criteria  would  allow  for  a  more 
comprehensive  and  complete  approach  for  the  establishment  of  criteria  aimed  at  improving  the 
sustainability performance of procured food and drink products. We would therefore recommend the 
European  Commission  to  facilitate  the  relevant  process  for  an  eventual  modification  of  the  term 
green for sustainable when addressing public procurement of food and drink products. 
Although the scope of GPP is focused primarily on reducing environmental impacts, it is important to 
acknowledge that the sustainability concept is much broader and includes economic, socio-cultural 
and ecological impacts. 
Proposed criteria should not be considered voluntary for providers of food as once it is adopted by a 
public authority it becomes mandatory for the tenderer. 

The  selection  criteria  for  the  procurement  of  catering  services  referring  to  environmental 
management measures and practices should include GMOs-free production practices 
Please add GMOs-free products both animal and plant based 
In Vienna´s ÖkoKauf food procurement programme, TS for food products from conventional origin, 
GMO-free products are mandatory prescribed. In organic production, GMO-free is automatically set 
by EC Reg. 834/2007. 
We will add another criterion referred to GMOs-free, both for animal and plant-based products. 

Under  name  categories  please  add:  Local  food  products  –  support  diversity  in  food  system  and 
economic growth for farming communities. 

Comment partially accepted 
Wording of the criteria has been modified.  

Comment rejected 
The  scope  of  the  GPP  is  stated  in  the  corresponding 
regulation.  This  policy  tool  addresses  mainly  the 
environmental  aspects  while  the  SPP  is  another  tool 
with a broader scope.  

Comment rejected 
GPP  is  set  as  a  voluntary  tool  and  like  so  should  be 
considered. 
Comment rejected 
No  criterion  is  included  requesting  the  purchase  of 
GMO-free products. reasons for that are 
- most of the GMO products that are consumed in the 
EU market are feed for the animals, only soya can be 
considered as a relevant food product 
-  the  environmental  risk  assessment  is  carried  out  by 
EFSA  in  accordance  with  the  Guidance  Document  on 
the  ERA  of  GM  plants  and  Directive  2001/18/EC.  The 
studies are carried out in a case-by-case base and only 
those considered as safe are allowed to enter into the 
EU market.  
Comment rejected  
Local  food  products  are  not  considered  any  longer  in 
the criteria set.  

127 

 
 
 
 
 
 
 
Environmental 
hotspots 

please add no antibiotics use 

Comment acknowledged 
Provisions including hygiene and medication or the use 
of antibiotics are in place in the different schemes to 
verify criteria.  

Please add soil degradation and potential run-off of excessive nitrogen into near-by waterways in 
monoculture 
please add another point: preservation and economic stability of local fishing communities 
Various policy instruments and industry-led voluntary initiatives have been introduced or are under 
development (see examples in the paragraphs below). Therefore we suggest that a thorough update 
of the proposed TR is conducted in order to understand the current state of play. 
The sustainable production of food is a process of continuous improvement of environmental 
performance, social/ethical circumstances and economic welfare, throughout the food manufacturing 
process and throughout the food supply chain. We believe therefore that the setting of GPP criteria 
should reflect this improvement-driven approach and take into account overall environmental 
performance rather than prescribing specific techniques (e.g. organic production). Moreover, the 
criteria setting should address improvements in the main environmental, welfare and social issues 
relevant to each product category. Criteria should be set on an objective, scientific basis and take a 
whole life-cycle approach. The availability of a robust and science-based environmental assessment 
methodology applicable to food and drink products should be an essential pre-condition for the 
development of these criteria. In this regard the review should take into account the learnings from 
current food sustainable consumption and production initiatives such as the ongoing Environmental 
Footprint Pilots [1] and the deliverables of the European Food Sustainable Consumption and 
Production Round Table [2] on : Environmental assessment methodologies: The ENVIFOOD Protocol 
[3];Communication tools: Guiding Principles on the voluntary provision of environmental information 
along the food chain [4];Continuous environmental improvement: European Food SCP Round Table 
Working Group 3 report [5]; ‘Non-Environmental Aspects of Sustainability’: European Food SCP Round 
Table Working Group 4 report [6] 
[1]http://ec.europa.eu/environment/eussd/smgp/pef_pilots.htm 
[2]http://www.food-scp.eu/ 
[3]http://www.food-scp.eu/files/ENVIFOOD_Protocol_Vers_1.0.pdf 
[4]http://www.food-scp.eu/files/Guiding_Principles.pdf 
[5]http://www.food-scp.eu/files/Continuous_Environmental_Improvement_FINAL_21_November_2012.pdf 
[6]http://www.food-scp.eu/files/Non-Environmental_Aspects_of_Sustainability.pdf 
Product quality should not be a factor in GPP  
Food  categories:  mineral  water  and  soft  drinks  are  mentioned.  In  school  catering  we  avoid  soft 
drinks as much as possible because of health reasons. Mineral water is not purchased because it is a 

Product  group 
categories  

the 

that 

combines 

economic 

Comment partially accepted 
The  criteria  proposed  are  based  on  the  information 
collected 
and 
environmental  performance  of  the  different  food 
products.  
The suggestion of setting the objectives in the criteria 
wording  instead  of  setting  the  methods  to  be  applied 
makes extremely difficult the verification process. This 
limitation is so significant that prevent us to go in that 
direction.  

Acknowledged 
Acknowledged 

128 

 
 
 
 
 
 
 
policy to let everybody use tap water.  
Foodservice segments:  
Caring homes: be careful with elderly people and disabled people because of the habits they have. In 
the  elderly  homes  of  the  city  fair  trade,  organic,  vegetarian,  etc.  isn’t  that  popular  because  the 
elderly  are  not  use  to  it.  They  focus  on  making  rich  food  that  tastes  good.  The  elderly  stay 
approximately 2 years in the homes. The elderly homes will probably need more time before GPP 
will  be  possible.  The  likeliness  of  GPP  being  possible  will increase  over  time  as  future  elderly  are 
expected to be more accustomed to vegetarian food, fair trade products, etc.     
Armed forces: does that include police and fire brigades? For example our professional fire brigade 
cooks themselves a meal every day, so GPP can be interesting for them. 
Ready prepared: the food can also be reheated (if necessary). For example: for school catering the 
meals are ready prepared, but they are stored chilled so we have to reheat before use.  
Assembly-serve: the food is reheated (if necessary) -> for example: a dish with puff pastry can’t be 
reheated - you have to bake it in the oven. If you serve steak, then you can’t reheat it - you have to 
cook it. Maybe it is better to write that the food has to be cooked/reheated (if necessary)? 
Besides ready-prepared there should also be a category for further preparation schemes like (Cook-
and-serve; cook-and-chill) since there are significant environmental impacts regarding thes different 
schemes. 
All  the  food  categories  relevant  for  the  foodservice  segments  are  relevant  for  the  procurement. 
There  should additionally  be  category  for  processed  products.  To  get  offers  also  from  local 
producers there must be possibility to provide products for example into one food category instead 
group.  
of 
In  all  these  food  categories  there  is  possible  to  tender  organic  products.  To  get  good  quality  and 
local products you must compile quality requirements for all products. 
The  “Food  service”  or  “End  user/consumer”  category  should  include  how  food  is  advertised  to  the 
customer base, e.g. plant-based options, to promote sustainable consumption choices. Without this, 
a major opportunity to help shift procurement practices will be overlooked.  

whole 

food 

Product  group 
categories  

The food categories should be expanded to recognise new innovations that do not necessarily fit in 
traditional  categories  but  that  offer  significant  potential  for  sustainability  improvements.  One 
example would be a category for plant-based meat alternatives. 

Product  group 
categories  

Why  wine  was  not  included?  Why  separate  schools  from  kindergartens  (I  think  this  is  the  correct 
designation instead of kinder gardens?) and nurseries. It seems to me the same type of food service. 

Acknowledged 
Processed  food  is  made  of  ingredients  that  should 
comply with the criterion proposed. It does not seem to 
be needed to set up criteria for each product category 
as  they  will  fall  in  one  or  more  of  the  proposed 
criterion.  
Comment rejected 
The scope of GPP does not cover the marketing logos 
to  be  used  or  information  to  be  provided  to  the 
consumers on nutritional aspects 
Comment rejected 
The  food  categories  proposed  as  based  on  the 
traditional  classifications.  Alternatives  classifications 
could be used as long as they are large accepted.  

129 

 
 
 
 
 
catering 

Food 
procurement 
vs 
service 
purchased.  
Environmental 
hotspots 

Criteria  for  direct  procurement  of  food  and  procurement  of  catering  should  be  approached 
differently. 
For food it is important to look at the division into different tenders (and thus different suppliers) - 
you can set the bar high for a specific product range of a separate lot. For catering you need a more 
general approach and it should be a process towards more sustainability. 
Please add the contamination of water through the use of inputs such as antibiotics and pesticides 
common in aquaculture systems 
Please add:  "contamination of near-by waterways or cross-contamination of agricultural fields where 
manure  from  meat  operations  where  pharmaceuticals  used  for  growth  promotion  or  antibiotics  are 
used. Development and spread of antibiotic resistant bacteria due to overuse and misuse of antibiotics. 

It  is  not  enough  to  only  include  environmental  hotspots  in  this  table.  Other  relevant  social 
development  considerations,  including  animal  welfare,  should  be  included,  as  recognised  in  this 
report. This includes relevant categories of animal products that completely ignore animal welfare, 
despite the inclusion in the preliminary report (see, e.g., p. 194, section 3.2.1.4). 
As  with  the  summaries  in  the  preliminary  report,  there  should  be  some  focus  on  the  relative 
magnitudes  of  the  environmental  hotspots  for  different  product  categories.  Generalised  as  it  is 
currently presented discounts some significant impacts, particularly from animal product categories. 
Without  more,  looking  at  this  table,  one  might  incorrectly  think  that  the  environmental  impact 
hotspots  of  fruits  and  vegetables  are  on  par  with  those  of  animal  products.  This  could  lead  to 
incorrect conclusions and poor efficacy of the GPP Guidelines. An additional graph showing some of 
the relative impacts would be useful here. 
For  example,  animal  agriculture  is  responsible  for  approximately  14.5%  of  human-induced  GHG 
emissions globally. According to a report from the Netherlands Environmental Assessment Agency, 
farm  animal  production  is  responsible  for  approximately  30%  of  terrestrial  biodiversity  loss 
globally.  And the impacts and mitigation through consumption changes is significant for Europe, as 
well. Another report, Nitrogen on the Table: On Nitrogen Emissions and the European Environment, 
said that animal agriculture was related to over 80% of the EU’s ammonia, nitrate, and nitrous oxide 
emissions  from  agriculture.  Halving  consumption  of  animal  products  could  nearly  halve  European 
agricultural reactive nitrogen.  Further, a just-released study shows global economic savings based 
on public health and environmental improvements from more plant-based foods.  Such potential co-
benefits should be included here. 
Main  environmental  hotspots  for  Food  and  Catering  Services:  Meat,  Milk  and  cheese,  Eggs  and 
Animal  feed  production  Impacts  on  water  use  and  pollution  are  glaringly  absent  from  the 

Comment accepted 
The  wording  of  the  criteria  has  been  modified  to  let 
procurers to focus on their points of interest and to set 
the ambition levels that they consider best 

Comment accepted 

Comment rejected 
The  proposed  sentence  is  out  of  the  scope  of  the 
current GPP and there are no means of verification for 
the specified requirement in food products. 
Comment rejected 
Even if some of the criteria proposed address hotspot 
beyond  the  strictly  environmental  ones,  the  section 
focuses on the environmental impacts/ 
Comment accepted 
Revision of the wording has been carried out 

Comment accepted 
Revision of the wording has been carried out 

130 

 
 
 
 
 
environmental hotspots in Table 5. This is particularly significant for animal products, since animal 
agriculture uses significant amounts of the water supply available to humans globally. For example, 
in terms of protein, the water footprint is six times bigger for beef, and one and a half times larger 
for chicken, eggs and milk, than it is for legumes.  Not only are water supplies shrinking, the farm 
animal  sector  is  increasingly  polluting  the  available  water.  According  to  the  FAO,  “The  livestock 
sector…is probably the largest sectorial source of water pollution, contributing to eutrophication, ‘dead’ 
zones  in  coastal  areas,  degradation  of  coral  reefs,  human  health  problems,  emergence  of  antibiotic 
resistance and many others.”  
In the Preliminary report, the JRC conducts a thorough scientific analysis of sustainability hotspots in 
the  lifecycles  of  food  and  drink  products.  We  understand  this  analysis  should  be  prominently 
reflected in the GPP-criteria setting (see for example below comments on organic production). 
Main environmental hotspots: Fruit: can refrigeration be added?  
Vegetables: can long distance transport (see fruit) be added?  
Oils and fats: isn’t land use an issue here also?  
Hot  drinks:  coffee  and  cocoa  (there  are  only  drying  tea  leaves)  are  not  included,  and  transport  is 
probably also an issue here?  
Overview environmental hotspots: Fruit: biodiversity is important. Can you add mono-culture?  
Main environmental hotspots: cold drinks: what about heavy duty cleaning in the bottling process 
We would like to propose in Food section "Technical specifications" to provide additional GPP criterion 
“Sustainable  food  delivery”,  delivery  of  the  environmentally  friendly  products  from  the  place  of 
production  in  a  way  that  reduces  the  air  pollution  by  exhaust  gases  and  load  on  the  road 
infrastructure. 
Sustainable deforestation = sustainable land use 
Main improvement potential is better land use, no deforestation and social/labour standards 
In the list of "…organic, IP, seasonal, more sustainable products" "regional p." should be added, due to 
their generally minor "CO2 rucksack"   
To us, most of the key sustainability aspects would seem to apply to both the “Food procurement” 
and  “Catering  services”  categories.  For  example,  animal  welfare  criteria  should  be  a  part  of  food 
procurement and catering decisions, yet it is absent from the latter here. Similarly, procurement of 
products with lower sustainability footprints, for example more plant-based foods, is important to 
both categories, yet it only appears vaguely in the “Catering services” category. HSI believes animal 
welfare and selection of more plant-based foods are appropriate for both areas.  
Unfortunately,  the  TR  carries  over  the  environmental  and  ethical  categories  as  singular 
considerations from the Preliminary Report,  for example sections 4.5.1.6 and 4.5.1.7 on less meat 

Environmental 
hotspots 

Environmental 
hotspots 

Environmental 
hotspots 

vs 

Food 
catering 
services 

Comment accepted 

Comment partially accepted 
The  table  with  the  environmental  hotspots  has  been 
modified aiming to provide clearer information.  

Comment rejected 
A  criterion  on  transport  is  set  in  the  catering  service 
criteria.  procurers  can  mirror  this  criterion  if  they 
consider that it is appropriate for their purposes 
Comment rejected 

Comment rejected 
The Catering service criteria set include a criterion food 
procurement that encompasses all the criteria included 
in  the  Food  procurement  criteria.  therefore  it  is  not 
need to repeat all the criteria in the catering service set 

Acknowledged 

131 

 
 
 
 
 
and  animal  welfare. However,  the best  GPP  opportunities lie  in  choices  that maximize  co-benefits 
and avoid or mitigate negative trade-offs. This is particularly important for animal-derived products 
in  both  production  criteria  and  consumption  choices.  On  the  production  side,  for  example, 
opportunities  to  improve  animal  welfare  and  climate  change  impacts  exhibit  areas  of  co-benefits 
and  trade-offs.  Shields  and  Orme-Evans  (2015)  outline  these  areas  and  show  that  a  number  of 
opportunities  to  achieve  co-benefits  exist.   Unfortunately,  the  Preliminary  Report  (section  4.5.1.7) 
only  mentions  trade-offs.  Instead,  the  GPP  criteria  should  seek  and  support  co-benefits. 
This is similarly important on the consumption side, where some animal products may have lower 
relative environmental impacts than others but also have worse impacts for animal welfare, A more 
holistic  analysis  of  combined  impacts  would  make  clearer  the  better  ethical  and  environmental 
consideration of plant-based options, and allow for more sustainable procurement choices overall. 
Finally, identification of innovative approaches, for example through the INNOCAT report, as well as 
areas in need of further research, should be identified. 
These should be included in both the aspects and improvement area portions of Table 6. 
Using terms such as green or environmentally friendly in several sections in the TR does not comply 
with ISO 14021:1999 self-declared environmental claims (Type II environmental labelling).  
ISO states that “an environmental claim that is vague or non-specific or which broadly implies that a 
product is environmentally beneficial or environmentally benign must not be used”. This concept 
neither complies with the Commission’s guidance on the implementation/application of Directive 
2005/29/EC on Unfair Commercial Practices [1] and Guidelines on environmental claims [2] 
[1] European Commission Directorate-General Health & Consumer Protection, Guidance on the implementation/application of Directive 
2005/29/EC on Unfair Commercial Practices, 3 December 2009, SEC(2009) 
[2] European Commission, Directorate-General Health & Consumer Protection. Guidelines for Making and Assessing Environmental Claims. 
December, 2000 
FoodDrinkEUrope  supports  the  proposal  to  introduce  a  new  criteria  on  food  waste  reduction  in 
catering through training and food waste minimisation plan 

In the first instance, organic production should be clearly acknowledged as the only farming system 
that  is  a  legally  recognised  and  certified  standard  for  production  and  labelling  and  marketing  in 
more  than  80  countries  or  regions  including  the  EU-28.  This  should  be  clearly  highlighted  in  the 
criteria  and  better  reflected  in  the  overall  technical  report.  This  harmonised  approach  is  further 
developed  in  different  Member  States  through  national  and  private  standards  which  reflect  the 
specific cultural, structural, geographic and climatic diversity of individual countries and regions and 
helped to pioneer further progress in sustainability.  
In some cases, organic standards for mass catering have been developed in a number of Member 
States.  Given  the  limited  intra-community  trade  and  national  specificities,  organic  mass  catering 

among 

Link 
criteria 

Comment accepted 
Wording  has  been  amended.  The  Type 
II  for 
environmental  labels  is  not  accepted  as  proof  of 
compliance with the criteria due to the lack of external 
verification.  

Comment accepted 

Comment accepted 

132 

 
 
 
Green 
sustainable 

vs 

standards  remain  outside  the  scope  of  the  EU  regulation  on  organic  production  and  labelling  of 
organic products. 
Although the scope of GPP is focused primarily on reducing environmental impacts, it is important to 
acknowledge that the sustainability concept is much broader and includes economic, socio-cultural 
and ecological impacts 

Comment rejected 
In  accordance  with  the  GPP  regulation  environmental 
aspects  should  be  addressed  first.  Other  sustainable 
aspects can also be covered on voluntary basis  

Annex 3. 

Table of stakeholder's comments on the Technical Report v1 

3.1.  Table of stakeholder's comments on the propose criteria for EU GPP criteria for Food procurement 

This section presents the comments received through BATIS and personal communication from the 1st AHWG meeting to the 2nd AHWG meeting.  

Organic food products 

This section presents the comments received through BATIS and personal communication from the 1st AHWG meeting to the 2nd AHWG meeting.  

Table 30. Feedback from the stakeholders on the TR1.0: Organic food products (TS1 and AC1) 

Topic 
Criteria  
overview 

Feedback from stakeholders 
This  should  be  the  (a) goal  that  should  be  mentioned  in  the  criteria.  Organic  is  not  the  goal. 
Organic  is  the  label  to  verify  that  this  goal  is  realised.  An  integrated  Production  label  can  be 
another possibility. 

Sometimes  better  to  specify  what  products  are  of  interest,  i.e.  only  accept  organic  milk 
and organic and/or ethically certified bananas for food products. 

JRC-Directorate B5 assessment 
Comment partially accepted 
The  wording  of  the  criterion  tries  to  follow  the  standard 
wording; which most of them do not include the goals to be 
achieved.  Labels  are  the  tools  to  verify  the  criterion.  IP  is 
another criterion.  
Contrary to the procurement purchase schemes (private), the 
Regulation 
the 
requirements  set  in  the  Public  Procurement  Directive  to  be 
required directly. 
Comment rejected 
By  setting  a  general  threshold  (not  specific  thresholds 
depending on the type of food products), flexibility is given 
to the tenderer to choose those products that are available 
in his/her area and that better meet the requirements of the 

(EC)  No  834/2007 

complies  with 

133 

 
 
 
 
 
 
 
 
Topic 

Feedback from stakeholders 

Certifications 
and 
verification 

vs 

Catering 
food 
procurement 

Ambition levels 

Farming methods that aims to have a low impact on the environment (e.g. no or low pesticide use 
and  no  synthetic  fertiliser  use).  (Working  with  ecosystems).  Organic  production  is  regulated  by 
Council Regulation (EC) No. 834/2007. All organic food, both fresh and processed fall under this 
regulation. 
SMEs represent 99.1% of Europe’s food and drink companies [Eurostat 2011]. When developing 
the new GPP requirements it is essential to consider the SME perspective. For example focusing 
exclusively on product certification as a core criterion for verification of the GPP requirements, 
whilst it might benefit larger food chain players, may present financial barriers for SMEs. Both 
SMEs and larger food chain players should be able to prove to tendering governments they meet 
GPP criteria in a verifiable and objective manner. Product or process certification should therefore 
be considered as one means to verify such compliance and not the only option. Other tools should 
be permitted to prove compliance with these criteria. 
We wish to stress the importance of public procurers carefully monitoring targets overtime, so 
that goals to reach a certain percentage of organic can be met. It is important to note in the case 
of catering, as there is no obligation to certify mass catering, there is no solid basis to control the 
percentage  to  be  achieved.  If  mass  catering  is  to  remain  outside  the  scope  of  the  EU  organic 
legislation, encouraging the uptake of legally binding obligations, at national and regional level, 
can be a means to better control the procurement of organic products. 
A demand of percentage is only relevant when a mixed range of products (or a catering service) 
is  procured.  When  a  unique  product  is  procured,  it  is  either  0%  organic  or  100%  organic.  A 
percentage can be set as a goal for the whole procurement policy (when monitoring is possible). 
Specifications can be made on product level in the inventory of the tender. A fixed percentage 
can't be copied in every (food) tender. 25% / 50% as  an overall goal will stimulate sustainable 
production methods. One might discuss the feasibility of this percentage, but since the guideline 
is voluntary, I think it is necessary to set the bar high enough. The guidelines should state out 
how to incorporate more organic within the general policy. 
Professional kitchens are important factor in increasing the organic market because of their big 
usage volumes. There for it is important that the ambition levels are set high enough. We agree 
that percentage set to 25% (core) and 50% (comprehensive) are ok and these levels are feasible. In 
Finland the public kitchens personnel are very interested to increase amount of organic products. 
At the moment organic food is difficult to get because lack of availability and higher price than 
conventional products. Therefore it is important that organic products are in procurement criteria. 

JRC-Directorate B5 assessment 
criterion 
Acknowledged 

Comment partially accepted 
The verification of the organic food products can be carried 
out  by  any  third  party  verified  schemes  that  complies  with 
the requirements set in the Regulation (EC) No 834/2007.  
Even  if  the  certification  implies  additional  costs  for  the 
companies, it is a reliable tool to check and communicate the 
nature of the product.  

Acknowledged 

to  cover 

Comment partially accepted 
The  percentage  of  organic  products  is  considered  the 
broader  approach 
the  diversity  of  public 
procurement  across  Europe.  Additionally,  even  if  only  one 
product is purchased, a percentage could make sense if this 
product is a perishable one purchased along the year. Some 
batches can consist of organic product and some others do 
not.  
Comment accepted 
The percentages of the organic food could be set in cost or 
weight. The consequences of setting the percentages in cost 
or  weight  could  be  significantly  different,  due  to  different 
reasons: the availability of products, the relative price of the 

134 

 
 
 
 
 
Topic 

Feedback from stakeholders 
This will  bring  out  the  demand  of  organic  products.  This  will  also  increase  the  organic 
farming, production  and  product  development  for  suitable  products  for  professional  kitchens. 
Organic is accepted criterion in tendering by procurement. 
Product testing enables to get more organic products into kitchens.  Testing is one part of menu 
planning. So it is possible to get involved to procurement agreement with public sector. Because 
organic products are more expensive the menu planning is important for increasing the usage of 
organic  products  in  public  kitchens.  (More comments  in  menu  planning).  In  organic  production 
animal  welfare is  more  strictly  controlled  than  in  conventional  production.  That´s why  it 
is possible to claim antibiotic and GMO free meat and dairy products in procurement.   
Probably too high with respect to the seasonal availability of organic products. Procurement of 
organic food with high transport burden is definitely counter productive 
This is not a recommendation for organic production.  
It does not support the TS for 25% organic products. 
The tendering documents are usually drafted with the wanted product groups listed and for those 
where organic alternatives are available this is set as a criterion for that particular product group. 
Thus, the procurer will separate the level of organic food within milk products, cereal products, 
meat products etc. And this is based on the market availability for each product group. The 
suggested criterion does correspond to how the procurement technical documents are drafted. It 
has more the character of an ambition level. The suggested 25% level of organic food is not 
realistic in many countries/cities. In Finland only 2% of the production is organic so 98% of the 
production is left outside. Thus, market availability is the biggest challenge for the criteria in 
Finland.  
The technical report does not sufficiently analyse the cost implications of the recommended 
criteria. Organic food is still generally more expensive, which makes the 25% level unrealistic for 
most public authorities. In order to raise the level of organic, changes in menu planning are 
needed for instance by reducing the amount of meat. 
We believe that a 25% target for the core criteria and 50% target for the comprehensive criteria 
are too high. For instance, in France there has been an obligation to reach a 20% organic food 
target by cost for some time but it has not been achievable for the vast majority of cantinas. The 
market availability varies greatly from one country to another, so it is impossible to suggest a 
workable target for the EU-28. 
I agree on the percentage. It’s a good ambitious amount to try to reach. The percentage is ok, but 
is it not too high for some countries? Ghent should be able to reach 25% (in mass), but the 50% 

JRC-Directorate B5 assessment 
products, the needs of the clients, etc.  
Generally  speaking,  a  higher  threshold  (in  absolute  value) 
could be set in percentage of weight than in percentage of 
cost.  This  was  in  agreement  with  this  feedback  of  the 
stakeholders 
The  ambition  level  of  this  criterion  has  been  revised. 
Opposite  comments  have  been  received  concerning  to  this 
point.  
Considering  the  information  analysed  below  and  related  to 
the units for expressing the thresholds, it was considered not 
appropriate to specify neither the units nor the thresholds.  
A generic wording is proposed in this criterion that should be 
read  together  with  the  explanatory  notes.  The  explanatory 
notes  thus  include  examples  of  possible  combination  of 
thresholds  and  units 
the 
for  both 
comprehensive criteria.  
For example, if the contracting authority selects the criterion 
to  be  expressed  in  mass,  the  recommended  percentage 
thresholds  are  in  the  range  of  20  to  60%  and  higher  than 
50% for the core and comprehensive level, respectively.  For 
example  the  contracting  authority  can  propose  a  minimum 
20%  of  organic  food  products  (keeping  this  value  as  the 
minimum recommended value) or go for 60%.  
If  the  contracting  authority  selects  the  criterion  to  be 
expressed  in  cost,  the  recommended  percentage  thresholds 
are 10-30% for the core level. The ranges work in the same 
way as explained before.  
The  lower  values  are  considered  to  be  feasible  and  the 
higher values are considered to be more challenging. 
Procurers are required to assess the possibilities of the area 
for which this criterion is going to be proposed. 

the  core  and 

135 

 
 
 
JRC-Directorate B5 assessment 

Topic 

Feedback from stakeholders 
will not be easy to reach knowing that the percentage organic farming in Belgium is very small so 
the food products will have to be purchased all over Europe. 
Latvia considers that requirement set up in the Section "TS"  that specific gravity of organic 
products has to be at least 25% (in the comprehensive criterion 50%) of total annual 
procurement costs of food and drinks, is disproportionately high and does not comply with real 
situation in Latvia regarding to production and processing of organic products. For example, in 
2014 only about 3% of total biological agricultural products in Latvia have been reprocessed. 
Although range of organic products is wide, but compared to total food market, it is still quite 
small. In addition, in the report (Market Analysis, page 12) is specified that in several EU 
countries, including in Latvia, organic products` market is poorly developed. 
For us, these levels are just the point of departure, thus they should be increased gradually and 
have to be measurable. For this reason, we will support any policy that encourages local and 
small-scale producers. 
In general I agree with the levels set. As a matter of fact the expression as total procurement 
costs seems to be in some instance difficult since the cost do not express the ecological impacts 
in any case (e.g. compare the costs and the impacts of meat and by products like 
cereals/potatoes/pasta).  Maybe it would be better to express these ambition levels as % based 
on the main food types (meat, pasta, seafood, ...) 
The levels of core and comprehensive can be OK but can be very costly. Sometimes better to 
specify what products are of interest, i.e. only accept organic milk and organic and/or 
ethically certified bananas. And if not delivered what is the penalty of the supplier? 
In Vienna, an "organic quota" of 30% (monetarily) was already set in 1999 in the Viennese Climate 
Protection Programme KliP, being mandatory for keeping to it (despite budget constraints) 
because concluded in the City Council. In kindergartens the quota is even 50%, in all-day public 
schools 40%. 
In the experiences from Copenhagen, stemming from the process of converting the entire public 
food system to consist of 90 % organic produce, the first goal to strive for when converting to 
organic should typically be 30%. This level of organic, measured in weight, corresponds with a few 
basic and quite common food groups, and most types of kitchens can reach 30 % by converting 
potatoes, milk and some fibrous vegetables like cabbage and roots. Another way of achieving 30% 
is to begin with flour and grains, by switching to organic versions and by baking organic bread, 
thereby substituting conventional and often costly bake-off products with a homemade organic 
product of lower cost. Often this method requires training or support from an organic conversion 

136 

 
Topic 

Feedback from stakeholders 
consultant to achieve a satisfactory result if baking is not in the individual kitchens usual 
repertoire. Baking, along with potatoes and milk, will land most kitchens between 30 - 40 % 
Answers to the consultation questions to stakeholders: 
o Do you agree with the ambition levels set (% for the criteria) for the technical specifications 
and award criteria?  I agree with the ambition levels set. 25% is not ambitious by Danish standards 
where Organic Denmark is working towards a goal with 60% organic in all public meals but since 
the guide covers the entire EU I believe it’s a satisfactory goal.  
The Copenhagen House of Food (our organic conversion expert) has this argument: “At 30% 
organic conversion there is a risk that the quality of the kitchen will decrease or the costs will 
increase, because most kitchens will convert and not reschedule. Only at 50-60% you can be sure 
that the work transitions in kitchens will change and the amount of waste will be reduced. We 
have experienced that the real change happens at 50% and 75%. 
We are broadly in agreement with the ambition levels set. A number of local authorities start off 
by asking for 20% organic – it might be worth lowering the core criteria to 20%. 
Allowing the use of organic indications such as only one ingredient (e.g. organic potatoes) or one 
component (e.g. all vegetables) in a mixed menu should be considered as part of the criteria. 
Minimum percentages of organic ingredients could also be specified. 
IFOAM EU welcomes the fact that there is a percentage on the organic produce required (25% in 
core criteria and 50% in comprehensive criteria). Having a percentage means that there is a clear 
target that must be achieved. The percentage of organic products should be regulated in two 
steps. First there should be a specific percentage of those products that can be sourced 100% 
organically. A second step would allow specific organic products to take up core criteria (25 %) 
with others accounted for in comprehensive criteria (50%). 
The % threshold could also be further defined based on an assessment of the availability of 
organic products. 
It is important to remember that a percentage requirement is not always relevant as the more 
specific the procurement requirements are, the less relevant the use of a percentage is. For 
instance, in relation to the procurement of specific products e.g. tea and coffee can be purchased 
100% organic. As a result, further guidelines in this regard could be considered 

JRC-Directorate B5 assessment 

See above 

Comment accepted  
Considering  the  information  analysed  below  and  related  to 
the units for expressing the thresholds, it was considered not 
appropriate to specify neither the units nor the thresholds.  
A generic wording is proposed in this criterion that should be 
read  together  with  the  explanatory  notes.  The  explanatory 
notes  thus  include  examples  of  possible  combination  of 
the 
for  both 
thresholds  and  units 

the  core  and 

137 

 
 
 
JRC-Directorate B5 assessment 
comprehensive criteria.  
Acknowledged 
Updated data have been considered during the revision 

See above 

Topic 

Feedback from stakeholders 

Market data 

Units 

The organic market continues to grow year on year (on average 6% per year) reflecting the 
demand amongst EU consumers for high quality food production that supports the environment, 
animal welfare and rural development. In the last decade alone, the EU market doubled in value 
from €11.1 billion in 2005 to €24 billion by 2014 (€11.9 billion to €26.2 billion in Europe). At the 
same time, the latest production and market data demonstrate a challenge in filling the gap 
between growing market demand and the development of the supply base (Stolze et al., (2016): ). 
The data used in the technical report are out-of-date, given that they are from 2011. The latest 
data available is from 2014, hence the report should be updated to ensure that the information 
is correct. On top of this, it needs to take into account that there is limited data regarding intra 
EU-trade and organic farming. Information of the latest market as well production trends can be 
founded in Organic in Europe: Prospects and Developments (http://www.ifoam-
eu.org/sites/default/files/ifoameu_organic_in_europe_2016.pdf) 
I agree to be in cost 
We believe that although total procurement cost is one of the most widely used metric, for this 
criterion, at least, we propose to focus on the total number of dishes of the menu. There is 
already one experience in Málaga (Spain) that is working under this approach: 
http://mensacivica.com/se-inaugura-en-malaga-la-primera-cocina-central-certificada-para-
platos-100-ecologicos/ 
Organic products are more expensive than conventional products on average. The Preliminary 
Report notes that organic eggs in Germany are at least double the price of conventional eggs 
(FiBL and IFOAM, 2014). As another example, the price of organic milk has increased by 30% 
while the average tender offered by public authorities has not increased. In other words, prices of 
organic food are more expensive but this is not compensated for in the tenders being offered by 
public procurers. This makes meeting the current organic criteria, which is based on volumes of 
specific products very challenging to meet when prices of those products increase or when the 
products are not available. 
Switching to a value-based approach allows contract caterers to choose what kind of organic 
products to procure depending on price and availability. This alleviates this challenge to some 
extent. However, we cannot support setting a percentage without a thorough market analysis that 
shows that the percentage would be feasible for all regions, because availability differs greatly 
from one country to another. For instance, according to recent studies, only 1.0% of global 
agricultural land is certified organic. As the Preliminary Report notes, apart from northern 
European countries, there is a lack of production capacity for organic meat due to high prices 

138 

 
 
 
Topic 

Vending 
machines 
relation 

Feedback from stakeholders 
compared to conventional production (FiBL and IFOAM, 2014) (ITC 2015) 
Cost as the basis for calculation is an option when procuring catering. When procuring food 
specifications should be made in another way; e.g. on product level or number of product 
references that are organic 
Revise the criteria on organic food with regard to express the criteria in terms of weight (or mass) 
of the total procurement amount of food and drink products within the contract instead of 
expressing the criteria in terms of the total procurement costs (or give the choice between these 
two possibilities) 
The percentage should be measured in mass and in cost. Mass is more stable than cost. However, 
when you reach a high percentage of organic food, mass is no longer more stable than cost (see 
Copenhagen). 
Procurement criteria should be expressed in terms of percentage mass as well as (or instead of) 
%cost. 
In general I agree with the levels set. As a matter of fact the expression as total procurement 
costs seems to be in some instance difficult since the cost do not express the ecological impacts 
in any case (e.g. compare the costs and the impacts of meat and by products like 
cereals/potatoes/pasta).  Maybe it would be better to express these ambition levels as % based 
on the main food types (meat, pasta, seafood, ...) 
The percentage should be measured in mass and in cost. Measuring in mass will also support 
converting a few basic and quite common food groups like potatoes, milk, flour, grain and some 
fibrous vegetables like cabbage and roots. These products also have a high impact on the 
environment when converted. 
We agree to express the criteria in terms of the total cost of food and drink products purchased 
within the contract. This reflects the reality that it is very difficult to get reliable data on the 
weight, as lots of products have differing weights and data is not available for many products 
bought per item e.g. eggs, bread etc. Difference between the weight of produce and processed 
products is also not easy to define, as well as for minimally processed produce e.g. peel fruits 
and vegetables. In order to ensure a simple and effective approach to keep administrative burden 
to a minimum (including those associated with certification), price is the most useful indicator. 
Very relevant for vending machines for coffee, tea and chocolate. There are organic products 
(coffee, the, chocolate and milk) and/or ethically certified Fairtrade/Rainforest 
alliance/Utz (coffee, the, chocolate). 

JRC-Directorate B5 assessment 

Acknowledged 

Comment accepted 

Comment partially accepted 

Comments accepted 
There is an unanimous agreement on the following points:  
-  the  criterion  on  organic  products  is  relevant  for  vending 
machines,  especially  for  those  that  offer  coffee  and  other 

139 

 
 
 
 
 
Topic 

Feedback from stakeholders 

For vending machines, we agree with a % threshold, but more details on the development and 
application of criteria are needed. 
Is this criterion particular relevant for vending machines (e.g. organic coffee and sugar)?  
If so, must we have a threshold for the % of organic in vending machines? The criterion is very 
relevant for vending machines, and the percentage can reach 100%. That is what we use for our 
coffee machines. The products we buy are both organic and fair traded. 
Again:  coffee  or  sugar  is  either  organic  or  not.  A  coffee  machine  offers  organic  coffee  or  non-
organic coffee; a % is not relevant - it should be a 100% organic. ( only in a contract with more 
machines 
interesting) 
For other vending machines with for instance candy bars the criteria should indicate how many 
products that are offered should be organic (100% on product level) 
It’s very relevant for vending machines. Coffee, tea and sugar can be easily 100% organic and 
even 100% organic-fair trade. I consider this as a quick win to be able to get reach the set % 
goal. 
The advantages of organic coffee are more disputable, we don't ask for organic coffee any more. 
Just 'fairly traded' 
Develop a guideline that explains how these criteria can be used for vending machines 

would 

can 

set, 

but 

not 

be 

be 

% 

a 

JRC-Directorate B5 assessment 
hot beverages.  
-  organic  and  fair  traded  products  are  on  the  market 
(especially  when  considering  hot  beverage  machines) 
Therefore,  both  criteria  are  complementary  and  can  be 
required simultaneously.  
-  the  good  market  availability  and  the  few  number  of 
products  supplied  in  the  hot  beverage  machines  (coffee, 
sugar, chocolate, tea, etc) makes possible to set an ambition 
level of 100% in mass.  
For  other  vending  machines  (e.g.  snacks)  this  threshold 
should be revised.  
Vending  machine  criteria  will  be  included  into  the  catering 
service criteria as a sub-group.  
See section 4 where the proposed vending machine criteria 
are detailed 
See above 

See above 

See above 

Comment rejected 
See above 
Comment rejected 
Unfortunately,  the  tool  does  not  provide  the  possibility  of 
developing  guidelines  explaining  in  detail  how  the  criteria 
can  be  used  for  vending  machines  or  any  other  aspect. 

140 

 
JRC-Directorate B5 assessment 
However,  the  tool  gives  the  opportunity  of  providing  some 
explanatory notes, where this comment will be considered.  
Vending machines criteria are included as a subgroup in the 
catering service criteria 
Comment accepted 
Comment accepted / Acknowledged 

Acknowledged 

Acknowledged 

Topic 

Feedback from stakeholders 

Scientific  base/ 
Rationale 

Products instead of produce. Organic is more than fresh produce. 
Organic agriculture as such is not by default a guarantee of better environmental performance 
for  all  impacts  categories  related  to  food  production.  More  specifically,  the  environmental 
analysis  by  the  JRC  on  Organic  Food  concludes  that  there  is  insufficient  evidence  available  to 
suggest  that  organic  products  have  overall  a  lower  environmental  impact  than  conventionally 
produced  products  [1].  Similarly  there  is  also  little  evidence  that  supports  the  better  effect  on 
human health of organic products over traditional ones. 
A  major  source  missing  in  the  descriptions  of  environmental  hotspots/side-effects  of  food 
production  in  any  type  of  plant  production  are  the  GHG  emissions  (NOx)  of  inadequately 
cultivated  soils.  One  of  the  major  environmental  benefits  of  organic  farming  are  less  GHG-
emissions from cultivated soils (see e.g. Skinner et al. 2014).  
Organic production and the related manufactured foodstuffs can contribute to the sustainability 
of food systems mainly in niche product areas. However, from a GPP criteria perspective, organic 
agriculture  as  such  is  not  by  default  a  guarantee  of  better  environmental  performance  for  all 
impacts  categories  related  to food  production.  More  specifically,  the  environmental  analysis  by 
the JRC on Organic Food concludes that there is insufficient evidence available to suggest that 
organic  products  have  overall  a  lower  environmental  impact  than  conventionally  produced 
products  [JRC  2016b].  Similarly  there  is  also  little  evidence  that  supports  the  better  effect  on 
human health of organic products over traditional ones. Furthermore the overall objective of GPP-
policy  is  to  stimulate  innovation  in  environmental  technologies,  products  and  services  [EU  GPP 
2008] and not to specifically support one production technique over another.  
In addition, having GPP criteria focusing exclusively on organic certification rules out the majority 
of food production and all the environmental improvements and development potential that is 
related to other means of production. 
Finally according to recent studies [ITC 2015], only 1.0% of global agricultural land is certified 
organic. Such figure raises questions about the real availability and pricing of organic products 
for public procurement in the EU and contrast argumentations provided in the technical report 
justifying that organic products are available throughout EU members and organic products are 
currently being used either as mandatory or optional requirements in public tenders [JRC 2016b]. 

141 

 
 
 
Topic 

Feedback from stakeholders 
This reasoning does not robustly justify the selection of organic production as a criterion for GPP. 
The foundation of GPP criteria should be objective and factual. 
According to recent studies [ITC 2015], only 1.0% of global agricultural land is certified organic. 
Such figure raises questions about the real availability and pricing of organic products for public 
procurement in the EU and contrast argumentations provided in the technical report justifying 
that organic products are available throughout EU members and organic products are currently 
being used either as mandatory or optional requirements in public tenders [JRC 2016b]. This 
reasoning does not robustly justify the selection of organic production as criteria for GPP. The 
foundation of GPP criteria should be objective and factual. 
The technical report relies significantly on the use of Life Cycle Assessments (LCAs), comparing 
organic and conventional agriculture as the basis for the development of the GPP criteria. While 
LCAs offer a very precise quantitative overview of environmental impacts, they are not a panacea 
as they only address certain environmental aspects. However, they tend not to take into account 
the multi-functionality character of sustainable agriculture systems in particular aspects related 
to  biodiversity  and  soil  fertility  where  organic  is  a  forerunner.  As  a  result,  LCAs  that  compare 
organic  and  conventional  systems  currently  do  not  to  take  into  account  the  multitude  of 
differences  between  farming systems  and  the  products  produced  and therefore  not  comparing 
like with like. The use of LCAs in the technical report is extremely narrow as it is based on the 
product  itself,  not  taking  into  account  the  background  of  the  enterprise.  While  a  variety  of 
different  approaches  has  been  developed  for  assessing  aspects  of  sustainability  in  the  food 
sector and agricultural production, these do not always have a clear definition of sustainability 
and different and inconsistent indicators can lead to contradictory assessment results that may 
not be comparable. 
Therefore,  we  question  the  over-emphasis  on  the  results  of  a  patchwork  of  LCA  studies  for 
organic food products. 
Given  the  limitations  of  the  LCAs,  only  existing  studies  that  have  conclusive  results  with 
significant differences between farming systems and products covering all environmental aspects 
should be considered in the first instance, with elements of sustainability also taken into account 
in the second instance. 
The EEB considers the arguments given in the technical report for integrating a criterion on 
organic food in public tenders as being rather weak and not very convincing. Therefore, the EEB 
thinks that the justification for defining TS on purchasing organic food in GPP needs to be revised. 
Since switching to the purchase of organic food products normally leads to higher purchasing 
costs, it is very important to deliver strong arguments for this criterion. 

JRC-Directorate B5 assessment 

See above 

Acknowledged 
GPP revision of criteria is science based  

Acknowledged / Comment accepted 
The rationale provided in the last TR1.0 cannot be changed 
at  this  stage,  but  the  provided  comments  have  been 
considered  to  draft  the  TR2.0  and  the  rationale  of  each  of 

142 

 
Topic 

Feedback from stakeholders 
At the same time, the EEB would like to emphasize that a certain % of organic food products can 
be purchased even without any increase in costs by changing the meal composition: e.g. lowering 
the percentage of meat and dairy products and substituting them by cereals and vegetables, as 
well as by buying fresh food according the seasonal offer of the region and establishing local 
food purchasing chains. The example of a project run by city of Munich called “Bio for Kids” 
demonstrated that it is possible to purchase even 100% organic food with an overall cost 
increase of only 13,3% compared to conventional food. 
(http://www.muenchen.de/rathaus/Stadtverwaltung/Referat-fuer-Gesundheit-und-
Umwelt/Bio_regional_fair/Biostadt_Muenchen/Leitprojekte/Bio_fuer_Kinder.html) 
Although the EEB is aware that in general the EU GPP criteria need to be based on the results of 
LCA studies, this only makes sense in our view when existing LCA studies come to conclusive 
results based on significant differences between the systems under considerations. In the case of 
organic versus conventional agriculture this is obviously not the case, mainly due to the 
overwhelming variety of existing agricultural systems. Therefore, in this case, the EU GPP criteria 
should take scientific results beyond LCA methodology into consideration. As a consequence, the 
EEB strongly recommends not focusing the argumentation for organic food products solely on the 
results of LCA studies. 
In addition, the EEB would like to stress that the results of those LCA studies cannot easily be 
generalized. The results of the different LCA studies are always given for the defined scope and 
system so that they cannot easily be compared. It is also obvious that with regard to the 
overwhelming existing variety of agricultural systems, there is big lack of data. This has also 
been confirmed e.g. by the results of the pilot study on meat products to establish Product 
Category Rules in the Environmental Footprint process coordinated by DG Environment. 
Not at all. The scientific analysis by JRC itself shows that organic cannot be unequivocally 
considered the better option environmentally. It is highly misleading for both supply chain actors 
and consumers to maintain organic procurement as a TC and thereby suggest it to be the 
greenest option.  
"…organic products…larger eutrophication acidification potential compared to conventional products 
(in particular for livestock production due to manure emissions and more extensive land 
use)….reasoning why organic larger environ. Impact than conv. is more land to grow crops...more 
feed for animals because they live longer..."  
To my opinion, this argumentation is misleading, because it completely neglects the type of 
stock-keeping, see also comment nr. 10. A recently released meta-study on milk and meat from 
organic vs. conventional production brought evidence about significantly higher content in healthy 

JRC-Directorate B5 assessment 
the proposed criteria.  
There are arguments in favour and against the inclusion of 
the  criterion  on  organic  food  in  the  GPP.  Most  of  them  are 
difficult to quantify. 
For additional information check section 2.2.1 

Acknowledged 

Acknowledged 

143 

 
Topic 

Other:  meat 
reduction 

JRC-Directorate B5 assessment 

Acknowledged 

Acknowledged 

Feedback from stakeholders 
omega 3 fatty acids, mainly due to better feeding and livestock-keeping in organic. The findings 
are based on 196 studies for milk and 67 for meat.   
The rationale of using an LCA approach seems narrow and the methodology used has been 
severely criticised by both FIBL and IFOAM. These do not take account of broader environmental 
aspects such as soil quality, water pollution etc. 
It may be worth rather considering broader aspects of organic food which have positive 
environmental impacts when compared to conventional agriculture. For example, organic farming 
methods exclude the use on neo-nicotinic fertilisers which are having a detrimental effect on bee 
population. 
Organic production and the related manufactured foodstuffs are a natural part of the 
sustainability discourse. However, from a GPP criteria perspective, organic agriculture as such is 
not by default a quality guarantee of better environmental performance in absolute terms. Hence, 
organic does not equal to more environmentally friendly; a label on organic produce is not an 
eco-label. Rather, it is just one alternative way to produce raw materials for foodstuffs among 
other production methods. At the moment the share of organic produce available on the market 
is marginal. Emphasizing organic produce within the GPP framework leads to ruling out the 
majority of foodstuffs and raw material for food outside the concept of GPP. ETL finds this 
problematic as this approach excludes the potential related to the so called conventional and 
other production methods available that the majority of food production is currently based on. 
This is not supported by scientific evidence! Studies show varying results in terms of health 
benefits of organic, with the most positive ones even reporting health benefits are next to 
negligible. Organic producers are not allowed to make health claims, so the government should 
neither. 
For the additional TS/AC on reduced animal-based and increased plant-based foods, we suggest 
the following language for the “Consequences” section of the TR1.0 (JRC 2016b). "This criterion 
awards points to tenderers that increase procurement of plant-based foods and decrease that of 
animal products".  
It is important to support the development of sustainable food systems across the EU for the 
following reasons: Due to the cost savings and improved environmental and public health, as well 
as reduced animal suffering. If more Member States signal to the market that a greater 
proportion of plant-based food products are sought, then it can favour the development of a 
more healthy and sustainable EU-wide food system.  
Per our previous comment, the following comprehensive criteria regarding animal products should  Comment rejected 

Acknowledged 

Acknowledged 

144 

 
 
Topic 

Feedback from stakeholders 
be added: 
Technical Specification: Animal products should make up no more than 15% of the total 
procurement cost of food and drink products 
Verification: The tenderer shall provide data (name and the amount in mass) of animal-based 
food products planned to be supplied in the execution of the contract indicating specifically the 
products that comply with the requirements. Products that have been third party certified by 
widely accepted and recognised international organisations) will be deemed to comply. 
Award Criteria: Points shall be awarded to tenders in which the amount of animal products is 
below 15% of the total procurement cost of food and drink products 
Verification: The tenderer  shall provide data (name and the amount in mass) of animal-based 
food products planned to be supplied in the execution of the contract indicating specifically the 
products that comply with the requirements. Products that have been third party certified by 
widely accepted and recognised international organisations) will be deemed to comply. 

Other:  animal 
welfare 

"Animals must be healthy and must have their special needs and furthermore enjoy freedom of 
pain, which entails rules on transport and slaughter methods (European Commission, 2014)"  
These requirements also apply to conventional animal husbandry 
Not only should the product comply - also the supplier. (EU-legislation stipulates that every 
company that sells organic B2B should be certified for organic) 
Depending on country legislation also a caterer should meet the certification requirement. 
Without specifically calling on tenders to meet criteria for purchasing a greater quantity of plant-
based foods, the GPP criteria run the risk of failing to mitigate a number of environmental 
impacts. At the very least, a very large mitigation opportunity could be lost, along with 
concomitant improvements in public health. Therefore, HSI suggests adding a TS and AC for 
reduced animal products and increased plant-based foods. 

Further analysis on organic food products 

a) Relevance of the organic food products from the environmental perspective 

JRC-Directorate B5 assessment 
Even if it is recognized that decreasing the amount of meat 
in  the  menu  is  one  of  the  most  effective  measures  to 
decrease the overall environmental impacts of the catering, 
it is difficult to set up the maximum or minimum levels that 
the meat should account for.  
The  menu  to  be  provided depends  on  multiple  factors such 
as the location and cultural characteristics of the clients, the 
type of client (age, daily activity, religion, specific needs, etc), 
this  means  that  a  unique  threshold  maybe  not  appropriate 
for  all  the  collectives  to  be  served  and  all  the  occasions. 
Based on this assessment, it seems preferable not to include 
a specific limit on meat content.  
The  reduction  of  meat  in  the  total  procurement  purchase 
does  not  fall  under  the  scope  of  the  EU  GPP  for  Food 
procurement, it is part of the catering service criteria and as 
such it is considered.  
Acknowledged 

Acknowledged 

Acknowledged 

145 

 
 
 
 
 
 
Stakeholders questioned the inclusion of criteria on organic food products as the scientific evidence was inconclusive and also questioned whether focus should be placed on a 
production system that accounts for only 1% of total agricultural food production. Others argued that the use of LCAs does not capture the full environmental benefit of organic 
production. Examples given include soil quality, water pollution and biodiversity. Additionally, if the functional unit was land use rather than mass of product then the evidence 
would be more in favour of organic production. As commented in the rationale of the organic production criteria (section 1.1.2) and more in detail in the preliminary report, the 
organic farming has in general lower impact for most impact areas compared to conventional systems.  

There are quite a large number of studies on organic production from the environmental perspective and on the comparison of organic and conventional production. For example, 
information collected from the UNEP 2008 shows that agrochemicals require energy in their production and distribution stages and that at least for some products, reduced 
energy use per tonne of organic vs non-organic produce can be achieved, demonstrating that in nearly all cases the organic option is much less demanding on resources.  

Table 31. Variance in Energy use per tonne of organic produce against conventional produce (www.wwf. org.uk) 

Vegetables 
Leeks 
Wheat 
Carrots 
Oilseed rape 
Onions 
Potatoes 

% Energy use / ton organic produce 
-58% 
-29% 
-25% 
-25% 
-16% 
+2% 

Livestock 
Beef 
Lamb 
Pork 
Eggs 
Chicken 
Milk 

% Energy use / ton organic produce 
-35% 
-20% 
-13% 
+14% 
+32% 
-38% 

b) Units and thresholds 

How the criteria should be measured was also questioned. Some stakeholders pointed out that it should be measured per mass and/or value and/or the number of dishes on the 
menu,  and  many  stakeholders  stressed  that  it  should  be  product  category  and  catering  service  specific,  e.g.  coffee,  tea  and  sugar  in  vending  machines.  One  stakeholder 
suggested that meal composition should be taken into consideration to compensate for higher costs, for example, a Technical Specific of maximum 15-20% meat content. 

It is agreed that the availability of the products and the effects that higher amounts of organic food will have in the  overall catering depends on the measured unit used. 
Minimum amounts of organic food expressed in mass will likely favour the consumption of relatively less expensive products and those that have less volatility in the prices (not 
seasonal  products such  as  pasta,  rice  or  legumes). On  the other  hand,  the  expression  of  the minimum  quantity  of  organic  food  in  costs might  favour  the  purchase  of  less 
amounts of organic food but more of those food products with relatively higher prices such as meat. However, these effects can change depending on the conditions of the 
tender (location, service to be provided, clients, etc) 

Combinations of both units were also considered. The combinations could be addressed by, for example, setting up minimum limits in mass for inexpensive food products and 
limits in costs for those considered as more expensive ones or setting minimum quantities of organic products in mass but thresholds in cost for the total procurement purchase. 

Additionally, feedback in the form of personal communication was received suggesting that the most suitable unit would also depend on the type of product served, the process 
to elaborate the food product, the size of the catering company and some other aspects. For example, the catering to the schools can be done through two food preparation 
processes:  

146 

 
 
- 

- 

the cold line: the raw materials are received, cooked in industrial/central kitchens, packaged in smaller portions and chilled out or frozen to be distributed among the 
schools or educational centers. The kitchens prepared the food for several schools by means of industrial equipment (mass production) which allows a perfect tracking 
of the raw materials, purchase of big food volumes, good waste management and good management of the energy and water consumption. In these cases, most of 
the tenderers expressed their preference for mass based thresholds as they can perfectly estimate the amount of food (kgs of each ingredient) that will need and are 
able to close contracts with organic suppliers in advance.  

the  hot  line:  the  raw  materials  are  received,  cooked  in  the  kitchen  of  the  education  centers  and  served.  There  are  no  intermedia  steps  and  the  food  volumes  are 
significantly smaller. Energy, water and waste management are also possible but they do not reach industrial levels. The number of menus served is also significantly 
lower. Most of the stakeholders that prepare the food products in a hot line express their preference for cost based thresholds.  

Opinion was divided on the proposed ambition levels. Higher threshold are a chance for public procurement to ‘lead by example’, however, some other stakeholders highlighted 
the poor market availability of organic products across all Member States and the difficulties to comply with the commitments. Higher thresholds will also have an impact on the 
overall  budget  and  will  likely  lead  to  higher  consumption  of  relative  inexpensive  non-seasonal  products  (e.g.  pasta,  rice,  legumes  and  some  vegetables  and  fruits).  Organic 
production has, for the time being, a higher variability in prices due to the less controlled production.  

The additional cost of the organic products, certification being a major barrier to market entry for SMEs and that poor seasonal availability in the country of consumption could 
lead to increased transport burden through imports were other points raised by the stakeholders. In order to assess the level of ambition that can be suggested at EU level, 
several experiences were investigated. The examples provided in addition to the information collected in Table 31 are as follows:  

-  The  city  of  Ghent  (BE)  considers  that  it  is  possible  to  reach  25%  (in  mass),  but  that  the  50%  will  not be easy  to  reach  knowing  that    the  market  availability  and 

therefore the percentage of organic farming in Belgium is very small so the food products will have to be purchased all over Europe" 

-  The municipality of Copenhagen (DK) reports a value of 100% organic food products in mass but it seems to be only for fruit and vegetables 
-  The Italian Call for Tenders (IT) analysed for this revision sets requirements on the minimum quantity of organic products. The limits sets that at least 40% in mass of 
the total for fruit, vegetables, cereals, bread, pasta, rice, flour, potatoes, polenta, tomatoes and transformed products (cheese, milk, yogurt, eggs and extra virgin olive 
oil), should be procured and that at least 15% in mass of the total for meat and at least 20% in mass of the total aquaculture fish must be organically produced. For 
the  Municipality of Rome, results show that organic food accounts for 69% of all food served in schools, except meat, fish and cold cuts  
In the City of Malmö (FI) it was reported that at the end of 2009, 43% of the food served in all school cantinas in Malmö was organic.  Malmö’s goal is to serve 100% 
organic food in all of its public catering services by 2020.  

- 

-  According to the call for tenders from the Government of Malta (MA) "at least 1% of [list of specific products, drawn by the procurer, selected according to the seasonality 

of produce] must be organically produced". 

-  Finally, UK Government Buying Standards, shows that "at least 10% of the total monetary value of primary commodity (i.e. raw  ingredient) food and drink procured 
must  be  labelled  as  organic"  for  the  core  criterion.  The  optional  criterion  (comprehensive  criterion)  is  that  "at  least  40%  of  the  total  monetary  value  of  primary 
commodity (i.e. raw ingredient) food and drink procured must be labelled organic".  

Product type 

in mass 

in costs 

147 

 
The  analysis  of  this  feedback  reads  that  most  of  the  procurers  set  up  thresholds  in  mass  and  some  of  them  even  make  a 
difference between the product types. Checking the level of ambition usually starts requiring 25 to 40% in mass of vegetables, 
dairies  and  non-perishable  products  up  to  100%.  The  limits  for  meat  and  fish  are  lower  being  set  up  at  15%  and  20% 
respectively. The differences are mainly attributed to the market availability commented previously.  

There is only one experience of setting up the limits in costs.  The thresholds range from 10% to 40% indicating that they are 
much lower.  

An interesting comparison between the contribution to the total weight and the total costs of each product types was carried out 
during this revision based on the input of several stakeholders. The results are shown in the following table.  

Vegetables 
Pasta, rice, etc 
Meat and Fish 
Fruits 
Bread 
Eggs 
Dairy products 
Others 

Table 32. Examples of caterings and the mass/cost ratios of the food product types 

School catering 
32% 
43% 
7% 
13% 
37% 
17% 
18% 
16% 
4% 
6% 

5% 

2% 

It can be seen that the vegetables and non-perishable food accounts for almost 60% of the diet (in mass) whereas they amount for 40% of the total costs. Opposite, meat and 
fish products account for less than 20% of the total mass but almost 40% of the total costs. Other types of products have a significant contribution neither in costs nor in mass. 
This point underlines the difficulties to set a unique threshold for both units: mass and cost.  

c) Other major initiatives 

Some  major  private  initiatives,  such  as  the  SAI  Platform  Farm  Sustainability  Assessment  and  ENVFOOD 
methodology for PEF are in place to make sustainability impact within international supply chains. Most of these 
inititatives follow the principles included in the Organic Regulation.  

The  principal  aim  of  SAI  Platform  Farm  Sustainability 
formed by more than 80 industry members, e.g.  Nestlé, 
Unilever and Danone, serves to support the development 
of  sustainable  agriculture  worldwide.  SAI  Platform 
develops (or co-develops) tools and guidance to support 
global  and  local  sustainable  sourcing  and  agriculture 
practices.  Examples  of  recently  developed  resources 
include:  Practitioner’s  Guide  for  Sustainable  Sourcing; 
Performance 
recommendations 
Assessment 
the  Farm  Sustainability 
Assessment (FSA).  

Sustainability 

(SPA);  and 

for 

The  ENVIFOOD  Protocol  is  a  scientific  methodology  by 
European  Food  SCP  Round  Table  adopted  for  the 
environmental assessment of food and drink products, in 
order  to  serve  as  basis  to  establish  the  product 

148 

 
 
 
 
 
 
environmental footprint of products.  

Figure 2. The ENVIFOOD Protocol represents an intermediate step between ISO standards,  the European Commission’s Product Environmental Footprint and 
product-specific rules. 

149 

 
 
 
 
 
 
Marine and aquaculture food products  

Table 33. Feedback from the stakeholders on the TR1.0: Marine and aquaculture food products (TS and AC) 
Topic 
Use of the 
MSC 
red 
list 

Feedback from stakeholders 
In Finland procurers use the WWF fish guide and the red list included in it, rather than the 
MCS  list  when  choosing  fish  from  Finnish  waters.  However,  when  for  international  fish 
and  aquaculture  products  the  MCS  list  is  usable.  Thus,  the  criteria  as  such  works  ,  but 
could include references also to other widely available lists 
The Marine Conservation Society guide (MCS) is just one of many purchasing guides for 
seafood  that  are  available.  FoodServiceEurope  members  use  a  variety  of  sustainable 
seafood certification systems and purchasing guides and scientific guidance, including but 
not  limited  to  WWF’s  Sustainable  Seafood  guides,  IUCN,  Seaweb  Europe,  CITES,  FAO, 
NOAA, Monterey Bay Aquarium Seafood Watch and Greenpeace. Based on these guides, 
contract caterers have also developed company-specific guidance. 
In  Vienna  GPP,  a  so-called  "position  paper"  released  by  ÖkoKauf  2012  recommends  to 
purchase fish (products) from a list combined of Greenpeace and WWF: "green" products 
are recommended, "yellow" accepted, "red" rejected.  
The market availability of MSC labelled fish is good, for ASC-labelled fish we do not have 
enough practical experience so far. There are also some MSC certified catering services 
on the market. 
Good market availability for MSC but much less for ASC. Hopefully public market demand 
can promote ASC production. 
Market availability in the Netherlands is sufficient 
For my opinion there should not be difficulties in getting the required amounts of MSC 
and/or ASC certified products since these certifications are quite common and have been 
expanded significantly in the recent years. 
The MSC fish are fairly widely available on the market (Danish market) 
MSC products are pretty widely available on the market so the percentages here could be 
increased 
The Danish suppliers say that here is a big problem. 
There should not be significant problems for SME´s to stick to the criteria since in most 
cases the sourcing is almost the same for SME and non-SME. 
Chain of custody certification is feasible but costly! 
When SME’s have to get the MSC/ASC label it can become expensive for them. This is also 

Market 
availability 

Feasibility 
of SMEs to 
comply 

JRC-Directorate B5 assessment 
Comment accepted 
The text for the criterion has been amended: 
-  see  footnote  of  the  criterion  wording:"1)"…  ,  and  others:  WWF’s 
Sustainable Seafood guides, IUCN, Seaweb Europe, CITES, FAO, NOAA, 
Monterey Bay Aquarium Seafood Watch and Greenpeace." 
Other fish to avoid lists, such as the proposed one might be used. 

Acknowledged 
The wording of the criteria has been edited.  
The  MSC  is  not  the  unique  label  that  public  bodies  should  accept. 
The  market  availability  of  third  party  environmental  certification 
schemes  in  all  Member  States  varies  and  the  following  wording  is 
now  in  place  with  the  hope  it  can  serve  as  a  guide  for  public 
procurers when launching their calls for tenders: 
´have  been  produced  meeting  the  requirements  of  a  certification 
scheme for sustainable production that is based on multi-stakeholder 
organizations with a broad membership and addresses environmental 
including  over-fishing  or  depletion,  biodiversity  and 
impacts 
responsible and sustainable use of the resources´ 
Acknowledged 
The ambition levels have been left to be chosen by the contracting 
authorities, attending to the specificity of the place where the tender 
is launched.  

150 

 
 
Topic 

Ambition 
level 

Feedback from stakeholders 
the reason ILVO is working on a label (sustainability stars) to keep the cost tolerable for 
the small shipping companies.  
Certificates  are  also  a  cost  issue  and  for  small  scale  fisheries  it  might  be  financially 
impossible to become certified.  
The rationale is based to a large extent on the MSC label. However, there are about 30 
different labelling systems for fish and aquaculture products. Although MSC labelled fish 
from international waters are widely available, the rationale could have a mention also of 
other labels. 
We agree, and even think the percentage can be set higher. 
In general I do agree with the ambition levels although I think it would be a problem to 
set higher levels (+5%). 
Low ambition for marine catch. Levels of 25% and 50% should be possible. And 100% 
for appointed species such as Hoki. 
The bar can be set much higher here. 10% means 90% are allowed not to comply. This 
should also be part of menu planning guidelines. For aquaculture: not only ASC should be 
considered, also Organic aquaculture. 
We ask for all fish to have a label (MSC/ASC or equal). We also forbid the usage of tuna, 
pangasius fish, Tilapia fish and Nile perch 
MSC products are pretty widely available on the market so the percentages here could be 
increased 
With  the potential  emergence  of  GMO  salmon  and  the  challenges  posed by  overfishing 
and loss of stocks due to climate change, the percentages for technical specifications and 
award criteria should be 20% and 50% respectively.   
Revise the criteria as described in the rationale. Define a threshold of 10% as core criteria 
and set the ambition level for the comprehensive criteria up to 25% 
Move  from  comprehensive  to  core  the  sentences:  "At  least  10%  in  mass  of  marine  OR 
aquaculture food products must be compliant with the following principles." 
IFOAM  EU  welcomes  the  marine/aquaculture  criteria.  However,  the  criteria  should 
complement organic, not exclude certified organic aquaculture products. The combination 
of organic food and aquaculture product criteria leads to more optimal results. Organic 
aquaculture  should  be  considered  as  one  of  the  criteria.  The  criteria  should  also  focus 
more on how harmful fishing methods can be avoided and the way in which the different 
aquaculture products are raised e.g. use of antibiotics, hormones, use of feed. 

JRC-Directorate B5 assessment 

Acknowledged 
The  rationale  has  been  edited  and  it  gathers  now  the  diversity  of 
schemes that can be used to verify the criterion. 

Acknowledged 
The ambition levels have been left to be chosen by the contracting 
authorities, attending to the specificity of the place where the tender 
is launched.  
Recommendations are given however to the procurers to ask in their 
tenders  for  0-20  and  20-50%  of  the  fish  not  complying  with  the 
requirements  of  organic  food  products  and  having  a  sustainable 
origin depending on the core or comprehensive level. 

Comment rejected 
Organic  aquaculture  is  promoted  in  the  organic  produce  criterion 
therefore  they  are  excluded  from  this  criterion.  This  way  the 
procurer  avoids  double  counting.  The  goal  of  this  criterion  is  to 
recommend  procurers  the  most  environmentally  friendly  option  to 
purchase marine and aquaculture products apart from those organic 

151 

 
 
Topic 

Feedback from stakeholders 

of 
Use 
antibiotics 

General 

Potential improvement areas: TS2; Marine and aquaculture food…: what about less use of 
antibiotics  in  aquaculture? University  Ghent speaks  of  carnivore  fish  and  herbivore  fish. 
The diet of carnivore fish contains of other fish (so we are still fishing our oceans empty 
in order to feed them) and the second one has a plant diet. This means that herbivore 
fish should have a lower environmental impact. But getting herbivore fish should probably 
be award criteria. 
If you look at fish products raised in aquaculture e.g. the use of antibiotics, hormones and 
feed could be addressed. 
From  a  climate  change  rationale  red  meat should be  more  often  replaced by  fish.  This 
suggests that the criteria for fish should on the one hand be strict enough to ensure that 
legally and sustainably caught fish is served in public kitchens, and on the other promote 
growth and innovation in the fishing industry. 

Please add: seafood that are “underutilized” and available through local fisheries in AC3 
(Additional marine and aquaculture food products) 

JRC-Directorate B5 assessment 
food  products.  The  third  party  certification  systems  already  cover 
sustainable  fishing  methods,  use  of  anitbiotics,  hormones  and  the 
use of feed. 
Acknowledged 
The  use  of  antibiotics  is  covered  by  the  certification  schemes 
proposed (e.g. ASC or Globalgap with add-on for aquaculture).  
If zero antibiotics want to be requested then the procurer may then 
require organic aquaculture products. 

Acknowledged 
The ambition levels have been left to be chosen by the contracting 
authorities, attending to the specificity of the place where the tender 
is launched.  
Recommendations are given however to the procurers to ask in their 
tenders for 0-20 and 20-50% of the fish having a sustainable origin 
depending on the ambition level required. 
Requirement  on  the  type  of  food  product  does  not  fall  under  the 
scope  of  EU  GPP  Food  products.  Reduction  of  red  meat  has  been 
included  in  the  EU  GPP  for  Catering  services  under  the  Menu 
planning criterion. 
Comment rejected 
While  the  clear  intention  of  the  comment  is  to  lower  the 
environmental pressure on traditional species, such as salmon, tuna, 
cod and shrimp, these species if sustainably managed, and certified 
by e.g. the MCS are best alternative.  
None  of  these  species  is  in  any  way  threatened  with  extinction  – 
some  individual  stocks  may  be  overfished,  but  no  commercially 
important species has ever gone extinct or even come close to it. For 
example,  Barents  Sea  cod  stock  is  at  record  abundance  levels  (4 
million tons compared to Gulf of Maine’s estimated 2,500 tons). So 
the  global  marketplace  for  Atlantic  cod  is  going  to  have  a  million 

152 

 
Topic 

Feedback from stakeholders 

As  we  state  in  the  attached  document,  the  misuse  or  overuse  of  antimicrobials  or 
antibiotics in animals, concretely in this case in aquaculture, can lead to contamination of 
water and consequently, they pose a threat to public health. 

Under Food Procurement please improvement areas should include: organic meat or meat 
raised without  routine  non-therapeutic  antibiotics  reduced meat  provision  for  maximum 
climate and resource impact.  
Products produced and processed locally 
Prefer fish sourced from local, smaller scale fisherman. 

JRC-Directorate B5 assessment 
tons of Barents Sea cod, and less than one thousand tons of Gulf of 
Maine  cod.  Alaska  produces  hundreds  of  thousands  of  tons  of 
sustainable  wild  salmon  —  that  is  both  MSC  certified  and  on  the 
Seafood Watch best choice list.  
Fish  that  is  underutilized  might  be  used  by  the  contractor  but  can 
not  constitute  a  requirement  for  a  tender  since  it  is  not  certified. 
Without a certification, it is uncertain under which conditions the fish 
has been caught.  
Comment acknowledged 
Provisions on aquaculture,  including hygiene and medication or the 
use  of  antibiotics  are  already  covered  by  the  schemes  in  place  to 
verify organic and sustainable aquaculture. 
Comment rejected 
Organic meat is included in the organic produce criterion. Due to the 
existence of a single market in EU-28, the GPP call for tenders can 
not  require  products  produced  and  processed  locally,  nor  the  fish 
sourced from local and small scale fisheries. 

Further analysis on marine and aquaculture food products 

With regard to the list of avoided fish provided by the Marine Conservation Society, stakeholders expressed in the 1st AHWG meeting, that other lists are used as well, such as 
the WWF Sustainable Seafood guides, IUCN, Seaweb Europe, CITES, FAO, NOAA, Monterey Bay Aquarium Seafood Watch and Greenpeace lists.  

Onto the targeted levels there is a majority agreement that the current levels are not ambitious and they could be raised. The main reasons to support the rise of the values are 
to prevent the emergence of GMO salmon or that the MSC products are widely available. As for the figures there are several proposals from low (+5%) to moderate: 20% and 
50% for core and comprehensive respectively, and going further up to a more ambitious 100%. There is also a common proposal to make the core level equal to comprehensive 
level. Several cases were exposed where the public procurement deliberately prohibits certain species such as e.g. pangasius fish and Nile perch. 

Marine Stewardship Council (MSC) scheme and the equivalent for aquaculture ASC are suggested as environmental certification schemes accepted as proof for verification, and 
the stakeholders commented the market availability of these MSC/ASC labelled products is good. However, some stakeholders expressed their concern for SMEs to get products 
since the chain of custody certification can be costly. The wording of the criteria has been edited, the MSC isn’t the unique labelled that public bodies should accept.  

GlobalGap certified production standards for farmed species (aquaculture but also other animal species) are one of the certification schemes proposed for verification, since it 
addresses a number of issues  associated with production of fish  of environmental concern, the auditing of which requires farm inspections and standard enforcement. The 
issues addressed include: habitat alteration; freshwater impacts; nutrient and organic pollution; escapes; interactions with local wildlife and enforcement of regulations. 

153 

 
 
 
 
The market availability in EU-28 of the third party environmental certification schemes has been revised in the EU campaign and the following table provides the list of schemes 
in EU-28. As shown all Member States have schemes in place that can be used for verification.  

Bulgaria 
Факти за рибарството 

Czech Republic 
Rybolov – základní údaje 

Table 34. Resources to help choosing sustainable fish in EU-28, (INSEPARABLE 2017)  
Austria 
Fakten über Fische 
MSC - Marine Stewardship Council 
Friend of the Sea 
Global G.A.P. 
Slow Fisch - Die Meere verstehen 
EUMOFA - Die Europäische Marktbeobachtungsstelle für Fischerei und Aquakultur 
WWF Shopping Guide seafood - fish, sushi and shrimp - food and fish - Consumer 
Tips  
Croatia 
Coming soon 
France 
Guide des espèces - Produits de la Mer 
La pêche en chiffres 
Friend of the Sea 
Global G.A.P. 
MSC - Marine Stewardship Council 
Mr. Goodfish - Good for the sea, good for you 
Slow Fish - Mieux comprendre nos océans 
Mangiamoli Giusti - Poissons pour Nous Régaler et Poissons a Laisser dans la Mer 

fish2fork - Le guide des restaurants pour les amateurs de poisson durable 

EUMOFA  -  L’Observatoire  Européen  du  Marché  des  Produits  de  la  Pêche  et  de 
l’Aquaculture 
SeaWeb Europe - Guide des espèces à l'usage des professionels 
Germany 
Fakten über Fische 
MSC - Marine Stewardship Council 
Friend of the Sea 

Belgium 
Global G.A.P. 
WWF Viswijzer 2013 
Friend of the Sea 
De visserij in feiten en cijfers/La pêche en chiffres/Fakten über Fische  
Mr. Goodfish - Good for the sea, good for you 
Slow Fish - Mieux comprendre nos océans/Die Meere verstehen  
Calendrier des poissons - Calendrier des crustacés et des fruits de mer 
Viskalender - Schaaldieren- en zeevruchtenkalender 
SeaWeb Europe - Guide des espèces à l'usage des professionels 
fish2fork - Le guide des restaurants pour les amateurs de poisson durable 
EUMOFA  -  L’Observatoire  Européen  du  Marché  des  Produits  de  la  Pêche  et  de 
l’Aquaculture 

Vis- & zeevruchtengids - voor professionele gebruikers 

Cyprus 
Greenpeace - Γνώρισε καλύτερα τα ψάρια που αγοράζεις 
Στοιχεία για την αλιεία 
ΑΡΧΙΠΕΛΑΓΟΣ Οδηγός για τη βιώσιμη κατανάλωση θαλασσινών στην Ελλάδα 

154 

 
 
 
 
 
 
 
medsos.gr - ΜΗ ΤΡΩΣ Ο,ΤΙ ΣΟΥ ΣΕΡΒΙΡΟΥΝ 

Hungary 
Halászattal kapcsolatos tények 

Denmark 
Fakta om fisk 
MSC - Marine Stewardship Council 
WWF Denmark - WWF’s Fiskeguide 
2 gange om ugen 

Infos zu Fischbeständen 
Global G.A.P. 
Slow Fisch - Die Meere verstehen 
Slow Food Deutschland 
Naturland - Fisch & Meeresfrüchte 
Fischbestände Online 
Stiftung Warentest - Fisch: Mit gutem Gewissen 
Greenpeace - Topics - Oceans - Fisheries 
WWF Germany - Reasonable Shopping 
Fisch-Einkaufsführer 
School of Fish - Fisch Nachhaltigkeit und gesundes Essen 
EUMOFA - Die Europäische Marktbeobachtungsstelle für Fischerei und Aquakultur 
Ireland 
Fish Fight 
MSC - Marine Stewardship Council 
Friend of the Sea 
Irish Wildlife Trust - Sustainable seafood guide 
Global G.A.P. - Aquaculture information 
Mr. Goodfish - Good for the sea, good for you 
Slow Fish - Good, clean and fair fish 
Facts and figures on the Common Fisheries Policy 
Greenpeace - sustainable seafood recipes 
EUMOFA - The European Market Observatory for Fisheries and Aquaculture 
Fish and kids - Sustainable seafood for schools, plus games for young and old alike  medsos.gr - ΜΗ ΤΡΩΣ Ο,ΤΙ ΣΟΥ ΣΕΡΒΙΡΟΥΝ 
Fish2Fork  -  The  campaigning  restaurant  guide  for  people  who  want  to  eat  fish  - 
sustainably 
Italy 
WWF guida 
Dati sulla pesca 
Pesce ritrovato 
Il pesce dimenticato 
Friend of the Sea 
Guida al pesce giusto 

Latvia 
Fakti par zivīm 
Lietuvos Gamtos Fondas 

Estonia 
Kalandusfaktid 

WWF - FishTips 

Finland 
Perustietoa kalataloudesta 
Kuluttajan kalaopas - Näin luet opasta - Kalaopas - WWF 

Netherlands 
Vis- & zeevruchtengids - voor professionele gebruikers 
De visserij in feiten en cijfers 

Greece 
Greenpeace - Γνώρισε καλύτερα τα ψάρια που αγοράζεις 
Στοιχεία για την αλιεία 
ΑΡΧΙΠΕΛΑΓΟΣ Οδηγός για τη βιώσιμη κατανάλωση θαλασσινών στην Ελλάδα 

155 

 
 
 
 
 
 
 
 
Guida alla pesca sostenibile 
MSC - Marine Stewardship Council 
Slow Fish - Per capire gli oceani 
Mr. Goodfish - Good for the sea, good for you 
Fishbox diffusione più consapevole del consumo del pesce  
Mangiamoli Giusti - i Pesci da Mettere nel Piatto e Quelli da Lasciare in Mare 
Che  pesci  pigliare  -  No  ai  pesci  sotto  taglia!  Righello  con  la  taglia  minima  delle 
specie ittiche Mediterraneo. 
Poland 
Fakty i liczby 
WWF poradnik  
Slovakia 
Rybárstvo – základné fakty 
Luxembourg 
Global G.A.P. 
La pêche en chiffres 
Friend of the Sea 
MSC - Marine Stewardship Council 
Mr. Goodfish - Good for the sea, good for you 
SeaWeb Europe - Guide des espèces à l'usage des professionels 
Slow Fish - Mieux comprendre nos océans/Die Meere verstehen  
fish2fork - Le guide des restaurants pour les amateurs de poisson durable 
EUMOFA  -  L’Observatoire  Européen  du  Marché  des  Produits  de  la  Pêche  et  de 
l’Aquaculture 
United Kingdom 
Fish Fight 
Good fish guide - consumer guide to sustainable seafood 
Facts and figures on the Common Fisheries Policy 
Greenpeace - sustainable seafood recipes 
Friend of the Sea 
Coolseas - Informative game for young and old alike 
Global G.A.P. - Aquaculture information 
Mr. Goodfish - Good for the sea, good for you 

MSC - Marine Stewardship Council 
Stichting De Noordzee - WWF - Viswijzer Goede Vis 

Portugal 
Factos sobre as pescas 
MSC - Marine Stewardship Council 
Lithuania 
Informacija apie žuvininkystę 
Sweden 
Fisket i siffror 
MSC - Marine Stewardship Council 
Friend of the Sea 
WWF's Seafood Guide - when you're buying eco-friendly fish - Sea and Fishing 

Slovenia 
Ribiški podatki 

Malta 
Quickfish Guide 
Facts and figures on the Common Fisheries Policy 
EUMOFA - The European Market Observatory for Fisheries and Aquaculture 
Fish Fight 
Global G.A.P. - Aquaculture information 
Mr. Goodfish - Good for the sea, good for you 
Slow Fish - Good, clean and fair fish 
MSC - Marine Stewardship Council 

156 

 
 
 
 
 
 
 
 
 
Slow Fish - Good, clean and fair fish 
MSC - Marine Stewardship Council 
Catchbox | Home 
The Marine Conservation Society’s Pocket Good Fish Guide 
Marine Conservation Society - Buying seasonal fish 
Good Fish Guide mobile App 
Fish Fight on the App Store on iTunes 
Fish 4 Ever - good canned fish, sustainably fished 
Take the taste test | Fish is the Dish  
Cefas: Under-utilised species 
Mangiamoli Giusti - Fish to Eat and Fish to Leave in the Sea 
Sustainable Seafood Coalition 
Sustainable Fish City 

Local Catch - Eat, buy and sell fresh, local fish directly 

EUMOFA - The European Market Observatory for Fisheries and Aquaculture 
The Ethical Shellfish Company | The Ethical Shellfish Company, Mull, Scotland 
Fish2Fork  -  The  campaigning  restaurant  guide  for  people  who  want  to  eat  fish  - 
sustainably 
Fish and kids - Sustainable seafood for schools, plus games for young and old alike 

Fatti dwar il-ħut 

Spain 
Datos de la pesca 
MSC - Marine Stewardship Council 
Friend of the Sea 
Global G.A.P. 
WWF - Guía de consumo responsable de pescado 
Alimentacion - Guia del tallas minimas 
Mr. Goodfish - Good for the sea, good for you 
Slow Fish - Para comprender los océanos 
Fedepesca - Guia del consumo responsable de pescado 
Pescados para el Paladar y Pescados que Hemos de Dejar en el Mar  
fish2fork  -  La  guía  de  restaurantes  para  quienes  quieren  consumir  pescado  - 
respetando el medio ambiente 
EUMOFA - Observatorio Europeo del Mercado de Productos de Pesca y Acuicultura 

Romania 

Date privind pescuitul 

The use of antibiotics was another concern expressed in the meeting by two stakeholders proposing these criteria include a statement to reduce the use of antibiotics and 
hormones. However, this consideration is not proposed here since the use of antibiotics is covered by the certification schemes proposed (e.g. ASC or Globalgap with add-on for 
animal welfare). If zero antibiotics want to be asked then the procurer can require organic aquaculture products. 

157 

 
 
 
 
 
 
Integrated production 

This section presents the comments received through BATIS and personal communications from the 1st AHWG meeting to the 2nd AHWG meeting.  

Table 35. Feedback from the stakeholders on the TR1.0: Integrated Production (TS and AC) 
Topic 
Ambition levels 

Feedback from stakeholders 
For us, integrated production should be considered as a step from conventional 
to  organic  production,  but  as  a  criteria  is  quite  difficult  to  define,  taking  into 
account  that  some  European  countries  don’t  know  what  it really  means  and  in 
Spain exist one national regulation, plus 17 ones for each region. Consequently, 
we will not set up any criteria (10%), but if it is not possible, at least consider its 
gradual increase. 
I agree with the ambition levels, I think they are reasonable, not too ambitious. 
10  %  is  a  low  ambition for  European  production.  IP  of  imported  products  like 
bananas,  oranges  and  coffee  more  difficult  to  comply,  but  still  10%  is  a  low 
ambition I think. 
The ambition levels should be higher since in comparison with ecological schemes 
integrated systems are not as ambitious. I suggest + 5-10%. 
Availability is very much dependent on the verification methods acknowledged.  
If scientific evidence suggests IP is the most sustainable production method, 10% 
is not very ambitious. 

Similar criteria 
in your tenders 

I don’t have any experience on this matter. Marijke Van Ranst (bio forum) told 
me that most of the Belgian fruit is already integrated production but that we 
are  not  aware  of  this.  Although  it  could  be  a  stepping  stone  towards  organic 
production. 

JRC-Directorate B5 assessment 
Comment partially accepted 
The number of countries lacking an IP certification scheme 
is not significant. Additionally there are some international 
certification schemes that can be used for compliance with 
this criterion.  

Comment accepted 
From the  environmental and economic points of view the 
IP  is  the  best  way  to  produce  at  low  costs  and  causing 
lower  environmental  impacts.  This  practice  is  considered 
cost-effective.  
Due to the fact that there are IP certification schemes in 
most  of  the  Member  States  plus  international  schemes 
that  can  be  accepted  as  proof  of  compliance,  a  higher 
ambition level can be considered.  
Flexibility  is  introduced  in  the  wording  of  the  criteria 
suggesting to the procurers' higher thresholds wherever IP 
regulation is in place.  
Acknowledged / Comment accepted 
The Belgian experience reported in this comment seems to 
be  the  common  practice  in  other  Member  States  such  as 
Germany or Spain.  

158 

 
 
 
Concept of 
Integrated 
Production 

I asked the organisations LF and ØL about this, and here are the answers to why 
we do not work with this in Denmark:  
Answers to the consultation questions to stakeholders:  
- Do you have experience in using similar criteria in previous tenders?  No.  
- Do you agree with the ambition levels set (% for the criteria) for the core and 
comprehensive  criteria?  Because  IP  products  have  never  been  successful  in 
Denmark. Consumers and the public sector choose either conventional or organic 
products. 

regardless of 

standards) can 

Before being able to comment, it would be critical to obtain a definition of what 
is  meant  by  IP.  We  would  need  a  clear  definition  of  the  standards  and 
certification systems in place. Since there is no harmonised EU definition or legal 
framework  and  only  some  EU  countries  have  IP  initiatives  in  place,  it  is 
premature to set a technical specification and target for IP. 
What to comply to for the producers when IP is not specified? What products can 
be  accepted  in  a  tender? Important that  equivalent  products  (products meeting 
origin.  
same 
compete 
For  example,  will  both  wheat  flour  produced  according  to  German,  Danish, 
Finnish and Swedish IP be accepted?   
IP  certification  is  an  often  accepted  verification,  but  the  criteria  must be more 
detailed than to accept IP. The IP standard comply with different set of rules in 
different  productions  and in  different  countries  due  to  climate,  national 
legislation, breeds of animals and so on. 
A proper definition of IP is currently lacking! 
ETL supports the chosen approach to include various forms of agriculture that 
result in less environmental burden in the GPP criteria set. However, the concept 
of IP seems to be fairly vague and not generally known throughout the Member 
States. A further clarification and definition on this matter is therefore needed. 
Besides IP, also other alternative schemes should be acknowledged. 
Specify the criteria according to which production methods should be promoted 

Acknowledged 
DK  is  one  of  the  few  Member  States  lacking  an  IP 
certification scheme. However, it should be noticed that DK 
is  one  of  the  countries  with  the  highest  %  of  organic 
products, although this kind of products are excluded from 
this criterion.  
Additionally, there are also international schemes that can 
be used for compliance with this criterion such as GLOBAL 
INITIATIVE 
the  SUSTAINABLE  AGRICULTURE 
GAP  or 
PLATFORM 
Comment rejected 
Even if the definition of IP slightly differs from country to 
country  or  from  region  to  region,  most  of  them  have  a 
scheme that clearly defines the concept and the technical 
requirements to be certified.  
A possible definition for IP that is pretty close to most of 
the  definitions  provided  by  the  respective  certification 
schemes  could  be:  "a  system  of  specific  rules  to  each 
culture,  applied  at  various  stages  of  the  production  of  a 
vegetable 
is  characterized  by  a  weak 
environmental impact" or in more detail and as defined by 
IOBC  "an  agricultural  system  for  producing  food  which 
makes  optimal  use  of  natural  resources  and  regulation 
mechanisms  by  ensuring  that  farming 
is  viable  and 
sustainable over the long term. Under this system, biological 
methods, cultivation techniques and chemical processes are 
carefully  selected,  seeking  a  balance  between 
the 
environment, profitability and social requirements" 
However, from the point of view of the applicability of the 
criteria, the exact definition of the  IP to be applied should 
be  that  of  the  certification  scheme  that  is  in  place  in  the 
area. In this sense, a procurer can buy IP certified products 
from  two  or  more  IP  certification  schemes  that  will  have 
different but similar definitions.  

food 

that 

159 

 
Verification 

As  there  is  no  mandatory  labelling  or  certification  of  food  products  produced 
according to integrated production standards in Austria, the visibility is low and 
verification of criteria complicated. 

The report indicates that there is no EU wide certification system setting out the 
minimum  requirements  to  verify  compliance  [JRC  2016b]  of  IP  systems.  It  is 
necessary that the report provides a definition of what is meant by IP and that it 
provides  a  list  existing  IP  Certification  Systems  in  the  Member  States  of  the 
European  Union  in  order  clarify  and  provide  certainty  as  to  which  integrated 
production systems can producers refer to.  
In  addition  major  initiatives  such  as  the  Sustainable  Agriculture  Initiative 
Platform [SAI 2017] should be taken into account both the Preliminary and the 
Technical report. This scheme, backed by major food manufacturers and retailers, 
builds  upon  the  Integrated  Production  principle  and  aligns  with  international 
sustainability agriculture standards.  
These and other privately owned initiatives should be acknowledged in addition 
to public IP schemes, as means to implement sustainable agriculture. 
Like  my  first  comment:  not  the  IP  is  the  goal,  but  the  advantages  that  are 
accomplished  by  this  production  method.  Restricted  use  of  pesticides  and 
synthetic  fertilisers  can  also  be  realised  with  the  organic  production  method. 
We  have  a  national  label:  http://www.milieukeur.nl/19/home.html that  can  be 
seen as an IP label 
Here, only public schemes are taken into consideration. There are many national, 
regional  and  international  privately  owned  IP  schemes  which  can  be  used  to 
verify compliance to GPP criteria, as well as the collective work done within SAI 
Platform. The FSA and schemes benchmarked against it (at least silver and gold 
levels) should be acknowledged by GPP schemes across the EU.  

Comment rejected  
According  to the  information submitted  by Austria for  the 
implementation of the integrated pest management, there 
is  no  national  label  to  easily  recognise  those  products 
grown following the IP rules. However, there are guidelines 
at  national  level  for  vegetables  and  mechanisms  in  the 
regulation for verifying.  
Global  GAP  is  an  international  scheme  that  can  help 
issues. 
regarding 
(http://ec.europa.eu/food/plant/pesticides/sustainable_use_p
esticides/ipm/index_en.htm), 
Comment accepted 
As reported in the table below, there are countries that rely 
on  private  schemes  for  the  IP  certification.  This  fact  was 
not well reflected in the wording proposed in the TR1.0. 
The new wording is now open to private and international 
certification schemes that are 3rd party certified.  

verification 

the 

Acknowledged 

Comment accepted 
See above 

160 

 
 
 
This limits GPP to niche products, which very much limits its impact. Certified IP 
is very small scale in the EU, and not the innovation route sustainability leaders 
choose  for.  When  producing,  trading  or  processing  large  volumes,  third  party 
certification of all products is not possible, nor is it necessary for safeguarding 
the  continuous  improvement  both  GPP  and  private  sustainability  programmes 
should be aimed at. 

Please  explain:  the  work  of  SAI  Platform  is  recognised  by  the  JRC  as  best 
practices in terms of improving environmental impacts in food production, yet its 
principles and the FSA (farm sustainability assessment) are not considered to be 
a valid IP scheme?  

Defining  integrated  production  as  a  technical  criterion  is  questionable  as  it  is 
neither defined nor controllable in all Member States. In several countries, such 
criteria  don’t  even  have  any  added  value  as  produce  produced  using  such 
methods  is  a  standard  requirement.  Therefore,  including  IPM  criteria  wouldn’t 
give advantage to more sustainable producers. 
The word 'compromise' suggests organic is the optimum and conventional is the 
minimum, and IP meets them halfway. Both conventional and IP can me MORE 
sustainable than organic in some aspects. 
Criteria for integrated production differ per country. 

Modifications  in 
the TR 

Comment rejected 
The IP is, according to the data reported to the Commission 
widely  spread  across  Europe.  There  are  countries  such  as 
Germany  where  the  IP  is  the  common  practice.  Also,  this 
technique is so widely spread that even most of the large-
scale multinational retailers require a certification such as 
GLOBAL GAP to accept the products.  
Comment partially accepted 
The IP criterion has been opened for verification to private 
schemes.  as  long  as  SAI  or  FSA  can  be  considered  as 
equivalent to the national regulations they can be used to 
shown compliance with the criterion. These schemes cannot 
be  used  to  show  compliance with  the  criterion  as  long  as 
they  are  not  considered  as  equivalent  to  the  national 
regulation.  
Comment rejected 
While it is true that not all Member States have put in place 
specific regulation or IP certificates, the implementation of 
the  integrated  pest  management  (Directive  2009/128/EC) 
is mandatory from 2014 on. 
Comment accepted 

Acknowledged 
see other replies above 

Further analysis on integrated production 

The IP represent a system of specific rules to each culture, applied at various stages of the production of a vegetable food (and in some countries also to livestock) that is 
characterized by a weak environmental impact. The IP practices are not defined at EU level but they are defined at national or regional level in most of the Member States. Table 
36 summaries the state-of-the-art of the IP in Europe. This information was obtained from the submitted reports for the implementation of the integrated pest management 
(Directive  2009/128/EC)  provides  information  on  the  IP  certificates  that  are  in  place  in  each  member  state  (European  Commission  2013).  The  data  are  from  2013  being 
mandatory the implementation of the integrated pest management from 2014 on. As seen in the Table 36, approximately two thirds of the Member States (and especially those 
with large production of crops, fruits and vegetables) have at national or regional level, public or private IP certification schemes in place.   

161 

 
 
 
 
 
Table 36. Existence of integrated production certified schemes across EU and their state of the art 
Schemes and state of the art of the IP  
Country 

IP  certified 
schemes 
in 
place? 
Yes 

Austria 

Belgium 

Bulgaria 

Croatia 
Cyprus 
Czech 
Republic 

Denmark  
Estonia 
Finland 
France 

Germany 

Greece 
Hungary 

Ireland 
Italy 

Yes 

Yes 

No 
No  
Yes 

No 
No 
No 
Yes 

Yes 

? 
yes 

No 
Yes 

At national and regional in Styria, Burgenland, Salzburg  
ÖPUL guidelines for certain arable crops and for vegetables, fruit, hops and wine. 
Only the vegetable integrated production guideline applies nationally  
Flammers since 2014 for vegetables 
Wallonie through public specifications and privates schemes. FRUINET is one scheme that goes beyond the IP 
The  terms  and  procedures  applicable  to  integrated  manufacturing,  together  with  relevant  registering  of  respective  farmers  (agricultural 
producers)  and  identification  of  integrated  production  are  all  well  laid  down  in  national  Ordinance  No  15  on  the  terms  and  procedures 
applicable to integrated production of plants and plant products, and their identification. 

In national CZ directives were issued for the application of IP systems in the cultivation of fruit, vegetables and vines. For vines the directive is 
issued  and  updated  by  the  Association  of  Integrated  and  Organic  Grape  and  Wine  Production  (EKOVÍN),  for  fruit  it  is  the  Association  for 
Integrated Systems for Fruit Cultivation (SISPO) and for vegetables the Association for the Integrated System of Vegetable Production. 

National Integrated farming reference document:  
Decree 2004-293 relating to the conditions on suing the term integrated farming 
Decree 2002-631 relation to the certification of agricultural farms under the "integrated farming" 
Order of 30th April relating to the integrated farming reference document, modified by the order of 20th april 2005 
There are charters per products such as: Pomiculteurs, Peches et Nectarines, Fraise, Tomate, Cucumbers, Table grapes, cherry and prunes 
The certifications for the IP of these vegetables are: FARRE, QUALITERRE, AGRICONFIANCE, GLOBAL GAP  
There are national guidelines for fruits and vegetables that are followed  by the growers association; but the retailers (i.e. the market) have 
defined IP as the standard production scheme. Therefore there is no IP/IPM certification/label  

The introduction of integrated production with certified trademark (trademark “Qualified Farmers/Produce of Integrated Production”), is only at 
high professional level and, therefore, only on a voluntary basis.  The elements that make integral part of it are defined in the Hungarian 
National Plant Protection Action Plan: http://ec.europa.eu/food/plant/pesticides/sustainable_use_pesticides/docs/nap_hungaria_en.pdf 

The national law of 3rd Februray 2011 in the Article 2(3) provides the implementation of the national system of integrated production quality 

162 

 
 
 
 
 
 
 
 
(SQNPI) 
The principal logos at regional level are:  
QUALITA CONTROLLATA: Regional law 28/99 creating the brand of the Emilia-Romagna to identify and promote the food manufactured with IP 
techniques 
AGRICUALITA: Regional law 28/99 creating the brand of the Tuscan area to identify and promote the food manufactured with IP techniques 
QUALITA  VERIFICATA  Regional  law  12/01  creating  the  brand  of  the  Venezia  region  to  identify  and  promote  the  food  manufactured  with  IP 
techniques 
QUALITA GARANTITA Decree 98/CSI 10/09 creating the brand of Piedmont to identify and promote the food manufactured with IP techniques 
PRODOTTI DI PUGIA Deliveration of area 1706/12 creating the mark of the Apuglia region to identify and promote the food manufactured with 
IP techniques 
National action plan, point 3.15 
There are public certification schemes with elements of IPM. Since 1997 is certified organic production, since 2012 is certified superior quality 
fresh fruits, berries and vegetables production. 

Only private schemes 
The national law basis for the IP system were the provisions of the Act of 18 December 2003 on plant protection (O.J. of 2008, No. 33, item 
849, as amended) and the Resolution of the Ministry of Agriculture and Rural Development of 26 July 2004 on integrated production (O.J. of 
2004, No. 178, item 1834, as amended). Control over the entire system was entrusted to the State Plant Health and Seed Inspection Service. 
An agricultural producer interested in acquiring of the IP certificate should inform of his intention to farm the Voivodeship Plant Health and 
Seed Inspection Service, being registered and obliged to fulfil a training, farming in accordance with the methodologies attested by the State 
Plant Health and Seed Inspection Service, document all actions in the IP crops and being inspected by the voivodeship. The certificate is issued 
for 12 months. The producers who comply with the above mentioned conditions have the right to use the certificate and tag products with the 
copyright IP logo.  
The national Decree-Law nº 256/2009 of 24 September establishing the principles and guidance for Integrated Pest Management practice and 
Integrated  Production  and  technical  guidelines  for  the  implementation  of  Integrated  Pest  Management,  Integrated  Production  and  Organic 
Farming and setting an official accreditation system for technical advisors. 
It is estimated that presently only ca 15 professional farmer organizations are actively promoting IPM and IP, mainly in the Lisboa and Vale do 
Tejo region and for the following crops: vegetables, pome and stone fruits and vines. It is also estimated that around 360.000 ha (data from 
2012) is under IP.  
In Romania there are implementing the following specific systems: the agricultural and food products quality systems, organic production and 
traditional products. These systems are managed by the Ministry Agriculture and Rural Development.  

Private certification organisation 

Latvia 
Lithuania 

Luxemburg  
Malta 
Netherland 
Poland 

Yes 
Yes 

? 
No 
Yes 
Yes 

Portugal 

Yes 

Romania 

Slovakia 
Slovenia 

Yes 

? 
yes 

163 

 
 
 
 
Spain 

Yes 

Sweden 

Yes 

UK 

Yes 

12 out of 17 regions developed regulations for IP under the umbrella of the national Royal Decree 1201/2002 and the modification by the 
Royal Decree 108/2010. The regional regulations establish a framework law laying down the requirements for IP, its certification schemes and 
the certifying mark it uses.  
There is a strong IP development in Spain with 766070 ha in 2011 of olives, rice, cereals, cotton, citrus, stone fruits, vegetables, grapes for 
wine making, pome fruits, dry fruits, beet, tobacco, table grapes, Lucerne, bananas, corn and others.   
Sigill Kvalitetssystem AB is a private scheme that develops and manages the IP standard which is the leading independent food and flower 
certification  scheme.  The  IP-standard  contributes  to  sustainable  development  in  crop  and  animal  production.  The  standard  also  comprises 
handling and processing of foodstuff and is coupled to the control and origin brand Svenskt Sigill. Today almost 4000 companies are certified 
according to one or more of the different standard modules 
http://sigill.se/IP-STANDARD/CERTIFIERING-ENLIGT-IP/CERTIFIERING-ENLIGT-IP/IN-ENGLISH/ 
Private schemes since 2000 through: the Soil Association (organic sector); Linking Farming And Environment (LEAF); Assured Food Standards 
(AFS) scheme  

Integrated Production: definition, objectives and principles 

Integrated production is a concept of sustainable agriculture developed in 1976 which has gained international recognition and application. The concept is based on the use of 
natural resources and regulating mechanisms to replace potentially polluting inputs. The agronomic preventive measures and biological/physical/chemical methods are carefully 
selected and balanced taking into account the protection of health of both farmers and consumers and of the environment. 

One of the most comprehensive definitions of IP reads as follows:  

''integrated production is a farming system that produces high quality feed and other products by using natural resources and regulating mechanisms to replace pollution 
inputs to secure sustainable farming" 

The principles and objectives of IP have been compiled, analysed and formulated by an IOBC panel of experts and updated in 2004. The principles cover ecological, ethical and 
social aspects of agricultural production as well as aspects of food quality and safety and are representative of the IP objectives of most of the existing European regulations. 
The objectives of the IP are:  

-  To integrate natural resources and regulation mechanisms into farming activities to achieve maximum replacement of off-farm inputs. This objective addresses the basic 
intentions of a sustainable agriculture. An intelligent management and careful utilization of natural resources can help to substitute for farm inputs such as fertilisers, 
pesticides and fuel. Total or partial replacement of these materials not only reduces pollution but also production costs and improves farm economics 

-  To secure sustainable production of high quality food and other products through ecologically preferable and safe technologies. IP aims at high quality products mainly 

through ecologically sound techniques that are safe from human health. The total evaluation of the agricultural products considers also all sustainable methods of crop 
production (ecological quality), adequate standards in animal production and adequate working conditions of the farm workers.  

-  To sustain farm income: farm products produced with a high level of ecologically safe, ethically sound and socially acceptable quality must generate justified "added 

values". Sustainable agriculture and marketing have to apply the principle of fair trade to the largest possible extent.  

164 

 
 
-  To eliminate or reduce sources of present environmental pollution generated by agriculture. Pollution of agricultural origin has to be reduced or eliminated and wherever 

this is feasible  

-  To sustain the multiple functions of agriculture (multi-functionality). Agriculture has to meet the needs of the entire society, including those requirements that are not 
directly connected with the production of food and fibre. Diversified landscapes, wildlife conservation, colonisation and cultivation of remote areas as well as 
maintenance of local cultural traditions are some of the non-agricultural environmental and recreational values provided by operational farms.  

The principles of IP are:  

- 

IP is applied only holistically. IP is not merely a combination of integrated pest management (IPM) and additional elements such as fertilizers and agronomic measures 
to enhance their effectiveness. Instead, it relies on ecosystem regulation on the importance of animal welfare and on the preservation of natural resources.  

-  External costs and undesirable impacts are minimised. Detrimental side-effects of agricultural activities, such as nitrate or pesticide contamination of drinking water, or 
erosion sediments in waterways, impose enormous costs to society. These external costs are normally not reflected in budgets for agricultural expenditure and must be 
reduced 

-  The entire farm is the unit of IP implementation. IP is a system approach focusing on the entire farm as the basic unit. Important strategies, such as balanced nutrient 

cycles, crop rotations and ecological infrastructures, become meaningful only if considered over the entire farm 

-  The farmers' knowledge of IP must be regularly updated.  
-  Stable agro-ecosystems must be maintained as key components. Agro-ecosystems are the basis for planning and realisation of all farm activities, particularly those with 
potential ecological impact. They are visible expressions of the holistic concepts and provide both natural resources and regulation components. Stabilisation means the 
least possible disturbance of these resources by farm activities 

-  Nutrient cycles must be balanced and losses minimised. Balanced in this context means targeting maximum reduction of nutrient loses (e.g. leaching), a cautions 

- 
- 

replacement of those amounts leaving the farmed area through sales of commodities and recycling of farm materials 
Intrinsic soil fertility must be preserved and improved.  
Integrated pest management is the basis for decision making in crop protection. IPM applies to noxious species of phytophagous animals, pathogens and weeds. In the 
context of sustainable agriculture emphasis with plant protection is placed on preventive (indirect) measures that must be utilised to the fullest extent before direct 
measures are applied. Control means management of the pest population to maintain it below that level that causes economic losses. Decisions about the necessity to 
apply control measures must rely on the most advanced tools available, such as prognostic methods and scientifically verified thresholds. The instruments of direct 
plant protection are the last resort if economically unacceptable losses cannot be prevented by indirect means.  

-  Biological diversity must be supported. Biological diversity includes diversity at the genetic, species and ecosystem level. It is the backbone of ecosystem stability, 

natural regulation factors and landscape quality. Replacement of pesticides by factors of natural regulation cannot sufficiently be achieved without adequate biological 
diversity.  

-  Total product quality is an important characteristic of sustainable agriculture product quality 
-  Animal production on mixed farms. Animal production should regard animal density and welfare of all species 

These objectives and principles are applied to many arable crops in Europe, pome fruits, stone fruit, soft fruits, grapes, olive trees, citrus and field grown vegetables. For each 
one or each family of crops or vegetables a specific technical guideline is published. The Guidelines, even for the same vegetable or crops maybe different depending on the 

165 

 
climatic conditions of the area, type of soil, etc to be applied. The availability of the guidelines is included in the national or regional regulation as well as in the website of most 
of the private schemes.    

166 

 
 
 
 
 
Animal welfare  

This section presents the comments received through BATIS and personal communications from the 1st AHWG meeting to the 2nd AHWG meeting.  

Table 37. Feedback from the stakeholders on the TR1.0: Animal welfare (AC) 
Topic 
Ambition 
levels 

Feedback from stakeholders 
HSI strongly disagrees with the approach of limiting animal welfare to a single AC and 
single product (free range eggs) 
I agree to the ambition levels 
AC4.  Improved  animal  welfare.  Points    shall  be  awarded  proportionally  to  tenders  in 
which the amount of animal products that meet additional high quality, verifiable animal 
welfare  standards  that  are  more  stringent  than  EU  standards  is  above  25%  (50%  for 
comprehensive) of the total procurement cost of animal products. 
TS  in  comprehensive: "Eggs:  where  not  organic,  the  eggs  used    shall  be  code  1  of 
Regulation 589/2008; Meat: At least 5% of the total amount in mass, used per year as 
‘free-range’ animal products (e.g. chicken meat and pig meat). 
5% of procurement cost? Very low ambition. Better to specify products that must meet 
specified criteria. 
TS4. Improved animal welfare. All animal products, whether produced within or without 
the EU,  shall meet EU animal welfare laws and regulations. Further, the animal products 
that  meet  additional  high  quality,  verifiable  animal  welfare  standards  that  are  more 
stringent than EU standards  shall be at least 25% (50% for comprehensive) of the total 
procurement cost of animal products. 
By aiming higher than 5% it would have a positive effect on meat consumption which is 
generally too high. 
When widening the scope to other production systems with significant welfare benefits, 
the threshold can be much higher and still remain feasible. Examples are: slow-growing 
breeds, indoor or sheltered roaming space 
If points are rewarded for more than 5% of the procurement costs, the side effect can be 
that  the  total  amount  of  meat  consumption  increases;  this  is  not  what  we  want  to 
promote. Maybe points can be awarded if a healthy vegetable alternative for meat can 
be offered. 

JRC-Directorate B5 assessment 
Comment accepted 
More animal product categories have been included 
Acknowledged 
Comment accepted 
Due to the fact that there are animal welfare certification schemes 
in most of the Member States plus international schemes that can 
be accepted as proof of compliance, a higher ambition level can be 
considered.  
However, since these thresholds may not be affordable to reach by 
all  Member  States,  the  proposal  is  to  set  the  criterion  as  award 
criterion.  They  will  be  left  to  fix  the  values  attending  to  the 
specificity of the place where the tender is launched.  

Comment accepted 
See above. 

Comment accepted 
The wording of the criterion has been changed. Instead of the % of 
the procurement costs the last proposal suggests a percentage of 
the  total  meat  purchased.  In  this  way,  the  total  amount  of  meat 

167 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Topic 

Feedback from stakeholders 

JRC-Directorate B5 assessment 
does not affect the number of points to be awarded.  

I ask for all our eggs to be free range as TS. Next to that there is an award criterion on 
animal welfare, where the tenderer can get points if they add meat in the menu from 
free range animals. 
The meat quality of free range animals should be better. There can be an extra cost, but 
you should be able to work around this with good menu planning. Also the usage of less 
animal protein and more use of vegetable protein can make the use of more expensive 
free range meat affordable. 
Specify the criteria which are most relevant according to widely available animal welfare 
standards Formulate the criterion on “free-range eggs” as technical specification 
"The EEB welcomes the intention to set criteria addressing animal welfare. Nevertheless, 
the  EEB  highly  recommends  specifying  the  criteria.  Since  there  are  animal  welfare 
standards  of  different  ambition  levels,  it  is  necessary  to  define  the  animal  welfare 
criteria that should be addressed in a public tender. 
Most  important  to  environmental  NGOs  would  be  aspects  such  as  respecting  natural 
behavioural  needs  of  farm  animals  and  meeting  their  minimum  space  requirements. 
Furthermore, the EEB recommends formulating the core criterion on “free-range eggs” as 
a technical specification since such eggs are easily available in high quantities. 
Mainly  representatives  from  different  environmental  ministries  and  from  public 
procurement offices pointed out that it is quite important to reduce the purchased meat 
quantities in order to switch to meat supply of higher quality." 

Acknowledged 
See above.  
An  increase  of  vegetable  proteins  usage  has  been  included  in  the 
menu planning. 

Comment partially accepted 
The rationale of the criterion includes some of the criteria that any 
animal  welfare  standard  should  comply  with.  Additionally,  some 
specific animal welfare standards are named as an example. 

Verification  Means  of  proof:  consider,  if possible,  to  add  also  ISO  14021  “free-range  animals” 
indicating  the  producer  references  useful  to verify  the  environmental  assertion  done 
or combining with the ISO 22005:2007 “Traceability in the feed and food chain”.   

Third party certified products to animal welfare standards are common for poultry, eggs, 
milk, pigs meat, cows meat, lambs meat and pasture meat. Even though some criteria, 
i.e.  stunned  slaughter,  can  comply  with  an  animal  welfare  standard  as  well  a  national 
legislation  in  some  member  countries.  5%  of  procurement  cost? Difficult  to  hold  track 
of. For  every  supplier  if  more  than  one  supplier?  Very  low  ambition.  Better  to  specify 

Comment rejected 
Both  mentioned  norms  are  self-declarations.  In  the  existence  of 
other third party and cannot be admitted as a verification proof. A 
third party verified product is the only accepted proof. 
Acknowledged 
The verification system is proposed. See above for further details. 

168 

 
 
 
Topic 

Feedback from stakeholders 
products that must meet specified criteria. 
The report could further investigate if there are further means to assess animal welfare 
criteria other than free range breeding. 

Market 
availability 

The  availability  of  meat  products  that  are  third-party  certified  for  animal  welfare 
standards varies across different countries in the EU. We would not recommend setting 
criteria for this aspect given the wide variability in availability across the EU. 

Market 
availability 

We have no problem in Denmark with availability, because we buy organic meat. 
Requiring “all” eggs that are not organic to be cage-free or free-range creates a conflict 
between demands for local sourcing and demands for cage-free or free-range eggs. .The 
availability of such eggs is highly variable across the EU. 

General 
comments 

We  do  not  have  faced  any  problem  buying  organic  eggs.  However  for  meat  is  more 
problematic. Overall though the amount of meat has been reduced to keep the available 
kitchen budget.  
The overuse of antibiotics should be considered.  
There  are  also  other  aspects  of  animal  welfare; The  use  of  antibiotics?  Stunned 
slaughter? Transportation time to the slaughter house? Grazing season for milk cow? No 
tail docking on pigs? 

JRC-Directorate B5 assessment 

Comment accepted 
The EC has regulated the best practices aimed at improving animal 
welfare,  specific  for  each  kind  of  farmed  species.  E.g  COM  (EU) 
2016/336  on  reducing  the  need  for  tail-docking  and  optimised 
solutions for providing enrichment materials for pigs. 
Comment partially accepted 
It  is  important  to  consider  animal  welfare  due  to  consumers 
demand and is linked with animal health and well-being.. 
The  market  availability  varies  but  there  are  a  number  of  animal 
welfare  certification  schemes  at  national  and  international  level 
that can be accepted as proof of compliance.  
Stakeholders  reported  that  the  proposed  ambition  levels  are 
feasible and could be even been raised up 
Acknowledged 
Comment accepted 
In  order  to  provide  higher  flexibility  to  the  procurers  to  adapt  to 
their  regional  conditions,  an  open  wording  of  the  criterion  is 
proposed.  Recommended  values  are  included  in  the  explanatory 
notes.   
Acknowledged 

Comment accepted 
The  welfare  of  animals  is  assured  by  Directive  2008/120/EC.  EU 
legislation sets welfare standards for their farming time, transport 
and  conditions  at  the  time  of  stunning  and  slaughter  Moreover, 
COM  REC  2016/336  on  the  application  of  the  directive  lies  down 
minimum standards for the protection of pigs as regards measures 
to reduce the need for tail-docking. Transposition of directives and 
rules into national legislation is a responsibility of Member States, 
which can be taken as verification system. 
Moreover,  MEPs  voted  to  adopt  an  EU  regulation  harmonising 

169 

 
 
 
 
Topic 

Feedback from stakeholders 

The evidence on setting animal welfare criteria has shown pros and cons in the respect 
to achievable environmental benefits. Moreover, procurement should be considered as a 
whole and the criteria should be set out so that criteria on animal welfare will not seem 
out of place. One way to increase animal welfare is thorough minimisation of livestock 
consumption  and  this  seems  to  be  lost  within  the  criteria  proposals.  The  connection 
between  criteria  also  deserves  further  attention.  A  stakeholder  responded  that  this 
criterion aims to promote the purchase of meat of higher quality in the case where it is 
chosen to be bought. At same time the menu planning criterion includes the aspect on 
reducing the livestock consumption. Both aspects tackle different points on the livestock 
consumption.  Implicitly  this  leads  to  the  conclusion  that  better  quality  meat  should  be 
bought in the smaller quantities. 
We  propose  the  inclusion  of  the  scheme  explained  in  the  Regulation  (EU)  No 
665/2014   with  regard  to  conditions  of  use  of  the  optional  quality  term  ‘mountain 
product’ 

General 
comments 

Healthier conditions prevent diseases and limit the use of drugs to cure animals, so this 
one it's not only an ethical criterion.  
We  propose  to  add  a  criterion  allowing  antibiotics  to  be  used  only  if  prescribed  by  a 
veterinarian. 

Even in free range systems, animal welfare is for an important part dependent on indoor 
housing facilities, as animals will not be outdoors 24/7. Free range production standards 
acknowledged by GPP should be based on an integrated approach on animal welfare. 

JRC-Directorate B5 assessment 
animal welfare rules will enter into force foreseeably in 2017, with 
a  key  goal  of  toughening  up  the  fight  against  antimicrobial 
resistance (AMR). Under these rules  the EC will monitor the use of 
animal  antibiotics  and  published  data.  European  Food  Safety 
Authority (EFSA) experts have been consulted to update the list of 
potentially 
farmer's 
organisations,  veterinary  associations,  animal  welfare  movements 
and others involved in drafting contingency plans. 
Comment accepted 
See above 

together  with 

dangerous 

diseases 

Acknowledged 
Mountain product is a designation of animal products produced in 
mountain areas The scope of the animal welfare criterion is on all 
farmed animal species, which comprises mountain products as well. 
Acknowledged 

Acknowledged/Comment accepted 
Animal  welfare  standards  include  a  rational  use  of  antibiotics. 
Healthier conditions prevent diseases and limit the use of drugs to 
cure animals. 
See previous comment above as well 
Acknowledged 
Integrated approach has been set as a different criterion. 

170 

 
 
Topic 

Wording  of 
the 
criterion 

Feedback from stakeholders 
There  is  a  wide  range  of  production  methods  in  between  conventional  and  organic  in 
terms of animal welfare levels. Solely focussing on free range is a missed opportunity to 
develop  this  segment,  as  it  is  the  segment  where  the  best  balance  between  welfare, 
environmental impact, human health and cost is achieved. 
IFOAM EU welcomes the inclusion of animal welfare standards. However, since this topic 
can be quite wide it is important to set clear criteria for these standards. 
Free range egg criterion should not undermine the procurement of organic eggs. 
It  is  important  to  highlight  also  that  organic  agriculture  already  has  clear  and  high 
standards for animal welfare compared to conventional produce. These products should 
not exclude organic labelling. The combination of these two criteria will lead to optimal 
results. 
Free range breeding is only one aspect related to animal welfare, others include issues 
such animal health (the use/avoidance of hormones and antibiotics etc.). In addition, the 
legal base related to animal welfare vary between Member States, others having stricter 
requirements than others. 
Municipalities  and  other  public  authorities  in  Denmark  which  focus  on  animal  welfare 
demand organic products. 
Free-ranged  animals  (e.g.  bovines)  use  land  which  cannot  be  cultivated  by  arable 
cropping,  that  is  why  organic  stock-keeping  is  environmentally  less  favourable  not 
because animals need more fodder because living longer (as written in the rationale) 
"The  binary  nature  of  the  discussion  on  trade-offs  between  animal-welfare  and 
environmental improvements here are erroneous.  Opportunities to both improve animal 
welfare and climate change impacts exhibit areas of co-benefits and trade-offs. Shields 
and Orme-Evans (2015) outline these areas and show that a number of opportunities to 
achieve  co-benefits  exist.   Unfortunately,  the  Technical  Report,  as  with  the  Preliminary 
Report  (section 4.5.1.7)  only  mentions  trade-offs.  Instead, the  GPP  criteria  should  seek 
and  support  co-benefits.  HSI  suggests  that  phrasing  to  this  effect  be  added  to  the 
Technical Report in lieu of the current line on trade-offs: “Opportunities to both improve 
animal  welfare  and  climate  change  impacts  exhibit  areas  of  co-benefits  and  trade-offs. 
The  GPP  criteria  should  support  opportunities  with  co-benefits  and  avoids  trade-offs 
wherever possible.” 
Further,  this  analysis  appears  to  rely  only  on  LCAs  with  functional  units  per  mass  of 
product—not  in  terms  of  land  use.  Garnett  (2011),  however,  has  pointed  out  that 

JRC-Directorate B5 assessment 
Comment accepted 
The criteria wording has been changed accordingly. 

Comment accepted 
See above 

Acknowledged 

Comment accepted 
The rationale wording has been changed accordingly. 

Comment accepted 
The rationale has changed accordingly to the suggestion. 

171 

 
 
Topic 

Wording  of 
the 
criterion 

Others 

Feedback from stakeholders 
environmental  impacts  per  land  use  units  can effectively  shift  the  results  for LCAs for 
farm  animal  production.   We  therefore  ask  that  the  Technical  Report  additionally 
consider this aspect of impacts analysis, which is required for a complete, holistic, and 
balanced sustainability analysis." 
The use of "slightly" when talking about the cost of animal welfare products, because the 
Cost difference is very much dependent on specific product and supply chain model used. 
“Points  shall be awarded to tenders where non-organic eggs in shell to be delivered have 
been  produced  respecting  animal  welfare  standards  on  outdoor  access,  depending  on 
availability.” 
In addition to water impacts, other impact categories particularly relevant to farm animal 
production  should  be  included:  methane  and  nitrous  oxide  from  manure  management 
should be included. 
As  we  state  in  the  attached  document,  the  misuse  or  overuse  of  antimicrobials  or 
antibiotics in animals have a negative impact on the environment and health. 
Besides  the  energy  use  in  slaughtering  there  should  also  be  the  slaughtering  and 
(e.g.  small  slaughtering  houses  with  consecutive 
handling  schemes  mentioned 
processing; centralised slaughtering units with cold storage/deep freezing/transport and 
further processing in other establishments 
Please add under Food Procurement: Impact from animal livestock: use of antibiotics and 
development and spread of antibiotic resistant bacteria in the environment 

Under  Food  Procurement  please  improvement  areas  should  include:  organic  meat  or 
meat  raised  without  routine  non-therapeutic  antibiotics  reduced  meat  provision  for 
maximum climate and resource impact. Products produced and processed locally 

JRC-Directorate B5 assessment 

Comment accepted 
Wording implemented 

Comment rejected 
The 
lack  of  schemes  on  this  topic  makes 
implementation of this requirement into the criteria set 
Acknowledge 

impossible  the 

Acknowledge 

Comment rejected 
The use of antibiotics is covered by the EU Regulation and some of 
the  third  party  certification  schemes  as  proof  of  compliance. 
Revised  regulation  is  expected  to  come  into  force  in  2017 
addressing this point 
Comment rejected 
Organic food products are already included in criterion 1 

Further analysis on animal welfare 
This  criterion  has  been  conceived  to  promote  the  purchase  of  animal  products  of  higher  quality  and  in  smaller  quantities,  being  this  criterion  linked  to  the  meat  reduction 
measure taken in menu planning. Despite no harmonized animal welfare labelling system exist in the EU, the majority of the stakeholders agreed on extending the scope of the 
criteria, limited up to now to free range eggs, and include as well all free range animal products (e.g. chicken and pig meat). Moreover, the common opinion is to increase the 
ambition levels, and to put the criteria as a technical specification. 

172 

 
 
 
 
When buying food of animal origin, consumers are increasingly interested in the animal welfare situation of the animals. Commission has taken steps to address the issue of 
labelling related to animal welfare and also introduced ban on cat and dog fur. 

Table 38. Steps taken for labelling related to animal welfare products, EU Commission. 
Community Action Plan for Animal Welfare 2006-2010 
Choose translations of the previous link - one of the main areas of action described in this plain was to involve the general public and enable consumers to make more informed 
purchasing decisions. The Action Plan envisaged the creation of an Animal Welfare Reference Centre, which could serve as a coordinating body for the different initiatives related 
to animal welfare labelling (standardisation/certification of welfare indicators, auditing schemes, databases related to existing certified labels). The Centre should also facilitate 
the preparation of relevant socio-economic studies and impact assessments. 
Council Conclusions 2007 
In 2007 the Council adopted Council Conclusions inviting the Commission to assess further the issue of animal welfare labelling in all its aspects, and to submit a report to the 
Council in order to allow an in-depth debate on the subject. 
UK Farm Animal Welfare Council report 2006 
The 2006 Report by The Farm Animal Welfare Council (FAWC) in the UK examined the case for the provision of animal welfare information to consumers to help improve the 
welfare of animals. These discussions highlighted that any animal welfare labelling needs to be based on science. Therefore the Action Plan proposed to link the labelling to the 
use of standardised animal welfare indicators, recognised both in the EU and internationally. 

Animal welfare indicators 2004-2009 
Such animal welfare indicators were being developed by the EU funded research project "Welfare Quality". The project focused on the integration of animal welfare in the food 
quality chain, and addressed public concern by improved welfare and transparent quality. The project aimed to: 

  accommodate societal concerns and market demand; 
  develop  reliable  on-farm  monitoring  systems,  product  information  systems,  and  practical  species-specific  strategies  to  improve  animal  welfare  including  welfare 

indicators; 
focus on three main species and their products: cattle (beef and dairy), pigs, and poultry (broiler chickens and laying hens). 

 

Conference "Animal Welfare – Improving by Labelling?", 2007 
During the conference the European Economic and Social Committee (EESC) presented an exploratory opinion on this issue. The Conference concluded that labelling could, under 
certain conditions contribute to improving animal welfare. 
COM RECOMMENDATION (EU) 2016/336 
On the application of Council Directive 2008/120/EC laying down minimum standards for the protection of pigs as regards measures to reduce the need for tail-docking 

Husbandry systems differ across the Member States. It is therefore necessary to recommend at Union level best practices for the protection of animal welfare, such as e.g. 
reducing the need for tail-docking and optimised solutions for providing enrichment materials. (COM (EU) 2016/336). 

173 

 
 
 
 
 
MEPs voted in 2016 to adopt an EU regulation harmonising animal welfare rules, with a key goal of toughening up the fight against antimicrobial resistance (AMR) (European 
parliament news, 2016). Under the regulation that will enter into force foreseeably in 2017, the European Commission will monitor the use of animal antibiotics and published 
data.  And  European  Food  Safety  Authority  (EFSA)  experts  have  been  consulted  to  update  the  list  of  potentially  dangerous  diseases  with  farmer's  organisations,  veterinary 
associations, animal welfare movements and others involved in drafting contingency plans. The Revision of the Veterinary Medicines Legislation is ongoing at the moment of the 
drafting of the GPP recommendations. Onto the reduction of red tape the regulation will: 

 
 

streamline marketing authorisation procedures will allow companies to place and maintain a veterinary medicine on the entire EU market; and  
pharmacovigilance rules (the monitoring of adverse effects of veterinary medicines on the market) will be simplified. 

To stimulate the development of new medicines: 

special rules for the authorisation of veterinary medicines for small markets such as apiculture and aquaculture will be introduced; and 

 
  a better reward mechanism will be put in place, i.e. extended data protection to innovative veterinary medicines, that will make the companies’ investments worthwhile 

economically. 

To help the circulation of animal medicines across the EU: 

 

rules are introduced to facilitate the internet retailing of veterinary medicines within the EU. 

The controlled used of antibiotics in the cattle is a major must of private schemes in labels such Globalgap when the add-on about Animal Welfare is comprised.  
In addition to farmed animals,  animals used for scientific purposes (in laboratory tests) and wild animals are also protected by harmonised EU standards, which are under 
responsibility of Directorate General Environment. 

174 

 
 
 
 
 
Fairly traded products 

This section presents the comments received through BATIS and personal communications from the 1st AHWG meeting to the 2nd AHWG meeting.  

Table 39. Feedback from the stakeholders on the TR1.0: Fair traded products (AC)  
Topic 
Market 
availability 

Feedback from stakeholders 
The market availability of fairly traded certified products is sufficient. 
Sugar  is  available  also  from  regional  (European)  and  sustainable  (organic)  production. 
This must also be taken into consideration as “produced having sustainable considerations 
in regard”. 
The  availability  of  such  products  is  variable  from  one  country  to  another.  For  most 
countries, it would be difficult to achieve a 20% target and impossible to achieve a 50% 
target,  while  for  a  small  number  of  countries  a  50%  target  may  be  relatively  easy  to 
achieve  if  this  refers  to  sustainable  products  more  broadly.  However,  achieving  even  a 
20% target will increase the cost. We recommend encouraging the procurement of some 
fairly traded products, depending on availability, without setting a specific target. Due to 
the variation in market availability in different EU countries, we also recommend keeping 
this as an Award Criterion.   
Good, and increasing, market availability of coffee, tea, chocolate.   
No problem with availability. In Denmark we have a wide range of Fairly Traded certified 
products and it’s not a problem to create competition in a tender of fair trade products  
The Fairly traded products mentioned (bananas, chocolate/cocoa, tea, coffee and sugar) 
are all easily available on the market so the ambition level here could be raised 
Vienna´s  KWP  (Retiree´s  homes  Organization),  completely  changed  to  fair  trade  & 
organic coffee in 2013. 
Due to the variation in market availability in different EU countries, we also recommend 
keeping this as an Award Criterion.   
I agree to the ambition levels. 
Yes, we agree and think that a minimum percentage of 20 as core criteria should be set 
for tea and coffee. 
We agree that a core minimum percentage of 20 should be set for coffee, tea and cacao 
(chocolate)  and  other  percentages  should  be  set  for  other  products,  such  as  sugar  or 
tropical fruits. For comprehensive criteria, we found correct the percentage of 50%. 
"Coffee,  tea  and chocolate should  be  100%  fairly  traded.  It  is  preferred  not  to  use the 

Ambition 
levels 

JRC-Directorate B5 assessment 
Acknowledged – Comment accepted 
Wide and increasing availability in the selected products  

Acknowledged – Comment accepted 
Due  to  the  fact  that  there  is  a  wide  market  availability  of  fairly 
traded  certified  products  in  most  of  the  Member  States,  a  high 
ambition level can be considered. .  
However,  since  these  thresholds  might  not  be  affordable  in  all 
Member  States,  the  latest  proposal  includes  in  the  explanatory 
notes the minimum level which tenders start scoring points.  These 

175 

 
 
 
Topic 

Others 

into  account  for 

taking  sustainable/ethical  considerations 

Feedback from stakeholders 
phrase  'fair  trade'  as  it  refers  to  a  specific  label.  Bananas  are  often  fair  trade  and 
organic. 
The EEB does not agree with the proposed thresholds that we consider being too low and 
not ambitious enough. Therefore, we suggest to require at least 50% by weight (not by 
procurement cost!) of the purchased coffee, tea, chocolate (cocoa), sugar or bananas that 
have  been  produced  taking  sustainable/ethical  considerations  into  account  for  the  core 
criteria; and 100% of the purchased coffee, tea, chocolate (cocoa), sugar or bananas have 
the 
been  produced 
comprehensive  criteria.  Stakeholders  from  public  procurement  departments  explained 
that they do not face any problems in buying “Fair Trade products” in higher amounts. 
Maybe we could go higher?  
Coffee  and  tea  should  be  10%  fairly  traded  and  a  more  extended  list  should  be 
considered 
In our tenders we require 10% for coffee, tea and sugar so a more ambitious levels for 
the criteria should be set. 
Is it possible to combine technical and award criteria? 
Greenwashing and over-valuing certain marketing schemes by certain companies should 
be avoided 
Add  another  Award  Criteria  "Points    shall  be  proportionally  awarded  to  tenders  that 
undertake a share of total amount of products constituted by protected designations of 
origin,  protected  geographical  indications  and  traditional  specialities  guaranteed  (PDO, 
PGI, TSG) products according to regulation UE 1151/2012".  
This AC is proposed as a social criterion. These kinds of products promote the safeguard 
of local traditions and, in some cases, the safeguard of the soil/land features useful to 
guarantee the high level of organoleptic and taste quality typical of them. Moreover, in 
these production protocols could be also addressed environmental criteria better than in 
food products without any standard. 
IFOAM EU welcomes the inclusion of fairtrade product criteria and sees the added value 
of such criteria to complement organic criteria. However, it is not a practical approach to 
have a percentage for specific products. When supplying coffee, you need to have several 
retailers of coffee to have a percentage. But, often, procurers only have one supplier of 
coffee in their contract that has a range of coffee products not all of which can meet the 
criteria.  These  products  should  not  exclude  organic  labelling.  The  combination  of  these 

JRC-Directorate B5 assessment 
explanatory notes are not mandatory and let the public institution to 
fix the most appropriated levels  attending to the specificity of the 
place where the tender is launched. Recommendations are given to 
the procurers to require in their tenders for 10-30 and 30-70% of 
each purchase of the mentioned products 

Comment rejected 
No,  it  is  not  possible  to  combine.  Third  party  certified  products 
ensure that greenwashing does not take place.  
Comment rejected 
The  scope  of  both  schemes:  fairly  traded  schemes  and  protected 
designations  cannot  be  considered  as  equivalent.  The  former 
focuses  on  the  social  and  sustainable  aspects  whereas  the  latter 
relies on traditions and geographical indications. 

Comment rejected 

176 

 
 
Topic 

Others 

Feedback from stakeholders 
two criteria will lead to optimal results. 
Fair trade could be included as a contract performance clause instead?  
Fair trade should be part of a contract performance clause or an award criterion but not a 
technical specification. 

Technical and award criteria addressing the same criteria areas can be combined. They 
proposed to have 100% organic (for coffee) as a technical criterion and fair trade as an 
award  criterion.  E.g. A  tenderer  that  offers  Organic  coffee  (TC:  100%  organic)  can  gain 
extra award points when it is also Fair trade. 
Are national targets an option to take into account when setting requirements on fairly 
traded products.  

Food products that are certified as organic (and fulfil criterion TS1, AC1) are out of the 
scope of this requirement. 
Fair  trade  vs  organic  fair  trade:  after  consultation  of  different  legal  advisors  from 
different public institutions, I’m giving extra points for organic fair trade (award criteria), 
so no exclusion of organic fair trade 
When  stimulating  sustainable  production  in  developing  countries,  you  should  stimulate 
both social sustainability as well as ecological sustainability. Technical and award criteria 
can  be  combined,  when  the  technical  criteria  are  not  seen  as  a  percentages.  E.g.  A 
tenderer that offers Organic coffee (TC: 100% organic) can gain extra award points when 
it is also Fair trade. 
Specification on product level can be made. A percentage is not relevant within a tender, 
but  should  be  set  as  a goal  for  the  general  policy.  Award  criterion  in  combination  with 
percentage  is  also  a  bit  strange:  normally  with  award  criteria:  the  one  that  scores  the 
highest  (percentage)  gets  the  most  points  on  this  specific  aspect.  So  there  is  no 
difference between  the  core  and  comprehensive  criteria  as such.(cid:13)The  list  of  products  is 
too limited. 
The list of products is too limited. 

General 

JRC-Directorate B5 assessment 

Comment accepted 
A  contract  performance  clause  could  assist  on  the  verification, 
especially of those criteria that rely on third party certified schemes. 
A  general  contract  performance  clause  will  be  included  in  this 
revision   
Comment accepted 

Comment accepted 
GPP is developed for the EU28 and then procurers adapt it to their 
own area's specificities.  
Comment rejected 
See above 
Comment accepted 
The products that are organic and fairly trade will score points from 
the two criteria.  

Comment rejected 
The  percentage  sets  a  threshold  from  which  tenderers  get  points. 
The word 'proportionally' has been added to make clear that the one 
offering a higher value above the threshold will get a higher score. 
Point scales are a matter of authorities. 
Even if the market availability for fairly traded products is growing, 
the list of products is still short: coffee (59%); being the next most 

177 

 
 
 
 
 
 
 
Topic 

Feedback from stakeholders 

"such  as  e.g.  Fairtrade,  Rainforest….”  who  decide  what  is  a  recognised  international 
organisations? 

Clarify Fairtrade®  (the registered trademark) and fair traded product 

Furthermore,  the  Rainforest  Alliance  and  UTZ  labels  are  not  fair  trade  labels.  ICLEI 
therefore does not recommend that they be recommended as a form of verification for 
fair trade standards, principles, issues, etc, in public procurement. Certain aspects of the 
following  publication  (STA  2013)  (on  fair  timber  procurement)  may  provide  useful  for 
your recommendations in this area 
The  rainforest  alliance  label  isn’t  a  label  we  use  and  we  don’t  want  to  use.  We  use 
Fairtrade  (FLO  standards)  because  we  want  to  support  smaller  farmers  and  pay  an 
honest price for what they have produced. UTZ and Rain forest alliance (RFA) have other 
goals.  RFA  mainly  wants  to  protect  the  rainforest  and  UTZ  has  its  goal  on  developing 
minimum  standards  and  transparency  for  the  production  (agricultural,  social  and 
environmental). 

General 

JRC-Directorate B5 assessment 
important products, bananas (15%), cocoa (8%), flowers and plants 
(6%) and seed cotton16. 
Acknowledged 
There are several schemes of international recognition. For example, 
for  product  certification,  the  Fair  Trade  Labelling  Organisations 
International  (FLO)  serves  as  a  coordinating  organisation  for 
national  labelling  initiatives  and  producer  networks  as  well  as  a 
certification body. 
The use of any scheme under FLO indicates that a product has been 
certified  by  independent  auditors  to  ensure  that  it  respects 
environmental, labour and development standards. 
Comment accepted 
It is rephrased in the rationale 
Comment rejected 
for  Sustainable 
A 
Development  (IISD)  and  the  International  Institute  for  Environment 
and  Development  (IIED)  evaluated  the  Standards  and  the  Green 
Economy in 2014. (see below) 
Acknowledged 
Schemes are suggested as a voluntary sustainability initiative to be 
used  for  the  verification.  They  are  examples  for  compliance,  it  is 
absolutely not mandatory to use them. Below there is a review of 
social  indexes  coverage  made  by  the  International  Institute  for 
Sustainable  Development  (IISD)  and  the  International  Institute  for 
Environment  and  Development  (IIED).  SAN/RA  seems  to  cover  the 
majority of social indices (except for the gender balance where only 
50% of the products comply with it).  
For UTZ the community involvement and the employment benefits 
are as well as gender balance out of coverage. 

International 

Institute 

report 

from 

the 

Copenhagen Municipality ask for fair trade products. We use fair trade (FLO standards)  Acknowledged 

16 Fair trade and consumers in the European Union, Ron Davies, European Parliamentary Research Service. 2014. 

178 

 
 
                                                           
Topic 

Vending 
machines 
related 

Feedback from stakeholders 
because we want to support smaller farmers and pay an honest price for what they have 
produced.  
UTZ  and  Rain  forest  alliance  (RFA)  have  other  goals.  RFA  mainly  wants  to  protect  the 
rainforest and UTZ has its goal on developing minimum standards and transparency for 
the production (agricultural, social and environmental).In our tenders on coffee, tea, sugar, 
and the tender on hot drink vending machines we ask for organic and fair trade products. 
One does not rule the other one out.  
Answers to the consultation questions to stakeholders:  
- Which is your experience in the market availability for products fair trade certified?  No 
problem  with  availability.  In  Denmark  we  have  a  wide  range  of  Fair  Trade  certified 
products and it’s not a problem to create competition in a tender of fair trade products 
- Do you agree with the threshold level (20%) and 50% set, respectively, for the core and 
comprehensive criteria)? Maybe we could go higher?  
- Is this criterion particular relevant for vending machines? It’s very relevant to go for fair 
trade in vending machines. It’s a quick win. And for coffee, tea and sugar you can go for a 
100%. 
The social or sustainability standards used and the way they are controlled should be the 
focus of GPP, whether or not this is made visible via a consumer facing logo 
Can the label from the Rain Forest Alliance be considered to comply with this requirement 
for fairly traded products? This is despite the fact that the label is awarded to products 
when only 30% of all volume is fairly traded.  
These percentages should be included to at the vending machines gradually, particularly 
whether we talk about coffee and tea. 
I consider equal relevant for vending machines. There are community councils procuring 
100% fairtrade coffee as they are Fair trade Cities without problem regarding whole and 
grained coffee as well as vending machines. 
In  our  tenders  on  coffee,  tea,  sugar  and  the  tender  on  hot  drink  vending  machines 
everything has to be 100 % fair trade (TS) and being organic fair trade is even better. 

JRC-Directorate B5 assessment 
See above 
Regarding the levels of ambitions, see above. 
Criteria  for  vending  machines  have  been  proposed  as  a  separate 
GPP criteria set in this second revision 

Acknowledged 
These are the goals pursued with this criteria 
Acknowledged. 

Comment accepted 
There is an unanimous agreement on the following points:  
-  as  the  organic  products  criterion  the  criterion  on  fairly  traded 
products is relevant for vending machines,  especially for those that 
offer coffee and other hot beverages.  
-  organic  and  fairly-traded  products  are  on  the  market  (especially 
when  considering  hot  beverage  machines)  Therefore,  both  criteria 
are complementary and can be required simultaneously.  
-  the  good  market  availability  and  the  few  number  of  products 
supplied in the hot beverage machines (coffee, sugar, chocolate, the, 
etc) makes possible to set an ambition level of 100% in mass.  
For  other  vending  machines  (eg  snacks)  this  threshold  should  be 

179 

 
 
Topic 

Feedback from stakeholders 

Wording 

It is not because a product is produced organically that it is fairly traded, so the following 
note should be removed: "Food  products  that  are  certified  as  organic  (and  fulfil  criterion 
TS1, AC1) are out of the scope of this requirement." 
“…having  sustainable/ethical  considerations….”: 
“sustainable OR ethical”   ? 

it  “sustainable  AND  ethical”  or 

is 

“Cost for all coffee, tea, chocolate, sugar or bananas have ….”:   
it is not clear whether 20% of the procurement of coffee AND 20% of the procurement of 
tea AND 20% of the procurement cost of chocolate AND…. Or if 20% of the procurement 
cost  of  coffee  +  tea  +  chocolate  +  …..  have  been  produced  having  sustainable/ethical 
considerations in regard. 
Fair  trade  products  criteria  should  bear  different  naming given  that  it  can  be  confused 
with  the  fair  trade  trademark.  We  therefore  recommend  using  a  different  wording  for 
referring to this criterion. 
We recommend using the term “fairly traded products” rather than “fair trade” products, 
which refers to a limited and specific trademark. It is also necessary to be clear about 
whether  these  will  need  to  be  fairly  traded  products  or  sustainable  products  more 
broadly,  since  the  criterion  refers  to  “products  that  have  been  produced  having 
sustainable/ethical considerations in regard”. 
Change wording; this implies GPP refers to the use of FLO-certified Fair Trade products 
specifically. 
This criterion should be named differently in order to reflect the ends (applying an ethical 
certification  scheme  or  otherwise  fulfilling  the  requirements  set  in  the  scheme)  rather 
than one specific means (the fair trademark which is a brand of its own). 
We consider the current wording chosen to be too vague, and thus will be ineffective in 
practice in achieving its aims.  

JRC-Directorate B5 assessment 
revised. 
Comment rejected 
Precisely because an organic product may not be fairly traded, this 
sentence should remain to avoid double counting  
Comment accepted 
Text  has  been  edited  to: 
considerations"… 
Comment accepted 
The criterion wording has been rephrased 

"…having  sustainable  and  ethical 

Comment accepted 
The  criterion  has  been  renamed  as  fairly  traded  products.  The 
concept of fairly trade has been clarified in the rationale: fair trade 
is  a  social  movement  whose  stated  goal  is  to  help  producers  in 
developing  countries  achieve  better  trading  conditions  and  to 
promote  sustainability.  Members  of  the  movement  advocate  the 
payment  of  higher  prices  to  exporters,  as  well  as  improved  social 
and environmental standards. 

Further analysis on fairly trade 

The EU has exclusive competence for trade policy. In a 2009 Communication on the role of fair trade in sustainable development, the European Commission held that it should 
not  take  a  role  in  regulating  non-governmental  sustainability  assurance  schemes,  including  those  for  social  and  environmental  sustainability  such  as  fair  trade  labels.  The 
Commission stated that it would, however, continue to provide some financial support to fairly trade initiatives through its development cooperation budget. On the other hand, 

180 

 
 
 
 
the European Parliament (which has an informal cross-party group on Fair Trade) has repeatedly called for promotion of fairly trade initiatives and a coherent policy on fairly 
trade.  In  early  2014  the  European  Parliament  and  Council  adopted  legislation  that  allows  public  bodies  in  the  EU  to  require,  in  their  procurement  procedures,  labels  as 
certification  that  a  product  meets  objective  criteria  related to  factors  such  as  environmental  or  social  sustainability.  However  suppliers  may  provide  any  label  that  certifies 
conformance with the criteria; if they are not able to obtain a label, they may offer alternative forms of proof. 

According to a report of the EU Parliament, there are two complementary approaches to fairly trade, each represented by an international organisation. For product certification, 
the Fair Trade Labelling Organisations International (FLO) serves as a coordinating organisation for national labelling initiatives and producer networks as well as a certification 
body. Secondly the World Fair Trade Organisation, that does not certify products, but seeks to influence the practices of organisations in the supply chain, 

The market availability for fairly trade products is growing, the stakeholders confirm it. According to the European Parliament research service, the EU is the most important 
region for fairly trade products, accounting for roughly two-thirds of world sales (including the USA), with the UK (€1.9 billion), Germany (€533 million) and France (€345 million) 
representing the largest markets. Estimated 'premium' receipts – over and above the Fairtrade minimum price which covers the cost of sustainable production – for 2012 were 
€80 million. In 2010-11, more than half of sales income came from sales of coffee (59%); the next most important products were bananas (15%), cocoa (8%), flowers and 
plants (6%) and seed cotton (3%). 

Table  40.  Average  coverage  of  social  indices  for  each 
voluntary  sustainability  scheme.  SSI  Review  2014. 
International  Institute  for  Sustainable  Development 
(IISD)  and  the  International  Institute  for  Environment 
and Development (IIED) 

About the ambition levels the stakeholders agree they could be 
higher,  since  they  were  not  ambitious  if  kept  as  presented  in 
the 1st AHWG meeting. Stakeholders from public procurement 
departments explained that they do not face any problems in 
buying “Fairly Trade products” in higher amounts.  

fairly 

There  were  several  stakeholders  that  raise  some  criticism 
about 
trade  marks.  The  Fairtrade  Foundation 
(International  Fairtrade  Certification  Mark)  does  not  monitor 
how  much  of  the  extra  money  paid  to  the  exporting 
cooperatives reaches the farmer. Furthermore, retailers almost 
never  sell  identical  Fairtrade  and  non-Fairtrade  lines  side  by 
side,  so  it  is  rarely  possible  to  determine  how  much  extra  is 
charged or how much reaches the producers in spite of Unfair 
Trading legislation. WFTO Fair trade principles include however, 
transparency and capacity building. And the coverage of social 

181 

 
rights and environmental and economic indexes by several voluntary schemes has been reviewed in a report from International Institute for Sustainable Development (IISD) and 
the International Institute for Environment and Development (IIED): 

Table  41.  Average  coverage  of  environmental 
indices for each voluntary sustainability scheme. SSI 
Review 2014. International Institute for Sustainable 
Development  (IISD)  and  the  International  Institute 
for Environment and Development (IIED) 

Research  on  the  minimum  percentage  of  content  to  hold 
logos on fair trade  

It  has  been  noted  by  stakeholders  that  requirements 
specified  to  hold  the  fairtrade  logos  vary  considerably 
across  products  and  labels.  Many  of  the  labels  certify 
farms  production  not  products.  It  can  happen  therefore 
that  the  label  will  allow  blends  with  as  little  as  30% 
content  from  certified  farms.  There  is  a  review  below  of 
these  minimum  certified  contents  that  the  labels  set  to 
award their certification to one product. 

Rainforest Alliance 
Rainforest  Alliance  and  Fairtrade  have  different 
systems for creating certified blends. Fairtrade certified blends must contain 100% Fairtrade coffees. Rainforest Alliance will allow blends from 30% content 
onwards from Rainforest Alliance Certified farms to carry their green frog seal, while companies are asked to commit to increasing the certified content to 
100%  over  time,  thus  enabling  brands  and  producers  to  build  on  implementing  sustainable  practices,  promoting  long  term  trading  relationships,  and 
increase certified volumes over time. However, this increase in the percentage in time is difficult to be verified throughout the label.  

Fairtrade defines a minimum price for all certified coffees, tracks the shipments from grower to retailer, claims a small fee from each component of the supply chain along the 
way, then uses these funds to effectively advance public awareness of Fair Trade and the issues it addresses, thus increasing the market value of the certification for both 
producers and retailers.  

UTZ products (UTZ, 2016) 
The minimum percentages that UTZ allows for labelling products are the following: 

182 

 
 
 
 
- 90% of UTZ certified content while > 60% of the cocoa 
- 90% of UTZ certified content while > 60% of the coffee 
- 30% of the tea 

Bonsucro 

183 

 
 
 
 
 
For  consumer  products  containing  a  pre-determined  percentage  of  Bonsucro  certified  sugar  cane,  it  will  be  possible  to  display  the  Bonsucro  logo  and  related  claim  on  the 
packaging (on-product). 
The requirements to claim on-product when the sugar cane is 
1. Single product OR 
2. Hidden ingredient of your products and: 
a. These products only contain sugar made of cane AND/OR 
b. Sugar cane is in the top 3 of ingredients used in these products. In other cases only off-product communication is allowed. 
3. What can I claim on-product? 
If you comply with the above mentioned requirements you may claim on-product: 
a. In case the product contains at least 90% of certified sugar cane (segregation): The sugar in this product is responsibly produced 
b. In case the product contains at least 30% of certified sugar cane (mass balance of segregation): 
X% of the sugar in this product comes from mixed responsible sources and we are committed to Y% in [year] 

Ethical Tea Partnership 

No detail information on the minimum percentage needed for the certified products to get the label. Only applies to products containing more than 5% of tea content. 

184 

 
 
 
 
 
Packaging 

This section presents the comments received through BATIS and personal communications from the 1st AHWG meeting to the 2nd AHWG meeting.  

Table 42. Feedback from the stakeholders on the TR1.0: Packaging   

Topic 
General 
Environmental 
of 
impact 
packaging  and 
LCA 

Feedback from stakeholders 

JRC-Directorate B5 assessment 

In the technical report, the impact of packaging is defined in some cases as low compared to food production 
and process. Change the sentence so that it is not so dogmatic regarding the impact of packaging. 
In the technical report, it is written: 
- Table 3, page 8: Packaging generally has a low total environmental impact compared to the production and 
processing stages of food products. The exceptions are bottled water and milk, where packaging has a large 
total impact 
-  §2.3,  page  10:  At  the  catering  service  stage  in  the  foodservice  supply  chain,  energy  and  water  use  are 
important contributors to environmental impact, as well as waste generation and management. 
We could conclude that packaging could help to reduce food waste, over dosing, over use of energy, while 
having a "low total environmental impact compared to the production and processing stages of food products" 
These general recommendations are an approach not based on science. They are too generic and can be in 
contradiction with other findings. Only a case by case approach and comparative life cycle assessments can 
reveal  sensible  conclusion.  When  we  look  for  example  to  the  peer  reviewed  TNO  study  "single  use  cups  or 
reusable 
(available  at 
https://www.tno.nl.downloads%5C2006-a-r0246e_b_summary.pdf)  then  we  see  that  single-use  cups  may 
have indeed a lower environmental impact.  
Single-unit  packaging  may  be  used  for  hygiene,  (food)  safety,  resource  savings  (less  content  loss),  lower 
energy  consumption  at  the  production,  and  finally  practicability  by  the  applicant.  Therefore,  without  any 
scientific  underpinning,  single-unit  packaging  should  be  allowed  as  any  reusable  products.  The  packed 
products should be assessed on the basis of their full life cycle. Packaging is part of the product and serves a 
purpose. Only LCA can provide the proper answer. The same holds for the criteria 45% recycled content as 
well as the raw material source to produce the package. LCA and functionality play a key role.  

(coffee)  drinking  systems:  an  environmental  comparison,  October  2007 

Comment accepted 
The rationale has been changed accordingly. 

Acknowledged 
In  general,  the  use  of  excessive  packaging 
can drive environmental impacts up. Since in 
other  cases,  it  has  been  demonstrated  that 
may  serve  to  prevent  food  waste,  the 
criterion has been removed 

Existence of the  Packaging is an inseparable part of the product, no product are delivered/sold without packaging, whatever  Comment accepted 

185 

 
 
 
 
 
 
Topic 
packaging 
criterion 

Feedback from stakeholders 
this  packaging  is  reusable,  bulk  or  single-unit,  metal  or  fibres  based,  and  this  packaging is  in  many  cases 
influencing the use phase and food waste and therefore the environmental impact of the products on its life 
cycle. Therefore there should not be a criterion which is specific to packaging. Packaging should be addressed 
with the product on a scientific basis and full life cycle approach.  Remove the criteria on packaging 
It  has  been  repeatedly  shown  by  LCA  that  food  packaging  is  typically  less  than  5%  of  the  overall  impact 
associated with food. Furthermore, using packaging significantly reduces food waste by extending shelf-life, 
portioning and convenience features that allow consumption "on the go". As such I seriously question whether 
there is a place for packaging in this GPP document.  
Re-write  the  section  explaining  that  the  relative  benefits  of  packaging  far  outweigh  the  negatives  and 
unnecessarily  complicate  the GPP  process.  European  Commission  PEF  pilots  have  shown that  one  way e.g. 
PET  water  bottles  and  single  use  packaging  e.g.  coffee  capsules  have  the  lowest  overall  environmental 
impact. Other LCA's show that there is no correlation between a lower environmental impact and the use of 
renewable materials or higher recycled content. In fact most often these have higher environmental impacts. 
In general I agree to the criteria. The verification of the secondary packaging recycled content should be very 
difficult since not in any cases data are available. 
Most important is of course less packaging, but if necessary we like to promote bio based packaging. I would 
like to present an attachment with a catalogue of bio-based materials. 

of 

Primary packaging 
Inclusion 
recycled 
content  in  the 
packaging 

Indeed it is not applicable across all materials, however the materials which are known to be recyclable and 
which can be reused in primary packaging (i.e. steel, aluminium), should be considered in the award criteria at 
the same "level" as sustainably sourced fibres or compostable are.  
Add a criterion for materials which are highly recyclable, highly recycled and usable as primary packaging (i.e. 
aluminium).  
Aluminium is: 
- highly recyclable  (aluminium is not using its technical properties when recycled and can therefore be used 
for the same purpose it was made for the previous time),  
- highly recycled (more than 80% of the soda cans are back as recycled soda cans), 
- infinitely recyclable (more than 75% of aluminium ever produced is still in use), 
- have a very good ratio (performance/weight): less mass of aluminium is often required to pack a product 
than plastic 
Answers to the consultation questions to stakeholders:  
- Do you have any experience on how the verification of the recycled content for the packaging materials being 
used?  

JRC-Directorate B5 assessment 

Comment accepted 

Comment accepted 

Acknowledged 

Comment rejected 
Although  the  potential  benefits  of  recyclable 
materials  is  acknowledged,  there  is  not,  for 
the  time  being  any  certification  scheme  or 
label  that  specifies  the  amount  of  recycled 
content.  
Therefore, setting up a criterion on this point 
is  very  difficult 
the  verification 
from 
perspective.  

Acknowledged 

186 

 
 
 
 
 
 
 
Topic 

LCA 
packaging 

of 

Single-unit 
packaging  

to 

on 

set 

the 

are 

that 

then 

being 

based 

ensure 

criteria 

Feedback from stakeholders 
In Copenhagen Municipality we have a project called “Zero plastic”, working to get black plastic out of food 
packaging because black plastic can’t be discarded in waste sorting plants.  
- Are you aware of any GPP scheme that uses type 1 Ecolabel (e.g for Nordic Ecolabel restaurants) as a proof of 
compliance for the requirement on recycled content and renewable materials for this criterion?  
Yes  some  of  the  governmental  institutions  e.g.  The  Prime  Minister's  Office  use  Nordic  Ecolabel  for 
canteen/catering.  
As explained above, the approach is too generic and therefore fails the science test. In some cases reusable 
packaging may be better than disposable packaging or vice versa. The criteria should therefore be based on 
the full life cycle of the packed product. The package is there to save and protect food and is often only a 
minor part of the environmental impact. Having criteria specifically on packaging needs to show in the first 
place that this is a main environmental impact over the total life cycle of the packed product on the one hand 
science.  
and 
LCA  should  be  the  only  criteria  used  to  assess  whether  single-unit,  renewable  raw  materials  or  recycled 
content is better and should be preferred.  
Appropriate single unit packages favour avoidance of food/drink waste and indirectly improve water and 
energy efficiency food/drink during preparation stages. While portioned solutions are designed to prepare the 
right amount of food intended to be eaten/drunk, bulk options might lead to overdosing (excess of product 
quantity used to prepare food/drink servings) and/or over preparation (excess of food /drink quantity per 
serving). These two phenomena have a direct effect on food/drink wasted and the efficiency of water and 
energy used in the preparation of servings (eg. water used for of single-served coffee brewing when 
compared to bulk brewing [Quantis 2015]). 
Portion sized packaging is also developed to provide quantity balanced portions from a nutritional point of 
view and it is necessary under certain health or religious dietary requirements. Finally, allowing tenderers not 
to meet the proposed criteria [JRC2016b] (“the supplier must explain why this is more adequate than bulk”), 
puts tendering competitors in an unequal foot in the tendering process. 
In the first place does packaging help to avoid food waste. Good packaging makes sure that our food stays 
eatable for a longer time. It can also help that less additives have to be used because for example the food is 
air tight packed (vacuum). Individual portions can’t always be avoided because it is important for diet food 
(no gluten, no peanuts, no dairy,…), for food safety it is also important.  
On the other hand it also keeps food waste under control for example in Ghent we buy ready meals that are 
offered in different package sizes. This makes it possible to order big packages and small packages and if 
there are some children sick that day you don’t have to heat the single portions. You can then serve the single 
portions another day. If you would only order big packages you have to heat up all the food and what is left 
has to be thrown away. 

JRC-Directorate B5 assessment 

Acknowledged 
In  general,  the  use  of  excessive  packaging 
can drive environmental impacts up. Since in 
other  cases,  it  has  been  demonstrated  that 
may  serve  to  prevent  food  waste,  the 
criterion  has  been  removed,  considering  also 
the limitations of the verification. 

Comment accepted  
The  last  proposal  of  the  criterion  allows  the 
use of single-unit packaging.  
This  use  of  single-unit  packaging  could  be 
beneficial in those situations where this type 
of  packaging  can  help  to  reduce  avoidable 
good waste.  

Comment accepted  
See above 

187 

 
 
 
Topic 

Single-unit 
packaging  

Recyclability  of 
the packaging  

Role 
packaging  

of 

Composability 
vs 
biodegradability 

Feedback from stakeholders 
We don’t tell our tenderers what packaging material they have to use, because we are no experts in it.  
We ask for as much packaging sizes as possible (AC) (to make the packaging puzzle so we don’t have to heat 
up all the food for less children and so avoid food waste).  
We ask for the national criteria regarding the packaging that is in contact with the food – and I believe we do 
not have enough focus on this in our contracts. We have a problem with single packaging, primarily because 
items  that  are sold  in  food  service  often  originally  were  intended  for  retail.  Therefore  the  problem  will  be 
minor over time, as the food service market is growing (and therefore producers begin to pack targeted for 
food service) This is what we see in Denmark right now.  
Answers to the consultation questions to stakeholders:  
- Do you consider feasible the requirements for the core and comprehensive criteria? · Yes  
- Are you aware of any legal constraints within FSCIS17? · No 
The packaging the tenderer uses, has to be recyclable (TS).  
We ask for a proof on what happens with the recycled product. Our current catering supplier let the packaging 
be recycled into swimming pool foil and blankets. I also notice that a small amount of the smaller packages 
aren’t always returned because the school/kindergarten reuse it to store craft materials in it (it is a strong 
material so they use them for a very long time although this is not our idea of recycling but who are we to 
prevent them from being creative). 
The packaging has to be recyclable (TS). 
Packaging is essential to reduce food waste. For instance, a cucumber wrapped in a plastic sleeve can last up 
to 14 days, while without a plastic sleeve it last only 3 days on average. This text should also acknowledge 
that packaging plays an important role in preventing food waste. 
The term biodegradable applied to packaging products seems not to be appropriate. Therefore it is suggested 
to  use  the  term  composability  according  to  EN  13432  which  guarantees  biodegradation  in  an  industrial 
composting  plant.  Biodegradation  can  be  defined  as  a  process  by  which microbial  organisms  transform  or 
alter the structure of chemicals introduced into the environment (US EPA, 2009). The claim that a product is 
biodegradable  can  mean  different  things;  it  can  mean  that  a  product  can  biodegrade  under  different 
conditions  (i.e.  heat,  anaerobe  or  aerobe)  and  different  environments  (water,  soil,  sea-water)  therefore  it 
leaves to much room for misunderstand or misperception.  
Also the term is should not be used to describe packaging material which should never end-up in the natural 
environment but in residual waste streams. Using this term might lead to the misperception by consumers 
that the product can be littered without negative consequences for the environment. 

17 Food safety and inspection services 

JRC-Directorate B5 assessment 
Acknowledged 

Comment accepted  
See above 

Comment rejected 
Although  it  is  acknowledged  that  recyclable 
materials can bring environmental benefits if 
properly  managed,  currently  there  is  no 
certification  schemes that  label  materials  as 
recyclable under any circumstance.  

Acknowledged 

Comment accepted  

188 

 
 
  
                                                           
Topic 

Feedback from stakeholders 
The wording seems to suggest that on the one site there are bio-based polymers which are compostable and 
on  the  other  site  oil-based  polymers  which  are  not  compostable.  Such  is  distinction  is  not  correct.  It  is 
suggested  to  use  the  wording  ‘non-compostable  polymers’  instead  of  ‘oil-based  polymers’  in  the  first 
sentence. Bio-Based and oil/fossil-based polymers can be compostable or non-compostable. There use of the 
term bio-based or fossil-based only refers to the used feedstock it does not refer to certain characteristics. 
Bio-based  products  do  help  to  decrease  dependency  from  oil  and  fossil-based  resources.  Some  bio-based 
polymers  such  as  PLA  can  be  produced  with  less  GHG  emissions  than  traditional  fossil-based  polymers. 
Therefore they can assist climate change mitigations.  Compostable products certified according to EN 13432 
can be made of fossil-based or bio-based feed stocks.    

JRC-Directorate B5 assessment 
Acknowledged 

Secondary packaging 
Single-unit 
packaging  

Single-unit 
packaging  

This technical report is often referring to LCAs scientifically demonstrating by LCA (which is the toll promoted 
by EU for the PEF project) that single portion coffee has environmental benefits as it avoids over-dosing and 
over preparation which both often create water, food (Roast&Ground coffee) and energy (the electricity used 
to heat up the water) wastage. Humbert & al. (200): User phase: 50-75 % of total energy use – depending on 
behaviour has a large total impact on GWP. Spray dried soluble coffee had lowest environmental impact (of the 
three systems investigated) since least dry matter (coffee beans) was needed. The espresso used a bit more 
coffee and its single-use packaging system added to the total. Filter coffee had the greatest impact since it was 
assumed that too much is brewed and 1/3 of the total is wasted. Hence the use of coffee was highest and also 
the use of heated water for making the coffee. 
As highlighted during the 1st AHWG for the revision of the EU GPP criteria set for food and catering services, 
single unit packaging might offer the best environmental performance in some specific situations, if the 
whole life cycle is considered. E.g: is it better to prepare litres of coffee without knowing how much is going 
to be drunk and potentially have left overs OR to have single portion coffee pods/capsules so that each 
person willing to drink a coffee is preparing exactly on demand the coffee (s)he is going to drink. 
This award criteria could be written in a less strict was, such as "single unit packaging are accepted if the 
supplier can explain why this is more adequate thank bulk option, including sustainable design, recyclability, 
recycling schemes in place, recycled content, sustainable packaging production." 
As stated in the executive summary, the aim of the GPP is to "help public authorities ensure that the food and 
catering services procured are executed in a way that reduces their associated environmental impacts", but not 
to minimise the environmental impact associated to packaging. Especially, as related few times in this TR, 
from an LCA perspective there are ALSO many environmental benefits to gain by using single unit packaging 
which of course means more packaging. This comment has to be removed 
For some products and in some situations, single portion can help saving food, energy and water by avoiding 

Comment accepted 
 See above 

Comment accepted 

189 

 
 
 
 
Topic 

Background 
information 

in 

Feedback from stakeholders 
over dosing and over preparation during the use phase. 
The context is important, for example, Is it better to have a on demand hot water dispenser in offices to 
prepare a single cup of tea, or to have thermos of hot water prepared in the morning for an unknown number 
of cups. Energy wise and waterwise, the first solution is better 
Esp. in catering services, single unit packaging is an important tool for food waste prevention. Manufacturers 
would not use single unit packaging (i.e. voluntarily make more costs) if this was not beneficial for product 
preservation, reducing wastage or portion control. This criterion should therefore be left out of GPP. 
Packaging plays a crucial role in food safety and hygiene. Single-serve packaging is sometimes required for 
food safety reasons. For instance, in Spain contract caterers are required by law to use single serve 
packaging for olive oil to ensure food safety and hygiene.   
We suggest removing item 2, which states that no single unit packaging should be provided. Requiring 
suppliers to explain every time single unit packaging is necessary for food safety and hygiene reasons would 
be onerous on businesses. 
This criterion 'no single unit packaging must be provided' does not seem to follow from the recommendations 
on the previous page (page 33 - Evaluate single unit packaging), which state 'if it is more resource efficient to 
use single portion packaging - this is recommended'. 
Appropriate single unit packages favour avoidance of food/drink waste and indirectly improve water and 
energy efficiency food/drink during preparation stages. While portioned solutions are designed to prepare the 
right amount of food intended to be eaten/drunk, bulk options might lead to overdosing (excess of product 
quantity used to prepare food/drink servings) and/or over preparation (excess of food /drink quantity per 
serving). These two phenomena have a direct effect on food/drink wasted and the efficiency of water and 
energy used in the preparation of servings (eg. water used for of single-served coffee brewing when 
compared to bulk brewing [Quantis 2015]). 
Portion sized packaging is also developed to provide quantity balanced portions from a nutritional point of 
view and it is necessary under certain health or religious dietary requirements. Finally, allowing tenderers not 
to meet the proposed criteria [JRC 2016b] puts tendering competitors in an unequal foot in the tendering 
process. 
Potential environmental improvement areas for food and catering services  
-Materials  in  packaging:  It  should  be  included  in  which  situations  single-use  portions  are  better  than  bulk, 
namely for safety reasons. 
Why this award is limited to fibres, and not to sustainably sourced materials in general? “Food products are 
supplied  in  packages  produced  from  sustainably  sourced  fibres"  should  be  changed  into  “Food  products  are 
supplied in packages produced from sustainably sourced materials”. Indeed, some materials are requesting a 

JRC-Directorate B5 assessment 

Comment accepted  
See above 

See above 

See above 

See above 

Comment accepted 
Wording has been modified.  

190 

 
 
Topic 
the TR1.0 

Biodegradable 
VS 
Compostable 

Feedback from stakeholders 
lot  of  energy  to  be  produced  the  first  time,  but  then  are  fully  and  indefinitely  recyclable  into  the  same 
products (e.g aluminium soda cans). 
not  every  food  products  can  be  delivered  in  fibres  packaging  as  fibres  can't  be  used  for  liquid  and  don't 
protect food from light, oxygen, moisture. 
In analysing the impact of packaging, the avoided impact of food waste in supply chains should be accounted 
for.  
... as long as an environmental benefit can be demonstrated in a LCA. 
Compostable packaging should receive an award only if the sorting and logistics are in place to bring this 
packaging to a composting plant WHICH IS ACCEPTING AND COMPOSTING IT. 
An award should also be given to recyclable packaging 
It might be good to source compostable packaging but ONLY if this packaging is indeed composted. 
Compostability / biodegradability is a technical properties but not a guarantee of better environmental 
performance, which is the aim of the GPP. There is no clear scientific evidence that "biodegradable" delivers 
environmental benefits over other forms of packaging end-of-life scenarios. 
Industrial composting is only available in a few Member States, hence composting according to EN 13432 is 
not possible. 
Again, a proper LCA must compare this type of packaging to an alternative. 
This award should be either removed or based on a scientific assessment on the market, there are products 
which are delivered by some companies in compostable material and by others in oil based plastic or metal.  
When comparing these products, the compostable / biodegradable option has a higher environmental impact 
because(cid:13)the amount of compostable / biodegradable material is 3 to 4 higher than oil based plastic or metal 
as the barrier properties of the compostable / biodegradable material is not good enough, each product need 
a second packaging. 
Biodegradability only has environmental benefits if separately sorted with bio-waste. In many countries, this 
is  not  even  allowed.  If  sorted  with  other  packaging  waste,  biodegradable  decreases  the  quality  and 
recyclability of other materials. Littering of biodegradable materials has negative environmental effects as 
well. Therefore, this criterion should be left out or made conditional to separate bio-waste collection.  
Compostable  and  biodegradable  packaging  does  not  necessarily  have  a  better  environmental  footprint  if 
there is no appropriate waste stream available and it end up in landfill or incineration. If this packaging is 
mixed  with  other  packaging  waste,  biodegradable  packaging  can  decrease  the  quality  and  recyclability  of 
other packaging materials.   
We recommend stating that the packaging used should be aligned to available waste streams. The EU criteria 
should  also  allow  Member  States  to  have  the  flexibility  to  adapt  the  criteria  to  locally  available  waste 

JRC-Directorate B5 assessment 

Acknowledged 

Comment partially accepted 
Due to the difficulties to assess if this clause 
will bring some environmental benefits, it has 
been removed.  
Acknowledged 
See above 

Acknowledged 
See above 

Acknowledged 
See above 

191 

 
 
 
 
Topic 

Recycled 
content 
recyclability 

and 

Feedback from stakeholders 
streams.    
Awards are given only to reusable or bio-based packaging, while recyclable and recycled material should also 
be awarded 
Add an award: "Food products are supplied in recyclable and recycled packages material. Some packaging is 
made of highly recyclable and/or recycled material, which based on LCA can have as good environmental 
performance as compostable / biodegradable material or reusable material.  
Some are even part of a close loop system (e.g. aluminium can) as long as the consumer recycle it 
Recycled content is from a food safety perspective not always desirable (e. g. MOSH/MOAH migration), even 
in  packaging  which  is  declared  here  as  secondary.  This  paragraph  should  be  made  more  specific  to 
corrugated board. Corrugated board is anyways made from recycled fibres. Hence, this paragraph is obsolete. 
As a general word of caution, while the EU Circular Economy Package puts an emphasis on recycling, setting 
criteria  in  GPP  on  using  recyclable  packaging  would  be  a  challenge.  There  is  no  EU  definition  for  what  is 
‘recyclable’, and what is recyclable varies depending on the local infrastructure available. For instance, there 
is a lot of recyclable packaging that ends up in landfill because it is not collected separately from other waste 
and sent to a recycling plant. 
We recommend stating that the packaging used should be aligned to available waste streams. The EU criteria 
should  also  allow  Member  States  to  have  the  flexibility  to  adapt  the  criteria  to  locally  available  waste 
streams.    
Availability  of  packaging materials  for  packaging  production  largely  depend  on  external market  conditions, 
e.g: availability and use of recycled content for plastics can be dependent on price relative to virgin as well as 
material of sufficient quality. In certain circumstances sourcing these types of materials can result in loss of 
competitiveness for food manufacturers. 
Prioritize reusable/ returnable packaging options within the award criteria 
Require a check with competent authorities if biodegradable packaging materials are compatible with local 
treatment processes for biowaste 
In general, the EEB welcomes the criteria set, but we are concerned that all listed options for primary and 
secondary packaging are rated equally. We would suggest to clearly prioritize the first option in the award 
criteria, i.e. reusable and returnable packaging systems. Only in cases where this is not possible or adequate, 
the other options such as use of recycled content, sustainably sourced fibres or biodegradable materials 
should be eligible for award points. 
With regard to the requirement “Food products are supplied in packages certified compostable/biodegradable 
according to EN 13432, or equivalent and 90% biodegradability in 6 months has been demonstrated in a 
single or combined composting and/or anaerobic digestion process”, the EEB would like to establish a link with 

JRC-Directorate B5 assessment 

Acknowledged 
See above 

Acknowledged 

Comment accepted 
No  criterion  about  recyclable  packaging  has 
been included.  

Acknowledged 

Comment accepted 
Removal  of 
secondary packaging has been introduced.  

for  primary  and 

criteria 

192 

 
 
 
 
 
Topic 

Returnable 
bottles 

Certification 
schemes 

Feedback from stakeholders 
the criteria on waste sorting and disposal (TS6). Environmental benefits can only be assumed if separate 
collection of biowaste actually takes place. Why should biodegradability be rewarded if the packaging waste 
is burned? In addition, only if biodegradable packaging materials (that meet the above mentioned 
requirements) do not disturb or deteriorate the local treatment process for biowaste (i.e. composting or 
anaerobic digestion), it would make sense to define it as an award criterion. The JRC should provide a 
disclaimer for the procurer to check this issue with local waste authorities before defining it as a default 
option. 
Using returnable bottles is not necessarily more environmentally advantageous than non-reusable bottles, 
once water use from cleaning and the wastewater associated with disinfection are taken into account. The 
additional environmental impact and economic cost of cleaning, water consumption and use of soap products 
must also be taken into account. 
This practice also requires a certain amount of space for bottles to be stored. It also poses a logistics issue 
because in many cases, due to dense traffic and narrow city streets, smaller trucks must be used but they 
would need to make extra trips to collect all the bottles. The need for extra logistics has cost implications 
that must be factored into the tender. 
Using returnable bottles can also create barriers to the internal market if drinks are imported. When drinks 
are imported, the environmental impact of transporting returnable bottles over long distances must also be 
taken into account.   
Given  that  reusable  packaging  systems  (e.g.  returnable  bottles)  are  not  necessarily  more  environmentally 
advantageous  than  non-reusable  packaging  once  water  use  and  wastewater  from  cleaning  and  extra  road 
miles to transport the packaging for reuse are taken into account, we suggest removing this item. 
At Nestlé we use the Responsible Sourcing Guidelines for fibre packaging. These are more stringent than FSC, 
hence we are not using FSC declaration 
Criteria on packaging produced from sustainable sourced fibres, with a specific recycled content or certified 
compostable or biodegradable, both for primary and secondary packaging might be too restrictive from the 
point of view of the materials food and drink producers can use.  
The food and drink industry’s first priority is to ensure that the safety and quality of food and drink products 
is maintained throughout the supply chain including when products reach their place of consumption. It does 
this  by  selecting  packaging  materials  that  are  fit  for  this  purpose  taking  into  account  the  nature  of  the 
product and the demands of the supply chain. Whilst this may include using materials with a specific recycled 
content, certified compostable or biodegradable or from sustainable source fibres, these options might not 
always  be  appropriate  both  from  a  technical  standpoint  (including  food  safety)  and  whole  supply  chain 
sustainability  perspective.  In  addition  the  benefit  of  separate  collection  of  biodegradable  packaging  is  not 

JRC-Directorate B5 assessment 

Comment accepted 

Acknowledged 

Comment accepted 

193 

 
 
 
Topic 

Other  

Feedback from stakeholders 
guaranteed, as there is no clear scientific evidence that "biodegradable" delivers environmental benefits over 
other forms of packaging end-of-life scenarios. Furthermore industrial composting according to the required 
EN  13432  standard  is  only  available  in  a  few  Member  States.  If  sorted  with  other  packaging  waste 
biodegradable packaging could decrease the quality and recyclability of other packaging materials. 
We recommend stating that the packaging used should be aligned to waste streams that are locally available 
and in line with the waste hierarchy. For instance, a country might want to encourage the use of recyclable 
packaging where recycling facilities exist.    
If the Nordic Ecolabel complies with criteria, the public consumer often ask for compliance of standards on 
energy,  food  products  as  well  as  packaging  materials,  not  packaging  materials  alone.  Still,  packaging 
materials can still contain phthalates and PVC... 
Only the latter should be the aim. The amount used CAN be a factor in the total environmental impact but not 
necessarily.  
Actually, here is rather distribution packaging meant. Then, it should be described like that. 
With regards to packaging, referring specifically to the technical report, some improvements could be made. 
Firstly, a wider spectrum of stages in food supply chain (outlined in Table 3, p.3) should be considered. This 
includes: 
- emissions from processing i.e. the processing stage creates … and emissions 
- packaging exceptions for juice and soft drinks e.g. water and milk, juice and soft drinks 
The main environmental hotspots and causes from food and catering services (outlined in Table 5, p.11-12) 
should consider: 
- water and energy in the context of meat processing, milk and cheese production, fruit processing 
- packaging materials in the context of vegetable packaging e.g. production of steel, glass and plastic 
- manufacturing processes in the context of hot drinks production e.g. drying of teas leaves, roasting 
coffee 
- production of materials in the context of packaging materials i.e. (e.g. glass, paper, cellulose) 
Food packaging requirements should also be able to meet the needs of the user. 

JRC-Directorate B5 assessment 

Comment accepted 

Acknowledged 

Acknowledged 

Acknowledged 

194 

 
 
 
 
 
 
 
 
 
 
 
Environmentally responsible palm oil 

This section presents the comments received through BATIS and personal communications from the 1st AHWG meeting to the 2nd AHWG meeting.  

Table 43. Feedback from the stakeholders on the TR1.0: Sustainable palm oil (AC7) 
Topic 
Existence  of 
labels 
and 
certification 
schemes 

Feedback from stakeholders 
There is no (mandatory) labelling or certification of RSPO food products.  
Thus the level of information about and the visibility of these products are low and verification of criteria is 
very complicated. 

Food and Drink producers have already made substantial progress in the shift towards certified sustainable 
palm  oil.  Including  sustainability  criteria  in  GPP  would be  an  important market  signal  and  would  increase 
consumer awareness.  
A comprehensive sustainable sourcing policy is the appropriate approach to tackle palm oil use in food. It is 
the  only  way  to  a  truly  sustainable  production  system  and  would  provide  industry  with  the  flexibility  to 
choose  sustainably  sourced  commodities.  Sustainability  criteria  must  be  relevant  and  be  set  according  to 
science based schemes such as the Round Table on Sustainable Palm Oil (RSPO). 
Here,  only  visibly  labelled  products  are  considered,  whereas  the  bulk  of  certified  palm  oil  is  processed 
invisibly for the consumer. RSPO-certified palm oil is widely used in the European food industry, and is even 
becoming the norm thanks to company- and sector commitments. Availability is no problem at all.  

feasible  since 

there  should  be  enough  availability 

This  criterion  should  be 
the  market. 
It should also be relevant for vending machines since there is in most cases a valuable fat content (e.g. for 
soups coffee creamer) 
Promoting  sustainably  sourced  palm  oil  is  a  way  to  secure  more  sustainable  production  and  use  of  this 
widely used ingredient. Also other existing initiatives for various critical raw materials should be considered in 
order to promote sustainable sourcing practices. However, limitations such as market availability and price 
should be taken into account as the uptake and development of various schemes has so far been gradual. 
There is on the national level in some countries, such as the Netherlands 
Comment accepted. 
Other certification schemes for sustainable palm oil should be mentioned as well. We suggest mentioning as  Comment accepted. 

in 

JRC-Directorate B5 assessment 
Comment rejected. 
Even  if  the  visibility  of  these  products  is  low,  it  is 
possible  to  track  back  the  origin  of  the  palm  oil 
ingredients  to  know  if  they  are  coming  from 
sustainable certified sources or if at least the book 
and claim (B&C) system has been used.  
Comment accepted. 

Comment accepted. 
The  wording  of the  criteria  has  been  split  into  two 
parts  addressing  the  limits  of  units  containing 
sustainable  certified  palm  oil  and  the  limits  of 
sustainable  certified  palm  oil  purchased  by  the 
tender.  
Comment accepted. 

Comment accepted. 
The inclusion of some other schemes for certifying 
sustainable vegetable oils has been considered.  

195 

 
 
 
 
 
 
 
 
 
 
Topic 

Promotion  of 
other oils 

Promotion  of 
other oils 

Feedback from stakeholders 
additional  certifiers  or  schemes  for  sustainable  palm  oil:  ISCC  Plus,  Rainforest  Alliance,  RSB.  The  RSPO 
Certification system is the only one mentioned. In fact there are other alternatives with similar requirements 
for sustainable palm oil production including: ISCC Plus, Rainforest Alliance, RSB. 
Olive oil or sunflower oil should be preferred to sustainable palm oil. 
For us, the criteria will be not to use palm oil, even if it is sustainable, but should rather promote the use of 
oils  and  fats  produced  in  Europe,  such  as  olive  oil  or,  failing  this,  sunflower  oil  because  of  their  healthy 
properties, the reduction of food miles and the economic benefits for some producers. 
This  criterion  should  be  about  the  level  of  commitment  to  sustainable  palm  oil  in  the  contract  caterer’s 
overall  strategy  rather  than  a  percentage  of  food  products  procured.  A  percentage  would  be  extremely 
complicated to implement in practice because of the variety of products that contain palm oil.  
In  Spain,  contract  caterers  have  an  agreement  with  AECOSAN  (Agencia  Española  de  Consumo,  Seguridad 
Alimentaria y Nutrición), NAOS STRATEGY (Strategy against obesity): “To favour improvements in school food, 
an agreement has been drawn up with leading businesses from the catering industry, belonging to the Spanish 
Federation of Associations Given to Social Catering (FEADRS). These businesses undertake to: Not use oils rich 
in saturated fats (palm oil, saw palmetto and coconut) or trans-fatty acids when frying, replacing these oils 
with other healthier oils.” 
In  addition,  by  law,  “In  nursery  schools  and  schools  selling  food  and  beverages  with  a  high  content  of 
saturated  fatty  acids,  trans  fatty  acids,  salt  and  sugars  must  not  be  permitted.  These  contents  will  be 
established by regulation. “In industrial processes that can generate "trans" fatty acids, operators responsible 
establish the right conditions to minimize formation thereof, when intended for food, either individually or as 
part of the composition of foods.” (Ley 17/2011, de 5 de Julio, de seguridad alimentaria y nutrición). 
We  believe  that  the  GPP  criteria  should encourage  moving towards  more  sustainable  palm  oil  production 
rather  than  avoiding  palm  oil.  We  recommend  awarding  extra  points  if  the  contract  caterer  can  provide 
proof that the palm oil is from sustainable sources in cases where frying oil and products are used that 
include palm oil. 
Shouldn’t palm oil be avoided in the first place and if there is no other option it should be sustainable. When 
it comes to health and nutritional issues I put it under the technical specifications, if it is about sustainability 
I put a lot more under award criteria (unless I know for a 100% that it is already common). 
As palm oil is inherently unhealthy and leads to deforestation, it would be better to switch the focus. In the 
first instance, palm oil should be avoided (thus the requirement should be rephrased to ask for palm oil free 
products) and if this is not possible sustainable palm oil should be requested. 
Impacts of cultivation are very much dependent on type of oil or fat 
Sustainable palm oil should be included under technical specifications. In addition, olive oil or sunflower oil 

JRC-Directorate B5 assessment 
See above 

Comment rejected 
The  GPP  criteria  for  food  procurement  are  not  a 
suitable tool to:  
-  limit  the  consumption  of  a  certain  product  or 
ingredient based on its nutritional characteristics 
-  promote  the  use  of  other  oils  based  only  on 
nutritional grounds 
The  decision  on  which  is  the  most  appropriate 
ingredient to be used/purchased should be done by 
the  procurers.  The  GPP 
food 
procurements  will  therefore  only  encourage  the 
purchase of more sustainable ingredients (especially 
if it is the same ingredient). 

criteria 

for 

Comments rejected 
See above 

196 

 
 
 
 
 
 
Topic 

Level 
ambition 

of 

Feedback from stakeholders 
should be promoted as a substitute for palm oil, even if sustainable.  
Modify the AC: Points must be awarded to tenders that prove that at least 50% (100% in comprehensive) 
units of food products are palm oil free products or contain palm oil from sustainable sources.  
This  criterion  should  be  about  the  level  of  commitment  to  sustainable  palm  oil  in  the  contract  caterer’s 
overall  strategy  rather  than  a  percentage  of  food  products  procured.  A  percentage  would  be  extremely 
complicated to implement in practice because of the variety of products that contain palm oil.  
In  Spain,  contract  caterers  have  an  agreement  with  AECOSAN  (Agencia  Española  de  Consumo,  Seguridad 
Alimentaria y Nutrición), NAOS STRATEGY (Strategy against obesity): “To favour improvements in school food, 
an agreement has been drawn up with leading businesses from the catering industry, belonging to the Spanish 
Federation of Associations Given to Social Catering (FEADRS). These businesses undertake to: Not use oils rich 
in saturated fats (palm oil, saw palmetto and coconut) or trans-fatty acids when frying, replacing these oils 
with other healthier oils.” 
In  addition,  by  law,  “In  nursery  schools  and  schools  selling  food  and  beverages  with  a  high  content  of 
saturated  fatty  acids,  trans  fatty  acids,  salt  and  sugars  must  not  be  permitted.  These  contents  will  be 
established by regulation. “In industrial processes that can generate "trans" fatty acids, operators responsible 
establish the right conditions to minimize formation thereof, when intended for food, either individually or as 
part of the composition of foods.” (Ley 17/2011, de 5 de Julio, de seguridad alimentaria y nutrición). 
We  believe  that  the  GPP  criteria  should encourage  moving towards  more  sustainable  palm  oil  production 
rather  than  avoiding  palm  oil.  We  recommend  awarding  extra  points  if  the  contract  caterer  can  provide 
proof that the palm oil is from sustainable sources in cases where frying oil and products are used that 
include palm oil. 

Verification 

Palm oil free products, means of proof: tags.  
In  catering  services,  information  on  amount,  kind,  and relevant  environmental  aspects  (also  this  one  if 
awarded) of the food served, must be reported in the aforementioned biannual report.      
Very much so, as long as B2B-standards and certification is alongside consumer-facing labels. Tenderers 
can  select  brands  based  on  their  reported  CSPO  use,  or,  in  some  countries,  can  rely  on  the  fact  that 
eventually all palm oil used will be certified sustainable. 

JRC-Directorate B5 assessment 

Comments rejected 

Comment partially accepted 
The  percentage  of  CSPO  is  easy  to  calculate  when 
this commodity is bought as an ingredient (without 
being yet part of a processed food, such as the case 
In  these  cases  the 
of  e.g.  frying  palm  oil). 
accounting of CSPO should be straight-forward. The 
purchase  of  CSPO  raw  ingredient  should  also  be 
possible  across  EU  as 
the  system  operates 
worldwide. 
For  pre-packed  food  products  (i.e.  biscuits  or 
chocolate bars), the calculation of the percentage of 
CSPO  purchased  is  more  complex  and  becomes 
especially  difficult  if  the  relative  weight  of  the 
ingredients  in  the  processed  food  product  is  not 
clearly stated.  
To  deal  with  these  cases,  a  modification  has  been 
introduced in the wording of the criteria, considering 
the whole pre-packed food product as the reference 
unit  and  calculating  the  %  of  CSPO  as  the  %  of 
units  of  pre-packed  food  products  that  contain 
CSPO.  
E.g.  if  the  procurer  buys  100  items  made  of  palm 
oil, 20 items should be made with CSPO.   
Comment accepted 

Comment partially accepted 
The RSPO scheme provides on their website a public 
database with the companies and trades that hold 
the  certification.  This  can  be  another  way  of 

197 

 
 
 
 
 
 
Topic 

Feedback from stakeholders 

Palm  oil  is  a  product  that  is  almost  unavoidable.  There  are  different  names  used  to  refer  to  palm  oil 
(ingredient list speaks of vegetable oil and there’s a big chance it is palm oil). This makes it difficult to check 
and to avoid. 

Traceability 
system /  
Level of 
traceability  

RSPO is available to a limited extent and including sustainable palm oil as award criteria gives an important 
signal to the market, however this is very difficult to verify. 
Unfortunately palm oil is almost unavoidable and it goes by different names in ingredient list, and it makes 
it difficult for the end buyer to check and avoid. If we want to create awareness palm oil should be avoided in 
the first place and if there is no other options it should be sustainable. Answers to the consultation questions 
to stakeholders:  
-This is a new proposal criterion. From you experience is this criterion feasible in terms of market availability 
and verification process for certified RSPO food products within tenders? 
It should be avoided. It would be impossible to follow up if only part of the oil should be sustainable.  
- Is this criterion particular relevant for vending machines? I do not know 
Palm  oil  from  more  sustainable  sources.  Green  certificates  (mass  balance  certificates) not  accepted 
as I understand it.  
Still, that really could promote the demand of RSPO-oil produced according to RSPO in products. And, in the 
longer run, buy RSPO-oil from segregated origin. 

related 

LCA 
issues 

This does not hold an in a full LCA including land use, as palm oil has the highest yield per hectare of all 
vegetable oils 
The aspect of land use & land grabbing in tropic regions  and underdeveloped countries should be clearly 
stressed in the rationales. 
Add the following environmental hotspots to the technical report: Land use and land use change in the food 

JRC-Directorate B5 assessment 
verifying the use of certified sustainable palm oil 
Comment rejected 
According  to  the  information  provided  below  (Dec 
2014), it is no longer possible to hide the palm oil 
ingredient  under  other  names  such  as  "vegetable 
oil".  This  should  make  the  tracking  of  the  palm  oil 
much easier 
Comment rejected 
See above 
Acknowledged  
The % of sustainable palm oil indicated in the latest 
criterion  wording  refers  to  the  %  of  total  frying 
palm  oil  use  or  the  %  of  total  palm  oil  used  as 
ingredient.  If  the  procurers  are  buying  processed 
food  (e.g.  biscuits)  the  %  refers  to  the  number  of 
cookies  that  contain  palm  oil  with  respect  to  the 
total number of cookies bought. 
Clarification 
All  traceability  systems  provided  by  RSPO  or  an 
equivalent  scheme  are  accepted  as  proof  of 
compliance with this criterion.  
Even  if  the  traceability  of  the  book  and  claim 
system is not as strict as in the other systems, book 
and claim (B&C) should guarantee the sustainability 
of this commodity. 
Additionally,  it  gives  flexibility  to  the  tenders  to 
comply  with  this  criterion  as  B&C  system  is 
available worldwide.  
Acknowledged 

198 

 
 
 
 
 
 
 
Topic 

Feedback from stakeholders 
product categories “oils and fats” (e.g. palm oil), “hot drink” (e.g. cultivation of coffee, cacao, sugar cane and 
tea) and “confectionaries”. 
Specify 
in 
production and require traceability of the original source at least in the comprehensive criteria. 
Change in land use is also a significant issue here  

sustainable 

relevant 

aspects 

criteria 

most 

palm 

the 

for 

oil 

JRC-Directorate B5 assessment 

Further analysis on sustainable palm oil 
Figure 3. Member States targets for CSPO 2017. 

a) Inclusion of the sustainable palm oil criteria 

Stakeholders were divided as to whether the criterion on palm oil should avoid entirely its 
use, due to the associated health issues (40% atherogenic saturates which causes cardio 
vascular problems), or should  aim at purchasing oil sustainably sourced, which addresses 
the environmental issues of deforestation.  
Although it seems clear that the GPP criteria is not the correct tool to prohibit any ingredient 
due to its nutritional characteristics, the inclusion of this criterion seems to be challenging 
due to both the difficulties in the traceability of the palm oil and in the verification process. 
Regarding  the  first  point,  it  has  been  commented  that  palm  oil  is  an  ingredient  in  many 
products  and  it  is  not  always  declared  as  a  specific  ingredient.  Thus,  tracking  back  the 
origins of the palm oil in pre-packed food can be challenging. Regarding this point, it should 
be  noticed  that  under  a  new  EU  law  which  came  into  effect  on  13  December  2014,  the 
types  of  vegetable  oil  used  in  food  products  must  be  stated  explicitly  on  the  label.  This 
means that manufacturers can no longer hide palm oil in their ingredients under the generic 
term  ‘vegetable  oil’.  Therefore,  the  proposed  solution  about  limiting  the  scope  of  the 
criterion  to  frying  oil,  which  would  be  much  easier  to  implement,  seems  to  be  no  longer 
valid.  
A  number  of  stakeholders  stressed  that  the  availability  of  sustainable  palm  oil  is  not  a 
problem  and  hence  the  challenge  is  identifying  where  the  palm  oil  is  used  to  enable  the 
substitution  to  take  place.  Regarding  the  first  point,  it  is  confirmed  by  the  information 
provided by http://www.sustainablepalmoil.org/europe/ that certified palm oil is available in 
Europe:  "Europe  is  a  core  consumer  goods  manufacturing  and  retail  market  for  certified 
sustainable palm oil (CSPO= CSPO is palm oil from  a plantation that has been managed and 
certified according to the  principles and criteria of the RSPO. CSPO is  certified through one of four  RSPO supply chains: 'Identity Preserved', 'Segregated', 'Mass Balance' or 'Book 
and Claim'.).  USDA data for the EU-27 countries shows imports of 6.7 million metric tonnes and consumption of 6.5 million metric tonnes in 2015, making it the second largest 

199 

 
 
 
market for imports after India, and the fourth largest for domestic consumption after India, Indonesia, and China" The availability of CSPO in the coming years will even be higher if 
the  commitments  expressed  by  the  Member  States  are  realized  according  to  the  previous  figure.  The  state  of  the  art  for  most  of  the  European  Member  States  has  been 
summarized in Table 44.  

Table 44. State of the art on the sustainable certified palm oil and vegetable oils.  
Country  
Belgium 

State of the art 
In 2012 the Belgian Alliance for Sustainable Palm Oil (BASP) was launched to address sustainability issues, and more recently nutrition and health in the Belgian 
palm oil market. 
The commitment of BASP is to have 100% CSPO used by its members by the end of 2015 and thereafter to achieve full traceability, incorporate a High Carbon 
Stock approach and exclude palm oil sourced from peat lands by 2020. 
BASP is currently led by the food sector, but has reached out to the cosmetic industry association which has reacted positively and is interested in the issue of 
sustainable palm oil, despite finding it very difficult to trace palm oil in its members’ products. 
Retailer  and  the  animal  feed  industry  federation  are  not  currently  a  member  of  the  Alliance,  however  BASP  is  exploring  ways  to  include  them 
through membership or support.  
www.duurzamepalmolie.be and www.huiledepalmedurable.be 
There  are two  separate  initiatives  in  place  in  Denmark:  the  first  run  by  the  Danish  Chamber  of  Commerce  (which  covers  retailers);  the  second  led  by  the 
Confederation of Danish Industry (DI) (which covers food producers). 
The  Confederation  of  Danish  Industry-led  initiative  made  a  commitment  in  June  2014  to  buy  100%  CSPO  by  2016,  including  the  purchase  of  GreenPalm 
certificates, and to have 100% segregated certified palm oil by 2018. 
There has been progress amongst the larger retail companies towards transforming their palm oil supply, with the three main supermarkets (accounting for 90% 
of the market) advancing with their efforts. Most of the large retailers are already covering all private label food products with certificates and moving towards 
mass balance  
However, there is a general lack of consumer information and interest. As in Norway and Sweden, companies and associations are cautious when it comes to 
reaching out to consumers for fear of provoking the ‘no palm oil’ movement. 
www.di.dk and www.danskerhverv.dk/CSR www.huiledepalmedurable.org 
In 2010, a number of NGOs raised awareness of the negative impact of palm oil production on the environment. At the same time, the media reported criticism 
from  some  nutritionists  about  palm  oil  and  its  effect  on  the  nation’s  health  due  to  its  high  saturated  fatty  acid  content.  This  lead  to  the  Food  Industry 
reconsidering its approach to palm oil. 
Whilst some companies opted to remove palm oil from their products, others chose to take action by forming the  French Alliance for Sustainable Palm Oil in 
2013. 
The Alliance consists of 12 members (including global leaders such as Nestlé and Unilever and medium- sized companies such as Labeyrie Traiteur Surgelés and 
Royale Lacroix), and has two main goals: to give French citizens information on palm oil; and to encourage the use of palm oil produced in highly sustainable 
conditions, by mobilising the industry as a whole. 
Alliance members have made two major commitments: to use 100% RSPO-certified palm oil in their products by the end of 2015; and use 100% sustainable 

Denmark 

France 

200 

 
 
 
Germany 

Italy 

NE 

palm oil, according to stricter criteria, by 2020. Stricter criteria include traceability, no peat, no deforestation and no conflict. 
Since 2014, the Alliance has managed to position itself as a key reference point in the palm oil debate, recognized by all the stakeholders involved (NGOs, media, 
key opinion leaders, scientifics, governments, growers, producing countries, refiners, companies, retailers and final users). The Alliance has also become a strong 
channel of communication to promote a sustainable and traceable palm oil under the criteria defined by its members 
The  German  Palm  Oil  Forum  (FONAP)  was  set  up  in  2013  with  the  goal  to  increase  the  proportion  of  segregated  CSPO  in  the  German,  Austrian  and  Swiss 
markets. 
Members of FONAP include food manufacturers and retailers, as well as a large number of cosmetic, personal and home care members., but none from the 
animal feed sector. 
FONAP members have made a public commitment that by the end of 2014 they will use only certified sustainable palm oil in their products, in all supply chain 
options. 
FONAP conducted a monitoring report in 2014, based on 2013 figures provided by their members. According to that data, progress so far shows that amongst 
the Forum’s members they have achieved: 52% CSPO in the food sector; 30% across all sectors; 50% in the cosmetics, personal and home care sector; 10% in 
the chemistry and pharmacy sector; and 1% in the feed sector. 
Most of the sectors are still far from reaching their target; the only one which is close to 100% CSPO is the margarine producers 
Italy is Europe’s second largest importer of palm oil, including for use as biofuels. 
On 29th October 2015 the European Palm Oil Conference (EPOC 2015) held in Milan welcomed the launch of the Italian Union for Sustainable Palm Oil (Unione 
Italiana per l’olio di palma sostenibile). Members include manufacturers such as Ferrero and Nestlè and industry associations such as Aidepi and Assitol. 
The aim of The Union is to achieve the 100% CSPO goal by 2020. 
The Union’s first step is to raise awareness of the benefits and contribution of certified sustainable palm oil for the food industry. 

The  Netherlands  is  Europe’s  largest  importer  of  palm  oil,  importing 
approximately 6 million tonnes a year. 
The  Netherlands  is  committed  to  using  100%  RSPO  certified  sustainable 
palm oil by 2015. 
On 2 December 2015 the ‘Dutch Alliance on Sustainable Palm Oil’ (DASPO) 
was  launched.  The  DASPO  is  the  successor  of  the  Dutch  Task  Force 
Sustainable Palm Oil which was created in 2010 initially because there was 
a lack of CSPO uptake. 
In  2014,  72%  of  the  palm  oil  processed  by  the  Dutch  food  industry  was 
sustainable – an 11% increase compared to the 2013 reporting. 
To  support  the  European  demand,  IDH  (The  Sustainable  Trade  Initiative) 
and  MVO  – the  Netherlands Oils  and  Fats  Industry,  recently  launched  the 
‘European Sustainable Palm Oil’ (ESPO) initiative. The Task Force supports 
this initiative and its objective to work together on sustainable palm oil on 
a European level. 

201 

 
 
 
 
 
Norway 

Sweden 

UK 

Norway is committed to using 100% certified sustainable palm oil by 2015. 
The National Initiative in Norway was set up in response to mounting pressure from Norwegian civil society to tackle the problems associated with palm oil – 
both from an environmental and health standpoint. 
Prominent NGOs, such as the Rainforest Foundation, were highly influential in raising the debate and pressuring companies to do something about palm oil. The 
Norwegian food and beverage association was responsible for bringing together food and retail sector companies to make a commitment to sustainable palm oil 
in 2014. 
Members of the National Initiative in Norway committed to either reduce use of palm oil in products or to use only RSPO CSPO  by 2015. They have further 
committed that by 2018 any palm oil products used will be segregated and traceable. The Norwegian commitment applies both to imports of palm oil or finished 
products consumed in Norway.The main sectors involved in the drive to increase the use of sustainable palm oil in Norway are the food and retail sectors. The 
animal feed sector is not formally involved with the Norwegian network 
The key driver for change in the Swedish market has been NGO pressure. As in Norway, NGOs push for both certification and also replacement of palm oil in 
products. 
The Swedish food industry federation set up an initiative in 2014, the main goal of which is to achieve 100% CSPO in the Swedish food sector by the end of 
2015, via any supply chain delivery method, including Book & Claim. 
There is a separate initiative within the detergent industry which is adopting a similar statement to that of the food industry. 
While other sectors are not currently part of the initiative, the retailers have adopted their own individual commitments, but not through an association as there 
are only three or four major retailers in Sweden. 
The UK is committed to using 100% RSPO certified sustainable palm oil by 2015. 
Organisations  that  have  signed  up  to  the  UK  statement  represent  oil  processors  and  distributors,  food  and  drink  manufacturers,  retailers,  animal  feed 
manufacturers, contract catering and hospitality sector, renewable energy sector, cleaning products industry, speciality chemicals sector, WWF and ZSL. 
On 17th November 2015 DEFRA announced new figures that show UK imports of certified sustainable palm oil (CSPO) rising to as much as 93% of all palm oil 
imported. 

The second point commented by the stakeholders is regarding the substitution of palm oil. It is understood under the scheme of GPP for food products that whenever palm oil is 
included as an ingredient, certified sustainable palm oil should be preferred. This scheme does not address which type of ingredients should be purchased or used for preparing 
the food products.  

EU legislation sets legal limits for trans-fat in infant formulae and follow-on formulae (3% of the total fat content of the food, to allow for the use of milk, which naturally 
contents ruminant trans-fats, as a source of fat). Other food products are however not regulated at EU level. Legislative measures limiting the content of industrial trans-fats to 
2% of the total fat content of the food were adopted for instance in Denmark (2003), Austria (2009), Hungary (2013) and Latvia (2015). In Belgium, Germany, the Netherlands, 
Poland, the UK and Greece voluntary self-regulation measures have been agreed with the food industry.  

b) Traceability of the palm oil in the catering services and food products.  

Regarding the traceability and accounting of the palm oil in the food products, it was commented that there are two different points:  

202 

 
 
 
 
 
- the traceability and accounting of the palm oil in the food products (which food products contain palm oil and in which quantities)  

According to the information provided by the stakeholders, palm oil can be purchased as a raw ingredient to be used in the preparation of the food products that are going to be 
served or that can be purchased as part of already prepared and pre-packed food products that are purchased and served. In the former case, the identification and accounting 
of the certified sustainable palm oil is easy. Invoices of the CSPO and non-CSPO can be collected as well as the associated certificates. In the latter case, the identification of palm 
oil in the pre-packed food products is difficult and accounting of the amount of CSPO in those products is even more difficult.  

Concerning the identification of palm oil in pre-packed food products, the Regulation (EU) No 1169/2011 requires since 13 December 2014 to specify in the ingredients list of all 
pre-packed  foods  (non-pre-packed  foods  are  not  covered  by  this  provision)  whether  refined  fats/oils  are  partly  hydrogenated.  Ingredients  should  be  specifically  named  and 
generic or aggregated names must not be used. The Regulation however does not require the indication of the exact trans-fats content of the food in the nutrition declaration. It 
is important to note in this context that the Regulation (EU) No 1169/2011 also prohibits operators from declaring the trans-fats content of foods on nutrition labels on a 
voluntary basis. It was indeed considered that this possibility would be used as a marketing tool by only some operators, leading to consumers' confusion. This fact makes the 
accounting of the palm oil contained in the pre-packed food products difficult as well as the accounting of the CSPO in those products.  

Due to this fact, two different accounting systems are proposed in this criterion with the same level of ambition. One deals with the palm oil bought as raw ingredient and another 
one deals with the pre-packed food products containing palm oil. 

- the traceability of the palm oil back to its origins and the proof of being CSPO.  

Another point concerning this criterion is the tracking system requested to demonstrate the CSPO. The RSPO scheme (which is considered the scheme with the highest market 
share) allows the purchase of certified sustainable commodities through mainly four different supply chain systems that are briefly explained. Each of these systems comes with 
its own advantages, requirements and pre-approved consumer claim. The four systems ensure that sustainability in the production is supported.  

- 

"Segregated" or "identity preserved": Under these schemes the manufacturers and the retailers have the option to reassure their clients that the actual palm oil they buy 
came from plantation(s) that work in a sustainable way. They can do so by saying: "This product contains [only/...%] RSPO certified sustainable palm oil". In order to make 
such a claim, oil from sustainably producing plantations has to be kept apart all the way: at the mill, in trucks, in vessels, in processing lines and in storage tanks. 
Manufacturers who purchase the oil at the end of the chain much be able to trace it all the way back to one or more RSPO-certified plantations.  

The claim can be underpinned by either of two supply chain systems: "Identity preserved"18 tracing sustainable palm oil all the way back to specific RSPO-certified plantations or 
"segregation"19, permitting the mixing of RSPO-certified oil from various sources as long as the mix is kept apart from uncertified oil 

18 The identity preserved supply chain system provides an elaborate way to separate and track sustainability produced palm oil. The model requires that fruit bunches and oil receive unique identifiers and are kept physically apart by growers, 
mills, transport and storage providers, refiners, and manufacturers. All steps in the supply chain are documented, creating a paper trail that can be followed back all the way from end-users to one specific palm grower. The end-user is assured 
that the physical palm oil he received came from the uniquely identifiable, RSPO-certified plantation. Because of the extensive need for documentation and verification, IP is the most costly of the for supply chain systems 
19 The segregation supply chain system provides an elaborate way to separate and track sustainably produced palm oil. The model allows for the mixing of palm oil or derivatives from various RSPO-certified sources. The model requires that 
fruit bunches and oil from RSPO-certified sources are kept physically apart from other palm oil by growers, mills,, transport and storage providers, refiners and manufacturers. The end-user is assured that the physical palm oil he received came 
from one or more RSPO-certified plantations. However, other than with the IP system, the oil cannot be traced back to individual plantations. Because of the extensive need for documentation and verification, segregation is a relatively costly 
supply chain system. However, it is less costly than IP 

203 

 
                                                           
- 

"Mass balance" or "book and claim": Under these schemes the manufacturers and retailers can also tell customers that they advance sustainable production of palm oil 
in cases where they cannot be sure that the actual oil in the products originated from certified plantations. Administrative certification procedures still ensure that such 
a claim corresponds with actual production of sustainable palm oil. The claim can be underpinned by either of two supply chain systems. The first of those "mass 
balance"20 allows  for  administratively  monitoring  at  any  mixing  of  RSPO-certified  and  uncertified  palm  oil  in  the  supply  chain,  to  check  whether  the  volume  of 
sustainable oil that is claimed does not exceed that amount that is actually produced. The second 'book and claim"21, does not track oil through the supply chain but let 
suppliers and end-users trade sustainability certificates through an online trading system. Every ton of oil sold under this claim corresponds with one ton of oil that is 
produced sustainably without the need for tracking and tracing.  

All the RSPO supply chain systems support the sustainability of this commodity and therefore all they are accepted as a proof of compliance with this criterion. In the case of 
the book and claim system, which is the widest available system, it should be noted that the purchased certificates should be redeemed during the same administrative year to 
be valid.  

C) Sustainable certification schemes – requirements comparison 

Table 45 compares the sustainability requirements of the schemes proposed to show compliance with the criterion. The compliance with this criterion is not restricted to these 
three schemes but they fulfil other requirements needed for the verification process such as the requirements on traceability and chain of custody.  

Table 45. Comparison of the principal requirements of three certification schemes.  
RSPO 
Commitment to transparency 
Environmental responsibility and conservation of natural 
resources and biodiversity 
Responsible development of new plantings 

ISCC 

Protection of land with high biodiversity value or high 
carbon stock. this includes primary forests and other 
wooded land of native species, highly biodiverse 
grassland, peatland, wetland, continuously forested 
areas, areas designed for the protection of rare, 
threatened or endangered ecosystems or species as well 
as high conservation value (HCV) areas. 
Environmentally responsible production to protect soil, 
water and air 

RSB 

Conservation 

Greenhouse gas emissions 
Soil 

Use of appropriate best practices by growers and millers 

20 The mass balance supply chain system relates volumes of RSPO-certified palm oil delivered into an unsegregated supply chain to volumes of oil purchased by the end-users. The model allows for mixing of sustainable palm oil with oil from 
uncertified sources at any point in the supply chain so long as the total volume of oil purchased as being RSPO-certified does not exceed the volume of RSPO-certified sustainable oil that went into the chain. For this system, trade in sustainable 
palm oil  is  monitored  administratively  throughout  the entire  supply  chain.  Sustainable  palm  oil  does  not,  however,  have  to be stored  or  shipped  separately.  For  this reason,  the mass  balance  supply  chain  system  is  relatively  inexpensive. 
However, under the system end-users cannot make claims about the actual physical content of their products.  
21 The book and Claim system is the most flexible and cost-effective way for end-users to claim their support for specific volumes of sustainably produced palm oil based on RSPO-guaranteed certificates they have purchase online. At the very 
origin of the chain, RSPO-certified palm oil suppliers may put such certificates up for sale. Under the scheme, certified growers and mills feed crude palm oil to unsegregated supply chains; end-users obtain their oil from unsegregated sources. 
Digitally traded certificates specify oil volumes credits. Traceability requirements in this system are limited to the manufacture of end products to ensure that claims are covered by purchased certificates. End-users cannot make claims about 
the actual physical content of their products.  

204 

 
 
 
 
                                                           
Water 
Air 
Use of technology, inputs and management of waste 

Responsible consideration of employees and of 
individuals and communities affected by growers and 
mills 
Commitment to long-term economic and financial 
viability 
Compliance with applicable laws and regulations 

Commitment to continuous improvement in key areas of 
activity 

Safe working conditions 
Compliance with human, labour and land rights and 
responsible community relations 

Human and labour rights 
Rural and social development 

Compliance with applicable laws and relevant 
international treaties 
Good management practices and commitment to 
continuous improvement 

Local food security 

Legality 

Planning, monitoring and continuous improvement 

205 

 
 
 
 
 
 
3.2.  Table of comments on the proposed criteria for EU GPP criteria for CATERING SERVICES 

Staff training 
This section presents the comments received through BATIS and personal communications from the 1st AHWG meeting to the 2nd AHWG meeting.  

Table 46. Feedback from the stakeholders on the TR1.0: Staff training (SC1) 
Topic 
Ambition 
level 
SME 

and 

Feedback from stakeholders 
As  the  document  states,  staff  training  is  a  crucial  aspect  for  sustainability  in  food 
services.  The  exact  content  on  what  should  be  required  as  a  selection  criterion  varies 
according  to  what  the  sustainability  targets  for  the  particular  procurement  is.  Staff 
training should also form an integral part of environmental management, thus it should 
be included in the criteria on EMS. As the rationale states the list in the criteria is to be 
seen as a checklist to choose the most relevant issues for each procurement. The current 
wording is too detailed for practical purposes and may be a challenge for SMEs. If the 
market  analysis  reveals  that  it  is  too  hard  to  meet  as  a  selection  criteria,  it  can  be 
included  as  a  contract  clause.  Setting  a  criterion  for  the  minimum  duration  of  training 
does  not  seem  as  a  proper  procedure.  It is  the  quality,  rather  than  the  time  used  that 
makes a difference. Also, cost-implications for SME:s should be considered. The savings 
from the training can only be estimated if energy and waste consumption, food waste 
reduction etc. are monitored. If the same procurement omits to require monitoring, the 
training criterion loses its credibility 
We  propose  that  staff  training  is  included  as  part  of  the  criteria  on  EMS  and  that  the 
environment  plan  for  the  service  to  be  executed  should  influence  the  exact  content  of 
training. 
Catering staff should be informed of the detergents used and potential allergies.  

Content 

We  consider  relevant  to  inform  and  train  staff  in  terms  on  cleaning  and  cross 
contamination when it is referred to intolerances or allergies and how to avoid them.  

JRC-Directorate B5 assessment 
Comment partially accepted 
Staff  training  is  now  mentioned  in  the  EMS  criterion  as  an 
important  item  to  accomplish  the  minimization  of  environmental 
burdens of the catering service. Internal evaluation and monitoring 
of  the  achievements  are  vital  for  the  development  of  an  EMS 
system  to  detect  and  correct  failures;  to  see  e.g.  whether  the 
savings from the investment in training are being fruitful. 
A certain number of hours has been considered taking into account 
the  rotation  of  the  personal  in  this  sector.  The  quality  of  the 
training might not be easy to proof by the tenderer nor to verify by 
the procurer. 

Comment partially accepted 
While the staff has to be trained on the use of detergents in order 
to  avoid  their  overuse,  the  object  of  the  GPP  is  to  diminish  the 
environmental  impact,  and  allergies  are  as  such  a  health  and 
safety topic. 
Comment partially accepted 
Dosage and handling of chemical products have been included as 
one of the points of the staff training.  
Another  point  dealing  with  cleaning  procedures  that  are  more 

206 

 
 
 
Topic 

Feedback from stakeholders 

Duration 

You can also give training for cleaning! How to use environmental products 
The  second  bullet  under  Procurement  staff  should  include  the  TS  and  AC  on  Reduced 
animal products and increased plant-based foods, as well as the TS4 and amended AC4 
on Improved animal welfare. 

Eco driving if transport is necessary 
Maybe  eco-driving  training  could  also  be  included  (this  may  fit  better  in  the  vehicles 
section) 

The  bullet  on  potential  improvement  areas  should  be  edited  to  read:  “Multiple 
sustainability benefits (use of food products with lower environmental impacts such as 
plant-based foods, improved animal welfare, as well as energy and water minimisation in 
food storage and meals preparation), minimisation, management and adequate disposal 
of solid waste (including food waste).” 
We  strongly  agree  with  the  importance  of  staff  training.  But  the  requested  "minimum 
duration" of 16 hours seems too ambitious and not realistic. 
We believe that different levels of training / education, with diverse content and duration 
should be provided to the intended recipients. We think, then, that 16 hours is not enough 
for  explaining  these  issues  and  others  more  concretely  to  the  staff according  to  their 
function. In addition, we believe that the establishment of a reminder system, within no 
more  than  2  years,  should  be  set  in  specific  topics  (such  as  peeling  fruit  for  school 
monitors) and in short sessions.  
Setting a minimum training requirement of 16 hours for new staff within 4 weeks would 
be difficult to achieve. For instance, some staff work part-time. Even for full-time staff, it 
seems to be too much too soon given all the new information and processes a new staff 
member needs to learn upon arrival. 
It would be more efficient to have a training programme that includes initial training plus 
some modules within 3 to 6 months after arrival, when the person is fully operational. 

JRC-Directorate B5 assessment 
environmentally friendlier has been included.  
The information about cross contamination should be included in a 
training related to health aspects 

Comment partially accepted 
The  training  of  the  staff  involved  in  the  purchases  has  been 
removed in this revision as the purchase is considered to be part of 
the food procurement. 
 Comment partially accepted 
The wording of the criterion reflects now the training of the staff 
involved  in  the  delivery  of  food  and  eco-driving  is  an  important 
aspect to achieve it.  
 Comment partially accepted 
The wording of the criterion has been edited and now there is no 
bullet  on  improvement  potential  areas.  However,  the  suggested 
aspects have been incorporated  

 Comment partially accepted  
Your suggestion has been taken. It is true that the duration of the 
training  can  be  ambitious  in  a  sector  where  there  is  a  large 
rotation, a recommended value of 16h per year has been proposed 
for permanent staff while for temporary and short term staff must 
be proportional to the duration of the contract. 
The wording of the criterion has been edited as follows: 
"For permanent staff 16h per year is a recommended value for the 
duration of the formation while for temporary and short term staff 
must be proportional to the duration of the contract."  
"Depending on their specific functions, the training should be 
different. The staff working at the kitchen must be trained …..l 
among other aspects". 

207 

 
 
 
JRC-Directorate B5 assessment 

Acknowledged 
See above. 

Topic 

Examples  of 
training 

Feedback from stakeholders 
16 hours  of training for kitchen staff that isn’t much. Especially if you see the subject 
they have to be trained in. In Belgium there are hotel-and catering schools (high school) 
and a full program takes 6 to 7 years to become a chef. Cooking organic, seasonality, 
vegetarian,  avoid  food  waste,  menu  planning  is  complex,  so  I  think  it  is  impossible  to 
have a well trained staff with only 16 hours. Basic training should be minimum 35/38 
hours  (work  week)  and  then  every  year  there  should  be  extra  training  of  16  hours 
(repeating importing things + new information/techniques). 
16 hours staff training time seems relatively low, considering the breadth and complexity 
of the subject matter 

Increase the minimum duration of 16 hours for new catering staff 
The  EEB  fully  supports  the  criteria  on  staff  training  proposed  by  the  JRC.  It  is  very 
important  to  train  both  staff  responsible  for  procurement  and  staff  responsible  for 
catering. Representatives from the cities of Gent and Copenhagen also pointed out that 
the proposed minimum duration is too short. 
With conversion to 90% organic produce our kitchen staffs attends a training course if 
they want to. The course is a 5 week course, and it costs nothing for the unit to attend 
because  it  is  a  training  course  for  the  unemployed  giving  them  a  chance  to  get  the 
experience  in  a  real  unit,  and  afterwards  a  better  chance  to  get  a  fulltime  job.  The 
conversion to 90 % organic produce is done within the budget of the kitchen and some of 
the key factors are huge reduction due to reduced wastage and a major upgrading of the 
kitchen  staff  so  that  it  can  be  done.  Which  result  in  better  food  quality  and  nutrition. 
Children  and  Youth  Administration,  Copenhagen  Madhus  and  Job  Centre  Copenhagen 
have  partnered  on  a  rotation  project.  Therefore,  we  can  offer  kitchen  employees  five 
weeks  of  career  advancement  in  AMU  auspices,  while  a  rotation  agency  handles  the 
kitchen work. Temporary workers are up skilled to cook organic food through a two-week 
course  in  Copenhagen  Madhus  and  are  now  at  work  in  one  of  the  institutions  that 
participate  in  the  first  course.  The  course  is  both  for  kitchen  staff  with  little  or  much 
experience.  The  key  is  motivation  and  desire  to  develop  their  own  skills  and  gain  new 
inspiration.  On  the  course  we  teach,  inter  alia,  in:  •  Cooking  methods  •  Sensory  and 
seasoning • Ecology • Nutrition for children • Menu Planning • Knowhow knowledge into 
practice. If you want more information about this program we can forward it. Answers to 
the consultation questions to stakeholders: . 
o Do you consider relevant to add new requirements to this proposal? · Eco-driving and 

208 

 
 
 
 
 
 
 
Topic 

Scope of the 
training 

Feedback from stakeholders 
training for environmental friendly cleaning.  
o Is the 16 hours’ minimum duration of training for all new staff adequate? · 16 hours of 
training for kitchen staff that isn’t much. Especially if you see the subject they have to be 
trained in. 
We will include some training / support to food producers for working cooperatively and 
to be able to (1) provide food at a competitive price which is accredited for food safety, 
(2) ensure there is sufficient capacity to supply and at a consistent quality, and (3) have 
the potential to manage complex distribution arrangements. 

This  requirement  should  be  limited  to  staff  that  is  involved  in  the  procurement  and 
preparation of food. For instance, monitors who supervise students during the lunch hour 
should not be included in the training requirement. 
We suggest clarifying what is meant by "all other staff" and specifying that the training 
requirement pertains only to staff that is involved in the procurement and preparation of 
food. 

Terminology 

Which staff has to be trained? Staff working for the tenderer? Staff of the contracting 
authority? Is the training meant for the staff on the floor (kitchen staff + procurers of 
food  products)  or  do  you  also  foresee  training  for  administrative  staff  (who  write  the 
tender + follow up)? For example if the caterer gives training for his administrative staff 
on procurement of seasonal fruits and vegetables, why should the public procurer not be 
able to join in? 
Both  the  core  criteria  and  comprehensive  criteria  sections  under  Staff  training  should 
replace “environmentally responsible” with “more sustainable.” This would reflect the fact 
that environmental improvements are just one aspect of sustainability, whereas the GPP 
goes beyond this to include, for example, improved animal welfare. 
“Environmentally”  should  be  replaced  with  “sustainability”  to  reflect  the  more  inclusive 
meaning it entails in relevance to the GPP Guidelines. 

Verification 

For verification purposes there should not only be the need to provide records but also a 
curriculum / training concept of the staff training. Very often the training records do not 

JRC-Directorate B5 assessment 

is 

trained 

to  diminish 

the  catering  service 

Comment rejected 
The  suggestions  are  out  of  the  scope  of  this  criterion:  the  staff 
providing 
the 
environmental impacts of the service, and allergies are as such are 
a health and safety topic. 
Comment rejected 
The training is meant to be given to the personnel involved in the 
catering service. Depending on their specific functions, the training 
should be different. The staff working at the kitchen must be 
trained on some aspects that can be different from those the 
serving staff is trained. Also the staff involved in food delivery 
must be trained on environmentally-conscious driving on a regular 
basis to increase fuel efficiency. 
Acknowledged 
See above for the first questions.  
For  the  last  one,  the  public  procurer  might  attend  voluntarily  to 
whatever training they consider relevant. 

Comment rejected 
The definition of green public procurement is to lower the 
environmental impact of public purchases. 
Comment rejected 
The scope of the training criterion is to serve to public procurers to 

209 

 
 
Topic 

Feedback from stakeholders 
indicate detailed enough the topics mentioned in the training activities. 

JRC-Directorate B5 assessment 
select only those companies in which specific and relevant training 
on environmental aspects is given to the staff delivering the 
catering service. The CVs of the personnel are private information 
that is not of interest for the public authorities. The records must 
include the keywords on environment aspects. 

Further analysis on Staff training 
The stakeholder's opinion on the minimum duration of the training is rather divided. While some stated it would be difficult to achieve, others advocated for an increase. There 
are as well opinions about focusing on quality more than in time, i.e. the staff needs to reach a minimum standard irrespective of how long this takes. 
The cost of staff training is not significant when  the overall savings that can be realised through reduced food waste, energy consumption and water usage are taken into 
consideration.   Including staff training as a technical specification will allow procurers to assess if tenderers can ensure that their staff has the appropriate skills to deliver more 
environmentally conscious catering services. 
Different trainings are here proposed depending on the specific functions of the personnel. Eco-driving is a relevant practice to the staff involved in the delivery of food, while 
the use of cleaning products and detergents are relevant for the staff working in the kitchen. Safety aspects are covered by different legislation and are therefore put of the 
realm of this criterion. 

210 

 
 
 
 
 
Food procurement 
This section presents the comments received through BATIS and personal communications from the 1st AHWG meeting to the 2nd AHWG meeting.  

Feedback from stakeholders 

Table 47. Feedback from the stakeholders on the TR1.0: Food procurement 
Topic 
Scope 
(plant 
based  products 
and 
improved 
animal welfare) 

In  line  with  our  previous  comments  and  justifications, this should  include  the  TS  and  AC  on 
Reduced animal products and increased plant-based foods, as well as the TS and amended AC 
on Improved animal welfare. 

Aspects  related  to  meat  production  are  mentioned  as  part  of  the  menu  planning.  Although 
vegetable-based  foodstuffs  tend  to  have  in  general  a  lower  environmental  burden  than 
animal-based  foodstuffs,  there  are  also  various  ways  to  produce  meat  and  other  animal-
based foodstuffs. Hence, improvements have been accomplished in terms of climate and other 
environmental impacts and with the increased knowledge base additional potential exists and 
various  means  to  improve  the  climate  efficiency  of  meat  production  are  developed.  In 
addition, meat production should not be regarded in isolation since the same animals often 
are  a  source  of  also  other  foodstuffs  (dairy)  and  provide  raw  material  even  for  other 
industries 
In regard to sustainably sourced fibres, the FSC scheme is mentioned as an example of how to 
verify  compliance.  However,  there  are  also  other  certification  schemes  available  for  fibre-
based packaging, such as the PEFC which is widely used for example in Finland 
The EEB fully supports the idea that the final set of criteria on food products is also applied 
for the procurement of catering services 

Packaging 

General 
comment 

JRC-Directorate B5 assessment 
Comment partially accepted 
The  criterion  itself  does  not  include  a  reduction  of  the 
meat consumption but a specific criterion on this point 
has been developed 
Acknowledged 

Comment accepted 
Examples of other schemes are also included as well as 
the possibility of verifying using equivalent criteria 
Acknowledged 

211 

 
 
 
 
 
 
 
Promotion of vegetarian menus (BEFORE: Menu planning) 
This section presents the comments received through BATIS and personal communications from the 1st AHWG meeting to the 2nd AHWG meeting.  

Table 48. Feedback from the stakeholders on the TR1.0: Menu planning TS5 
Topic 
Animal welfare  On the sentence "The criterion will encourage the use of food and beverage products with low environmental impacts 

Feedback from stakeholders 

and will help reduce the quantity of food waste being generated" 
HSI recommends the following edits to the “Consequences” of TS5 to better reflect the justifications and goals set 
out in our prior comments: 
“The criterion will encourage the use of food and beverage products with: lower environmental impacts; improved public 
health and animal welfare; and cost savings; and will help reduce the quantity of food waste being generated.”  

JRC-Directorate B5 assessment 
Comment rejected 
The  criterion  has  been  changed  to 
"Promotion of vegetarian menus" and 
it does not contain the referred text. 

Meat limit 

By  menu  planning  it  is  possible  to  increase  organic  products  into  public  kitchens.  By  reducing  meat  in  menu  and 
recipes it is possible to increase organic although it is more expensive than conventional products. 
It is not needed to set maximum % meat content. The quality and amount of meat are the most important things. 
The quality impacts also to animal welfare (4.1.1.5). 
In the revision there are good proposals to seasonality and food waste. It should be considered that seasons differ in 
EU countries. It is possible to get perishable raw ingredients locally. 

Comment rejected 
The  increase  on  organic  produce  is 
targeted  in  a  separated  criterion. 
With  respect  to  seasonality,  due  to 
the controversy around the subject it 
is proposed to be left aside.  

Could taste be one of the criteria? This could reduce food waste. 

A maximum % meat content might be difficult to implement and to verify. It might be easier to require a minimum 
of meatless dishes (per day / week) 

accepted 
partially 
Comment 
Taste has been proved to be one of 
the  factors  for  reducing  food  waste 
especially in schools and hospitals. It 
is therefore recommended to include 
the consumers in the menu planning, 
in order to encounter their tastes and 
thus reducing food waste. . 
Comment accepted 

212 

 
 
Topic 

Feedback from stakeholders 
On the sentence "Hence, there are opportunities available to minimise environmental impacts by reducing the use of 
livestock products. It is not proposed to limit the use of such products, but suggested to use them in moderation." 
The second line here is superfluous. Due to the immense negative impacts on animal welfare, public health, and the 
environment overconsumption of animal products has on health and environment, these products should be limited in 
public authorities catering services. At the very least, the GPP Guidelines should allow public authorities to choose 
their course of action; the Guidelines should not recommend against limits, which can cut against the goals of the 
Guidelines  and  stifle  innovation  and  implementation.  Therefore,  the  following  line  should  be  deleted:  “It  is  not 
proposed to limit the use of such products, but suggested to use them in moderation.” 
A maximum % meat content for the core and comprehensive criteria can and should be set.  In the US the HCWH 
Healthier Hospitals Program Less Meat goal sets a standard for “reduce meat purchased by 10% per year OR achieve 
ultimate goal of an average 1.5 oz (.09375 lbs / meal) per meal served.” Please visit: http://healthierhospitals.org/hhi-
challenges/healthier-food 
We agree with the nutritional guidance given by countries like Sweden or the Netherlands that limit meat at 500 g 
per week (200 g of red  meat as maximum). In plus, other sources of protein should be explored, as for example, 
pulses.  
We believe that a maximum percentage of meat content should not be included in the criteria. In some contracts, 
contract  caterers  are  required  to  provide  a  minimum  amount  of  meat  (e.g.  meat  must  be  served  three  times  per 
week). There are also specific nutritional standards for how much food should be given to children depending on their 
age.  In  addition,  calculating  the  percentage  of  meat  served  would  be  difficult  in  practice  when  processed  meat 
products 
ham). 
We  recommend  keeping  the  text  as  it  is  and  not  setting  a  maximum  percentage,  which  would  be  unfeasible  to 
implement. 
I think it would be better to not state the maximum content of meat but to ask for at least 1 full meal without meat 
every day. 
In Finland the menu rotation is usually for a 6 week period. The national nutritional guidelines reduce the amount of 
red meat. It is quite difficult to set the amount of meat as a criterion. The environmental impact is of course also 
different between different sources of meat and it cannot be bundled together as one product group in a call for 
tender. Rather it should be expressed as an objective, which then the service provider takes into account in menu 
planning, done tightly together with the procuring authority. Following nutritional recommendations should always be 
a mandatory requirement. 

considered 

tortellini 

stuffed 

with 

(e.g. 

are 

JRC-Directorate B5 assessment 
Indeed  the  proposal  is  to  leave  the 
figure  on  percentage  of  meat 
reduction  to  be  fixed  by  the  public 
authority. 
The  pointed  out  sentence  will  be 
removed 

is 

burden 

Acknowledged 
While one of the tools to reduce the 
environmental 
the 
reduction  of  meat  protein  in  the 
menus,  a  requirement  has  been 
proposed  in  this  revision:  "Reduction 
of red meat" 
A  fixed  target  for  the  EU  might  not 
be  set,  due  to  the  diversity  of 
catering services, guests and country 
authorities, 
Public 
specificities. 
however,  are  hereby  informed  and 
recommended  where  to  direct  the 
efforts  to,  letting  them  to  choose 
their course of action.  

 Acknowledged 

213 

 
 
 
 
 
Topic 

/ 

Meat 
limit 
plant-based 
options 

Feedback from stakeholders 
The percentage of meat: a dish has to contain a certain amount of protein. Dieticians are not willing to touch the 
norms set out by our High council of health. You can’t lower the amount of protein in a dish, but you can say that it 
can exist out of animal proteins and vegetable protein. With this system you can lower the amount of meat but you 
have to add vegetable protein so you reach the norms. 
The idea of maximum meat percentages is broadly positive, but there is a perception that meat is necessary as part 
of a balanced diet. It would be useful to consult with nutritionists to overcome dietary fears relating to meat intake. It 
might be worth considering a balanced menu as including a certain amount of protein rather than meat specifically 
and then limiting amounts of meat or suggesting diverse protein sources.  
Formulate a new core criterion on menu planning to provide a “daily vegetarian offer” or to set a maximum share or 
amount of meat on the weekly offer. 
Add  a  technical  specification  that  requires  providing  a  feedback  system  that  helps  adapting  food  portions  to  the 
client 
The EEB welcomes very much the proposed criteria on menu planning because of the great potential of lowering the 
environmental  effects  of  food  consumption.  But  we  highly  recommend  formulating  a  new  core  criterion  “daily 
vegetarian offer”. Especially the public procurers present at the 1st AHWG meeting supported this proposal 
For those caterers that offer only one meal or menu per day, a maximum amount of meat based menus should be 
set. The EEB suggests a maximum amount of two meat based menus per week. Another option could be that the 
share  of  meat  products  in  the  menu  week  plan  should  be  based  on  general  nutrition  recommendations  like  the 
recommendation of the German Society for Nutrition that recommends 300-600g meat/week for an adult. 
We also recommend adding another two aspects to the food waste minimisation plan: As part of the core criteria, the 
catering service has to provide a feedback system that helps adapting food portions to the clients. The offering of 
doggy bags could be considered within the comprehensive criteria. 
We have a weekly veggie day (vegetables only). Additionally we offer a full two-week vegetarian menu that follows 
national dietary recommendations. In Denmark we have some institutions with a vegetarian profile who don’t serve 
meet. Seasonality should be incorporated in menu plans, both from an economic and an environmental perspective. 
Meat is not essential for a balanced diet – protein on the other hand is. Nursery and daycare facilities in Denmark 
operate  with  1  or  2  weekly  meet  days  in  the  institutions.  The  protein  intake  in  the  resisting  meals  is  covered  by 
vegetable protein and fish. Nutritional values of  the menus and information’s on allergens should be available on 
request. Include a requirement and fresh raw vegetables ingredients in every meal and a weekly fish day. Include a 
requirement  to  provide  tap  water  rather  than  bottled  water.  http://altomkost.dk/raad-og-anbefalinger/de-officielle-
kostraad/ Answers to the consultation questions to stakeholders: o Can a maximum % meat content for the core and 
comprehensive criteria be set? · I would like a balanced menu including a certain amount of protein rather than meat 
%. 

JRC-Directorate B5 assessment 

 Acknowledged 
The 
criterion  has  been  edited 
accordingly.  The  food  portions  and 
is 
all 
considered  now  in  the  specific  food 
waste criterion. 

food  waste 

related 

to 

 Acknowledged 
criterion  has  been  edited 
The 
accordingly.  Weekly 
vegetarian 
day(s)  is/are  included  as  well  as  an 
increase in vegetarian proteins at the 
expense  of  a  strong  reduction  of 
meat.  
A  balanced  menu 
requirement 
cannot  be  set  since  there  is  not 
agreement  on  what  this  can  be 
across the EU. 

214 

 
Topic 

Feedback from stakeholders 

limit  to 
other 

Meat 
cover 
animal 
products 

Per our previous comment, the following core criteria regarding animal products should be added: 
Technical Specification 
Animal products should make up no more than 20% of the total procurement cost of food and drink products 
Verification 
The tenderer must provide data (name and the amount in mass) of animal products planned to be supplied in the 
execution of the contract indicating specifically the products that comply with the requirements. Products that have 
been third party certified by widely accepted and recognised international organisations) will be deemed to comply. 
Award Criteria 
Points must be awarded to tenders in which the amount of animal products is below 20% of the total procurement 
cost of food and drink products 
Verification  
The  tenderer  must  provide  data  (name  and  the  amount  in  mass)  of  animal-based  food  products  planned  to  be 
supplied  in  the  execution  of  the  contract  indicating  specifically  the  products  that  comply  with  the  requirements. 
Products that have been third party certified by widely accepted and recognised international organisations) will be 
deemed to comply.  
For the reasons we set out above, yes, we believe a maximum percentage of meat, dairy, and egg contents can and 
should be set for the core and comprehensive criteria. 

JRC-Directorate B5 assessment 
Tap  water  for  drinking  has  been 
stablished  now  as  a  Contract 
Performance Clause. 

Comment partially accepted 
Although a fixed value has not been 
set,  the  criterion  has  been  edited 
accordingly.  
It  now  requires  for  an  increase  in 
vegetarian  proteins  at  the  expense 
of a strong reduction of meat. 

215 

 
 
Topic 

Perishable 
ingredients 

Feedback from stakeholders 
HSI advises against recommending substituting red meat with chicken or pig products. As monogastrics tend to be 
more intensively farmed than ruminants, this raises animal welfare concerns and therefore would conflict with AC4. 
We further note that plant-based foods have the lowest environmental impact and can improve public health and 
save lives and money,   Further, a 2014 study found that a 50 percent reduction in all EU consumption of meat, dairy 
and  eggs  would  cut  agricultural  greenhouse  gas  emissions  by  19  to  42  percent.   Among  others,  studies  in  the 
UK,  US, India,  and Italy  have shown lower emissions for more plant-based diets. 
Therefore, we recommend these lines be edited to say: “Reducing content of animal products and replacing with plant-
based  options  is  one  example  of  how  to  minimise  environmental  impact.  Red  meat  was  found  to  have  the  largest 
impact on the environment in the current production systems and chicken and pork had lower impact (section 3.1.5.1.4., 
Preliminary Report), Further, plant-based diets are consistently shown to have the lowest environmental impacts, while 
at the same time exhibiting potential improvements in public health and animal welfare.” 
As recognised, the dairy industry has a large impact on the environment and on animal welfare.   Therefore, rather 
than  simply  recommending  substation  of  dairy  products  based  on  fat  content,  the  Technical  Report  should 
recommend  reducing  all dairy  products  and  substituting  with  plant-based  alternatives  (e.g.  soya  or  almond  milks). 
Thus, we recommend adding the following sentence: 
“Furthermore,  full-fat  dairy  products  have  larger  environmental  impact  than  half-fat  dairy  products  due  to  the 
attribution of the fat to the product (section 3.1.5.1.5., Preliminary Report). Additional environmental and animal-welfare 
benefits may be had by reducing all dairy products and substituting with plant-based alternatives (e.g. soya or almond 
milks).  Hence,  there  are  opportunities  available  to  minimise  environmental  impacts  by  reducing  the  use  of  livestock 
products.”  
Based  on  our  prior  justifications,  we  recommend  the  following  changes:  “The  meat,  dairy  and  egg  content  in  the 
overall meal composition must be limited whilst maintaining the correct nutritional balance.” 
As recommended in the 2012 report commissioned by the European Commission (DG ENVI), “Assessment of Resource 
Efficiency in the Food cycle,” which states that “Provision of more food products that serve as alternatives to meat and 
fish,”we  recommend  this  text  be  amended  to  say:  “The  meat,  milk,  egg,  and  fish  content  in  the  overall  meal 
composition must be limited whilst more food products that serve as alternatives will be sought, while maintaining the 
correct nutritional balance.  
On the sentence "Perishable raw ingredients must be included in more than one dish, (e.g. carrots, onions, potatoes)."  
It should be noted that the more perishable raw ingredients are used, the more food waste there will be. 

Planning  based 
past 
on 

On  the  sentence  "The  menu  must  be  planned  based  on  past  performance,  i.e.  what  meals  do  customers  like  best." 
This is difficult, it makes it difficult to introduce new, and healthy choices.  

JRC-Directorate B5 assessment 
 Comment accepted 
Although a fixed value has not been 
set,  the  criterion  has  been  edited 
accordingly.  
It  now  requires  for  an  increase  in 
vegetarian  proteins  at  the  expense 
of a strong reduction of meat.  
Other  alternatives  to  reduce  the 
meat  consumption  are  given 
in 
Explanatory notes. 

Comment partially accepted 
The criterion has been changed to a 
"Promotion  of  vegetarian  menus"  in 
the  scope  it  does  not  include  the 
dairy products. 
 The  sentence  about  the  nutritional 
balance has been added as follows: 
"…reduced  meat  consumption  whilst 
maintaining the nutritional balance in 
the  menus  recommended  for  the 
targeted guests." 

 Acknowledged 
The use of ingredients and all related 
to  food  waste  is  considered  now  in 
the specific food waste criterion. 
 Acknowledged 
The  proposal  now  has  been  taken 

216 

 
  
 
Topic 
performance 

Plant-based 
options 

Seasonal 
products 

Feedback from stakeholders 
A client may have certain requirements (e.g. meat three times per week). If those are not the dishes that are most 
favoured by consumers, then the contract caterer would not be able to fulfil this requirement since they would still be 
contractually required to provide the dishes.  
What we hear works best is when the client and the contract caterer can work together to see how food waste can 
be reduced in canteens. Perhaps this can be addressed in implementation guidance rather than GPP criteria, which is 
not the best place for setting rules on contract caterers that actually require the consent of both the contract caterer 
and the public authority. 
The inclusion of shaping menus to what consumers ‘like’ would not work for example in the context of schools, where 
part of the purpose is to educate children on healthy eating and educate their palates. 
Add to core criteria that daily plant-based meal options must be available, for example, one third of meals must be 
plant-based. HSI suggests the following language: “A weekly ‘veggie day’ must offer a fully plant-based meal at least 
once per week.” 
Part of the core criteria, in efforts to reduce animal products and increase plant-based options, should be to have a 
weekly plant-based offer. Thus, we suggest adding an additional bullet stating: “A weekly plant-based offer must be 
available.” 
The  current  wording  is  unclear,  does  this  a  vegetarian  option  once  a  week?  We  suggest  the  following  alternative 
wording: “A plant-based offer, including main dishes, must be available daily.” 
There  should  always  be  a  vegetarian  (or  plant  based)  alternative.  Although  it  should  not  be  the  only  possibility  it 
should always be possible and attractive to choose.  
A vegetarian meal should be provided on a daily basis. Thus, we recommend that having a veggie day would better 
serve as a comprehensive criterion.   
Our core TS is Thursday veggie day and a daily vegetarian alternative. The vegetarian dish can’t be more expensive 
than a traditional meal. 
The  definition  of  a  veggie  day  as  ‘including  a  vegetarian  option’  seems  relatively  weak.  We  would  prefer  it  to  be 
defined rather as a vegetarian-only day. 
Seasonal produce is not a synonym for less environmental impact. For instance, a vegetable might be in season in 
the country of consumption but in order to source a sufficient quantity it may be necessary to source the vegetable 
from a country where it is not in season. If the intention is for the produce to be in season where it is grown, the 
verification would require seasonal calendars for every agriculture-producing country.     
 Forcing  food  service  providers  to  purchase  only  seasonable  produce  would  be  extremely  limiting  in  terms  of  the 
variety of offer. We would need to ensure that seasonal calendars still allow for variety and nutritional balance. 
 The quantity of seasonal produce available must also be taken into consideration. There may not be a sufficient 
supply of non-refrigerated produce to meet the demand for seasonal produce based on local seasons. There is also 

JRC-Directorate B5 assessment 
but  under  the  specific  food  waste 
criterion created. . 

 Acknowledged 

 Comment accepted 
Although a fixed value has not been 
set,  the  criterion  has  been  edited 
accordingly.  
It  now  requires  for  an  increase  in 
vegetarian  proteins  at  the  expense 
of a strong reduction of meat.  
Other  alternatives  to  reduce  the 
meat  consumption  are  given 
in 
Explanatory notes. 

 Comment rejected 
The  criterion  is  now  about  reducing 
the  meat  consumption  and  not  any 
longer  about  menu  planning  since 
the  planning  is  reflected  in  the  rest 
of the criteria. Seasonal produce has 
moreover  been  removed  from  the 

217 

 
 
 
  
 
Topic 

Feedback from stakeholders 
the potential for this requirement to become a barrier to trade in the internal market if the intention is to limit 
sourcing to local suppliers. We recommend "The menu must endeavour to make use of produce in season when 
available and affordable"  

Seasonality is a TS criterion for the tenderer to show us what food products are in season. A real seasonal menu 
planning according to the 4 seasons is an AC. 
In menu planning there is more than one goal. E.g. eat less meat, eat more healthy, get less food waste. Maybe it is 
better to present these goals separately? Employee health is very important now and food is an important mean to 
contribute. This criterion is becoming the most important of the catering services! 

Separate 
criteria:  meat 
reduction  and 
food waste  

Tap water 

Include a requirement to provide tap water rather than bottled water. 

Consumer 
information 

Consumer 

These “Information to consumers” requirements go beyond the scope of GPP, the aim of which is to facilitate for 
public authorities the purchase of products, services and works with reduced environmental impacts. There also 
appears to be no justification for this requirement in the Technical Report or Preliminary Report. Furthermore, the EU 
Food Information to Consumers (FIC) Regulation leaves it up to Member States to determine whether and how 
nutritional information is provided to consumers for non-pre-packed food, so this technical specification would not be 
in line with existing EU and national rules. 
We recommend removing “Nutritional values of menus and information on menus” from the list of elements that must 
be included under menu planning. 
In any case, providing nutritional information and allergen information in a contract catering setting, where a variety 
of food options are often freshly prepared by hand, is more challenging and entails a higher administration cost than 
in a retail environment, where a large quantity of one type of food is generally industrially produced in a standard 
way. When providing nutritional and allergen information has been required by contract caterers, some contract 
caterers have had to dedicate a full-time staff member to this task. SMEs who have less flexibility to dedicate 
someone to the task would particularly struggle to fulfil this criterion. 
Regarding allergen declarations, such information is required under the FIC Regulation to be provided for non-pre-
packed food but how contract caterers are required to provide this information varies per Member State. For instance, 
in some Member States the information can be given orally upon request.   
Please add cooking techniques, such as vapor, low temperature, etc. 

JRC-Directorate B5 assessment 
list because of the discrepancy about 
the benefits of a product whether is 
globally seasonal or locally seasonal 
and the impossibility to be verified. 

 Comment accepted 
The criterion has been changed to a 
"Promotion of vegetarian menus" and 
the food waste will be targeted in a 
separate criterion indeed. 

 Comment accepted 
This suggestion has been included as 
a contract performance clause. 
 Acknowledged 
The criterion has been changed to a 
"Promotion of vegetarian menus". 

 Comment accepted 

218 

 
  
  
Topic 
information 

Verification/ 
Consumers 
feedback 

Feedback from stakeholders 

Menus should be balanced, nutritive and that respect the seasonality of products. On the other hand, we would like to 
consider  the  aspect  of  participatory/collaborative  management,  as  a  way  to  verification, where  consumers  can  be 
involved in the food service and provide feedback about the quality and taste of it in order to improve meals and 
their satisfaction. At this point, some cooking techniques should also be considered.  

Food waste 

Food waste is an important aspect of circular economy and it should be more elaborated in the criteria set maybe 
even as a criterion separate from menu planning. The proposed draft comprehensive criteria concerning food waste 
does not suffice as a criterion for promoting circular procurement with regards to best practices already available. 
In  the  Finnish  procurement  guidelines  regular  monitoring  and  reporting  of  food  waste  is  recommended  as  a  core 
criteria. The recommendation for the comprehensive criteria is that the amount of biowaste is regularly monitored by 
weighing the following fractions: total amount of biowaste, kitchen waste, serving waste, plate waste. The results are 
reported to the buyer. 

JRC-Directorate B5 assessment 
This suggestion will be dealt with in 
energy  and  water 
consumption 
criterion indeed. 
 Comment accepted 
For keeping the nutritional balance a 
sentence  has  been  added  to  the 
wording of the criterion.  
The  information  to  the  guests  and 
collaborative  management  is  both 
reflected in the EMS criterion and in 
the foodwaste criterion. 
The  suggestion  about  the  cooking 
techniques  will  be  dealt  with  in 
energy  and  water 
consumption 
criterion indeed.  
 Comment accepted 
This  suggestion  has  been  accepted 
and  foodwaste  is  now  a  different 
and 
criterion. 
reporting  of  food  waste  is  being 
dealt in EMS criterion. 

The  monitoring 

219 

 
  
Topic 

Feedback from stakeholders 
The  focus  should  be  on  prevention.  Contract  caterers  are  actively  working  to  prevent  food  waste  in  the  kitchen 
through data recording, awareness raising and changing food preparation techniques. But preventing food waste in 
cantinas often requires collaboration with the procurer. For instance, when a procurer requires the full range of menu 
options to be available from the start to the end of the service, there is more food waste than when the caterer can 
provide limited options at the beginning and end of the service.   
 Post-consumer food waste is the responsibility of the procurer. Contract caterers are limited in their ability to reduce 
post-consumer food waste. Nonetheless, when procurers wish to take action in this area, contract caters have taken 
initiatives together with procurers to raise awareness among consumers, to encourage consumers and to discuss with 
the server what portion size they would like. 
We see food donation as a last resort. Much of the food waste from cantines is unsuitable for redistribution due to 
food safety and hygiene. For instance, food in the contract catering sector needs to be consumed within 24 hours of 
being prepared and unrefrigerated food that should be refrigerated is no longer deemed suitable for consumption 
after a certain fixed period. Only a limited amount of food that has not been offered to consumers can be donated 
(e.g. sandwiches that are fully packaged). In addition, it is the procurer, not the contract caterer, who decides whether 
food is donated.    
The text should specify that the obligation to sort and report bio-waste only pertains to kitchen waste where space 
allows for separation. 
While  reducing  post-consumer  food  waste  is  also  very  important,  this  should  not  be  addressed  in  GPP  criteria  for 
contract caterers since post-consumer food waste belongs to the client. 
Including  a  food  waste  minimisation  plan  is  a  useful  first  step,  but  it  would  be  useful  to  provide  more  practical 
information and suggestions on what this should include and how to manage it. 

Waste  sorting 
and disposal 

This is also a key criteria and should be compulsory for all public spaces to have one waste management programme 
in which it was included its separation (paper, glass, plastic, organic waste and (hazardous waste - in some cases), as 
minimum).  Also,  disposal  and  incineration,  in  except  of  hazardous  products,  should  be  looked  as  an  ultimate 
alternative according to the EC Circular Economy Package, so more re-utilization and recycling strategies should be 
designed and implemented. 
Also, food donation should be considered, if possible, both for human or animal purposes, prioritizing human ones, as 
food Banks or social entities/organizations, instead of throwing it away or dispose it.  
Sorting on site should only be required where space allows for such separation. 
 We suggest "must be sorted into the correct waste stream categories wherever the client provides the means and 

JRC-Directorate B5 assessment 
 Comment accepted 
This  suggestion  has  been  accepted 
and  foodwaste  is  now  a  different 
and 
criterion. 
reporting  of  food  waste  is  being 
dealt in EMS criterion. 

The  monitoring 

 Comment accepted 
This  suggestion  has  been  accepted 
and  foodwaste  is  now  a  different 
criterion  where  practical  information 
and options to reduce it are given. 
 Comment accepted 
The  sorting  and  disposal  for  waste 
comments  are  considered  for  the 
Waste 
disposal. 
Foodwaste 
is  now  a  different 
criterion. 

sorting 

and 

 Comment accepted 
The  sorting  and  disposal  for  waste 

220 

 
  
  
Topic 

Feedback from stakeholders 
where space allows for such separation..." 

JRC-Directorate B5 assessment 
comments  are  considered  for  the 
Waste sorting and disposal.  

See suggestion to align this with previous comment. add "...and when space allows..." 
Sorting  into  waste  stream  categories  (including  packaging)  only  makes  sense  if  the  waste  streams  for  separate 
collection and recycling are available. 
Suggestion to state "....wherever the client provides the means (e.g. waste containers for distinct solid streams) for 
the sorting of different solid waste and when waste streams for the separate collection and recycling of that waste 
is available. 
I agree with the modification. 
Since  there  are  different  schemes  of  waste  segregation  (e.g.  in  Germany  differing  on  community  by  community) 
these legal schemes should be taken into account. When sorting is done by the community waste disposal agency 
sorting within the catering firm does not make sense and should not lead to a negative evaluation.  
For now we ask the supplier to show us a plan for waste sorting and disposal. Answers to the consultation questions 
to  stakeholders:  o  Do  you  agree  on  the  modifications  proposed  for  this  criterion?  ·  Yes  o  Are  you  aware  of  any 
limitation to implement and verify this criterion? No 
The EEB welcomes the proposed criteria set on waste sorting and disposal.  

 Acknowlegded  

Further analysis on menu planning 

Meat  production  accounts  for  almost  one  fifth  of  the  world's  total  GHG  emissions.  Cattle  and  sheep,  which  are  ruminant  animals,  cause  particularly  large  greenhouse  gas 
emissions due to their feed digestion (15-40 kg of greenhouse gases/kg of meat). Pigs and chickens produce significantly lower emissions (respectively, approximately 5 and 2 
kg of greenhouse gases/kg of meat). 

The comments on the ambition levels for meat content were divided with one stakeholder stating that some contracts specify a minimum meat content clause and others in 
agreement  with  the  ambition  levels.  However,  measuring  meat  content  was  considered  problematic  in  pre-prepared  ready  meals  where  the  meat  content  is  not  readily 
quantifiable. Additionally, another stakeholder stated that both the core and comprehensive criteria should be extended to include dairy, eggs and fish. For example, plant based 
alternatives to dairy products include soya or almond milk. 

The substitution of red meat with chicken or pig products could conflict with the criterion on animal welfare since the latter are more intensively farmed.  

The number of weekly vegetarian / plant based options  is debated issue among stakeholders with some proposing that vegetarian options are available every day and one 
completely vegetarian / plant based day per week. 

221 

 
    
  
 
 
 
Avoidable food waste prevention 

Food waste prevention has been identified during this revision as one of the main environmental aspects of whole catering service. Food waste is actually a problem in today's 
catering services and it accounts between 4 and 10% of their food procurement (Technology university of Michigan,  www.leanpath.com). the reduction of food waste in the 
catering services is considered an evidence of good performance, and a better management from the social and the environmental point of view.  

The food waste is defined as follows:  

Food waste is composed of raw or cooked food materials and includes food loss before, during or after meal preparation in the household, as well as food discarded in the 
process of manufacturing, distribution, retail and food services activities (Technical report 2010-054) 

This section includes information about the food waste generation, possible ways to reduce it as well as the needs for implementing these proposed measures and the benefits 
(economic and environmental perspectives) that they can bring to the caterers and the society.  

Sources of food waste 

The  studies  about the diversity  of  causes  of  food  waste  causes  in  the manufacturing, wholesale/retail  and  food  service  sectors  have  been  revised  in  this  section.  They  are 
expected to be similar across Europe even though they will vary according to product specificities. Manufacturing food waste was estimated at almost 35 Mt/year in the EU 27 in 
2010 (approx. 70 kg per capita), although a lack of clarity over the definition of food waste (particularly as distinct from by-products) among the Member States makes this 
estimate fragile. According to this further estimate, the wholesale or retail sector generates close to 8 kg per capita (with an important discrepancy between the member States) 
representing around 4.4Mt for the EU27 in 2010 and the food service sector an average of 25 kg per capita for EU 27 in 2010. There is a notable divergence between the EU 15 
at 28kg per capita (due to the higher trend of food waste in the restaurant and catering sector) and 12kg per capita in EU 12 (Technical report 2010-054). These figures are 
expected to rise in the future if no additional prevention policy or activities are implemented.  

Betz et al 2015 carried out a study about the magnitude and potential reduction of food waste in the Swiss food service industry. They realized that in Europe 280-300 kg of 
food per capita is wasted per year (Gustavsson et al 2011), the losses being spread over the whole value added chain but they are concentrated at the end as typical from high-
income countries. Beretta et al (2013) claimed that in the food service industry, more than two  thirds (13.5% of the food input) was avoidable. Wong (2011) investigated a 
German university canteen and found that the total loss in the value added chain came to 9.65%. Furthermore, Baier and Reinhard (2007) calculated an average of 7.41 tonnes 
of food loss per year per food service company (in the education and business sectors) in the Swiss canton of Aargu.  

Other studies have calculated food waste per meal: Andrinin and Bauen's (2005) figured 50g food waste per meal, whereas Baier and Reinhard (2007) estimated 124 g per 
meal. In two Swedish canteens food waste was found to vary from 46g to 115g per meal (Engstrom and Carlsson-Kanyama, 2004) Moreover, in a study which took place in 
secondary  schools  in  the  UK  over  a  period  of  three  weeks,  pupils  produced  159-191  g  per  meal  per  day  of  waste  (Cordingley  et  al  2011).  The  results  per  portion  vary 
considerable, which may be accounted for by the different assessment methods used.  

Finally, Betz et al 2015, reported that in two analysed companies in the education and the business sector, 10.73% and 7.69% respectively of total food delivered waste lost 
over  the  value  added  chain.  With  10.47-16.55  tonnes  of  annual  food  waste,  a  food  waste  service  company  has  huge  financial  losses.  In  a  company  the  losses  reached 
78957CHF and in the other 68346CHF that are potentially avoidable each year. This study pointed out that the food that is wasted in the later stages of the value added chain 

222 

 
 
has  a  greater  negative  effect  than  food  which  is  wasted  in  the  agriculture  stage,  because  additional  resources  (eg  staff,  transport  and  packaging)  have  been  employed  to 
prepare the food stuff for consumption. This is one main reason why the reduction of food waste at the end of the value added chain (including the food service industry) is of 
major importance.  

The data shown that service losses, which are the main group of losses and almost completely avoidable could be minimized by adapting portion size and using smaller serving 
bowls. The customer survey showed that the importance of this topic is known. Long-term implementation, control and evaluation of reduction measures were recommended in 
the study. Furthermore, it is important to increase the awareness of staff as well as to sensitise customers to the issue of  food waste avoidance in order to increase their 
tolerance towards measures taken.  

A Nordic study carried out in 2012 (Marthinsen 2012) estimates that each serving generates in average 125 g of food waste and several studies carried out in Sweden report 
that as average the mean plate loss in the schools reaches between 7.5 and 9.6% of the served food. According to the study if a portion weights 0.333kg, a plate loss of 7.5% 
equals 25g. Similar studies report that the plate loss at an average of approx. 6% of prepared food, while waste from the kitchen and the buffet was approx. 12% on average. 
Another survey performed in the same project of 4 different types of dining places (school kitchen, restaurant and staff canteen) showed similar amount of food waste. In total, 
they recorded 18% avoidable food waste of which a plate loss of 10%, 4% loss in storage and preparation and 4% loss in serving. Based on an average portion at schools of 
0.333kg, an avoidable food waste of 18% equals 60 g per portion. Based on data from EUROSTAT 2006, the BIOIS report uses and average of 27.32 kg per capita of food waste 
from "food services and catering" in EU 15 (European commission, 2010). 

The main reasons for this increase are the population growth and the increase in the disposable income. 

In the food manufacturing and especially in the catering service sector, three main aspects have been identified as key points that affect the generation of food waste:  

-  the  preparation,  distribution  and  serving  of  the  food:  the  restaurants  and  catering  services  are  covered  by  the  Regulation  HHAC  on  the  processes  that  should  be 
regarded for serving and delivering the food products. For example, this regulation stipulates the temperature to be held for frozen products as well  as the need to 
discard products if the regulation has not been regarded at any point of the delivery.  

- the conservation and deadlines in the conservation of the food:  the need for clarification and standardization of current food date labels (that all the pre-packed or 
packed  food  products  should  display)  such  as  "best  before",  "sell  by"  or  "display  until"  dates,  and  the  dissemination  of  this  information  to  the  public  to  increase 
awareness of food edibility criteria, thereby reducing food waste produced due to date label confusion or perceived inedibility. For example WRAP 2010 reported that in 
the UK 45-49% of the consumers misunderstand the meaning of the date labels "best before" and "use by". 

Table  49 provides information about the types of expressions, the meaning and the mandatory requirements to display this information as well as complementary 
information  that  can  come  along  with  the  mandatory  one.  There  are  food  products  that  are  exempted  of  this  requirement  such  as  fresh  fruits  and  vegetables, 
refreshments, wines, liquours, bread and bakery products, salt, sugar or vinegar.  

Deadline expressions 
Best before…  
Best before the end of….  

Table 49. Information regarding the date label on the food products. 
Where?  
Pre-packed and packed food products 

Minimum duration  

Examples 
dd.mm.aaaa  < 3 months 
> 3 months 
- between 3 and 18 months 

mm.aaaa 

Complementary information 

223 

 
 
 
Expired date 

- > than 18 months 
aaaa 
dd.mm.aaaa  No minimum period  

Very perishable pre-packed and packed food products 
that can be considered as a risk to the health after a 
short period beyond the expired date.  

Description  of  the  conservation 
conditions  that  are  needed  to  be 
regarded.  

The display date is always closer than the expired date in terms of health and food safety. The expression 'best before" has  to be understood as a recommendation 
about the date by which the product should be consumed. If this date is over, some organoleptic characteristics of the product can be varied, but there is no a risk from 
the health or food safety perspectives.  

- the residues. The actual regulation considers that the residues coming from most of the catering services such as bars, restaurants, hotels, cantinas or school cantines 
can be considered as municipal residues. On the other hand, the residues coming from catering services that prepare food to be packed and delivered and where the 
processes used are similar to those industrial ones should be considered as industrial residues.  

Therefore the caterers should manage their residues depending on its classification. The management of the industrial residues is very specific and this is not the case 
of  the  majority  of  the  caterers.  According  to  the  regulation,  those  caterers  considered  as  non-industrial  ones  can  manage  their  residues  throughout  the  municipal 
collection system in place.  

The municipality is usually the authority responsible for the management of the municipal residues. This authority decides the end-of-life of the municipal residues that 
have been collected as well as the price or fees of this service. The catering services are obliged to hand in the residues in a way that allows their proper sorting,. This 
means that depending on the municipality there the catering service is located; the caterer should sort out the residues into organic residues, packaging, paper and 
glass. Therefore, this requirement was included in the criterion on Waste sorting and disposal 

Ways for preventing food waste generation in catering services 

Waste prevention incorporates the first three terms of the waste management hierarchy: eliminate, reduce and reuse. The elimination/reduction is the best option for minimising 
waste. But first of all, how much food waste is generated in Europe? The literature provide little information or evidence to estimate the amount of editable food waste. WRAP 
reported data of avoidable and unavoidable food waste in the hospitality sector in UK. The average rate for avoidable food waste for the profit sector is calculated to 67%.  This 
value varies from 63% in the hotels or 64% is the pubs to 72% in the fast food restaurants or 70% in the restaurants.    

Several instruments and initiatives have been implemented at EU level to try to reduce the food waste generation. Among them, the ""from farm to fork" initiative tries to reduce 
by 50% the food waste generation by 2025 or the food waste generation targets placed in 2014 in accordance with the waste framework directive. Recently EU has developed a 
Strategy 2020 including a plan for resource efficiency. Reducing avoidable food waste might also be regarded as part of this  overall strategy. In the Roadmap to a Resource 
Efficient Europe food is described as a key sector and actions are proposed in order to reduce the amount of food waste.  

Some other initiatives have been implemented at national level and are related directly to the food services:  

-  Serving portions according to the needs of the guests (Portugal) 
-  Good practice guide for restaurants (Belgium, Spain, etc) 
-  Guide for food waste prevention for canteens and hospitals (Ireland) and other catering services (Spain) 

224 

 
-  Sustainable catering (Netherlands 
-  A la carte menu for hospitals (Denmark) 
-  Experiment at lunch catering (Netherlands)  
-  Green hospitality award scheme (Ireland)  

The guide "'less food waste more profit" provides a number of measures that can be implemented in the catering sector to prevent the food waste generation. Proper food stock 
management (ordering minimum stock, rotating stock), menu planning and portion control are the most important areas for minimising catering food waste. Another important 
issue in waste prevention is the training and motivation of stall. All staff must be aware of the procedures and steps that should be taken.  

This section comments some suggestions and recommendations on how to prevent and reduce food waste. All these suggestions may not be applicable to all the business 
models because of the size and location of the catering service.  

Table 50. list of measures to prevent food waste generation in catering services Source: Less food waste more profit 2012 
Prevention - purchase 
Do not over-
order food 
Buying in bulk 

The actual use of the ingredients should be checked out against a number of orders. The caterer should establish an accurate stock inventory and ordering 
system to avoid over-ordering and spoilage of stock. 
It should only be performed if the all the products will be used. otherwise it becomes waste and when the waste cost is included the bulk product may be 
more expensive 
caterers should carefully check all deliveries to ensure that food is free from contamination, packaging is not damaged and cans are not leaking or rusty, 
perishable food is within it "best before" or "use by" date, temperature check particular foods eg fish, to ensure it is fresh and has been stored and 
transported at the right temperature (food should either be hot or cold, but not warm) 
All ordering of stock should be through a single primary purchaser. This purchaser can prevent over-ordering of a product by different employees. Thy can 
also look at trends in stock and food covers to highlight wastage 
Considering setting up a "stock and order" form in your food storage areas. this from highlights what Is in stock and what should be ordered. As an ingredient 
is used the member of the staff reduces the number of stock and adds the quantity to be ordered. This allows staff to know at a glance what is being used 
for accurate ordering.  
Ordering food as close to the time of use as possible. May food distributors are able to deliver in a short period of time.  

Check deliveries 

Single primary 
purchaser 
Accurate 
ordering 

Ordering 
Prevention - storage 
Label upon 
delivery 

Storage 
temperature 
Storing fruits 
and vegetables 

Label and date upon delivery. Label should indicate the contents and the products expiration date. Other necessary information, such as handling and storage 
instruction, may also be included 
Operate a back-to-front (FIFO) policy. Place the new products at the back or the bottom of the self. The older product will be then used first 
To prevent spoilage store perishable fresh food should be stored at temperatures below 5C (refrigerator or chill room or freezer) or above 63C 

Vegetables particularly leafy vegetables should be stored as far as possible from cooler condenser units to prevent freezing. Store all soft fruit (except 
bananas) and salad items in the refrigerator. Store all other fruit and vegetables in wire baskets. This allows air to circulate around the food reducing 
microbial growth.  

225 

 
To avoid picking up a strong flavour all oils and grease should be stored away from strong smelling foods. 

Storing oils and 
grease 
Storage areas 

Storing lettuce 

Storing herbs 
Vacuum packs 
Prepared food 
and perishables 
Prevention - preparation 
Avoid over-
trimming 
Food to order 
Pre-portioned 
meat or fish 
Prevention - cooking 
Recipes 
Pre-prepared 
food 
Equipment 
Portion size - 
Adjust portion 
sizes 

Store areas should be dried and clean. Storage areas should have easy access to product. Place all dry goods off the ground on pallets or shelving. These 
steps will help to minimise waste due to spills, breakages and spoilages 
Never store tomatoes and lettuce in the same container or close to each other, as tomatoes emit a gas that will turn lettuce brown,. Never cut lettuce with a 
meal knife as it encourages browning of the leaves.  
Certain vegetables and herbs (eg parsley can wilt when stored) freshen these vegetables by trimming off the bottom section and storing in warm water.  
Consider vacuum packaging for expensive food such as meat and fish upon delivery or ask the supplier 
Washed and prepared food should be stored in reusable airtight containers to prevent unncesary dehydration and spoilage, especially if the containers are 
stored at or below 5C 

Over-trimming typically occurs in the preparation of bulk meats, fish and whole vegetables. Be aware of how much over-trimming occurs and try to reuse it. 
Alternatively the product pre-prepared and portioned can be ordered 
Prepare foods to order to avoid waste generation from over-preparation 
Purchasing pre-portioned and cut meat or fish can reduced the quantity of meat or fish trimmings to be disposed of. Waste meat or fish trimmings are 
difficult to handle and its methods of disposal are limited.  

Whenever possible prepare foods to order to avoid waste generation from over-preparation 
Cook smaller quantities of pre-prepared staple food (pasta, potatoes and vegetables) in smaller batches as required. This reduces the likelihood of excess 
food being unnecessarily prepared and thrown away 
Keep oven equipment calibrated to avoid over-baked products 
Look at the size of meal portions and accommodate the quantities depending on the possible left-over of the returns 
The following steps can help decide which meal portions should be adjusted:  
- obtain feedback from service staff, who see on a daily basis which meals have the largest quantity of leftovers 
- undertake a leftover waste survey 

Prevention - serving 
Serving options  When serving vegetables or bread provide them in the centre of the table as opposed to individual portions. This allows customers to decide the portion size 

Condiments 

Customer 

they require.  
When possible use refillable bottles or dishes instead of individually wrapped single-use packages for condiments. These dishes are refilled from bulk 
containers. This step reduces both food and packaging waste.  
Where you need to use single0use condiments packages avoid putting these items in one central location. This usually case in takeaways and restaurants. 
Customers will offer take more than they actually need, with eh unopened packages being thrown out with any leftovers and napkins. Place condiments in 
each table 
Obtain feedback from guests on their preferences for portion size and meal types 

226 

 
feedback 
Doggy bags 
Excess food for 
staff 
Prevention – food storage and post cooking  
Hot food cooling 

Routines for doggy bags are important as part of the efforts to reduce food waste today. Food brought home is not regarded as an avoidable food waste 
Internal routines for eating not sold food internally (by staff) can be another way to reduce avoidable food waste 

Food should be cooled in a cold room or preferably in a blast chiller where available. Food should not be cooled at room temperature.  
All hot food should be chilled and placed in the refrigerator within 90 minutes of cooling commencing to prevent microbial growth 

Prevention – reuse 
Turn leftovers 
into turnover 

Donate 

Plan menus that use leftover food or food that is approaching its use-by-date. Consider promotional offers to encourage customers to buy this dish. 
Examples includes:  
- vegetable and meat offcuts for soup stock, garnishes and pates 
- excess bread and toast for bread crumbs and croutons 
- main course meats in salads 
Donate food what will not be used before its use-by-date to local charities. Ensure that all food to be donate is carefully managed in line with HACCP and 
food hygiene regulations 

Apart  from  the  mentioned  list  of  measures,  some  communicative  instruments  have  been  considered  to  involve  other  interested  parties  in  the  commitment  of  reducing  or 
preventing food waste. Some examples are:  

-  Management  reporting  systems:  most  companies  report  on  avoidable  food  waste  as  part  of  the  cost  control  and  their  management  reporting  systems.  Within  the 
hospitality  sector  advanced  systems  follow  up  the  cost  of  goods  per  serving.  Each  canteen,  restaurant  and  hotel  are  measured  on  these  hey  figures  (besides 
productivity and quality) and do benchmarking with other units in the chains/industry in order to be more efficient. This management reporting systems seems to be a 
common and efficient tool in order to prevent avoidable food waste within the hospitality sector. Education of the staff is an important part of the work today reducing 
the avoidable food waste. a 

-  Production  optimization  and  logistics  including  the  structure  of  the  kitchens  (eg  central  vs  local  kitchens)  is  also  an  aspect  to  be  considered.  the  structure  of  the 
production might have an influence also on the avoidable food waste along the value chain. Dependent on strategy waste generation can be moved upwards to the 
food producer (the central kitchen) or downwards to the local kitchen or even to the guest being served at home.  
Internal communication and dialogue with the guests: in order to develop and implement the communication with the guests is important. Netter dialogue with guests 
can be regarded as a food basis for right portions. For example, a buffet normally generates an avoidable food waste of 1kg/guest. Information to the guests about the 
avoidable food waste issue can help to reduce it 

- 

Environmental and economic benefits due to the food waste prevention  

The food waste reduction has a direct effect on the purchase cost of the food (considered as an internal cost). Additionally other external costs can be identified that impact the 
environment and the society, but not the cost of the products. The variety of costs are presented in Table 51 

227 

 
 
Table 51. Costs due to the food waste generation 
Type 
Internal 

Catering service costs 
Facilities amortization 
Equipment amortization 
Furniture and food ware 
Utilities (electricity and 
water) 
Purchases of food and drink 
products and other purchases 
Stock 

Labour costs 

Marketing 
Insurances 

External 

Financial costs 
Taxes and fees 
Societal costs 
Environmental costs 

Description / comments 
An increase in the costs of amortization caused by the need for larger storage space to accumulate food, more pieces of furniture 
to show the available food and more equipment and machinery to process the  purchased food. 
Higher costs to purchase extra food ware such as trays, casserole and other instruments to prepare, preserve and serve food.  
Higher energy expenses by the increase of the installed power in the machinery/equipment and the warehouse space 
Higher water consumption to process the extra  purchased food and clean the instruments to prepare it 
Higher bills on food and drink products and consumables products associated to the food and drink products 

Higher value of the stock and higher costs of the stock management 
An increase in the likelihood of spoiling more food during the storage phase. Any incident in the warehouse, in the cold rooms or in 
the freezer implies more food wasted by incidence. 
Higher costs due to the time spent in processing the food that finally is not served or the post-consumer food waste and more time 
to manage the waste 
Potential extra losses due to the misdistribution in the space between the warehouses and the serving areas 
Higher  insurance  fees  to  have  higher  amounts  of  food  covered  and  higher  insurances  fees  related  to  the  larger  areas  and  the 
higher cost of the equipment 
Loss of financial incomes due to higher amounts of stored food or getting spoiled. 
higher taxes or fees due to the higher food waste generation  

The most important costs for catering services are the labour cost and the purchase of food and drink products and associated products, which accounts for 25-33% of the total 
costs depending on the service provided. The amortization of the facilities, equipment, furniture and other costs related to the taxes and fees, insurances, utilities and so on are 
not  as  important  as  the  two  previous  ones.  The  estimation  of  the  food  waste  per  kg  generated  is  relatively  easy  if  only  the  internal  costs  are  considered.  According  to 
(Universidad de Barcelona, 2013), a catering service needs around 1200g of food to be able to serve 800g. The difference is broken down into food waste (approx. 84 gr) and 
other unavoidable losses due to the preparation process, cooking and stock. Therefore, the authors estimated that a caterer that provides approximately 120 serves, wastes 
approximately 10kg or 31euros per day (this means approximately 3000kg or 9200euros annually). 

Apart from the food and drink purchase, there are other costs as depicted in the second column in Table 51. The quantity and importance of each of the costs depends on the 
policy and the type of service that the caterer wants to follow. If the caterer followed a policy oriented to the total and immediate satisfaction of the customer, the restaurant 
will have a tendency to over buying, to increase the security margins of the stock, to overcooking and to serve larger quantities per portion and with large variety. This strategic 
decision implies that eh quantities of food products treated will be higher and consequently the associated costs. The associated direct and indirect costs are included in the 

228 

 
 
 
 
Table 52 The only benefit from the economic point of view is that it triggers a lower price per food product unit thanks to a better position in the negations with the suppliers 
due to the scale economy.  

Table 52 includes an example of the costs associated to a catering service published in the Universidad de Barcelona 2013. The first part depicts the value and percentage of 
the  costs  a  catering service  incur  and  the  second  part  provides  an  overview  of  the  possible saving  that  the  catering service  can  get  if  a  food  waste  prevention  aptitude  is 
adopted.  

Table 52. Breakdown of the costs per serving of a catering service (example) 
Costs 
direct 

3.66 euro 

33.2 % 

Value 

Indirect 

7.36 euro 

66.8 % 

Served raw material 
Security margin 
Labour 
Utilities 
Amortizations 
Purchases 
Marketing  
Insurance 
Taxes 
Financial costs 

3.18 euro 
0.48 euro 
6.39 euro 
0.12 euro 
0.60 euro 
0.13 euro 
0.03 euro 
0.04 euro 
0.04 euro 
0.02 euro 

Percentage 
28.9 % 
4.3 % 
58.0 % 
1.1 % 
5.5 % 
1.2 % 
0.3 % 
0.4 % 
0.3 % 
0.2 % 

If the catering service is generating more than 3000kg of food waste, even if the purchase price of the  food products are around 33% of the total, a prevention policy will 
trigger a reduction of the direct and indirect costs as shown in Table 53 

Total 

11.02 euro 

100 % 

Table 53. Possible savings if a food waste prevention policy is applied 
Without food waste prevention policy  With a food waste prevention policy 
Kg waste 
3014 

Kg waste 
2162 

Euro/kg 
3.06 
6.15 
9.21 

Total euro 
9223 
18548 
27771 

Euro/kg 
3.06 
7.83 
10.90 

Costs 

Direct 
Indirect 
Total  

If the external costs, those that are not easily accounted but that represent the damage to the society and the environment, are considered, the total amount depicted in table xx 
will be likely higher.  

From the social point of view, the food that is going to be wasted could be donated to collectives that cannot afford buying it. To do so, it is needed that the food is preserved 
from the preparation steps.  (Universidad de Barcelona 2013) estimated the costs associated with the management of the food donation. This cost was calculated based on the 

229 

 
 
costs incur by charitable organizations. They reported that the food waste due to the societal aspects could be considered as 0.13euro/kg or 0.30euro/kg. the first one is reported 
when the food is provided directly by the companies and the second one when the food provides from an European programme.  

From the environmental point of view, the food waste triggers also additional costs. This cost could be estimated based on the emissions to the air and water that are produced 
when preparing, storing, serving and finally managing the waste of 1 kg of food. The study reports that as an average 1.98 t CO2 equivalent is produced per ton of food. If an 
average  ETS  price  of  13.9euro  /  tCO2eq  is  considered,  the  food  waste  generation  of  3000  kg  will  generate  an  extra  environmental  cost  of  approx.  83  euro/year  (the  extra 
environmental cost per kg will be 0.03euro).  

Table 54 shows the total costs of the food waste generation according to the example showed in Table 52 and Table 51. The figures of the example indicate the importance of 
the food waste. The cost of food waste (as raw material) is lower than half of the indirect costs and does not reach one third of the total processing costs.  

Table 54. Total estimated cost of food waste generation 

Internal 

External 

Total 

Direct 
Indirect 
Societal 
Environmental 

3.06 euro 
6.15 euro 
0.13 euro 
0.03 euro 

9.21 euro 

0.16 euro 

9.37euro 

Better understanding and use of date marking on food, i.e. "use by" and "best before" dates, can prevent and reduce food waste in the EU. 
It is estimated that a considerable share of household food waste (15-33%, depending on the studies) could be linked to date marking due, amongst others, to consumer 
misunderstanding of the meaning of these dates. The approaches and practices adopted by the food business operators and regulatory authorities in the supply chain can also 
have impact on food waste, for example: 

-  use in addition of "sell by" dates in-store; 
- 
-  different national rules and practices regarding marketing and redistribution of foods past the "best before" date, etc. 

shelf life requirements requested by retailers on delivery; 

The Commission is considering possible options to simplify date marking on foodstuffs: 

 

Extending  the  list  of  foods  which  are  exempt  from  the  obligation  to  include  a  "best  before"  date  in  food  labelling  (as  specified  in  Annex  X  of  Regulation  (EU)  No 
1169/2011). Today these include foods such as vinegar, sugar or salt. In the future, other non-perishable foods for which removal of date marking would not pose a 
safety concern could be also included in the list. 

  Modification  of  the  terminology  used  for  "best  before"  labelling,  especially  if  there  is  evidence  that  alternate  wording  is  better  understood  and  more  useful  to 

consumers. 

The Commission is currently exploring these options with both public authorities in EU Member States and actors in the food supply chain and consumers. If any changes are 
proposed in the future, it is critical that these: 

  meet consumer information needs, 
 
 

can contribute to food waste reduction, 
do not put consumer safety at risk. 

230 

 
 
 
 
In order to help inform its work on date marking, the Commission has launched a new study to map how date marking is used in the market by food business operators and 
control authorities. Findings from this research, expected by end 2017, will support future policy making in relation to date marking and food waste prevention. 

 

Terms of Reference: Market study on date marking and other information provided on food labels and food waste prevention (SANTE/2016/E1/024) 

Best environmental management practices (BEMP 2013) 

The BEMP recommends procedures for waste management and/or separating organic waste from general waste to avoid it going to landfill. The benchmarks of excellence for 
organic waste management are stated below: 

“≥95 % of organic waste separated and diverted from landfill, and, where possible, sent for anaerobic digestion or alternative energy recovery. 

- 
-  Total organic waste generation ≤ 0.25 kg per cover.  
-  Avoidable waste generation ≤ 0.18 kg per cover”. 

These benchmarks are indicative for the companies registered in EMAS and help to design and deploy actions within their environmental management systems that lead to 
measurable improvements. As mentioned above, (see section 3.2.8). 

Food donation 

The comparative study carried out in 2014 by Deloitte (Deloitte 2014) provides the main findings and issues that the Member States under study faced when increasing the rate 
of food donation.  

The general food law applies to all food and organizations placing food on the market, including non-profit organizations such as food banks. According to the law, food business 
operators are responsible for the safety of foods at all stages of the food chain and must ensure that the requirements of the General Food Law are met within their area of 
responsibility. This legal framework does not seen to incentivise food surplus donation in the selected Member States, as food donors are wary of jeopardising brand image and 
facing fines in the unfortunate case of food poisoning.  

France and Italy are the only EU Member states which have put in place a Good Samaritan Law which recognises food banks themselves as the final link in the food chain and 
prevents individuals receiving food from food banks being able to lawsuit against the food donor.  

A lack of knowledge and misinterpretation of the EU Hygiene Package is another issue that prevents food donation in EU. For example, Poland seems to have transposed in a 
more rigid way the EU directive and in Portugal until some years ago the prepared food or meals were disposed of due to the consensual misunderstanding that according to the 
available EU legislation, it is forbidden to recover such as food.  

In terms of food durability and labelling, the study shows that although the donation of products past their "best before"" date is allowed under EU law. Greece, Hungary, Spain 
and Sweden have introduced national provisions that present barriers to donating food which has passed its best before date. One of the main causes is that food donors are 
not willing to take the risk of liability for the donated foods, or fear a reduction in quality after this date impacting their brand image.  

Another barrier is the tax on the donated food. The Council Directive 2006/112/EC clarifies that food donors are taxable and that "the taxable amount is the purchase price at the 
moment of the donation adjusted to the state of those goods at the time when the donation takes place (article 74)". Even if the European commission recommends setting "fairly 

231 

 
 
low or even close to zero" the value of foodstuffs close to their best before date or which cannot be sold due to their external appearance. Most of the Member States do not 
imposed VAT when food is donated to food banks and charities, is certain conditions are fulfilled. One reason might be that they interpret VAT Directive such that the value of 
the donated food nearing expiry is small or zero, as their own national tax legislation "abandoning the imposition of VAT on food donation: Greece, Poland, Belgium and Germany.  

Finally the study demonstrates that fiscal incentives through tax credits and tax deductions encourage food donations. In France 60% and in Spain 35% of the value of donated 
food can be claimed as a corporate tax credit, meaning that food donors are able to deduct that percentage of the value of the donated food from the corporate tax on their 
revenue. In other Member States food donation can be treated as a deductible tax expense and can reduce the taxable income (the income basis used to calculate the income 
corporate tax), within certain limits and thresholds depending on the Member State. Portugal has in place an enhanced tax deduction, meaning that donors can deduct 140% of 
the value of the food at the time of donation, provided that the food will be used for social purpose and limited to a certain percentage of the turnover.  

There  is  no  EU  legislation  or  specific  guidance  on  how  to  apply  the  EU  waste  hierarchy  to  food.  National  approaches  are  found  in  some  countries  that  include:  prevention, 
redistribution to humans, feeding to animals, energy or nutrient recovery by methods such as anaerobic digestion (AD), composting and landfilling.  

The study concluded with some recommendations, among they are: 

-  Food use hierarchy: it is recommended that the EU publish guidance on a food use hierarchy that clearly prioritises feeding humans, through food waste prevention and 
donation to the charities of unsaleable foods, over waste management options such as composting, anaerobic digestion and landfilling. This hierarchy would be provide 
further clarification on the existing EU waste hierarchy in the context of food and send a clear signal to business and governments that economic incentives, investment 
in infrastructure, and communication activities should be prioritise food redistribution.  
there are a range of fiscal tools being used successfully in the EU to support food donation, including the abandonment of VAT liability and the use of corporate tax 
credits for donated food. VAT liability appears to have been "abandoned" in a number of Member Stes, although the use of the term VAT "exemption" is controversial an 
the compatibility of these policies with the EU VAT Directive is unclear 

- 

-  Good  Samaritan  legislation  as  it  exists  in  Italy  and  the  United  States,  limits  civil  and  criminal  liability  for  good  faith  donation  of  products,  known  to  be  fit  for 
consumption at the time of donation. In Italy, charitable organizations redistributing food are not considered food business operators, and thus the transaction between 
donor and charity carries the same liability conditions as retailer to consumer. In the United States, liability protection is extended to donors, gleaners, persons and non-
profit organisations distributing this food; liability being limited to acts of "gross negligence" or intentional misconduct.  

-  An extension of the list of products that could be exempted from the requirement for a best before date (annex X of the EU Regulation 1169/2011) is suggested, 
facilitating  both  donation  and  the  likelihood  of  final  consumption,  as  misunderstandings  around  the  importance  and  meaning  of  best  before  dates  persist  among 
consumers. The development of EU guidance is recommended for assessing additional lifetimes of products after their initial (producer indicated) date of minimum 
durability has passed 

232 

 
 
 
Waste sorting and disposal  
This section presents the comments received through BATIS and personal communications from the 1st AHWG meeting to the 2nd AHWG meeting.  

Table 55. Feedback from the stakeholders on the TR1.0: Waste sorting and disposal (TS6)) 
Topic 
Food 
donation 

Feedback from stakeholders 
We see food donation as a last resort. Much of the food waste from cantines is unsuitable for 
redistribution due to food safety and hygiene. For instance, food in the contract catering sector 
needs to be consumed within 24 hours of being prepared and unrefrigerated food that should be 
refrigerated  is  no  longer  deemed  suitable  for  consumption  after  a  certain  fixed  period.  Only  a 
limited amount of food that has not been offered to consumers can be donated (e.g. sandwiches 
that  are  fully  packaged).  In  addition,  it  is  the  procurer,  not  the  contract  caterer,  who  decides 
whether food is donated.    
Also,  food  donation  should  be  considered,  if  possible,  both  for  human  or  animal  purposes, 
prioritizing  human  ones,  as  food  Banks  or  social  entities/organizations,  instead  of  throwing  it 
away or dispose it.  
Post-consumer  food  waste  is  the  responsibility  of  the  procurer.  Contract  caterers  are  limited  in 
their  ability  to  reduce  post-consumer  food  waste.  Nonetheless,  when  procurers  wish  to  take 
action  in  this  area,  contract  caters  have  taken  initiatives  together  with  procurers  to  raise 
awareness  among  consumers,  to  encourage  consumers  and  to  discuss  with  the  server  what 
portion size they would like. 
This  is  also  a  key  criteria  and  should  be  compulsory  for  all  public  spaces  to  have  one  waste 
management  programme  in  which  it  was  included  its  separation  (paper,  glass,  plastic,  organic 
waste and (hazardous waste - in some cases), as minimum).  
Also, disposal and incineration, in except of hazardous products, should be looked as an ultimate 
alternative  according  to  the  EC  Circular  Economy  Package,  so  more  re-utilization  and  recycling 
strategies should be designed and implemented. 

Food waste 
from post-
consumer  

Waste 
management 
plan or 
programme 

JRC-Directorate B5 assessment 
Comment accepted 
Even if food donation could be a practice to decrease the 
food  waste  of  catering  services,  this  option  shows 
difficulties for verification.  
Additionally,  there  are  some  limitations  on  when  food 
donation can be carried out that makes even harder to set 
up this option as a criterion.  
Comment rejected  
See above 

Comment accepted 
Offering different size is considered as a possible measure 
to  better  match  the  consumers  demand,  in  this  way,  the 
consumers  decide  which  the  quantity  of  food  that  better 
matches their needs.  
Comment partially accepted 
The  criterion  aims  at  ensuring  a  proper  management  of 
the  residues  that  are  generated  at  all  the  stages  of 
catering, including the food preparation and serving.  
Therefore  the  minimum  requirements  for  sorting  out  the 
waste generated are included in the criterion even if it is 
not  explicitly  requested  to  include  a  waste  management 
programme  or  plan.  An  implementation  of  a  plan  or 
programme  under  the  framework  of  an  international 
standard  is  considered  a  step  forward  that,  even  if  it  is 
highly recommendable, it may be an extra burden for the 
SMEs.  

233 

 
 
 
 
 
Topic 

Feedback from stakeholders 

JRC-Directorate B5 assessment 
In most of the cases the hierarchy of the waste treatment 
is not a decision to be made by the procurer or tender, but 
it depends on the local or national authorities. 

Space 
limitation 

Including a food waste minimisation plan is a useful first step, but it would be useful to provide 
more practical information and suggestions on what this should include and how to manage it. 
While reducing post-consumer food waste is also very important, this should not be addressed in 
GPP criteria for contract caterers since post-consumer food waste belongs to the client. 
The focus should be on prevention. Contract caterers are actively working to prevent food waste in 
the kitchen through data recording, awareness raising and changing food preparation techniques. 
But preventing food waste in cantines often requires collaboration with the procurer. For instance, 
when a procurer requires the full range of menu options to be available from the start to the end of 
the service, there is more food waste than when the caterer can provide limited options at the 
beginning and end of the service.   
For now we ask the supplier to show us a plan for waste sorting and disposal. Answers to the 
consultation questions to stakeholders:  
- Do you agree on the modifications proposed for this criterion?  Yes  
- Are you aware of any limitation to implement and verify this criterion? No 
On  the  sentence  "must  be  sorted  into  the  correct  waste  stream  categories  wherever  the  client 
provides  the  means  (e.g.  waste  containers  for  distinct  solid  streams)  for  the  sorting  of  different 
solid waste" Sorting on site should only be required where space allows for such separation. 
We suggest "must be sorted into the correct waste stream categories wherever the client provides 
the means and where space allows for such separation..."  
On the sentence "When facilities for the collection and recycling of bio-waste are available". See 
suggestion to align this with previous comment" add "...and when space allows..." 
On  the  sentence  "Waste  generated  at  the  sites  where  the  catering  service  is  provided  must  be 
sorted into the correct waste stream categories wherever the client provides the means (e.g. waste 
containers for distinct solid streams) for the sorting of different solid waste."  
Sorting  into  waste  stream  categories  (including  packaging)  only  makes  sense  if  the  waste 
streams for separate collection and recycling are available. 
Suggestion  to  state "....wherever  the  client  provides  the  means  (e.g.  waste  containers  for  distinct 
solid  streams)  for  the  sorting of  different  solid waste  and  when  waste  streams  for  the  separate 
collection and recycling of that waste is available. 
The text should specify that the obligation to sort and report bio-waste only pertains to kitchen  See above 

Acknowledged 

Commented accepted 
The prevention of food waste is considered in this set of 
criteria through the menu planning criterion and the newly 
developed criterion on food waste.   

Comment rejected 
The verification of the availability of space in the kitchen 
and  catering  services  is  difficult  to  assess  and  not  the 
objective of this criterion.  
There  are  multiple  designs  of  the  kitchens  and  disposal 
bins that make difficult to judge if the room is enough.  

Comment accepted 
The wording has been modified accordingly 

234 

 
 
 
 
 
 
 
 
 
Topic 

General 
comment 

Feedback from stakeholders 
waste where space allows for separation. 

I  agree  with  the  modification.  Since  there  are  different  schemes  of  waste  segregation  (e.g.  in 
Germany  differing  on  community  by  community)  these  legal  schemes  should  be  taken  into 
account.  When  sorting  is  done  by  the  community  waste  disposal  agency  sorting  within  the 
catering firm does not make sense and should not lead to a negative evaluation.  
The EEB welcomes the proposed criteria set on waste sorting and disposal.  
Food  Waste  avoidance  should  be  seen  as  a  positive  impact  of  food  packaging  in  the  analysis 
made in the Technical report 

Others 

From my opinion this holds not true: the food waste emerging by cleaning of fresh foodstuff (e.g. 
potatoes, salad) in C&C kitchens usually is outsourced to packing companies, but occurs to the 
same  amount  as  in  a  (smaller)  Cook  Warm  kitchen  processing  fresh  from  field  products 
themselves. 

JRC-Directorate B5 assessment 

Comment accepted 
The note that the sorting out of the waste should only be 
required  when  and  where  there  is  a  separate  municipal 
collection system in place has been included.  
Acknowledged 
Acknowledged 
The  relation  between  packaging  and  food  waste  was 
discussed in the rationale of the Packaging criterion. it will 
also  be  included  in  the  rationale  of  the  Food  waste 
criterion 
Acknowledged 

Further analysis on Waste sorting and disposal 

Once the waste is generated, it should be properly managed to avoid further economic and environmental impacts on the catering service business. Due to the biodegradability 
characteristics of the food waste, it is expected to cause high amount of CO2 if landfilled.  

The management of the waste sorting and disposal depends on several factors that will be described in this section.  

EU legislation  

Catering services are covered by mainly two EU legislation regarding the waste sorting and disposal:  

a) The EU Landfill Directive (1999/31/EC) 

The EU landfill Directive 1999/31/EC highlights the waste management hierarchy to be implemented across Europe in most of the sectors. The catering service sector falls then 
under this directive. Accordingly, the two first measures to be implemented are the elimination and reduction of the waste generated. These measures are commented in more 
detail in the previous section. Subsequently, the directive suggests the reuse of the waste generated. Regarding the food waste, the reuse of food includes the reuse of unused 
food in meals; donate unused food/meals to local charities or homeless hostels (although there are legal barriers in some member states that do not allow to implement this 
measure). If the catering service separately collects the food waste these measures could be easily implemented. The four measure highlighted is  recycling. Compost, either 

235 

 
 
 
 
onsite  or  off site,  convert  food  waste  into  fuel by  anaerobic  digestion  or  other  processes  are  examples  of  waste management  covered by  recycling.  The  final  option  is the 
treatment or landfill disposal. There are already countries where national legislation bans the landfilling of commercial food waste, therefore it is no longer and alternative and it 
is practice that should be whenever possible avoided.  

The EU Landfill Directive requires all member states to reduce the quantity of biodegradable municipal waste disposed in landfills. The EU Landfill Directive 1999/31/EC outlines 
measures to prevent or reduce the negative effects of landfills on the environment. The main aspects of the Directive which will have a significant effect on the management of 
catering food waste is the mandatory, staged reduction in the amount of biodegradable waste that is allowed to be landfilled. By July 2010 only 75% of the total quantity (by 
weight) of biodegradable waste, which was generated in 1995 could be landfilled. This was further reduced to 50% by 2013 and 35% by 2016.  

The EU Landfill Directive implementation could trigger different needs depending on the type of business. On a phased basis, specified premises will not be allowed to dispose of 
food waste to landfill. Instead:  

-  all food waste arising on the premises will need to be segregated and kept separate from other waste and contaminants. This means that all food waste should be 
separated from the general waste and stored in dedicated containers. This separation prevents other waste streams being contaminated, making it easier to recycle all 
streams (cardboard, plastics, food waste, etc) 

-  such segregate food waste will have to be treated in an authorised treatment process either:  

-  on-site or 
- 
-  brought by the producer to an authorised facility.  

collected by an authorised collector or  

Where the local authority has already implemented separate food waste collection there is no change, of all other areas the requirements are being implemented on a phased 
basis:  

- 
- 

for specified premises from July 2010, except 
for  specified  premises  where food  waste  produced  is  less  than  50kg  per  week, from  July  2011 but  only  if  a  written declaration  to  this  effect is  sent  to  the  local 
authority before July 2010 

Where a separate food waste collection service is available to producers of food waste, and without prejudice to the conditions of a discharge licence or a waste collection 
permit, such producers must 

-  not put food waste in the residual waste collection 
-  not use macerators to send food waste to sewer.  

Specified premises include  

-  premises that supply hot food for eating on or off the premises, including where this is just a subsidiary activity 
-  pubs where food is supplied 
-  premises where food is supplied to employees 
-  hotels, guest houses, and hostels with > 4 guest bedrooms 
-  shops or supermarkets selling food, including sandwiches or hot food, including where this is just a subsidiary activity 

236 

 
restaurant, cafes, bistros, wine bars, etc where food is prepared on the premises 

- 
-  hospitals, nursing homes, etc where food is prepared on the premises 
-  schools, colleges, higher level institutions, training centres, etc where food is prepared on the premises  
-  state buildings where food is prepared on the premises, including prisons, barracks, government department, local authorities, etc 
- 

-stations, airports, ports, harbours and marines where food waste is unloaded 

In addition, organizers of trade shows, exhibitions and events where food is supplied must prepare plans before and reports after the event, on the provisions made to meet 
these Regulations.  

This means that the most of the caterers are obliged to segregate the food waste and either to treat it by themselves or to ensure that a manager will take good care of it. This 
requirement indicates that the waste sorting and disposal criterion is of high importance and therefore most national or local authorities have implemented a collection system 
that allows the caterers to dispose the different waste streams.  

In regions with separate collection of food waste, the solution are often more expensive than the residual waste solutions. Organizations without a clear policy to sort the kitchen 
waste are thus tempted to leave the kitchen waste with the residual waste for incineration. Incentives for sorting are often  missing and to fill in this gap is the idea of this 
criterion. In those regions with a separate collection of food waste, once separated from other waste streams a waste disposal company will collect catering food waste, and 
treat it in an appropriate manner e.g. compost or anaerobic digestion treatment. Charges are usually based on combination of pick up and disposal or treatment charges  

The cost for separate collection vary according to Member States differences and treatment differences, but are comparable to the treatment costs of mixed waste according to 
a 2007 UK study (see Error! Reference source not found.). This fact points out that waste separation is a cost-effective measure:  

Table 56 Estimated costs associated with the implementation of waste collection or alternatives end-of-life ways. 

Costs of implementing separate food waste collection 
Cost of separate collection followed by composting 
Cost of separate collection of bio-waste followed by anaerobic digestion 
Compared with landfill and incineration 
Cost of landfill of mixed waste 
Cost of incineration of mixed waste 

35-75 euro2006/tonne 
80-125 euro2006/tonne 

55 euro2006/tonne 
90 euro2006/tonne 

b) The Animal by Product Regulation (EC) No 1069/2009 

Over the years the management of catering food waste has changed. Some years ago, most facilities separated their waste and recycled it by sending it to the local swill man 
for feed and farmed animal e.g. pigs. However, as a result of the food and mouth crisis the practice of the feeding of swill to farmed animals (cattle, sheep, pigs, goats, deer, 
poultry or other biungulates) has been banned. Swill includes any broken or waste foodstuff (including table, catering or kitchen refuse, scraps or waste). 

The 2002 EU Animal By-Products Regulation set out how different categories of animal's by-products (ABP) can be disposed. Under the ABP Regulation the majority of catering 
waste (including cooked food, eggs shells, processed foods, etc.) is a lower risk material, classed as Category 3 and can be disposed of the in biogas or composting plants. This 
provision remains regardless the 2009 amendment of this regulation. 

237 

 
 
c) Communication on circular economy COM (2015) 614 

At the light of this communication, a platform on food losses and food waste was built up. The platform aids the Commission in identify and prioritising actions to be taken at 
EU level in order to prevent food losses and food waste and supports all actors in identifying and implementing appropriate actions to take at national, regional and local levels. 
The platform makes easier sharing of information, learning and best practice related to food waste prevention and food waste management. The platform's work covers such 
areas as:  

- 

implementation  and  application  of  the  EU  legislation  related  to  waste,  food  and  feed  to  ensure  the  highest  value  use  of  food  resources  (in  line  with  a  food  use 
hierarchy) 

-  optimization of use of former foodstuffs and by-products form the food chain in feed production 
-  promoting better use and understanding of the date marking 
-  awareness, information and education campaigns 

One of the main points worked by this platform is on food donation. This platform carried out a study aimed to provide an overview of current legislative or practical barriers to 
food donation; and establish best practices and recommendations. Outcomes of the study point to the need for clarification on how to implement a 'food use' hierarchy that 
clearly prioritises redistribution of surplus food for human consumption, role of fiscal measures in encouraging food donation; how to comply with food safety / food hygiene 
rules; implications of liability legislation for food donation and date marking rules in relation to food donation.  

Among the barriers that prevent the food donation identified by the study and the subsequent meeting are the storage and logistic issues, including the need to maintain the 
cold  chain  during  the  transport  and  throughout the supply  chain,  could be hurdles  to  food  distribution.  The  platform  recognized  the  work  of  some  member  states  that  had 
developed guidance for the catering sector such as France, Spain or Germany but highlighted that specific guidelines for food donation at EU level are still needed. The EU 
guidelines on food donation could provide direction on issues subject to different interpretations by the member states authorities; for instead, clarifying that EU legislation does 
not restrict placing on the market of foods past the 'best before' date provided that these are safe and that their presentation is not misleading.  

This EU guideline could also outline the principles of the food use hierarchy, recommending the highest value use of surplus food which should preferably be utilised for human 
consumption, followed by possible use in animal feed prior to possible utilization for energy/nutrient recovery.  

One of the main troubles to be solved is the concern regarding the issue of liability and transfer of responsibility between actors in the food chain, including food banks as well 
as the fiscal rules which apply for food donation (eg VAT) and the role of fiscal incentives in this regard.  

Fats, oils and grease (FOG) 

Large  quantities  of  cooking  fats,  oils  and  grease  are  used  for  a  number  of  processes  in  the  catering  business  including  deep  frying,  mustow  frying,  stir-frying,  and  griddle 
cooking, roasting or in dressing and sources. This food category when becoming food waste should be handled very carefully as it can cause important environmental impacts. 
Fats, oils and grease share common physical properties and produce similar environmental effects. They can 

cause devastating physical effects, such as coating animals and plants with oil and suffocating them by oxygen depletion 

- 
-  be toxic and form toxic products 
-  produce rancid odors 
- 

foul shorelines, clog water treatment plants and catch fire when ignition sources are present and  

238 

 
- 

form products that linger in the environment for many years.  

Scientific research and experience with actual spills have shown that spills of animal fats and vegetable oils kill or injure wildlife and produce other undesirable effects. Wildlife 
that becomes coated with animal fats or vegetable oils could die of hypothermia, dehydration and diarrhea, or starvation. Aquatic life may suffocate because of the depletion of 
oxygen caused by spilled animal fats and vegetable oils in water. Spills of animal fats and vegetable oils have the same or similar devastating impacts on the aquatic 
environment as petroleum oils. 

Therefore the disposal of food waste and oil down drains either in solid form (from washing) or from the use of macerators should be avoided as this only transfers the waste 
from landfill to the local wastewater treatment plant (WWT). Waste food, particularly FOG can cause significant blockages as they coat, congeal and accumulate on pipes. These 
blockages can be in the pipes in the caterer's premises and later downstream in the main sewer pipes. The costs of clean these pipes can be quite expensive with one local 
authority spending roughly 40000euro/year to clean the sewer network at only one pumping station. For this reason food waste and FOG should be prevented from entering into 
the sewer. A number of steps can be taken to minimise the quantity of FOG entering the sewers, including the installation of grease traps.  

Some of those measures are:  

-  Never put oil or food directly down the drain: collect and scrape all FOGs from ware, cooking equipment and storage containers (eg tuna oils). This FOG should be put 
into a suitable container for recycling. This is essential when washing cooking equipment as UK studies have shown that in fast food restaurants 93% of the oil and 
grease discharged to the WWT is generated from ware washing. For full service restaurants 75% of the oil and grease discharged to the WWT is generated from the 
pot sink 

-  Make sure all kitchen staff are trained how to use and dispose of FOG correctly: trainning the staff to put food in waste food containers. Explain the staff how failure to 
do so can block drains and grease traps leading to expensive cleaning costs. Reminders placed near relevant bins and sinks and on the staff noticeboards can help.  

-  Make sure all sinks have as trainer in the plug hole: this prevents solids going straight down the drain 
-  Never house materials down the drain when cleaning large areas: when cleaning floor areas  don’t hose food and dirt into the drain, even if cleaned out afterwards. 

Always use a dry clean system first 

-  A dry clean-up system: this should be used for the first clean of the area and prior to washing of equipment. Dry cleaning methods not only reduce the quantity of food 

waste entering the drain but also reduce the quantity of costly cleaning materials and water. Dry clean-up methods include:  

o  Scrape as much of the leftovers on the dish into a food waste container fro recovery or disposal 
o  Use rubber scrapers and squeegees and paper towels to remove FOGs from cookware, utensils, oven dishes and serving ware 
o  Use food grade paper to soak up oil and grease under fryer baskets 
o  Use brooms or vacuum to sweep up spills of dry ingredients 
o  Use  paper  towels  to  wipe  down  work  areas  and  clean  spills.  Cloth  towels  will  accumulate  grease  that  will  eventually  end  up  in  your  drains  from  towel 

washing/rinsing.  

The correct treatment of FOG is therefore considered in the drafting of this criterion.  

239 

 
 
 
 
 
Chemical products and consumable goods (BEFORE: consumable goods) 

This section presents the comments received through BATIS and personal communications from the 1st AHWG meeting to the 2nd AHWG meeting.  

JRC-Directorate B5 assessment 

Acknowledged 

 Acknowledged 

Comment rejected 
A lack of information about the importance from 
an  environmental  point  of  view  of  the  staff 
uniforms and their cleaning process is the main 
reason for not including this aspect in the scope 
of this GPP revision.  

Table 57. Feedback from the stakeholders on the TR1.0: Consumable goods (AC8) 
Topic 
Scope 
of 
the criterion 

Feedback from stakeholders 
On  the  question  "Are  the  proposed  consumable  goods  providing  a  good  coverage  of  the  consumables  being 
used within the catering services provision?" Yes. 
On  the  question  "Are  the  proposed  consumable  goods  providing  a  good  coverage  of  the  consumables  being 
used within the catering services provision?"  
Apart  from  trying  that  consumable  good  (e.g.  cleaning  products,  paper  products  and  bulbs)  are  safe  and 
environmentally-friendly; other goods should be considered, such as energy or water. 
Man-made bio-based fibres should be considered as sustainable option  
This criterion should include staff uniforms and reusable textiles for table cloths from man-made bio-based 
fibres. 
Points will be awarded to tenders that use at least 20% of staff uniforms and table cloths from man-made 
bio-based textiles.  
Energy and water uses in meals preparations are an environmental hotspot, also due to cleaning of staff 
uniforms and table cloths.  Use of man-made bio-based fibers in stuff uniforms and table cloths means 
fewer washings, resulting in savings on water and energy. Textiles for stuff uniforms can be made from many 
materials. These materials come from following main sources: animal (wool, silk), plant (cotton, flax, jute) and 
synthetic (nylon, polyester, acrylic). Additionally, man-made cellulose fibres are increasingly used. Cotton, the 
most common natural cellulose fibre, has several environmental downsides; high water requirements being 
just one of them (WWF 2015). However, there is a lack of other viable plant-based textile alternatives, 
particularly since hemp and soya currently constitute only a very small proportion of the world fibre supply. 
Therefore, dissolved-pulp fibres – both innovative and traditional – offer the greatest potential for a 
sustainable clothing material in sufficient abundance to meet growing global demand (FAO 2014). Man-made 
bio-based fibres comprised 11% of the total 55 million tons of man-made fibres produced worldwide in 2013 
(Aeschelmann et al. 2015). Bio-based fibres include both natural cellulose fibres and manufactured cellulose 
fibres. Natural cellulose fibres are fibres that are still recognizable as being from a part of the original plant 
because they are only processed as much as needed to clean the fibres for use like hemp or cotton. 
Manufactured cellulose fibres come from plants that are processed into a pulp and then extruded in the same 
ways that synthetic fibres like polyester or nylon are made. Wood-derived "manufactured" cellulose fibres 
such as viscose (also known as viscose rayon or rayon), but also the newer and more innovative versions 

240 

 
 
 
Modal® and Lyocell or Tencel®, occupy the third place in the overall fibre market, after synthetics and cotton 
and ahead of wool (FAO 2014). As of today, the vast lion’s share is held by viscose.  Lyocell, or Tencel®, is 
made in a closed-loop process using less toxic chemicals than are used in conventional viscose production. 
Like conventional viscose, it can be made from any form of cellulose including eucalyptus and bamboo. What 
makes it more environmentally-friendly is simply that it is made from biomass but also that the production 
process is less pollutant (e.g. amino acid compound recovery; water recovery). Clothing made of the 
innovative man-made fibre e.g. Lyocell remains odour-free through multiple wearing, and for much longer 
than cotton. This means fewer washings, resulting in savings on water and energy, along with less tearing 
occurring on any fabric during the cleaning and drying processes (Mass 2015). Synthetics, on the other hand, 
have hundreds to thousands of times higher bacteria count over the same usage time period than, for 
example, Lyocell®. Lyocell’s® anti-bacterial property is inherent to the fibre without the need for chemical 
additives such as those used on synthetics or on many cotton products. Additionally, no micro-plastics are 
created as a result of washing. Comparing the global warming potential (GWP) of different fibres figure  
shows: (a) it can be seen that from cradle to factory gate, 1) all man-made cellulose fibres have lower GWP 
than PET fibres; 2) all man-made cellulose fibres except for Lenzing Viscose Asia have lower GWP than PET, 
PP, PLA without wind and cotton; 3) Lenzing Modal and Tencel Austria 2012 have nearly zero carbon 
emissions; and 4) Lenzing Viscose Austria has a negative GWP, which means that it sequestrates more carbon 
in the product than it emits. (Shen & Patel, 2010)                                                                                                                                                                                                                                               
Compostable gloves and bin bags 
The end of life option play a role if the gloves or bin bags (composted according to EN 13432) as might be 
important for bio-waste disposal (BioPlastic Magazine 2015). The disposable gloves as well as the bin bags 
can be produced additional to virgin or recycled polymers of biodegradable bio-polymers. That lowers the 
environmental impact on the climate change compared to virgin fossil based alternatives of plastic and helps 
to solve the problem of disposal with food waste (FNR 2013). Disposable gloves used in cleaning and cooking 
are made of different polymers including latex, nitrile rubber, vinyl and neoprene; they are produced 
unpowered, or powdered with corn starch to lubricate the gloves. Due to the increasing rate of latex allergy 
among in the general population, gloves made of non-latex materials such as vinyl, nitrile rubber, or neoprene 
have become widely used in the market. Compostable disposable bio-based gloves offer alternative to the 
fossil based products.  

 Acknowledged 
The 
accordance with EN 13432 has been kept 

inclusion  of  compostable  material 

in 

241 

 
Ambition 
level 

In our tenders these are TS and not AC. 

Verification 

Please refer also to all available and relevant ISO Type 1 Ecolabels on the European market (not only the EU 
Ecolabel), e.g. Nordic Swan, Blue Angel, Austrian Ecolabel, ... 

Biodegrada
ble goods 

Disposable 
goods 

With regard to the core requirement “Points will be awarded to tenders that prove that a minimum of 50% of 
the  cutlery  units  is  certified  according  to  EN  13432,  EN  14995  or  equivalent  and  90%  biodegradability  in  6 
months has been demonstrated in a single or combined composting and/or anaerobic digestion process”, we can 
assume that this would create a mixed stream of biodegradable and non-biodegradable waste.  
In order to promote separate collection and treatment of biowaste, this situation should be avoided. Either the 
requirement is raised to 100% or it should be removed from the core criteria set.  
Furthermore,  the  EEB  would  like  to  establish  a  link  with  the  criteria  on  waste  sorting  and  disposal. 
Environmental  benefits  can  only  be  assumed  if  separate  collection  of  biowaste  actually  takes  place.  Why 
should biodegradability be rewarded if the disposable tableware is burned? In addition, only if biodegradable 
tableware  materials  (that  meet  the  above  mentioned  requirements)  do  not  disturb  or  deteriorate  the  local 
treatment process for biowaste (i.e. composting or anaerobic digestion), it would make sense to define it as 
an award criterion.  
The JRC should provide a disclaimer for the procurer to check this issue first with local waste authorities 
before defining it as a default option. It should be required a check with competent authorities if 
biodegradable tableware materials are compatible with local treatment processes for biowaste 
Like packaging, the use of reusable tableware needs to be aligned to available waste streams in line with the 
waste hierarchy and must allow flexibility for local markets. For instance, there is no benefit to using crockery 
instead of disposable cups if there is no way to wash the dishes.  
The  additional  environmental  impact  and  economic  cost  of  cleaning,  water  consumption  and  use  of  soap 
products must also be taken into account. A FoodServiceEurope member trialled the use of reusable tableware 
and found that it did not make environmental or economic sense. The additional environmental impact and 
economic cost of cleaning, water consumption and use of soap products should be further assessed before 
setting a GPP criteria for an action that may not be environmentally beneficial when cleaning, water use and 
water effluence are taken into account. 

Comment accepted 
The  attributed  environmental  impacts  that  this 
criterion  addresses  is  largely  dependent  on  the 
type  of  catering  service  offered.  However,  the 
use of chemical products is in all or most of the 
catering services and therefore it has been also 
proposed as TS.   
Comment accepted 
The wording has been modified accordingly 
 Comment accepted 
The  explanatory  notes  includes  the  clarification 
that  this  requirement  should only  be  included  if 
an appropriate collection system is in place.  

Comment accepted 
The  use  of  disposable  items  whenever  the 
tenderer demonstrates that it is more convenient 
from  an  environmental,  economic  or  feasible 
perspective.  

242 

 
Reusable 
and 
disposable 
goods    and 
biodegradab
ility-  
terminology 

to 

the 

first 

sentence: 

reusable  
Differentiate 
Directed 
Therefore  the  distinction  needs  to  be  between  reusable  and  disposable  products  were  one  option  (among 
others) 
13432. 
The  first  sentences  suggests  a  distinction  between  reusable  and  biodegradable  (see  comment  above) 
tableware on the one hand and disposable tableware on the other. This seems to be incorrect. Products which 
are compostable must be applied when reuse is not an option.   

products  which 

composted 

disposable 

according 

between 

and 

can 

use 

EN 

be 

to 

to 

is 

Comment accepted 
The terminology used has been modified 

Although reusable tableware is clearly prioritised within the award criteria, the environmental benefits of the 
proposed criteria for disposable tableware needs to be validated 
Regarding the use of the term ‘biodegradable’ (i.e. line 2) see comment 1  
Key environmental aspects and impacts: suggestion to add as example of consumables goods: gloves, packs)   Comment accepted 

 Acknowledged 

Acknowledged 

Cleaning 
products 

In  some  markets,  there  is  a  problem  with  the  availability  of  the  cleaning  products  that  are  being 
recommended.  Therefore,  the  criterion  related  to  cleaning  products  should  take  into  account  market 
availability. We suggest conducting a market analysis on the availability of cleaning products across the EU 
before setting a threshold. 
Probiotic cleaning methods could be used in the comprehensive criteria. 

Thresholds 

Paper products: aim higher for example we purchase 100% ecological toilet paper and paper handtowels. 

Cleaning products: all products can be 100% ecolabel or Nordic swan 
Cleaning products should be 100% ecolabel or Nordic swan as we have in our cleaning contracts. Answers to 
the consultation questions to stakeholders: 
- Are the proposed consumable goods providing a good coverage of the consumables being used within the 
catering services provision? · Yes 
- Are the proposed threshold % limits accessible to all service providers? · In my opinion it is no problem. 
Ambition  levels  here  are  seen  as  weak,  these  products  are  easily  available  on  the  market.  We  suggest: 
Handsoap – 100% environmentally friendly and Dishwasher detergents and other cleaning products  – core 
50%, comprehensive 100% environmentally friendly 

Examples have been included 
Comment accepted 
The wording has been modified accordingly 

Comment rejected 
The  use  of  microbial  cleaning  products  is  only 
advisable  in  certain  cases.  Anyway,  their  use  is 
not restricted by this criterion 

 Comment accepted 
The thresholds have been modified accordingly 

243 

 
 
 
  
  
  
  
Increase the thresholds for purchasing sustainable paper and cleaning products to 50% as core criterion and 
100%  as  comprehensive  criterion.  The  EEB  does  not  agree  with  the  proposed  thresholds  for  paper  and 
cleaning products that we consider being too low and not ambitious enough. It is quite easy to reach 100% 
sustainable  products  for  these  categories.  Therefore,  we  suggest  50%  as  core  criterion  and  100%  as 
comprehensive  criteria  for  both  product  groups.  Several  public  procurers  stated  that  they  do  not  have 
problems to get environmental-friendly consumable goods as paper articles and cleaning agents. 

Further analysis on Chemical products and consumable goods 

How to choose the right consumable good? 

There are several materials the consumable disposable goods are made of:  

-  plastic is the material to make most of the common disposable utensils. Almost all types of catering consumables: plates, cups, bowls and trays can be made of plastic. 
Depending  on  the  type  and  density  of the  plastic  used,  the  products  take  longer  or  shorter  to  break  down  in  a landfill  or  to  be  converted  in  compost  in  industrial 
facilities. This aspect has been considered for the requirement on biodegradability that is aligned to the requirement included in the packaging criterion 

-  paper is a popular choice for many stall holders for hot beverage cups. Paper is a renewable resource as long as the forestry it comes from is managed in a sustainable 

- 

way. Therefore the inclusion of a sustainable certification is required 
fibre/bagasse is the biomass that remains after the sugarcane stalks are crushed to extract their juice. It is annually renewable. Fibre comes from renewable plants such 
as seed and bamboo. Usually, these two raw materials  are combined to produce a pulp product. it is 100C water resistant and 150C oil resistant, microwable and 
refrigerator safe, as well as being biodegradable in a home compost in under 3 mouths 

-  potato  starch  is  also  used.  When  potatoes  are  washed  in  the  preparation  between  the  farm  and  dinner  plate,  starch  is  extracted  from  the  waste  water  after  the 
potatoes  have  been  sliced  or  cut  into  the  shapes  required.  These  products  are  biodegradable  within  approximately  4  weeks  in  a  home-compost  and  contain  no 
chemicals or bleaches. The average costs of a box of 25 servings trays was 6.5AU$ in 2009. 

-  wood  is  used  for  few  disposable  catering  supplies.  Wood  comes  from  trees,  most  often  virgin  trees,  but  they  are  a  renewable  resource,  talking  several  years  to 

biodegrade. The requirement in this sub-criterion focuses on the coverage by sustainable forestry management certification schemes.  

The comments on the ambition levels were split with market availability being cited as an issue in some Member States but other stakeholders stating that they lack ambition. 
Therefore, the recommended values have been increased by an exemption wherever a lack of availability is identified has been introduced.  

Cleaning products.  

The scientific evidence suggests that cleaning products do not represent a significant environmental burden within the food and catering service sector and is absent from most 
LCA studies that were reviewed. However, to ensure that the environmental burden from cleaning products is minimised it is proposed that the criterion for cleaning products be 
kept as an award criterion for catering services. Stakeholders' feedback required specificity on the criteria applicable to the cleaning products to be used within catering services. 
The current EU GPP criteria for indoor cleaning services can be used as a guideline and it includes floor cleaning, sanitary cleaning, glass/window cleaning and surface cleaning - 
with technical specification limits for hand soaps and cleaning products. 

244 

 
 
Energy and water consumption in kitchens (BEFORE: Equipment)  
This section presents the comments received through BATIS and personal communications from the 1st AHWG meeting to the 2nd AHWG meeting.  
Table 58. Feedback from the stakeholders on the TR1.0: Equipment (AC9) 
Topic 
GWP 
refrigerants 

of 

Feedback from stakeholders 
All  newly  procured  equipment  should  already  meet  the  full  F-gas  regulation  in  order  to  be  compatible  with  future 
technology  and  maintenance  services.  This  means  refrigerants  with  GWP  below  150  instead  of  2500.  The 
comprehensive criteria can be set at GWP below 5 and asking for natural refrigerants. CO2, R600a and R290 are the 
most commonly used green refrigerants and they are all natural and with GWP below 5.  
The F-gas regulation will ban refrigerants with GWP below 2500 in 2020, and already two years later, in 2022, those 
with GWP below 150. Therefore products using refrigerants with GWP of 150 or higher should be avoided starting today. 
They will be outdated soon. 
For plug-in refrigeration equipment the most commonly used green refrigerants are CO2, R600a and R290. They are all 
natural and with GWP below 5. Therefore this can be set as comprehensive criteria without problem 
Change text for core criteria to: "Points must be awarded to the equipment using refrigerants with a GWP below 150" 
Change text for comprehensive criteria to: "Points must be awarded to the equipment using natural refrigerants with a 
GWP below 5" 
We recommend introducing core criteria also for storage chest freezers and wine storage appliances. These two product 
categories are often used in food services and catering, and it is easy to recognise the best available technology models 
using the EU energy label for household refrigerating appliances. 
Stock in the EU: wine storage appliances 1.7 mio. units and growing; no estimates for storage chest freezers, but almost 
every small food service business has one. 
Savings: A+++ storage chest freezer compared to A+ (typical new model) = half the energy costs; 
A+  wine  storage  appliance (one  temperature  zone)  compared  to  G  (typical  new  model) =  70%  reduced  energy  costs; 
A wine  storage  appliance (multi  temperature  zones) compared  to  C  (typical new model) =  30%  reduced  energy  costs. 
Add the following core criteria under 1 Refrigeration: 
Points must be awarded to storage chest freezers and wine storage appliances with Energy efficiency index (EEI) as set 
in the following table: 
Storage chest freezers: EEI < 22, Min. energy efficiency class A+++ 
Wine storage appliances with one temperature zone: EEI < 42, Min. energy efficiency class A+ 
Wine storage appliances with multi temperature zones: EEI < 55, Min. energy efficiency class A 
Note:  The  Energy  efficiency  index  must  be  calculated  according  to  EU  regulation  1060/2010  (energy  labelling  of 
household refrigerating appliances). 

Scope  of  the 
for 
criteria 
professional 
refrigeration 

JRC-Directorate B5 assessment 
Comment accepted 
The  criterion  proposal  is  based  on 
the  work  done  by  TopTen  and 
ProCold,  therefore,  the  criterion  will 
be updated accordingly, 

Comment accepted 
The  criterion  proposal  is  based  on 
the  work  done  by  TopTen  and 
ProCold,  therefore,  the  criterion  will 
be updated accordingly, 

245 

 
 
Topic 
Energy 
classes 
requested  to 
professional 
refrigeration 
Energy 
classes 
proposed and 
ambition 
level 
Energy 
classes 
proposed and 
ambition 
level 

EMS: 
Monitoring 
energy  and 
water 
consumption 

Length 
contracts 

of 

Feedback from stakeholders 
Topten will update its criteria for 2 categories in July 2016 due to the market development of top-performing products 
and the coming-into-force of the EU energy label. We recommend to already update the core criteria accordingly. 
 New criteria: 
Storage refrigerators 1-door: EEI < 35, min. energy efficiency class B 
Storage freezers 1-door: EEI < 50, min. energy efficiency class C 
I agree with the thresholds.  
Even in case that there are increased costs there is also a return on investment for energy saving investments 
The US energy star should be withdrawn since there are enough energy ratings introduced in the EU. 

JRC-Directorate B5 assessment 
Comment accepted 
The  criterion  proposal  is  based  on 
the  work  done  by  TopTen  and 
ProCold,  therefore,  the  criterion  will 
be updated accordingly, 
Acknowledged 

In  general,  the  EEB  agrees  with  the  proposed  criteria  on  equipment,  but  we  recommend  checking  if  the  proposed 
ambition levels for these award criteria are too difficult to fulfil for catering services provided by Small and Medium 
Sized Enterprises (SMEs). 

The  aspects  of  energy-  and  water  consumption  would  deserve  to  be  given  more  emphasis.  The  environmental 
improvement potential and relevance from activities related to these are more considerable than those of consumable 
goods and vehicle criteria 
According to Finnish studies the energy consumption in professional kitchens amount to 1/3 of the CO2 emissions. It is 
also  of  non-negligible  relevance  to  achieving  the  targets  in  the  EU  EED  article  6.  Recently  published  criteria  on 
professional  kitchen  equipment  (  dishwashers  and  refrigerators  and  freezers)  and  criteria  for  energy-  and  water 
consumption 
Finnish 
http://www.motivanhankintapalvelu.fi/files/748/Motiva_Ammattikeittiolaitteiden_hankinta_FINAL_versio_1.0.pdf 
http://www.motivanhankintapalvelu.fi/files/462/Motivan_hankintaohje_Ruokapalvelu_Energia_ja_vesi_15.5.2014.pdf  
Monitoring energy consumption as part of the environmental program/plan can be a comprehensive level award criteria. 
A stakeholder informed that the carbon calculator tool, produced by the Carbon Trust, provides the energy consumption 
by meal, among other information. This tool is in the public domain but lacks energy efficiency indexes. 
The length of a contract also has an influence, as for short contracts companies tend to invest in low cost equipment 
due  to  the  low  return  profits. A  requirement  for  companies to  buy  high  quality equipment  even  for  shorter  contracts 
should be in place. 
Another stakeholder said that the length of the contracts is too short (2-3 years) to buy high quality equipment to pay 

available 

are 

in 

technologies 

Acknowledged  
It  is  proposed  as  award  criteria  to 
prevent 
the  exclusion  of  SMEs. 
However,  the  criterion  is  meant  to 
award  best 
the 
market that have been proved to be 
cost-effective. 
Comment accepted 
It is proposed to be included as part 
of  the  EMS  criterion.  Best  practices 
for  the  use  of  kitchen  equipment 
have been added. 

in 

Acknowledged  
The criterion proposal does not cover 
any  provisions 
to  exclude  short 
length  contracts.  It  is  proposed  as 

246 

 
Topic 

Feedback from stakeholders 
back investment. Stakeholder said that this in itself can be an obstacle to innovation in technology 

Durability 
and lifetime 

A stakeholder said that they agree with the general approach but, in the scope of the circular economy package, the life 
of the equipment should be considered as well as the origin of energy, specifically renewable energy 

Space 
limitations 

A  stakeholder  said  that  the  contract  caterer  may  face  some  space  limitations,  or  even  be  impeded  in  bringing  new 
equipment, when working at the client premises. 

Water 
consumption 

A stakeholder mentioned that the criterion lacks a reference to water consumption, especially for dishwashers. 

JRC-Directorate B5 assessment 
award  criteria  to  enable  enough 
flexibility to be adapted to the broad 
variety of catering services 
Comment rejected 
The  lifetime  and  durability  of  the 
equipment  are  very  important  but 
difficult  to  measure  and  verify.  A 
criterion on extended warranty would 
only  apply  to  new  purchases,  and  it 
would  have  no  effect  in  equipment 
already installed and not covered by 
the  warranty.  With  regards  of  the 
origin  of  electricity,  it  is  covered  by 
the GPP criteria for electricity. 
Acknowledged  
It  is  proposed  as  award  criteria  to 
enable  enough 
to  be 
adapted  to  the  broad  variety  of 
catering services 
Comment accepted 
The  criterion  proposal  has  been  
requirement  on 
completed  with 
for 
technology 
saving 
water- 
professional dishwashers  

flexibility 

Further research/analysis on Energy and water consumption in kitchens (BEFORE: Equipment)  

The literature review has shown that the LCA studies for catering services are scarce, meaning that results should be considered with caution, especially with regard to their 
representativeness. From the life cycle perspective, the primary production of food stands for the major environmental impact (Baldwin et al., 2011; Calderón et al., 2010), 
nevertheless, the energy use in kitchen operations has an impact on fossil fuels, carcinogens and eco-toxicity, and it plays an important part once the catering service is analysed 
isolated from the primary production of food (Fusi et al., 2015). The study carried out by IEEA (2012) showed that almost 40% of the energy the four sites is used for cooking 
with refrigeration at 28%, extraction at 17% and dishwashing at 5%. In carbon terms cooking at 27% is less important than refrigeration at 34%. This is due to the lower carbon 
impact of gas which accounts for 68% of cooking energy.  In the case of extraction, the main parameters affecting the energy consumption are related to the type of cooking 
appliances and dishwashers. The other parameters, as the speed variable fans, are usually part of the kitchen design which is out of the control of the catering service operator 

247 

 
 
on some occasions. Even though most of the measures proposed in the study are cost-effective, it is also highlighted that in many occasions, the caterer does not pay the 
energy bill. Therefore there are not economic incentives for caterers to reduce the energy consumption, and other type of drivers may be needed. 

Best practices in the use of kitchen equipment 

The study by IEEA (2012) also showed that there is considerable potential for improvements based on  how staff uses the kitchen equipment. The study estimated that the 
energy  savings  could  reach  40%  in  cooking  and  25%  in  dishwashing,  with  very  affordable  investments.  Therefore,  it  is  proposed  that  the  GPP  criteria  include  a  technical 
specification  requiring  the  implementation  of  best  practices for  the  use  of kitchen  equipment,  aimed  at the staff  working  in  the kitchen/s  providing  the  contracted  catering 
service. In the explanatory notes, the recommendations from the study by IEEA (2012) are provided as guidance for the caterer. 

Harmonisation with EU product policies 

Another relevant aspect relates to the harmonisation other product policies setting requirements on professional kitchen equipment, as shortly described below for refrigeration 
appliances, cooking appliances and dishwashers. 

The European Energy Label and Ecodesign schemes cover professional and commercial refrigeration equipment commonly used by catering services. Professional refrigeration 
equipment includes appliances used in professional kitchens. Commercial refrigeration equipment covers appliances used to show and make accessible refrigerated food to the 
final consumers (supermarkets, shops, vending machines, etc.)  

For professional refrigeration, the Ecodesign Regulation EU No 2015/1995 sets minimum requirements for professional refrigerated storage cabinets, blast cabinets, condensing 
units  and  process  chillers,  while  the  Energy  Label  Regulation  (EU)  No  2015/1995  settles  the  energy  classes  for  professional  refrigerated  storage  cabinets  (Section  3.2.2 
Preliminary  report).  According  to  the  comments  received,  the  Regulation  (EU)  No  1060/2010  on  energy  labelling  of  household  refrigerating  appliances  is  also  relevant  for 
professional purposes, since its scope comprises storage chest freezers and wine storage appliances that may be used in catering services.  

Another policy ruling the refrigeration appliances in Europe is the so called F-Gas Regulation (Regulation (EU) No 517/2014 of the European Parliament and of the Council of 16 
April 2014 on fluorinated greenhouse gases and repealing Regulation (EC) No 842/2006). This regulation aims at the phase out of HFC refrigerants with high global warming 
potential, particularly for commercial and professional refrigeration; it sets the following deadlines to ban high and medium GWP refrigerants (Table 59).  

Table 59: Phase out deadlines for refrigerants with a high GWP according to the F-Gas Regulation (Regulation (EU) No 517/2014) 

Refrigerators and freezers for commercial use (hermetically sealed equipment) 

That contains HFCs with GWP of 2500 or more 

1 January 2020 

The  harmonisation  of  product  policies  bolsters  their  appropriate  implementation  and  interpretation  by  means  of  common  framework,  terminology  and  test  methods,  and 
therefore they should be taken as references for the wording of the GPP criteria. However, the other energy consumers within the catering services, i.e. the professional cooking 
appliances, lack European Ecodesign or Energy Labelling policy tools, which are just developed (or under development) for domestic appliances, that are out of the scope of the 
criterion. The existing gap for professional appliances might be overcome by the US Energy Star, which sets minimum energy efficiency requirements several cooking appliances 
(Section 3.2.2. JRC 2016a). 

That contains HFCs with GWP of 150 or more 

1 January 2022 

248 

 
Regarding US Energy star cooking appliances, the market availability of those appliances in Europe is uncertain. No data have been found for the European market and some 
comments from stakeholders pointed out that US Energy star was not relevant. Besides, as an example of non-US market, a Canadian market analysis of commercial kitchen 
equipment (commissioned by the Natural Resources Canada and carried out by the consultancy company Dunsky) showed that the availability of commercial kitchen equipment 
in Canada is quite uneven across the different categories of products, and in general it is still very limited. US Energy Star cooking equipment is difficult to find and is often 
questioned regarding its ability to meet the same quality standards necessary to guarantee food uniformity (Gobeil et al, 2015). This was also supported by the stakeholders in 
the field of equipment manufacture. The lack of information about the uptake of US Energy Star cooking appliances in the European market, together with the comments related 
to its low relevance, has led to the withdrawal of this energy rating system in the revision of the current criterion.  

Regarding professional dishwashers, there is not Ecodesign and Energy labelling. 

Best available technologies in cooking appliances 

The BEMP on Tourism services identified a set of measures related to cooking equipment that might help public procurers in the wording of award criteria.  

  Replace electric hob with induction hob. 
  Replace electric hob with gas hob (optimised burners). 
  Replace gas hobs with new hobs controlled by pot sensors. 
  Replace uninsulated food heating unit with insulated model. 
  Replace conventional oven with convection oven. 
  Use a combi oven or pressure cooker instead of conventional oven. 
  Use microwave instead of oven or hob to (re)heat food. 

The study carried out by IEEA, (2012) also recommends choosing gas appliances over the electrical ones, where possible. These recommendations are used as to propose a 
criterion aimed at rewarding the most efficient technologies. 

Best available technologies in professional refrigeration 

The market segmentation of the professional refrigeration in Europe has been analysed by TopTen.eu the project ProCold, whose main goals are showcasing best products, 
supporting green procurement and helping to implement effective policies (ProCold, 2016). In their publication focusing on professional refrigerated storage cabinets and blast 
cabinets, it is provided data of the energy classes available in the European market, according to the Regulation 2015/1994 (Table 60) (TopTen, 2016b) The product lists on 
Topten.eu  represent  7  different  brands  (Gram,  Desmon,    Electrolux,  Foster,  Liebherr,  Porkka,  Snowflake)  with  65  model  types  (not  counting  similar  models  with  different 
configurations) that are all at least class D or better. It is important to highlight that the models registered in the TopTen.eu database must meet at least class D, so it is not 
known the models below class D that are available in the market. 

Table 60. Models for professional refrigeration in Europe for energy classes above G (TopTen, 2016) 

Category 

A+ 

Energy classes 
B 
A 

C 

D 

Total 

249 

 
  
 
  
  
  
Storage counter refrigerators 
Storage refrigerators 1-door 
Storage refrigerators 2-doors 
Storage counter freezers 
Storage freezers 1-door 
Storage freezers 2-doors 
Storage refrigerators freezers 

Total 

1 

1 

3 
12 
1 
1 
1 
… 
… 

18 

1 
10 
… 
3 
4 
… 
… 

18 

… 

2 
… 
16 
… 
1 

19 

… 
… 
3 
… 
… 
5 
1 

9 

5 
22 
6 
4 
21 
5 
2 

65 

Based on these figures, TopTen (2016a) recommends the following Energy Class for each type of refrigeration equipment: 

Table 61: TopTen recommendation for professional refrigeration (TopTen, 2016a) 
Category 
Storage counter refrigerators 
Storage refrigerators 1-door 
Storage refrigerators 2-doors 
Storage counter freezers 
Storage freezers 1-door 
Storage freezers 2-doors 
Storage refrigerator-freezers 

Energy efficiency index 
<35 
< 35 
<75 
<35 
<50 
<75 
<75 

Min. energy efficiency class 
B 
B 
D 
B 
C 
D 
D 

The proposal of TopTen would ensure an alignment to the Ecodesign tier planned for 2019 (EEI < 85, i.e. Energy Class must be above F), and also that there are models currently 
available in the market. For that reason the ProCold (2016) recommendations are taken to draft the core criterion. For the comprehensive criterion, it is proposed to require 
Energy class A (EEI < 25) for all categories, in order to reward the highest energy rating classes (A and above). There is no data about the availability of some of these product 
categories in the market; therefore, this criterion proposal is open to discussion based on market data that the stakeholders might provide. 

In the case of storage chest freezers and wine storage appliances, TopTen data base also offers the energy classes of the best performance products in the EU market (Table 
62) 

Table 62: Models for household refrigeration in Europe for energy classes above G (TopTen, 2016) 

Category 

Energy classes  
A 
A+ 
A++ 

A+++ 

Total 

250 

 
 
    
 
 
 
 
 
 
  
 
  
Storage chest freezers 
Wine storage appliances with one temperature zone  
Wine storage appliances with multi temperature zones 

Total 

19 

19 

4 

4 

11 
3 

14 

6 

6 

19 
15 
9 

43 

For these appliances, TopTen recommends Energy class A+++ for storage chest freezers, A+  for wine storage appliances with one temperature zone and A for wine storage 
appliances with multi temperature zones. 

Best available technologies in professional dishwashers 

The study carried out by IEEA (2012) provides the following recommendations: 

  Purchase the most energy efficient equipment (in kWh/100 dishes) when replacing. 
  Consider models with heat recovery from hot sanitation. 
  Purchase water-efficient dishwashers as these tend to be the most energy-efficient. 
  Where local hot water generation exists, it may enable heat recovery from refrigeration. 

The stakeholders pointed out that the water consumption was not taken into account in the criteria proposal, but the strong relationship between the energy consumption and 
the water consumption in the performance of the dishwashers ensures that this aspect is already considered. Additionally, one of the stakeholders recommended not to set any 
thresholds for dishwasher water consumption if the test method was not standardized, since the results would not allow any comparison. For that reason, an approach based on 
the promotion of more efficient technologies is proposed. In this regard, the criterion proposal is drafted to award points to dishwashers equipped with heat recovery systems.  

251 

 
 
 
 
 
    
 
 
 
 
 
Food transportation (BEFORE: Vehicle fleet and planning of food delivery)  
This section presents the comments received through BATIS and personal communications from the 1st AHWG meeting to the 2nd AHWG meeting.  

Table 63. Feedback from the stakeholders on the TR1.0: Vehicle fleet and planning of food delivery (TS7) 
Topic 
Scope of the 
criterion 

Feedback from stakeholders 
Yes, we consider the typology of refrigerants should be covered in this criterion. 

I  think  the  criterion  should  also  cover  refrigerator  transports  since  in  the  last  years  the  use  of  deep  frozen 
food/components  increased  significantly.  In  this  regard  also  heavy  duty  trucks  are  being  used  for  transport..  One 
stakeholder raised the point that this criterion may also be relevant for the procurement of food. Another stakeholder 
added that heavy vehicles such as trucks should also be taken into account because they are used to deliver food.  
One stakeholder raised the point that this criterion may also be relevant for the procurement of food, and its transport 
of food to catering locations.  

Ambition 
level 

In general, the EEB agrees with the proposed criteria but we recommend checking if these technical specifications could 
be formulated as award criteria in order to not exclude SMEs that might find it too hard to comply. 

Logistics 

Logistics 

A stakeholder shared the opinion that the efficiency of the transport logistics should be awarded more than the types of 
vehicles  used. As  an  example  of  a  possible  indicator,  a  stakeholder  mentioned  an  Environmental  Product  Declaration 
where the reference unit is set to be CO2 emissions per mileage. Another stakeholder highlighted the importance of an 
optimisation of logistics as well as route planning  
Another  stakeholder  stated  that  logistics  are  very  important  but  that  in  some  situations  trucks  are  owned  by  the 
wholesale companies so it might difficult to set requirements for low environmental impact vehicles. 

Training 

Besides  the  emissions  classes  for  the  vehicles  there  should  also  be  a  mandatory  training  for  the  drivers  on  energy 
saving driving. So far this in only mandatory for heavy duty vehicle drivers.  

GPP 

EU 
alignment 

Another stakeholder said that it would be useful for procurement purposes if the criteria align between different GPPs 
(e.g. transport and catering) 

JRC-Directorate B5 assessment 
Comment accepted 
A  criterion  on  GWP  has  been 
included 
Comment accepted 
HDVs  are  included  in  the  scope  of 
the criterion. 

Comment accepted 
The scope of the criterion includes a 
definition  of  food  delivery,  covering 
the food transport to the kitchen 
Comment accepted 
The  criterion  on  EURO  6/VI 
formulated as award criterion.  
Acknowledged.  

is 

Comment accepted 
The  criterion  is  proposed  to  be 
applied to the fleet owned or leased 
by the tenderer. 
Comment accepted 
Ecodriving  is  included  in  the  SC  on 
competences  of  the  tenderer  and 
staff training CPC. 
 Comment accepted 
It  has  been  aligned  as  much  as 
possible. 

252 

 
 
 
Further analysis on Vehicle fleet and planning 

Transportation was not identified as a main hotspot in food supply chains although contributing to overall environmental impact (depending on food category and depending on 
situation). The use of fossil fuels leads to global warming, abiotic resource depletion, ozone depletion and acidification. Nevertheless, Cerutti et al. (2016) found that the GHG 
emission share of urban food distribution in the carbon footprint of the school catering service is relevant (24–28% of the total CF); and highlighted the possibilities for GHG 
emission reductions. The distribution of food is part of the catering service, and therefore, falls under the caterer responsibility. By requesting vehicles to be more fuel efficient or 
have  lower  emissions,  will  also  minimise  the  impact  on  the  other  impact  categories.  But  food  supply  chains  are  too  complex  to  require  all  vehicles  to  achieve  a  certain 
environmental standard.  

Reduction  plan  for  fuel  consumption: The BEMP for Food and Beverage Manufacturing had recommendations on logistics and route optimisation. It is good practice to  avoid 
empty loads and to use back-haul, in order to minimise the so called last mile issues. The review of other GPP criteria shows four procurers apply requirements to reduce the 
food delivery transportation. Some examples are the following: 

  Deliveries to be made once a week and on a more regular basis when needed  
  A contractual delivery stop on orders with a value below EUR 100 

Eco-driving has also an important potential of fuel reduction, which could be reinforced by additional measures other than the training, for example, the drivers could receive 
regularly information on their fuel efficiency performance, so they could improve their driving behaviour continuously. 

Air pollutants emissions: With regards to air emissions covered by Euro standards, for light commercial vehicles, the Euro 5 standard became mandatory for all new registrations 
in  January  2015.  As  for  Euro  6,  it  sets  stricter  diesel  NOx  limits,  PN  limits  for  gasoline  vehicles,  on-board  diagnosis  requirements,  its  implementation  will  be  completed  in 
September 2018, when real drive emissions requirements will be in force, and the New European Driving Cycling will be replaced by Worldwide harmonized Light vehicles Driving 
Cycling (ICCT, 2015). 

For heavy duty vehicles, the Euro V standard became mandatory for all new registrations in 2009. EURO VI was required to all new vehicles registration in January 2014, and 
some specific parts of it in 2017. It reduces 67% the PM emissions limit compared to EURO IV and V, and includes a PN limit. It also decreases the NOx emissions limit; replaces 
the European Stationary Cycle and Transient Cycle used for testing by the World harmonized Transient cycle. EURO VI also introduces in-service conformity testing using Portable 
Emission Measurement System. Besides, it sets new limit for ammonia emissions and stricter limits for methane on CNG and LPG vehicles (ICCT, 2015). Nevertheless, it is not 
clear how relevant these heavy duty vehicles are for distribution of food in the catering service activities  

In the view of the set of improvements that EURO VI/6 standards introduce, new vehicles on the market need to make important efforts to comply with their requirements, and 
therefore, it is proposed these new standards to be promoted within the EU GPP criteria. The total replacement of a fleet to EURO VI/6 may entail significant costs, therefore it is 
proposed an award criterion for fleets totally composed by EURO VI/6 vehicles. 

CO2 emissions Based on the information available in the Preliminary report for the revision of EU GPP Criteria for transport, the most fuel efficient internal combustion engine 
vehicles (ICEVs) are cost-effective, meaning that the additional cost of the vehicle is outweighed by the fuel saving over the lifetime of the vehicle. Conversely, electric and semi-

253 

 
 
electric  vehicles  are  still  at  a  lower  production  scale  which makes  their  prices  not  as  competitive  as  ICEVs.  For  this  reason,  the  comprehensive  award  criterion  is  meant  to 
promote the use of plug-in hybrids and electric vehicles, which are the only ones able to perform 50 g CO2/km (type approval CO2 value) 

Cyclelogistics  has  demonstrated  its  capability  to  operate in urban  deliveries,  which  makes  it  suitable  for  deliveries  within  catering  services.  According  to  CIVITAS 42%  of  all 
motorized trips in urban areas could be shifted to logistics by bicycle (this corresponds to 25% of all trips). As an example of cyclelogistics the CITIES Foundation as part of its 
Farming the City project, launched in summer 2014 a cyclelogistics start-up called FOODLOGICA in Amsterdam,. The initiative aims at offering to consumers and businesses in a 
real food delivery service making use of electric cargo bikes (Chiffi & Galli, 2014). 

HFC refrigerants: Refrigerant gases are also relevant for vehicles used in food delivery such as vans and refrigerated trucks. From 2017 onwards the GWP of air conditioning 
gases used in cars and vans should be below 150.  Alternative refrigerant options include CO2 and the HFO refrigerant called R1234yf, which has been introduced in certain car 
models recently. These refrigerants have a GWP of 1 and 4, have a high energy efficiency, bring no or acceptable additional cost and are commercially available. Given that the 
only currently available alternatives to meet the legal limit already perform very low GWP, an award criterion for lower GWP beyond that limit would be easily complied by all 
the vehicles and wouldn’t bring any added value.  

Trucks  are  excluded  from  the  MAC  Directive  (2006/40/EC),  however,  the  HFCs  used  in  these  systems  are  affected  by the  phase-down  put  in  place  by  the  F-gas  Regulation 
(Regulation (EU) No 517/2014), which will exert a strong pressure on prices of these gases as the supply will become more restricted. Therefore, there is a strong regulatory 
driver in place that favours the use of low GWP or even non-HFC (e.g. CO2) technologies in this sector. It is proposed to set an award criterion for those refrigerants with GWP 
(100 years) below 150 at comprehensive level.  

Implementing  these  criteria  may  help  reducing  for  instance  global  warming  potential  as  well  as  air  quality  in  cities.  EURO  VI/6  represents  a  significant  environmental 
improvement for air emissions, and it would be promoted by means of an award criterion. In order to complement the criteria proposal and achieved a level of harmonisation 
with  the  EU  GPP  criteria  for  transport,  it  is  proposed  to  promote  best  performance  vehicles,  low/zero  tailpipe  emissions  vehicles  and  cyclelogistics  at  comprehensive  level. 
Besides that, it is proposed to include a plan to minimise the fuel consumption. It is also proposed to define this criterion as technical specification complemented by a contract 
performance clause. This would allow the contracting authority to evaluate the criterion prior to the contract award.. 

254 

 
 
 
 
Environmental management measures and practices (BEFORE: environmental management system) 
This section presents the comments received through BATIS and personal communications from the 1st AHWG meeting to the 2nd AHWG meeting.  

Table 64. Feedback from the stakeholders on the TR1.0: Environmental management system (SC2) 
Topic 
Ambition 
level 

Feedback from stakeholders 
A  selection  criterion  that  requires  the  service  provider  to  have  in  place  an  environmental  management 
system containing an environmental policy, an action plan and an internal audit process risks excluding 
SMEs. For instance, in Hungary, around 50% of contract catering companies are SMEs.  
We recommend that the service provider "should have in place an environmental management system or 
should have the intention to implement one".  
Both SMEs and large companies should be able to fulfil and prove their compliance with GPP criteria. 
Change  the  core  and  comprehensive  selection  criteria  on  environmental  management  measures  and 
practices to award criteria and make sure that they do not exclude small and innovative catering services 
that have an outstanding performance on the food related criteria 
The EEB recommends adapting these criteria, since even the proposed core criteria are too ambitious for 
small companies. In Germany, especially some very good caterers for school and kindergarten catering 
could  not  fulfil  the  proposed  core  criteria.  A  representative  from  the  city  of  Gent  made  the  same 
experience. 

Using  EMS  as  a  selection  criterion  is  appropriate  as  long  as  also  non  third  party  certified  systems  are 
allowed. The comprehensive criteria can be used if there is a sufficient amount of service providers with 
certified schemes and it can be seen as proportionate to the aim. In Finland certified schemes are not 
generally  used  as  mandatory  criteria.  The  link  between  the  SC2  and  menu  planning  etc  should  be 
described  in  a  clear  way.  The  environmental  program  for  the  particular  service  procured  should  be 
provided to the purchasing authority either attached to the tender, or at the start of the contract period. 
We propose that the service provider must provide an environmental plan for the service to be supplied 
during  the  contract  period.  The  procuring  authority  should  state  which  aspects  are  to  be  included  as  a 
minimum in the environmental program/plan for the service to be provided. These mandatory elements 
can then be further defined as minimum and award criteria. The plan if followed up and further developed 
in cooperation with the procuring authority during the contract period. 
I fully agree to the criterion. The verification should not be a problem even for SME when looking at the 
core criterion 

General 

JRC-Directorate B5 assessment 
Comment accepted 
 The  criterion  has  been  simplified  and  the  wording 
tailored  to  the  catering  service  sector.  The  link  to 
the  GPP  criteria  based  on  operational  procedures 
and best practices has been made clear. 

Comment partially accepted 
 The  criterion  has  been  simplified  and  the  wording 
tailored  to  the  catering  service  sector  and  the  rest 
of GPP criteria. The criterion is now proposed as an 
essential  element  to  implement  the  GPP  criteria 
based on operational procedures and best practices, 
therefore,  it  cannot  be  defined  as  an  award 
criterion  
Comment accepted 
 The  criterion  has  been  simplified  and  the  wording 
tailored  to  the  catering  service  sector.  The  link  to 
the  GPP  criteria  based  on  operational  procedures 
and best practices has been made clear.  

Comment partially accepted 
EMS  are  very  helpful  to  implement  environmental 
criteria on services, however, other comments point 
out  the  difficulties  that  some  operators  may  find, 

255 

 
 
Topic 

Feedback from stakeholders 

Other 
sustainable 
issues 

Consider  renaming  this  “Sustainability  management  measures  and  practices”  and  tracking  broader 
sustainability  measures  such  as  impacts  on  animal  welfare.  Even  a  basic  framework  for  tracking 
purchases, which is already required to meet AC4 and TS4, can lay the groundwork for more detailed and 
improved measurements in the future. 

Verification 

EMAS  and  ISO  14001  are  not  very  common  instruments  among  catering  services  (in  Austria).  Also 
Ecolabels must been taken into consideration concerning verification, if they have a management section 
within  their  criteria.  Several  appropriate  ISO  Type  1  ecolabels  for  catering  services  are  already  on  the 
European market. 

Very  common  criteria  to  specify the  aspects  that  must  be  included  concerning  the  Environmental 
management measures and practices in  procurements of catering services 
The  applicant  most  often  provide  the  ISO  14001  certificate  and/or  EMAS  registration  as  a  mean  of 
compliance for this criterion, or sometimes equivalent if it is a SME. 

It  is  important  the  procurer  is  trained  to  deal  with  the  systems  used  by  the  tenderer  that  don’t  have 
certificates as EMAS/ISO14001., but I also noticed that these kind of certificates are not offered by SME’s 
and  if  they  have  to  offer  an  equal  system  (we  use  the  same  description  as  written  down  in  the  core 
criteria) it isn’t easy because it’s a rather abstract issue for them.  
IFOAM  EU  is  not  in  favour  obliging  SMEs  to  comply  with  EMAS/ISO14001  or  equivalent  schemes. 
Establishing  complex  requirements  with  an  additional  certification  system  is  too  far  reaching  approach 
with a tremendous additional burden (workload and costs) for SMEs. Imposing such systems has a high 
potential to exclude many operators. It is therefore highly important to define requirements which meet 
the needs of SMEs, rather than disadvantaging them in favour of larger industry players. 

JRC-Directorate B5 assessment 
and therefore it has been revised accordingly. 
Comment rejected 
GPP  is  a  tool  to  promote  best  environmental 
performance, and just considers other aspects such 
as social and ethical issues, when the product group 
raises a relevant concern. 
Comment accepted 
The certified EMS is no longer required as proof of 
compliance,  but  it  can  be  accepted  as  a  proof  of 
compliance.  Type  1  ecolabels  are  also  deemed  to 
comply. 
Comment rejected 
EMS  are  very  helpful  to  implement  environmental 
criteria on services, however, other comments point 
out  the  difficulties  that  some  operators  may  find, 
and therefore it has been revised accordingly 
Comment accepted 
The  verification  specifies  which  written  procedures 
should  be  provided  by  the  tenderers  and  technical 
specification sets their minimum content. 
Comment accepted 
The certified EMS is no longer required as proof of 
compliance,  but  it  can  be  accepted  as  a  proof  of 
compliance.  Type  1  ecolabels  are  also  deemed  to 
comply. 

256 

 
 
 
 
 
Annex 4. 

Table of stakeholder's comments from the Technical report v2 

4.1.  Table of stakeholder's comments on the propose criteria for EU GPP criteria for Report introduction and structure 

This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  

Introduction: summary of the preliminary report and changes from TR2.0 to TR3.0 
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 65. Feedback from the stakeholders on the TR2.0: introduction 
Topic 

Feedback from stakeholders 
In table 1 of 1.1.2, energy use for water boiling has been identified as an "environmental hotspot 
or potential improvement areas". boiled water is used for coffee and tea 

JRC-Directorate B5 assessment 
Acknowledged 

in table 2: liquid should be added to the text selected (solid waste management) 

Comment accepted 

4.2.  Table of stakeholder's comments on the propose criteria for EU GPP criteria for Food procurement 

This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  

Organic food products 
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 66. Feedback from the stakeholders on the TR1.0: Organic food products (TS1 and AC1) 
Topic 
Strictness of 
the thresholds 
and 
explanatory 
notes 

Feedback from stakeholders 
The value percentage of total purchase should be higher for organic products if it needs to match 
the mass percentage, given that organic products are more expensive than conventional ones.   
The thresholds for organic products should be more ambitious particularly in the case of 
voluntary comprehensive criteria, given that in the EU we have member states that have 
strategies requiring up to 90% of organic products of total food purchase in public institutions.   
20% and 10% as minimum levels for mass and value respectively are too high to be achievable 
across the EU-28 (see previous comment about the French schools requiring 20% organic). 
A big challenge for our sector is that often time, public authorities combine organic with local in 
the contract. 
The percentages for comprehensive criteria should be higher than core criteria and up to 100% for 

JRC-Directorate B5 assessment 
Comment rejected 
Even if the organic products tend to be more expensive than 
conventional  ones,  stakeholder's  feedback  indicated  that 
planning long-term purchases, the overall budget can be "not 
significantly  affected".  Therefore,  it  seems  correct  hat  the 
indicated percentages in value are lower than those in mass.  

Comment partially accepted 

257 

 
 
 
 
 
 
 
 
 
Topic 

Feedback from stakeholders 
specific tenders. This is because when the tender is about a specific product e.g. coffee or milk or 
biscuits, then a percentage is not relevant, it is either organic or it is not. So, the more specific the 
tender is the more specific is its demand. If organic is possible for this specific product, then 
100% can be advised. As a result, comprehensive, should go up to 100%.  
Core criteria should not be limited to specific product groups, for example dairy should not be 
limited to comprehensive criteria. 
AC should be higher than TS and a combination of the two should be possible. At product level TS 
is the minimum in the tender. For example, if you demand a minimum of 20% organic, you 
should be able to grant extra points to those that offer more used award criteria.  
For instance AC should be formulated as follows: "where suppliers offer x% more than required 
(e.g. 10%) they should get extra points" 
Percentages are only relevant when purchasing several different product lines, but not necessarily 
when purchasing a limited line e.g. coffee and tea which can already reach 100%. 
In "Table 3": Criteria "Organic food products, TS1, Comprehensive, Option A, 50% in mass" should 
that not be >50% in mass? 
The recommended target for the core criteria (page 10) might still be high taking into account the 
availability of organic produce. According to recent studies [1], only 1.0% of global agricultural 
land is certified organic. Such figure raises questions about the real availability and pricing of 
organic products for public procurement in the EU. 
[1] The State of Sustainable Markets: Statistics and Emerging Trends 2015 (International Trade Centre) 
http://www.intracen.org/publication/The-State-of-Sustainable-Markets/#sthash.qGlKoAPB.dpuf 

We welcome the greater attention to market availability and cost of organic versus conventional 
products. Organic food is only one element of sustainable public procurement. We believe that 
sustainable public procurement should not be defined by how much certified organic food can be 
sourced. Therefore, we support the introduction of ranges for the targets, which gives more 
flexibility for clients to take into account varying levels of organic production across the EU-28. 
Clients are increasingly asking for organic products, so we would challenge the perception by 
some stakeholders that this is not a standard practice and that the proposed thresholds can be 
easily fulfilled. Even though the Commission's guidance does not suggest this, contracting 
authorities frequently combine this with the need to source such products locally and/or in 
season, which can be very challenging, so this should be borne in mind when suggesting targets. 

JRC-Directorate B5 assessment 
The concept explained in this comment is the one that was 
intended to be communicated by the proposed wording and 
options of the criteria wording.  
Regarding the combination of AC and TS further explanations 
have  been  added  at  the  beginning  of  the  report  to  make 
clear how the thresholds should be understood. Even though, 
the  words  "more  than  the  required  X%"  have  been  added 
when appropriate.  

Comment accepted 

Comment rejected 
Although it is important to keep in mind the development of 
the  organic  market  in  EU,  the  thresholds  for  this  criterion 
don’t have to mirror the availability data. The reason for is 
that  not  all  the  procurement  in  EU  aim  to  integrate  these 
criteria  into  their  tenders.  Therefore,  proposing  higher  or 
stricter limits will not cause a shortage of these products on 
the market.    
Acknowledged 

258 

 
Topic 

Strictness of 
the thresholds 
and 
explanatory 
notes 

GMO 

Fairly trade & 

Feedback from stakeholders 
It is a reality that some caterers struggle to fulfil the organic criteria that contracting authorities 
are setting due to fluctuations in prices and availability, and have faced fines for non-compliance 
in relation to fulfilling the organic criteria. For instance, France set a national target of 20% 
organic food in school meals by 2017. French caterers find it very challenging to meet this 
requirement, even in France, where the share of organic farming is around 5% according to 
EUROSTAT.  
As Commissioner Timmermans said in a press conference on circular economy: "sometimes 
'better' is the enemy of what is good. "It is important to recall that GPP is a voluntary tool for 
contracting authorities, but once a contracting authority writes it into a contract, it is mandatory for 
the caterer to comply and there are fines for non-compliance. Therefore the levels that are 
recommended by the Commission need to be realistic and achievable even though the 
Commission's guidance is voluntary.  
In a general way, more explanatory notes should be provided to clarify the differences between 
the percentages in mass and in value, as percentages in value should be higher if they want to 
match percentages in mass.  
If an organic target is set above the capacity of local production, the environmental footprint of 
importing organic food from further afield needs to be weighed against the footprint of using 
conventional, locally-produced food. 
Perhaps in the future, the European Commission’s Product Environmental Footprint methodology 
can help public authorities make a science-based decision on the optimum level to set in the 
tender.     
The EEB welcomes the ambition levels set for the TS (20%/ 60% in mass or 10%/ 30% in value) 
and the respective AC for tenders going beyond those levels. We strongly recommend not 
lowering the ambition further. Other stakeholders like the cities of Copenhagen, Gent and Vienna 
stated that their cities did not have any problems to reach an ambition level of 30%. This 
percentage could even be reached by them without higher costs. 
There are several other examples in Germany, like the cities of Munich, Nuremburg and 
Heidelberg that can confirm these statements of the listed European cities. 
In addition to organic products there should be separate criteria for GMO-free products.  
In Europe GMOs do not only concern soya but also corn that is mainly grown in Spain both for 
animal and human consumption. There is increasing evidence of the toxic effects that GM crops 
have on humans, due to their embodied pesticides.    
For chocolate, the level of organic product is lower that 1% in the world. Impossible to comply 

JRC-Directorate B5 assessment 

Comment accepted 

Comment rejected  
Food  either  organically  or  conventionally  grown  is  mainly 
imported  in  Europe.  This  means  that  contribution  of  the 
transportation  should  be  considered 
the  overall 
environmental impact of organic as well as for conventional 
products.  
Comment accepted 

in 

Comment rejected  
This  information  is  not  fully  in  line  with  the  information 
gotten  from  our  colleagues.  According  to  their  data  the 
consumption of GMO-corn by humans in EU is negligible.  
Comment reject 

259 

 
 
 
 
JRC-Directorate B5 assessment 
Unfortunately 
implementation/undertaking  of  GPP 
the 
criteria across EU is not so high to exceed the current organic 
chocolate offer at world level. 
Comment reject 
According to most of the feedback received, both conditions 
can be easily fulfilled for the products listed.  
Comment accepted 
Two  options  are  kept  in  TR3.0  as  procurers  commented 
during the 2nd AHWG meeting that they can be combined  

Topic 
organic prod 

Feedback from stakeholders 
with the general statement 

Options to 
draft the 
criterion 

General comment: Strange approach to have values requested in Organic Food than Fairly traded 
product. The logic would be to ensure first Fairly traded product and then Organic Food? 

Regarding the JRC’s question, we support setting criteria based on total procurement as proposed 
in the 2nd Technical Report because it would be very challenging to have an overall organic target, 
organic targets for each of the food categories mentioned in the criteria and to have additional 
targets for certified sustainable products on top. Therefore, we prefer option A. 
Preference to Option B. 
Explain efficient and environmentally responsible practises and include biodiversity protection! 
I mind the sentence “At least X%1) of the total purchases of food and drink products must comply 
with the organic products standards.” refers to the buying of the good procured for.  
It is important to remember, that it is the kitchens that decide themselves what to buy, and 
therefore it is impossible to measure the total amount of purchases in the tender documents. To 
measure and implement controlling in the use of for instance organic products in public kitchens, 
is an undertaking that requires substantial resources in most systems, at least it does in the 
Municipality of Copenhagen.  
The purchases can only be measured during the contracting period, and if the supplier offers both  
organic and non-organic versions of a product there is no guarantee that the organic version is 
what the kitchens buy (that often depends on the price) and there by the technical specifications 
and/or award criteria of the tender has not been met.  The only way to do this is to lock some 
products that comply with organic requirements to the mass asked for in the tender and dividing 
this with the total mass. 
Instead, it might be more prudent to focus the demands on the percentage of the specifications 
in the tender, as this is a parameter that is within the procuring officers' control.  
As commented at the 2nd AHWG meeting and also mentioned in the minutes page 7: "However, it 
was pointed out that the procurement of merely food is very different from the procurement of 
food for the catering services. In the first case the menus are decided in the kitchen while in the 
second case, the menus are fixed by the procurer. These differences should be reflected in the 
criteria wording accordingly.", it is very important to have this in mind when formulating the 
criteria. I have tried to explain this under "2.1. Organic food products" and "2.1.3 Marine and 

260 

 
 
 
 
Topic 

Feedback from stakeholders 
aquaculture ...." 
Option B 
We would like to propose an Option C, which would be to make organic produce available several 
times a week, such as offering organic fruit or vegetables x times a week 

Standards for 
verification 

Organic 
products vs 
integrated 
production 

Organic agriculture is a step in the right direction for improving biodiversity protection. But within 
organic agriculture certificates there are differences between the various organic standards. 
Products from organic standards requesting the implementation of a biodiversity action plan 
should be the first option.   
Award criteria should include higher level of biodiversity performance, e.g. "Points must be 
proportionally awarded to tenders  in which more than X% of the total purchases of food and drink 
products have been produced in accordance with Regulation (EC) No 834/2007 and by 
implementing a Biodiversity Action Plan (or similar)". 

We believe in some instances the JRC could remove additional criteria, such as on Integrated 
Production and Fairly Traded Products, since EU harmonised definitions are lacking. That would 
result in inconsistent application of the criteria and an uneven playing field. The EU Organic 
Regulation sets out clear rules on what qualifies as organic, and there are EU labelling 
requirements so caterers can verify whether something is organic by looking at the label. 
The Integrated Production criterion, however, is not based on any EU rules so there is too much 
legal uncertainty. For instance, a supplier in a third country could claim to fulfil the environmental 
principles in the comprehensive criteria, even if they were planting on slashed and burned 
rainforest. This would theoretically be acceptable under this criterion as long as they addressed 
pest, crop and waste management, and conservation in some way.     
For these products and others that were removed, such as seasonal and local products, it would 
be beneficial if the EU first agrees harmonised definitions together with the co-legislators and a 
broader group of stakeholders before issuing guidance on GPP criteria for these products. 
The TR relies significantly on the use of LCAs, comparing organic and conventional agriculture as 
the basis for the development of the GPP criteria and presents a distorting picture between 
organic production as a multi-outcome approach to sustainable food production and 
predominantly conventional-orientated single outcomes approaches.  
Recent research on the EU Organic Regulation also demonstrates specifically how the Production 

JRC-Directorate B5 assessment 

Comment rejected 
After  considering  the  inclusion  of  this  option  it  has  been 
discarded  since  the  verification  of  the  frequency  is  difficult 
to be implemented. 
Comment rejected 
The  verification  of  this  criterion  is  a  pass/fail  scheme,  this 
means that it is not possible to establish different options  
The  requirements  must  be  those  included  in  the  EU 
Regulation 834/2007 because this ensures that:  
- the same requirements are applied across EU 
-  there  is  a  certification  and  labelling  scheme  in  place  that 
makes easier the verification 
- this GPP criterion is in line with other EU legislation 
Acknowledged 
There is a general agreement that well defined concepts of 
seasonal,  integrated  production,  fair  and  ethical  trade 
products  and  local  products  would  help  in the  development 
of GPP criteria. However, this task is out of the scope of this 
project  and  therefore  criteria  are  tried  to  be  built  on  the 
existing knowledge.  

Comment accepted 

261 

 
 
 
 
 
Topic 

Scope of the 
criterion  

Feedback from stakeholders 
rules, organic objectives and principles help to respect nature cycles/systems, contribute to 
biodiversity and make responsible use of natural resources (energy, water, soil air and climate). 
(See Sanders (eds.) 2013: Evaluation of the EU legislation on organic farming (Chapter 7). Available at: 
http://ec.europa.eu/agriculture/evaluation/market-and-income reports/2013/organic-farming/fulltext_en.pdf) 
There are very few organic drinks available, mainly fruit juices.  
We recommend keeping this limited to food products and removing drinks. 

Units 

Updating data 

Environmental 
impacts of 
organic 
products 

Presentation of 
the criteria doc 

Vending 
machines 

As a general comment, when it comes to some processed foods, caterers sometimes don't have 
records of the mass because they might be ordered by boxes or bottles. Usually caterers use a 
value-based calculation and convert it to mass through an equation rather than by actually 
weighing or tracking the weight. 
Please use most recent data. 
http://www.fibl.org/en/media/media-archive/media-release/article/biomarkt-waechst-zweistellig-bioflaeche-steigt-auf-fast-
13-millionen-hektar-an.html 
We would like to re-instate our April 2016 argument on organic products. Although organic 
products and the related manufactured foodstuffs can contribute to the sustainability of food 
systems mainly in niche product areas, from a GPP criteria perspective, organic agriculture as 
such is not by default a guarantee of better environmental performance for all impacts 
categories related to food production. The environmental analysis by the JRC on Organic Food 
concludes that there is insufficient evidence available to suggest that organic products have 
overall a lower environmental impact than conventionally produced products [1].  
[1] P.19 Technical Report 
As commented before (Introduction) I would like the "Core criteria" and the "Comprehensive 
criteria" to be divided by a line as it is in the green headlines, so that the systematics is the same 
throughout the whole GPP document. 

For vending machines a percentage threshold should be used but more details on the 
development and application of criteria are needed.   
Our comment: “The GPP criteria should provide guidance more on the ends than a limited set of 
means. The overall goal of decreased environmental burden can be achieved in various ways which 
should be reflected also in the chosen criteria. This approach would also encourage various actors 

JRC-Directorate B5 assessment 

Comment rejected 
The  threshold  does  not  make  any  difference  between  food 
products  and  drink  products.  There  is  no  a  minimum 
the 
percentage  of  drinks 
requirements  of  the  EU  organic  regulation,  therefore  it  is 
considered that a general threshold can be applied 
Acknowledged 

that  should  comply  with 

Comment accepted 

Acknowledged 

Comment rejected 
The  layout  of  the  TR  as  well  as  the  criteria  document  is 
agreed  for  most  of  the  product  groups.  It  is  a  standard 
practice to follow these templates.  
Comment accepted 

Comment rejected 
According  to  the  Public  Procurement  Directives,  the  criteria 
that the tenderer must fulfil must be precisely defined and 

262 

 
 
Topic 

Feedback from stakeholders 
to innovate new ways to improve the sustainability of food chain rather than adhering to a fairly 
narrow set of recognized means”.  
Answer  JRC  “Comment  accepted:  Several  means  of  compliance  have  been  suggested  whenever 
possible.”  
Discussion:  This  does  not  seem  to  be  the  case,  because  the  first  criteria  are:  "Organic  food 
products: 20-60% in mass (10-30% in value)". This is remarkably since it is stated in the Rationale 
that the organic production contribution is not at all clear. “The inclusion of a criterion on organic 
produce  is  proposed  based  on  studies  that  demonstrate  that  the  possibility  of  achieving  some 
environmental  benefits  can  be  brought  under  certain  conditions,  for  example  benefits  regarding 
biodiversity or the quality of soil. However, it is not yet possible to draw a general conclusion on the 
environmental benefits for all the conditions that are currently present across Europe.” 
Also other comments on page 73 “There are several criteria which verification has been enlarged 
including private schemes in addition to the national regulations. This is the case of the criterion on 
integrated  production  includes  the  wording  "or  equivalent",  so  that  procurers  feel  free  to  include 
other schemes that they consider are suitable for this purpose.”  
This sounds like free of obligation and this document does not set hard targets. 

JRC-Directorate B5 assessment 
verifiable.  In  the  case  of  organic  farming,  the  requirements 
on  production  and  verification  are  described  in  the  Council 
Regulation  (EC)  No.  834/2007,  meaning  that  they  are 
accepted  and  recognised  across  EU.  This is  not  the  case  of 
Integrated production criteria. 

Integrated production  
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 67. Feedback from the stakeholders on the TR2.0: Integrated production  
Topic 
Schemes 

Feedback from stakeholders 
Biodiversity protection aspects should be added. There are standards for integrated agriculture 
with better biodiversity performance than others. Relevant elements of biodiversity performance 
are: 
Food has been produced with products which have been cultivated/produced respecting the 
- The implementation of a Biodiversity Action Plan 
- The implementation of a water management plan for the sustainable use of water resources 
- The consideration of nutrient balances and product specific nutrient limits 
- The prohibition of pesticides with negative impacts in bees or other pollinating insects as well 
as on fish 
- No use of total herbicides 
Food has been produced with products which have been cultivated on farms which have not been 
created based on the destruction of primary ecosystems (e.g. tropical forest, peat bogs). Basis 

JRC-Directorate B5 assessment 
Comment partially accepted  
The  new  proposal  proposes  to  remove  the  criterion  on 
integrated  production  due  to  the  lack  of  homogenous 
regulation  across  EU  but 
includes  Explanatory  notes 
indicating  how  to  draft  the  criterion  if  the  contracting 
authority considers that it is relevant for the tender.  
The  indications  for  drafting  and  verifying  the  criterion  are 
based on the regulation developed and implemented in some 
Member States and international private schemes.  
The proposed standards can therefore be used as a proof of 
compliance if the contracting authorities consider so.  

263 

 
Topic 

Feedback from stakeholders 
year: 2005   
In the case of food from wild plants, the wild plants have been collected according to the Fair-
Wild Standard, UEBT-Standard or a similar standard to guarantee the sustainable collection of 
wild plants. 
Food produced with traditional plants or breeds should be preferred because of the contribution 
to the protection of agro-biodiversity. 
No GMO modified products (plants, animals) have been used for food production 
All criteria above described can be found in some quality standards for integrated production. 
The criteria "Implementation of a Biodiversity Action Plan" should also be included into organic 
produced food. Some organic standards request the implementation of a biodiversity action plan, 
but others no.     
There are big differences regarding biodiversity performance of standards for integrated 
agricultural production. 
If integrated agriculture will be accepted as more sustainable than conventional agriculture, 
biodiversity protection should be considered. That means, only food produced with products which 
have been certified by standards with higher biodiversity requirements as listed in the comment 
above. 
Today there are standards for integrated agriculture including all - or some of the requirements 
listed above. Products certified by these standards should be clearly preferred.   
The core criteria should clearly express a preference for products from integrated agriculture with 
an acceptable biodiversity performance. The main elements are listed in the comment 1 
As a starting point at least the implementation of a Biodiversity Action Plan (or Conservation Plan) 
during the production should be required. 
As we mentioned in the meeting, integrated production should be seen as a transitory procedure 
between conventional and organic production, encouraging the latter one. In this sense, we call 
for a harmonised definition and verification procedure at the EU level for facilitating the 
comparison of  offers received. 
We thank the JRC for providing more clarity about integrated production. 
Unfortunately, this is still not clear for us because unlike organic products, there is no EU-
harmonised definition of what integrated production is. The lack of an EU-harmonised approach 
means it is difficult to say what does and does not count as integrated production.   
There needs to be a common set of rules of what is and is not integrated production. Without an 
EU regulation, it would be difficult to verify whether food products are compliant. 

JRC-Directorate B5 assessment 

Acknowledged 

Comment partially accepted  
See above 

Comment accepted  
See above 

Comment accepted  
See above 

264 

 
 
 
Topic 

Relation 
organic 
products 

Feedback from stakeholders 
It would create an uneven playing field and legal uncertainty about verification and compliance. 
The EEB proposes clarifying that if a high percentage of organic produce are procured (>50%), 
additional criteria on integrated production could be dropped. 

to 

JRC-Directorate B5 assessment 

Comment no longer applicable 
See above 

Continuing to define integrated production as a technical criterion is questionable as it is neither 
defined nor controlled in all the Member States. In many countries where there the Sustainable 
Pesticide Use has been implemented to some degree such criteria do not even have any added 
value as produce produced using such methods is a standard requirement. Therefore, including 
IPM criteria would not give advantage to more sustainable producers, products or food service 

Comment accepted  
See above 

Maritime and aquaculture products 
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  

Table 68. Feedback from the stakeholders on the TR2.0: Maritime and aquaculture products 
Topic 
Endangered 
species/ 
Biodiversity 
preservation 

Feedback from stakeholders 
Improvements  regarding  biodiversity  should  be  added:(cid:13)-  Realization  of  measures  to  avoid 
negative  impacts  on  surrounding  ecosystems  provoked  by  location  and  cultivation  process  - 
especially negative impacts because of waste water and escaping fish.(cid:13)New installations should 
not cause the degradation or destruction of endangered ecosystems (e.g. mangrove forest, rain 
forest,  Natura2000  habitats).(cid:13)-  The  aquaculture  company  implements  a  sustainability  plan 
including  measures  to  prevent  the  degradation  /destruction  of  surrounding  ecosystems(cid:13)-the 
aquaculture company prefers native species for aquaculture. If non-native species are used, the 
company  realizes  appropriate  measures  to  avoid  the  escape  of  non-native  species  into 
surrounding ecosystems.(cid:13)-the aquaculture company maintains and protects native vegetation in 
aquaculture ponds (at least 5 % of the total surface of the ponds). 

Criteria for the protection of biodiversity are not considered and should be included 
- see my comments on page 9 for aquaculture 
- see my comments on page 9 for crops as well as oil and fats. 
Food has been produced with products have been cultivated /produced respecting the: 
- The implementation of a Biodiversity Action Plan 
- The implementation of a water management plan for the sustainable use of water resources 

JRC-Directorate B5 assessment 
Comment accepted  
As  we  have  now  drafted  the  criterion  it  encompasses 
biodiversity protection. A fraction of the fish purchased must 
come from the stocks  exploited at a rate that is consistent 
with producing the highest catch from the stock in the long 
term,  the  so  called  marine  sustainability  yield.  That  entails 
that the stocks have a proper management plan in place to 
producing  the  highest  yield  in  the  long  term,  so  they  are 
inside safe biological limits. 
Specific points listed do not have a verification system, being 
not accessible for the tenderer to access. 
See above 

265 

 
 
 
 
 
- The consideration of nutrient balances and product specific nutrient limits 
- The prohibition of pesticides with negative impacts in bees or other pollinating insects as well 
as on fish 
- No use of total herbizides 
Food has been produced with products which have been cultivated on farms which have not been 
created based  on  the  destruction  of  primary  ecosystems  (e.g.  tropical  forest,  peat  bogs).  Basis 
year: 2005   
In the case of food from wild plants, the wild plants have been collected according to the Fair-
Wild  Standard,  UEBT-Standard  or  a  similar  standard to  guarantee  the  sustainable  collection  of 
wild plants. 
No products from GNO modified plants and animals 

Food prepared with products from traditional plants /breeds should be preferred because of the 
contribution to the protection of agro-biodiversity 
Biodiversity performance should be considered in the Award Criteria! 
1. Points must be awarded proportionally to tenders in which more than X%2) of the amount of 
marine  food  products  purchases  not  complying  with  the  organic  produce  criterion  have  been 
produced meeting the requirements of a certification scheme for sustainable production that is 
based  on  multi-stakeholder  organizations  with  a  broad  membership  and  addresses 
environmental impacts including over-fishing or depletion, effective measures for the protection 
of biodiversity and responsible and sustainable use of the resources3). 
As  we  highlighted  in  the  previous  consultation,  different  certification  schemes  for  marine  and 
aquaculture  products  should  be  contemplated,  as  there  are  specific  ones  in  each  country 
according  to  the  seasonal  availability.  In  this  sense,  we  would  like  to  include  the  one  in 
attachment that also advocate for the protection of marine ecosystems and the re-establishment 
of sustainable fishing. 

An additional comprehensive criterion should be that 80% of any product not complying with an 
organic  certification  or  a  seafood  ecolabel  as  described  under  3)  should  be  “green”  or 
“recommended”  in  the  sustainable  seafood  guide  that  has  been  chosen  by  the  procurer  as 
reference.  

Certification 
schemes 

Comment accepted 

Comment rejected 
Purchase of marine products with certification schemes are 
deemed  to  comply  as  a  mean  of  verification  with  the 
criterion.  In  the  previous  technical  report,  Table  34  of  this 
Annex provides the list of schemes in EU-28 for the PAs to 
consult. For the seasonal aspect read above. 
Comment rejected 
As  agreed  by  the  majority  of  stakeholders  technical 
specifications,  both  at  the  core  and  comprehensive  level 
should  be  accessible  for  SMEs  Certification  schemes  are 
deemed  to  comply  but  can  not  be  requested,  since  they 
represent  a  burden  for  SMEs due  to  the  cost  increase.  It  is 
moreover  up  to  the  public  authority  to  select  the  figure 

266 

 
 
 
 
 
and 

Ask for at fish seasonal calendar in the tender? 

Lists 
seasonal 
calendars 

Marine and aquaculture: should the 'fish to avoid' list not be read together with fish calenders? 
Shouldn't this give an extra guarantee on avoiding the depletion of fish stocks? 

We welcome the inclusion of more third-party lists of fish to avoid. 

However, we consider that it would be very difficult to select only one of the existing lists due to 
differences in regional availability of different kinds of fish. For instance, the Marine Conservation 
Society list is UK-focused, so it might not make sense to apply it in other countries. 
We recommend that it is clearly indicated that in most of the EU MS (currently more than 70% of 
the EU MS) a national seafood guide is available and reflecting the national market. 

This is the list of the current national WWF Seafood guides for EU MS: 
Austria: www.fischratgeber.wwf.at  
Belgium: https://wwf.be/assets/Uploads/guid-pois-FR-21-08-15-195257.pdf  
Bulgaria: riba.wwf.bg  
Croatia: www.kojuribukupiti.org 
Denmark: http://www.wwf.dk/wwfs_arbejde/hav_og_fiskeri/wwf_fiskeguide/ 
Estonia:  http://www.wwf.se/wwfs-arbete/hav-och-fiske/wwfs-fiskguide/1243694-wwfs-fiskguide-
nar-du-ska-kopa-miljovanlig-fisk (Covered by SE WWF guide) 
Finland: http://wwf.fi/kalaopas/ 
France: www.consoguidepoisson.fr 
Germany: http://fischratgeber.wwf.de/desktop/#/ 
Greece: fishguide.wwf.gr 
Italypescesostenibile.wwf.it 
Latvia:  http://www.wwf.se/wwfs-arbete/hav-och-fiske/wwfs-fiskguide/1243694-wwfs-fiskguide-
nar-du-ska-kopa-miljovanlig-fisk (Covered by SE WWF guide) 

requested as % of total purchases. 
Comment rejected 
With  respect  to  seasonality,  due  to  the  controversy  around 
the subject it is proposed to be left aside (read the removal 
of  seasonal  food).  The  majority  of  the  fish  served  in 
canteens is frozen in any case. 
Comment rejected 
Fish is sometimes  purchased frozen, therefore the inclusion 
of the calendars although is not prevented is not specifically 
stated. 
Comment rejected 
The  PAs  will  always  have  the  freedom  to  suggest  the  list 
that better fits the local conditions. Read the footnote 1) for 
the equivalent lists. 

Comment accepted 
In  the  footnote  1)  we  have  included  now  the  reference  to  
Table  34  where  available  seafood  guides  for  EU  28  are 
compiled. 
Comment acknowledged 
We  have  moreover  included  now  the  reference  to  Table 34 
where  available  the  footnote  1)  where  available  seafood 
guides for EU 28 are compiled. 

267 

 
 
 
 
 
 
by 

SE 

WWF 

(Covered 

http://www.wwf.se/wwfs-arbete/hav-och-fiske/wwfs-fiskguide/1243694-wwfs-
guide) 

Lithuania: 
fiskguide-nar-du-ska-kopa-miljovanlig-fisk 
The Netherlands; http://www.goedevis.nl/ 
Poland: http://ryby.wwf.pl/publikacje/Available 
Portugal: guiapescado.wwf.pt 
Romania: ghidpeste.wwf.ro 
Slovenia: www.kateroribokupiti.si 
Spain: http://guiadepescado.com 
Sweden:http://www.wwf.se/wwfs-arbete/hav-och-fiske/wwfs-fiskguide/1243694-wwfs-fiskguide-
nar-du-ska-kopa-miljovanlig-fisk 
In order to avoid that the tenderer deals with contradictory recommendations the procurer should 
choose: 
One specific Seafood guide as main reference e.g. a national WWF seafood guide 
A potential second reference Seafood guide exclusively to cover species that are not covered on 
the first reference. In addition, as a minimum legal basis, an exclusion of Any sea or freshwater 
species assessed by the IUCN Red List as Critically Endangered or Endangered excluding products 
of species coming from aquaculture with closed life cycle (no impacts on wild populations) 
Any  wild 
1 
Endangered, Threatened and Protected Species as defined by national legislation or international 
agreements 
We recommend that the core criteria should comprise an exclusion of seafood under minimum 
conservation  reference  size  according  to  scientific  advice  as  listed  in  inter  alia  comprehensive 
seafood guides such as the national WWF seafood guides.  
Regarding  the  recommended  values  for  the  core  criteria  and  comprehensive  criteria,  we 
recommend  adding  “depending  on  local  availability  of  certified  sustainable  seafood  products”. 
The availability of certified aquaculture products can be an issue in some countries, particularly in 
Eastern Europe. 

freshwater 

Appendix 

species 

under 

CITES 

listed 

sea 

or 

Option A is the preferred as it is the most simple way to check the cost of product purchased 
under certain conditions 
This should specify whether this is intended to include both fresh and frozen fish as the mass for 
frozen fish is heavier than for fresh fish. To be clear, we would not want to see this become a 

Recommended 
values 

Comment rejected 
The  PAs  will  always  have  the  freedom  to  suggest  the  list 
that better fits the local conditions. Read the footnote 1) for 
the  equivalent  lists.  Moreover,  as  we  have  now  drafted  the 
criterion  it  requires  that  a  fraction  of  the  fish  purchased 
must  come  from  the  stocks  exploited  at  a  rate  that  is 
consistent with producing the highest catch from the stock in 
the long term, the so called marine sustainability yield. That 
entails  that  the  stocks  have  a  proper  management  plan  in 
place to producing the highest yield in the long term, so they 
are  inside  safe  biological  limits  (size  requirements  are 
considered within). 

Comment acknowledged 
The  sentence  has  not  sense  since  a  certification  scheme  is 
not  requested  but  certification  schemes  are  deemed  to 
comply.  The  recommended  values  span  from  0  to  a  higher 
value  in  agreement  with  the  higher  of  ambition  that  the 
public  authority  is  able  to  afford  (according  both  to 
availability and cost). 
Comment acknowledged 

Comment rejected 
The PAs will always have the freedom to choose the mass or 

268 

 
 
 
 
 
cost  options  that  better  fits  the  local  conditions,  value  in 
agreement with the higher of ambition that they are able to 
afford (according both to availability and cost). 
Comment acknowledged 

Comment acknowledged 

Comment rejected 
As  agreed  by  the  majority  of  stakeholders  technical 
specifications,  both  at  the  core  and  comprehensive  level 
should  be  accessible  for  SMEs  Certification  schemes  are 
deemed  to  comply  but  can  not  be  requested,  since  they 
represent  a  burden  for  SMEs due  to  the  cost  increase.  It  is 
moreover  up  to  the  public  authority  to  select  the  figure 
requested as % of total purchases according to the level of 
ambition  that  the  public  authority 
is  able  to  afford 
(according both to availability and cost). 

way to discourage the use of frozen fish because frozen fish offers the benefit of staying edible 
for longer than fresh fish, thereby avoiding food waste. Another solution could be to eliminate the 
% by mass option for this criterion and to have it only be based on % in value of total purchases. 
As a general comment, when it comes to some processed foods, caterers sometimes don't have 
records of the mass because they might be ordered by boxes or bottles. Usually caterers use a 
value-based  calculation  and  convert  it  to  mass  through  an  equation  rather  than  by  actually 
weighing or tracking the weight. 
In the example of marine products option A is more preferable. For other product ranges option B 
is more suitable. 
We  recommend  a  minimum  of  60%  by  weight  or  volume  for  both  marine  and  aquaculture 
products for comprehensive criteria.  

We  recommend  that  :  Core  criteria:  Points  must  be  awarded  proportionally  to  tenders  in which 
more  than  20-60%  of  the  amount  of  marine  and  aquaculture  food  products  purchases  not 
complying with the organic produce criterion have been produced meeting the requirements of a 
certification scheme for sustainable production that is based on multi-stakeholder organizations 
with  a  broad  membership  and  addresses  environmental  impacts  including  over-fishing  or 
depletion, biodiversity and responsible and sustainable use of the resources and 20-80% of the 
amount  of  marine  and  aquaculture  food  products  purchases  not  complying  with  the  organic 
produce  criterion  and  not   meeting  the  requirements  of  a  certification  scheme  for  sustainable 
production  that  is  based  on  multi-stakeholder  organizations  with  a  broad  membership  and 
addresses environmental impacts including over-fishing or depletion, biodiversity and responsible 
and sustainable use of the resources are “green” rated or “recommended” in the seafood guide 
chosen as a main reference. 
Comprehensive  criteria:  Points  must  be  awarded  proportionally  to  tenders  in  which  more  than 
60% of the amount of marine and aquaculture food products purchases not complying with the 
organic produce criterion have been produced meeting the requirements of a certification scheme 

269 

 
 
 
 
 
 
 
 
(EU) 

impacts 

Regulation  

for  sustainable  production  that  is  based  on  multi-stakeholder  organizations  with  a  broad 
membership  and  addresses  environmental 
including  over-fishing  or  depletion, 
biodiversity and responsible and sustainable use of the resources and 80-100% of the amount of 
marine  and  aquaculture  food  products  purchases  not  complying  with  the  organic  produce 
criterion and not  meeting the requirements of a certification scheme for sustainable production 
that  is  based  on  multi-stakeholder  organizations  with  a  broad  membership  and  addresses 
environmental  impacts  including  over-fishing  or  depletion,  biodiversity  and  responsible  and 
sustainable use of the resources are “green” rated or “recommended” in the seafood guide chosen 
as a main reference.  
In a general way, more explanatory notes should be provided to clarify the differences between 
the percentages in mass and in value, as percentages in value should be higher if they want to 
match percentages in mass.  
For the verification it should be highlighted that the tenderer should provide verified information 
that as a minimum includes the information that needs to be provided to the end consumer (see 
COM 
IV 
chapter 
No 
https://ec.europa.eu/fisheries/sites/fisheries/files/docs/body/eu-new-fish-and-aquaculture-
consumer-labels-pocket-guide_en.pdf    and  respective  regulation  for  tuna  Council  Regulation 
(EEC)  No  1536/9  and  sardines  Council  Regulation  (EEC)  No  2136/8).  This  level  of  information 
encompasses i.a. latin species name, production country (aquaculture) or catch area (wild catch) 
and  gear.  This  information  is  also  required  to  ensure  compliance  with  the  core  criteria  TS2.  In 
addition  adequate  traceability  should  be  ensured  (see  next  section).  Traceability  and  labelling 
Adequate traceability should be ensured in order to guarantee compliance with the criteria. This 
could  be  ensured  either  via  a  Chain  of  Custody  certification  of  a  recommended  Seafood 
certification or with compliance with the WWF seafood traceability principles. Link to traceability 
principles: 
http://assets.worldwildlife.org/publications/796/files/original/WWF_Traceability_Principles_for_Wild
-Caugh_Fish_April_2015.pdf?1430410438. WWF remains available to discuss further details on 
traceability or other criteria. 
The supplier do not decide what to supplie durring the execution og the contract. It is the kitchens 
that decide what to buy and when. That is why it would make sense to  
The only way to ensure that at least Y% of the amount of marine food products offered that not 
complying  with  the  organic  food  products  criterion  must  have  been  produced  meeting  the 
requirements  of  a  certification  scheme  for  sustainable  production  that  is  based  on  multi-
stakeholder  organizations  with  a  broad  membership  and  addresses  environmental  impacts 

1379/2013, 

Comment rejected 
Explanatory  notes  and  further  explain  the  differences 
between selecting one or other unit in a call for tenders. 
Comment rejected 
In the EU market, there is a common legal framework that 
sets the food safety requirements that ensure that only safe 
food  and  feed  is  placed  on  the  EU  market  or  fed  to  food-
producing  animals  and  traceability.  To  require  minimum 
information is a must for the suppliers, out of the scope of 
the EU GPP (read page 5, scope). 

Comment acknowledged 
This is a guide to perform a green choice and can not fix the 
way the % is calculated. Public authorities may do it the way 
it suit them best according to local specificities. 

270 

 
 
 
 
Antibiotics/Anti
microbial 

including  over-fishing  or  depletion,  biodiversity  and  responsible  and  sustainable  use  of  the 
resources is to lock some og the products and take the mass asked for in the tender and dividing 
this with the total mass of the tender. 
As commented at the 2nd AHWG meeting and also mentioned in the minutes page 7: "However, it 
was pointed out that the procurement of merely food is very different from the procurement of 
food for the catering services. In the first case the menus are decided in the kitchen while in the 
second case, the menus are fixed by the procurer. These differences should be reflected in the 
criteria wording accordingly.", it is very important to have this in mind when formulating the the 
criteria.  I  have  tried  to  explain  this  under  "2.1.  Organic  food  products" and  "2.1.3  Marine  and 
aquaculture ...." 
As  we  also  highlighted  in  out  previous  consultation,  the  use  of  antimicrobials  in  aquaculture 
should be addressed (please, see in attachment our position paper). 

As  the  WHO  says  (http://www.fao.org/antimicrobial-resistance/en/):  "Antimicrobials  are  often 
misused for treatment and prevention of diseases in livestock sector, aquaculture as well as crop 
production. These actions are often associated with the potential risk of emergence and spread of 
antimicrobial  resistant  micro-organisms".  For  this  reason,  we  also  call  at  a  high-level  for 
strengthening  the  AMR  surveillance  and  monitoring  programmes  for  aquatic  animals  and 
products,  and  for  a  better  regulatory  infrastructure  and  legal  framework  for  good  aquaculture 
practices by proving other models, as the proposed in our document, are possible and must be 
replicated. 
Certified  organic  aquaculture  products  should  come  under  the  aquaculture  product  criteria  too. 
The reference to “x% of the amount of aquaculture food products purchased not complying with 
the  organic  criterion”  is  extremely  confusing to  procurers  coupled  with  the fact  that  no explicit 
reference  to  organic  aquaculture  is  made  in  the  organic  food  product  criteria.  Reference  to 
organic  aquaculture  products  is  needed  in  both  the  organic  food  products  and  aquaculture 
products in the criteria to avoid confusion. Procurement of conventional aquaculture should not 
undermine organic aquaculture procurement. The criteria should also make more reference to the 
ways in which the different aquaculture products are raised and their environmental impact e.g. 
use of antibiotics, hormones, use of unsustainable feed. 

General 

In general, the EEB supports the proposed criteria but suggests strengthening them by following 
the clarifications and improvements as suggested in the comments of the WWF. 

Comment acknowledged 

Comment acknowledged 
The mentioned surveillance and monitoring programmes are 
out of the realm of the EU green public procurement. What 
EU  GPP  can  (only)  do  is  a  green  choice  among  the  ones 
provided by the market.  

Comment acknowledged 
Organic  aquaculture  is  deemed  to  comply  and  has  to  be 
computed under the organic food criterion, since this is the 
way the EU GPP has been designed. The sentence that may 
lead to confusion has been changed. 
Provisions on animal feed, including hygiene and medication 
or the use of antibiotics are in place. Therefore, there is no 
added value on specifically requesting it. For the verification 
purposes of these particular issues, the public authority has 
no other way than rely on a certification scheme. 
Comment acknowledged 

271 

 
 
 
 
 
 
 
Further research analysis 

Marine sustainability yield 
Most European landings of commercial fish and shellfish stocks come from the North-East Atlantic Ocean and Baltic sea (86%). Approximately 60% of commercial fish landings 
comes from stocks that are assessed with Good Environmental Status (GES) information. Strong regional differences exist, where the Mediterranean and Black seas remain 
poorly assessed. 

Around 58% of the assessed commercial stocks are not in GES. Only 12% are in GES for both the level of fishing mortality and reproductive capacity. These percentages also 
vary considerably between regional seas. 

The use of commercial fish and shellfish stocks in Europe, therefore, remains largely unsustainable. Nevertheless, important signs of improvement for certain stocks are being 
recorded in the North-East Atlantic Ocean and Baltic Sea. 

One of the fundamental objectives of the Common Fisheries Policy is that stocks are fished at a level that can keep them at maximum sustainable yield (MSY). 
In  general  terms  stocks  are  characterised  as  being  outside  safe  biological  limits  (or  overfished  stocks)  when  the  fishing  pressure  (mortality)  exerted  on  them,  exceeds 
sustainability i.e. when mortality exceeds recruitment and growth. 

The Commission's goal, and one of the pillars of the EU's reformed Common Fisheries Policy (CFP), is to have all stocks fished at sustainable levels by 2020 at the latest. Fishing 
at Maximum Sustainable Yield (MSY) levels allows the fishing industry to take the highest amount of fish from the sea while keeping fish stocks healthy. Europe started in 2009 
with only 5 Total Allowable Catches of stocks at MSY. By now (2017) there are more than 40 stocks to MSY in the North Sea, the Atlantic and the Baltic Sea and sets the 
foundation so that all stocks are fished at sustainable levels in the next two years. 

The CFP also aims to eliminate the wasteful practice of discards in EU fisheries by gradually introducing an obligation to land all catches. The agreement therefore includes so-
called quota "top-ups" for some fisheries that will come under the landing obligation in 2016. 

Fishing agreements and total catches 

Total allowable catches (TACs) or fishing opportunities, are catch limits (expressed in tonnes or numbers) that are set for most commercial fish stocks. The Commission prepares 
the proposals, based on scientific advice on the stock status from advisory bodies such as (ICES) and Scientific, Technical and Economic Committee for Fisheries (STECF). Among 
the tasks of the latter committee is to monitor the evolution of policy and good practices for the conservation and management of living marine resources, including biological, 
economic, environmental, social and technical considerations. 

272 

 
 
 
 
 
 
 
 
 
 
TACs shared between EU countries are set annually for most stocks (every two years for deep-sea stocks) by the Council of fisheries ministers. EU countries are responsible for 
ensuring that the quotas are not overfished. When all the available quota of a species is fished, the EU country has to close the fishery. For stocks that are shared and jointly 
managed with non-EU countries, the TACs are agreed with those (groups of) non-EU countries 

Bilateral agreements with countries outside the EU 
For stocks that are shared and jointly managed with non-EU countries, the TACs are agreed with those (groups of) non-EU countries. The EU has 2 types of fishing agreements 
with non-EU countries: 

•fisheries partnership agreements – the EU gives financial and technical support in exchange for fishing rights, generally with southern partner countries. 
•northern agreements – joint management of shared stocks with Norway, Iceland and the Faeroe Islands. 

Sustainable fisheries partnership agreements 
Sustainable fisheries agreements with non-EU countries are negotiated and concluded by the Commission on behalf of the EU. They are intended to allow EU vessels to fish for 
surplus stocks in that country's exclusive economic zone (EEZ), in a legally regulated environment. These agreements also focus on resource conservation and environmental 
sustainability, ensuring that all EU vessels are subject to the same rules of control and transparency. At the same time, a clause concerning respect for human rights has been 
included in all protocols to fisheries agreements. 

There are two main types of agreements: 

Tuna agreements – allow EU vessels to pursue migrating tuna stocks as they move along the shores of Africa and through the Indian Ocean. 
Mixed agreements – provide access to a wide range of fish stocks in the partner country's exclusive economic zone. 

In exchange, the EU pays the partner countries a financial contribution composed of 2 distinct parts: 

•access rights to the EEZ 
•"sectorial"  financial  support  which  aims  to  promote  sustainable  fisheries  development  in  the  partner  countries,  by  strengthening  their  administrative  and  scientific 

capacity through a focus on sustainable fisheries management, monitoring, control and surveillance. 

The EU has currently 12 active SFPAs protocols in force with third countries: 

•8 tuna agreements: Cape Verde, Ivory Coast, Sao Tomé and Principe, Madagascar, Senegal, Liberia, Seychelles and Cook Islands 
•4 mixed agreements: Mauritania, Morocco, Greenland and Guinea-Bissau 

The  EU  has  also  9  "dormant"  agreements  with  Mauritius,  Mozambique,  Micronesia,  Solomon  Island,  Gambia,  Gabon,  Comoros,  Kiribati  and  Equatorial  Guinea.  "Dormant 
agreements" stand for countries which adopted a fisheries partnership agreement without having a protocol into force, for structural or conjonctural reasons. EU vessels are 
therefore not allowed to fish in waters under the regime of the dormant agreements. 

Northern agreements 

273 

 
 
 
 
 
 
 
 
 
EU fishing activities in the North Sea and north-east Atlantic are closely linked to those of our neighbours – Norway, Iceland and the Faeroe Islands. With many of the targeted 
stocks shared across boundaries, it makes good sense for all 4 parties to coordinate their activities, especially as the different fleets aren’t necessarily interested in the same 
stocks. 

So  many  of  the  stocks  concerned  are  jointly  managed,  and  quotas  are  exchanged  to  ensure  they’re  not  wasted.  Some  of  these  stocks  are  managed  through  the 
intergovernmental  North-East Atlantic  Fisheries  Convention set  up  to manage  fish stocks  in  the  region,  while  others  are  managed through  agreements  between the  coastal 
states. 

These agreements are extremely important to a large section of the EU fleet, especially the agreement with Norway, which covers quotas worth over €2bn. 

The  EU has  also entered  other  international  agreements  and  conventions  that  have  a  bearing  on  fisheries. Among them  is  the  commitment made  at  the  World  Summit  on 
Sustainable Development in 2002 to reduce fishing to the level which gives the highest yield in the long run (maximum sustainable yield) by 2015 and to use an ecosystem 
approach in fisheries management. The EU is party to the Convention on Biological Diversity and the Convention on International Trade in Endangered Species of Wild Fauna and 
Flora (CITES). 

The law which applies to the high seas is founded on the United Nations Convention on the Law of the Sea (UNCLOS), which entered into force in 1994. An important element of 
UNCLOS was the undertaking by all signatory countries to promote sustainable fishing. 
Further info at https://ec.europa.eu/fisheries/cfp/international/agreements 

EU Market Observatory for Fisheries and Aquaculture products (EUMOFA) 

EUMOFA is an online tool developed by the European Commission to enhance market intelligence and to contribute to transparency and efficiency of the market for fishery and 
aquaculture products. Producers, processors, importers, retailers, consumers, markets' analysts and policy makers may all find useful information in the observatory. 

EUMOFA enables direct monitoring of the volume, value and price of fishery and aquaculture products, from the first sale to retail stage, including imports and exports. Data are 
collected from EU countries, Norway, Iceland and from EU institutions and updated every day. 

Eco-label  

Over the past 20 years, eco-label schemes have emerged on the EU market, a development linked to increased public awareness of the need to ensure sustainable exploitation 
of marine resources. Today, the EU is the main market for certified products. 

On 18 May 2016 the European Commission adopted a report on the feasibility of an EU ecolabel scheme for fishery and aquaculture products. The report will now be debated 
by the European Parliament and the Council. 

274 

 
 
 
 
 
 
 
 
 
 
 
 
Animal welfare 
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 69. Feedback from the stakeholders on the TR2.0: Animal welfare 
Topic 
Drafting of the 
criterion 

Feedback from stakeholders 
We would change this sentence to: "requires low stress, minimum use of antibiotics, stunned 
slaughter, minimum transportation times and address ...."   
The way of formulation is complex. Could this be changed? 

Antibiotics 

Mountain 
products 

Eggs 

Taking into consideration, resistance to antibiotics is considered one of the greatest global 
threats to public health and environment, we call for addressing this issue from the food 
procurement by purchasing meat-products raised without routine antibiotic use (or as mentioned 
later on in the procurement of catering services, reducing the offering of animal-based products).  
Information about antimicrobials used for feed and drinking of animals should be indicated in 
labels and procurement contracts; and in case they don't, procurers may be able to claim a 
waiver for that product.  

As you acknowledge in our previous consultation, we propose the inclusion of the scheme 
explained in the Regulation (EU) No 665/2014 with regard to conditions of use of the optional 
quality term ‘mountain product’ (please, see attached document for more information).  
We were wondering whether you could specify it in the text. Thank you in advanced!   

Most companies have made commitments to use cage-free (no code 3) so we can support the 
proposal for the TS 4. 
It would be extremely difficult to move to 80% free range in the short-term. We recommend 
include a range as has been done elsewhere. 

We would like to ask that procurers include a provision in the contract that allows for some 
flexibility in the sourcing criteria when supply challenges are due to a force majeure. For instance, 
in Belgium and many other countries, egg producers are no longer able to label their eggs free-

JRC-Directorate B5 assessment 
Comment accepted 

Comment accepted 
The  wording  has  been  slightly  changed  and  a  note 
introduced 
Comment accepted 
The  wording  of  the  requirements  has  been  changed  to 
require the "minimum use of antibiotics".  

Comment rejected 
Information  on  those  aspects  would  depend  on  the 
requirements  of  the  standard  that  is  used  to  label  the 
products 
Comment rejected 
The  schemes  that  awards  products  with  the  mountain 
include  environmental 
product 
requirements  but  they  are  based  on  the  quality  of  the 
products.  
Comment accepted 

certification  do  not 

Comment rejected 
The threshold proposed is for the AC, meaning that it is not a 
mandatory  threshold  to  be  fulfilled  by  all  the  tenders. 
Additionally, the threshold is included as explanatory note in 
the range from 80% to 100%. These values can be modified 
by the contracting authorities if they consider that the values 
are not suitable for that region or service.  
Comment accepted 

275 

 
 
 
Topic 

TS vs AC 

Rationale 

Rationale 

Thresholds 

Feedback from stakeholders 
range because of precautionary measures to stop the spread of bird flu. This has resulted in a 
major shortage on the Belgian market. By including a force majeure clause, it will help to avert 
cases of non-compliance for reasons that are beyond the caterer’s control.        
There is a missed opportunity to support the market for products that comply with higher animal 
welfare standards by only having a Technical Specification on eggs. We advise that meat and 
dairy are also included as a Technical Specification. 
We recommend that this AC should be a TS 
Proposed additional paragraph: "Farm animal welfare involves both the physical and psychological 
well-being of an animal. How they are raised and treated can have important repercussions, not 
just for animal welfare, but for environmental sustainability, food security, and the economic well-
being of farmers. Improving animal welfare can have positive impacts for sustainability and 
livelihoods in a variety of systems." 
Opportunities to both improve animal welfare and climate change impacts exhibit areas of co-
benefits and trade-offs. Shields and Orme-Evans (2015) outline these areas and show that a 
number of opportunities to achieve co-benefits exist. 
Potential co-benefits should be included here. 
Proposed additional language:  
Reducing animal product procurement could result in co-benefits of improved consumer health, and 
reducing the number of land animals raised for food in the EU, the number currently over 8.3 billion  
annually, alongside the environmental benefits. Halving consumption of animal products could 
nearly halve European agricultural reactive nitrogen.  Further, a recent study shows global economic 
savings based on public health and environmental improvements from more plant-based foods.   
In relation to animal production and the environment should be much more looking at the 
environmental impact of the production of individual products. Here there is a big difference in 
how much the burden to e.g. produce 1 kg pig in Denmark compared to other countries and again, 
there are differences within the various forms of production. In relation to the environment, 
organic shows not to be the strongest, so are other values it is about. In fruits and vegetables 
include greater resource efficiency. You could also write under the meat. 2.1.6 is explained better. 
It may be helpful to get the explanation for the encoding which is described in the "Rationale for 
the proposed criteria wording" in a note: Eggs with code 1 are free-range eggs while eggs coded 3 
are coming from caged hens. 
As mentioned in a previous comment, this is an opportunity to support the implementation of 
higher welfare standards across the EU28 so we recommend that a minimum threshold on 

JRC-Directorate B5 assessment 

Comment rejected 
The  lack  of  an  EU  regulation  prevents  the  inclusion  of  a 
criterion  on  meat  products  dealing  with  animal  welfare 
aspects as TS.  
Comment accepted 

Acknowledged 

Comment rejected 
This information is not directly related to the animal welfare 
criterion  but  has  been  considered  for  the  revision  of  the 
criterion on plant-based in the Catering services criteria set.  

Acknowledged 

Comment accepted 

Comment rejected 
The  lack  of  an  EU  regulation  prevents  the  inclusion  of  a 

276 

 
 
 
 
 
 
 
 
Topic 

Plant-based 
criterion 

Animal welfare 
vs 
organic 
production 

Feedback from stakeholders 
products complying with animal welfare standards of 25% to 50% should be included as a 
Technical Specification rather than an Award Criteria.    
Animal welfare can be improved in both small and large scale production systems often for 
relatively small production cost increases, bringing together improvements in food quality and 
food safety, while also showing a greater respect for the behavioural needs of animals. 
Regarding the criterion on meat, as we said before, the availability in all the EU-28 varies widely, 
and cost implications would be significant. 
We question the exclusion of these products? None of these products would be suitable for a 
vegetarian diet and indeed should not be included in dishes served as vegetarian. 
We recommend the inclusion of dairy and eggs as an additional category of animal products, as 
discussed during the 2nd AHWG meeting, as an Award Criteria for additional animal product 
reduction. 
In relation to the requirements for egg production, is this criteria not very low for meat? 
Important points about eggs. Milk is also an important by-product in many foods and should be 
covered equally. Nota about antibiotics that push the issue from ethical issues to health issues 
should be given high priority. 
As recognised, the dairy industry has a large impact on the environment and on animal welfare. 
Shifting away from red meat could encourage the substitution with meat from monogastric farm 
animals such as chickens and pigs, and both animals tend to be more intensively farmed, which 
could contradict GPP animal welfare criteria. 
Therefore, we recommend amending the text to “Limiting the servings of meat, dairy and eggs” 
and the deletion of "especially red meat".   
Certified organic animal products should come under the animal product criteria too. The 
reference to “X% of the eggs/meat not complying with the organic food products criterion” is 
extremely confusing to procurers coupled with the fact that no explicit reference to these 
products is made in the organic food product criteria. Free range egg criterion, for example, 
should not undermine the procurement of organic eggs. It is important to highlight also that 
organic agriculture already has clear and high standards for animal welfare compared to 
conventional produce. These products should not exclude organic labelling.   
The EEB recommends including organically produced meat into the AC for animal welfare. 

JRC-Directorate B5 assessment 
criterion  on  meat  products  dealing  with  animal  welfare 
aspects as TS. 

Acknowledged 

Comment accepted 
This  information  does  not  directly  relate  to  the  Animal 
welfare criterion but it has been considered under the Plant-
based criterion.  

Comment rejected 
This  criterion  does  not  exclude/undermine  the  organic 
products but it enhances those that are produced observing 
animal welfare provisions.  
The  EU  organic  regulation  provides  the  requirements  for 
producing  under  the  organic  standards  while  this  criterion 
observes the requirements to produce under animal welfare 
conditions.  

277 

 
 
 
 
from 

Environmentally responsible fats (previous  
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 70. Feedback from the stakeholders on the TR 2.0 Environmentally responsible palm oil  
Topic 
Change 
AC to TS 
Avoiding  palm 
oil 

Feedback from stakeholders 
As xxxx, commented during the meeting, these criteria should not be award criteria, but selection 
criteria (SC) under the specification of "try to avoid as much as possible". In this way, suppliers will 
not get additionally points for the use of certified palm oil, which has multiple impacts in our 
environment and health. Also, we think this kind of oil will not be promoted over other vegetable oils, 
and more when there is no criteria on other vegetable oils produced in Europe, such as olive oil, 
sunflower oil or canola oil. 
As mentioned before, we do consider these criteria should not be award criteria, but selection criteria 
(SC) under the specification of "try to avoid as much as possible". We wonder why we are using so 
much palm oil in products consumed particularly by children. This kind of oil would not be promoted 
over other vegetable oils, and more when there is no criteria on other types vegetable oils produced 
in Europe, such as olive oil, sunflower oil or canola oil. 
This award criterion would punish caterers and food producers who try to use other vegetable oils 
where possible because competitors who use palm oil from a sustainable certification scheme would 
have an advantage. 
It could also cause an adverse incentive for caterers to purchase more palm-oil containing products 
or cooking oil in order to win more points.  
We would recommend removing this from the Food criteria and moving this to the selection criteria 
for caterers.(cid:13)This criterion should be about the caterer’s commitment to sustainable palm oil, so 
under the Section Criterion on Competences of the tenderer, caterers could be asked to provide a 
method statement on the “sourcing of sustainable palm oil in packaged foods and cooking oil”. 
In our opinion there is no environmentally sustainable palm-oil. Therefore, it should be moved from 
the award criteria to selection criteria. The selection criterion should say that "palm oil, 
environmentally responsible certified or not, should be avoided as much as possible". My comments 
above are also valid for oils and fats! 
Palm oil cannot be AC because it gets promoted this way. It should be TS. There are healthier options 
with an ok-footprint. Therefore I advise to avoid palm oil where possible and if there's no other 
option than it has to be environmentally (and social) responsible palm oil. see attachment palm oil 
fat and footprint 
Products should not be prioritized on the basis that they contain sustainable palm oil over other oils. 
Points should be awarded proportionally to tenders with the smallest percentage of products that 

Change  to  TS 
or SC 
Avoiding  palm 
oil 

JRC-Directorate B5 assessment 
Comment accepted 
The award criterion on environmentally responsible palm 
oil proposed in the TR 2.0 promotes in a certain way the 
consumption of this type of vegetable oils over others as 
the tender receives points for it.  
We agree that no promotion of any vegetable oil should 
be included in this GPP criteria set, but at the same time 
we  recognized  that  when  palm  oil  is  used,  it  should  be 
ensured that causes the lowest environmental impact as 
possible.  
As  the  criteria  on  FOOD  procurement  can  only  be  set 
referring to  the  properties  of the  product,  only  AC  or  TS 
can be established. Proposing this criterion as TS could be 
a possibility that ensures that if palm oil is purchased, it 
will be certified. This criterion is evaluated and compared 
to  the  offers  of  other  tenderers  and  therefore  we 
consider that is the most suitable alternative.  

See above 

278 

 
 
 
Topic 

Feedback from stakeholders 
contain palm oil. Within this range, sustainable palm oil should be favoured. 

JRC-Directorate B5 assessment 

Need  of  using 
palm oil 

Market data 

Market data 
Certification 
schemes  

Core and comprehensive: avoid palm oil and if that is not possible make sure it is environmentally 
responsible palm oil 
Palm oil isn't easy to avoid but it's mostly used in ready-made foods. A lot of these foods are on the 
'unhealthy' list and thus better to be avoided.  
The high Council of Health in Belgium made following study on palm oil and also advices to avoid it. 
http://www.health.belgium.be/sites/default/files/uploads/fields/fpshealth_theme_file/19088464/De%20problematiek%20va
n%20de%20atherogene%20verzadigde%20vetzuren%20en%20palmolie%20(update%20november%202013)%20(HGR%2
08464).pdf 
The global production of palm oil is about 42 million MT coming mainly from Indonesia and 
Malaysia. The substitution of palm oil in recipes by other vegetable oils is not straightforward and if 
it is possible it will have an impact on cost. This oil cannot be banned from the tenders today. 

Please replace this sentence: "The availability of palm oil certified through the most demanding 
traceability systems is currently widely available in Italy, Latvia and UK, and progressing in France, 
Austria, Spain and Belgium" with "The availability of palm oil certified through the most demanding 
traceability systems is(cid:13)currently widely available in The Netherlands, UK, Belgium, Germany, Austria, 
Switzerland, France and progressing in the Scandinavian countries, Italy, Latvia, Poland, and Spain". 
I don't think this is correct. RSPO has by far the largest market share. RSB is not available in the 
market and is a biomaterials scheme and not a food scheme. ISCC is also a biofuels scheme and 
their plus module has gained some interest from companies for vegetable oil use that is not covered 
under Round Table schemes, like sunflower or rapeseed. SSI (2014) has done market studies that 
supports this 
There is not the same tenacity and the same needs as the food mentioned under fairly traded to 
pass the certification schemes (in a good way) connection palm oil production. RSPO has also proved 
to be good business for producers. I do not think this is a problematic field. 
The RSPO label: is this the only label on the market? are there other options? 
In the report, there is reference to environmentally responsible palm oil. I wonder why it does not 
speak about sustainable palm oil as this also covers production compliant with social criteria. 

Comment partially accepted 

Comment accepted 

Comment accepted 

Comment accepted 

Comment accepted 
The wording related to the schemes that can be used to 
demonstrate  that  palm  oil  has  been  responsibly  grown 
and  harvested  has  been  changed.  RSPO  remains  as  the 
only example.  

Comment accepted 
The  scheme  proposed  to  show  compliance  with  the 
criterion 
requirements 
(beyond the environmental one). In this sense, the criteria 
could be called "sustainable palm oil". However, as GPP is 
focused  on  environmental  issues,  we  consider  that  the 

includes  other 

requirements 

279 

 
 
 
Topic 

Feedback from stakeholders 

Ambition level 

Due to the high environmental impact of palm oil, the EEB recommends to increase the share of 
sustainable palm oil to 100% (organic production or "identity preserved" and "segregated" palm oil). 

References 
the rationale 

in 

Please refer to http://www.rspo.org/certification/rspo-next 
Please add:  
http://www.rspo.org 
http://www.rspo.org/members/all 

JRC-Directorate B5 assessment 
currently proposed title is more appropriate.  
Comment partially accepted 
Due to the high environmental impact it is proposed that 
when palm oil is used, this ingredient should be covered 
by a certification scheme.  
The  distinction  among  the  tracking  systems  have  not 
been proposed as there are no evidences on the market 
availability of each type of tracked palm oil.  
Comment accepted 

Fair and ethical trade products (BEFORE Fairly traded products) 
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 71. Feedback from the stakeholders on the TR2.0: Fair and ethical trade products  
Topic 
Implementation 
of a biodiversity 
action plan 
required 

Feedback from stakeholders 
There are differences regarding the biodiversity performance within standards for fairly trade 
products. Products certified with a standards which requires the implementation of a biodiversity 
action plan (or conservation plan) should be preferred! 
The biodiversity performance of standards for fairly traded products differs from one standard 
to the other. 
The  Award  criteria  should  include  the  implementation  of  a  sound  Biodiversity  Action  Plan  (or 
Conservation  Plan)  as  a  requirement  of  the  standard  who  certifies  the  products 
Option A 
Points must be awarded proportionally […] in accordance with ILO, sustainable trade and pricing 
as well the implementation of a biodiversity action plan (or conservation plan). 
UTZ and Bonsucro that are not members of the Fair Trade movement. 
In the report "Standard and the Green Economy" in 2014 there are no references to the fact that 
UTZ is a Fair Trade label. 
Please take a look at the charter of the Fair Trade principles the EC COM (2009) on Fair Trade 
which makes a distinction between Fair Trade and other sustainability schemes (such  as UTZ 
and Bonsucro). 

Certification 
schemes 

JRC-Directorate B5 assessment 
Acknowledged 

Comment reject 

Comment reject 
The title of the criterion "Fair and ethical trade products" does 
not refer to the Fair Trade movement and those labels that 
are included in this movement as a proof of compliance.  
The  name  was  selected  to  express  the  need  of  looking  at 
products  that  are  taking  care of  different  aspects including 

280 

 
 
 
Topic 

Feedback from stakeholders 

Ambition level 

JRC-Directorate B5 assessment 
the environmental aspects, labour conditions or pricing.  
Comment accepted 
The  ambition  level  of  the  option  A  has  been  increased 
accordingly 
An option B has been added being a combination of a list of 
products and a min % 

As  in  other  cases,  we  call  for  thresholds  more  ambitious,  in  this  case  even  for  core  criteria; 
taking into consideration coffee, tea and chocolate - products highly procured by public bodies - 
just come from third countries.  
The  JRC  should  increase  the  share  of  fair  trade  products  to  at  least  50%  by  weight  of  the 
purchased coffee, tea, chocolate (cocoa), sugar or bananas for the core criteria and to 100% for 
the comprehensive criteria 
The recommended values for core criteria are not ambitious in the percentages. 
The recommended values core criteria should be X=40-60% of total purchases of each product: 
coffee, tea, chocolate (cocoa), sugar and bananas. 
There should be a difference made between fairly traded labels and sustainable traded labels. 
Fairly traded labels should guarantee that there's a fair price paid for the product. A fair price 
means that it covers production costs which allow the producer to self-support him/her in daily 
needs and it can foresee in good life circumstances on the long term. And this on top of the 
environmental criteria. 
If a product claims to be fairly traded then that is 100. Sustainability labels as UTZ, rainforest 
already grant their labels at less percentage. 
The award criteria: 
Add option B to option A: work with percentage + list. Write which products you want to be fairly 
traded. Let those product be 100% fairly traded otherwise it becomes difficult to check it. for 
example if you procure for coffee, tea and sugar than choose for coffee to be 100% fairly 
traded, tea can be conventional and sugar also has to be 100% fairly traded. 
Although city of Ghent prefers fairly traded labels. Maybe it's an option to grant lower points to 
a sustainable label and grant a higher score to fairly traded labels? 
Can exotic fruit juices be added to the summary? 
Could also include avocados, tomatoes, and vanilla, unless they are the ones named “tertiary 
products". 
The recommended values for comprehensive criteria are not ambitious in the percentages. 
The recommended values for comprehensive criteria should be X=70-100% of total purchases 
of each product: coffee, tea, chocolate (cocoa), sugar and bananas.  
Core: should be 50% and comprehensive should be 100% 
Explanatory notes: core should be 50% and comprehensive should be 100% 
For cocoa and coffee the world supply on organic is certainly below 1% so impossible to reach  Comment rejected 

281 

 
 
 
Topic 

Feedback from stakeholders 
the % defined in TS1 
For chocolate, the level of organic product is lower that 1% in the world. Impossible to comply 
with the general statement 

and 
trade 

Organic 
fairly 
products 
Verification  

Strange approach to have higher values requested in Organic Food than Fairly traded product. 
The logic would be to ensure first Fairly traded product and then Organic Food? 

Some caterers source products that are certified under the certification schemes mentioned in 
this criteria, so we are not opposed to sourcing these products. 
However, a key question is: Who will verify if the “fairly traded” certification schemes are 
compliant with the criteria proposed here? Who will check whether working conditions in 
accordance with ILO and sustainable trade and pricing are being observed in production? Should 
the contracting authority or the contract caterer fly to Kenya to check the tea and coffee farms? 
The only EU legislation governing these certification schemes is the Unfair Commercial Practices 
Directive and provisions about misleading claims. There is no EU legislation that defines what 
we consider “fairtrade standards” and “sustainable trade”. 
Unlike the EU organic regulation, there are no fixed rules about what is “fairly traded”. A scheme 
could set low standards to in order to meet the 90% threshold, while another scheme might set 
high standards. 
Like with integrated production, we believe “fairly traded” needs to first be defined by the EU 
(co-legislators and broader stakeholder group) before setting EU GPP criteria about which 
certification schemes are in or out in order to ensure a level playing field and to allow for 
compliance and verification. 
Another key question is: what about products that are not from developing countries?, for 
instance sugar that is produced in Belgium and the Netherlands, which is not Bonsucro certified? 
Would this not create a discrimination against European sugar producers? 
We recommend removing this from the EU’s GPP criteria in the absence of an EU-harmonised 
definition of what a fairly traded product is and is not. 
Fairtrade highlighted as a recognized standard: It is super to require third - party certification or 
equivalent. Beware however that it does not become a burden on the producers who may make 
more than one certification as Fairtrade requires or makes it different - it will not be too 
difficult to prove it: "Procurers can also verify the purchases of fairly traded products throughout 
the detailed invoices. Invoices of the food and drink products purchased should be detailed 

JRC-Directorate B5 assessment 
As  commented  by  some  other  stakeholders,  currently  the 
demand of organic products (e.g. chocolate) is not so high to 
cause a shortage of this product or an excessive increase in 
the price. 
Comment rejected 
The approach is based on the market availability of products 
in Europe. 
The  verification  of  the  criteria  included  in  the  criteria  is 
proposed  to  be  done  by  checking  the  certification  scheme 
that  covers  the  food  or  food  product  and  checking  and  its 
minimum  requirements.  For  example,  if  the  GPP  criterion 
requires that the working conditions should be in accordance 
with ILO and the certification scheme that covers the food or 
food  product  also  includes  this  requirement,  then  it  is 
automatically verified.  

Comment accepted  
Regarding the discrimination of non-EU sugar and EU sugar 
a clause has been added indicating the EU sugar is excluded 
from this requirement.  

Comment rejected 
The  verification  of  this  criterion  by  detailed  invoices  is  not 
possible  when  the  TS  and  AC  are  evaluated.  These  criteria 
are evaluated before signing the contract and, mostly before 
purchasing the products.  

282 

 
 
 
 
Topic 

Feedback from stakeholders 
enough and include the name of the product, the quantity in mass or volume and the costs" 
Important to be very aware of these requirements and consider the classic banana case in 
which a third-party certification in countries with widespread corruption can lead to distortions 
in the market and ultimately culminate in slave-like conditions. 
We are working towards cooperation and dialogue across supply chains, and away from the 
controls, audits and certifications. The dialogue one retailer may have with landlords and 
farmers is very important to reward. 
We welcome the change in wording in the ‘Fairly Traded’ criteria. As the JRC itself 
acknowledges, with the use of ‘Fairly Traded’ instead of ‘Fair Trade’, confusion with the Fair 
Trade trademark is avoided. 
There should be a difference made between fairly traded labels and sustainable traded labels. 
Fairly traded labels should guarantee that there's a fair price paid for the product. A fair price 
means that it covers production costs which allow the producer to self-support him/her in daily 
needs and it can foresee in good life circumstances on the long term. And this on top of the 
environmental criteria. 
If a product claims to be fairly traded then that is 100. Sustainability labels as UTZ, rainforest 
already grant their labels at less percentage. 
The award criteria: 
Add option B to option A: work with percentage + list. Write which products you want to be fairly 
traded. Let those product be 100% fairly traded otherwise it becomes difficult to check it. for 
example if you procure for coffee, tea and sugar than choose for coffee to be 100% fairly 
traded, tea can be conventional and sugar also has to be 100% fairly traded. 
Although city of Ghent prefers fairly traded labels. Maybe it's an option to grant lower points to 
a sustainable label and grant a higher score to fairly traded labels? 
Can exotic fruit juices be added to the summary? 

Interaction 
between fairly 
traded products 
and organic 
products 

The fairly traded product criterion has huge potential to complement the organic criterion, but 
the complementarity between the two criteria is still not explicitly apparent. At this moment the 
list of products remains limited to coffee, tea, chocolate (cocoa), sugar and bananas but should 
be adjusted accordingly when the market evolves. In addition, products that can be produced in 
Europe e.g. apples should be promoted over produce sourced outside of Europe. 

JRC-Directorate B5 assessment 
The  checking  of  the  invoices  to  verify  that  the  tender 
performs as promised is included in the CPC 

Comment accepted 

Comment  partially accepted 
An option B has been added to the proposal 

Comment accepted 
This product has been added as suggestion in option B 
Comment partially accepted 
EU  products  cannot  in  accordance  with  the  single  market 
principles be promoted over the non-EU products.  
The revision of the thresholds and listed products is foreseen 
as  a  tasks  carried  out  by  the procurer  his/herself  or  by  the 
European Commission at the time of the next revision.  
Finally  the  relation  among  both  criteria  ""fairly  trade"  and 

283 

 
 
 
 
Topic 

Feedback from stakeholders 

Revision  of  the 
rationale 

Inaccuracies on the WFTO guarantee system.  
The sentence should be replaced with the following “The World Fair Trade Organisation counts 
with a guarantee system, which is recognised by the EC Communication EC COM (2009) 215 final 
as a system implementing Fair Trade criteria".   
Inaccuracies on the Fairtrade system   
A product that wants to carry the Fairtrade label has to follow the rule that every ingredient 
that can be Fairtrade, must be Fairtrade. This is easy for coffee and bananas for example, but 
much more difficult for chocolate or biscuits. For example, for biscuits, the sugar, chocolate, 
nuts have to be Fairtrade, while the flower, butter and/or milk do not have to be Fairtrade. 
Moreover, at least 20% of the total volume of the ingredients must be Fairtrade.   

Further research analysis 

JRC-Directorate B5 assessment 
"organic"  is  done  in  the  rationale;  "This  criterion  does  not 
exclude  those  products  that  are  complying  with  the  organic 
food  product  requirements  for  two  main  reasons:  there  is  a 
wide  availability  of  products  that  are  double  labelled  (in 
accordance  to  organic  produce  and  fairly  trade)  and  both 
criteria address aspects completely different. 
Comment accepted 

Comment acknowledged  
We  acknowledge  the  remark.  After  the  screening  of  the 
voluntary  schemes,  the  most  comprehensive  ones  reach  to 
90% of certified content. This is the reason to specify in the 
criterion that a 90% of the content of the product is certified 
by a fair and ethical trade scheme. 

Certification schemes 
The State of Sustainability  Initiatives (SSI) Review 2014 Standards and the Green Economy' (IISD and IIED, 2014), gathers the description of the most relevant schemes of 
sustainable  production,  together  with  the  market  information  of  the  penetration  of  these  schemes  within  some  product  categories.  A  brief  description  of  each  initiative  is 
explained below (IISD and IIED, 2014). 
Round Table on Responsible Soy 

The Round Table on Responsible Soy (RTRS) is a member-based initiative founded in 2006, which works in the sector of responsible  soy value chains. The initiative 
develops and manages standards for responsible soy production and operates across 21 countries. The RTRS offers a generic set of principles and specific criteria for 
genetically modified, conventional and organic production systems. The initiative operates business to business. RTRS units are evaluated for certification each year, by 
means of third party audits and, accredited auditors. RTRS offers a separate Chain of Custody certification and applies the segregation and mass balance models of 
supply chain traceability to its products to ensure accountability of compliance claims in the marketplace (IISD and IIED, 2014). 

ProTerra Foundation 

The  ProTerra  Foundation  is  a  member-based,  not  for-  profit  foundation,  starting  in  2012.  The  ProTerra  Standard  is  applicable  to  any  food  or  agricultural  product, 
although it is currently used mainly for soy production and soy-derived consumer products. The initiative operates business to consumer, developing standards and 
managing and maintaining quality control over certification. The validity period of ProTerra certificates is one year, with all audits conducted by third-party auditors. 

284 

 
 
 
 
Identity preservation and the segregation models of supply chain traceability are applied to all ProTerra soy products to ensure accountability of compliance claims in 
the marketplace. (IISD and IIED, 2014). 

Market penetration of standard compliant food products for soya  
Soybeans are widely present in the global food chain; from edible oils to a source of protein for humans and livestock feed. According to SSI Review 2014 (IISD and IIED, 2014), 
approximately 87 % of all soybean production is crushed into soy meal and soy oil, with the remaining 13 % for direct human consumption. From the soybean crushing process, 
roughly 80 % is extracted as soy meal for use in animal feed, and 20% is extracted as oil for human consumption and as a biofuel feedstock. The total production of standard-
compliant soybeans (including ProTerra, RTRS and organic), represent a small share of the market, at 2.0 %, which is equal to 5 million tons (2012). Sales of standard-compliant 
soybeans were equivalent to 1.5 % of exports. ProTerra certified soybeans account for the largest volumes of soybeans of the major voluntary sustainability standards active in 
the sector, with 3.4 million metric tons certified in Brazil in 2012 or 5.2 % total Brazilian soybean production and 6.4 % Brazilian exports. 

Feedback from stakeholders 

Seasonal produces 
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 72. Feedback from the stakeholders  
Topic 
Seasonal products removal 
In  favour  on 
re-introducing 
seasonal 
products 

We strongly believe that Seasonal Products intended as "locally seasonal products" should stay in 
the GPP criteria as an important category. Many public institutions are collaborating with regional 
farmers across Europe to procure fresh, locally sourced and seasonal  products, including in the 
healthcare  sector.  By  taking  out  this  category  their  efforts  will  be  hampered.  We  believe  that 
there  is  not  such  a  category  as  globally  seasonal  products,  as  any  product  can  fall  under  this 
category.  In  addition,  locally  seasonal  products  have  a  lower  carbon  footprint  than  products 
sourced  from  far  away.  Locally  seasonal  products  also  contribute  to  increasing  local/regional 
economic growth.   
In the hope that locally seasonal products are reintroduced, we believe that guidelines should be 
provided to procurers on how to set seasonal calendars and on which specific info they have to 
ask to local/regional farmers.   
As we mentioned during the meeting, we do believe this criteria (applying the definition of "locally 
seasonal" i.e. produced in the natural production season and consumed within the same climatic 
zone),  should  be  re-introduced  as  a  TS  in  the  section  of  food,  or  failing  this,  in  the  section  of 
catering services as a requirement for "food procurement" or "staff training".  
From  our  point  of  view,  this  will  benefit  the  environment,  the  food  diversity,  and  the  local 
economy. For  more 
blog 

information, 

recommend 

reading 

this 

the 

of 

I 

JRC-Directorate B5 assessment 

Comment rejected 
According to the literature revision there are several aspects 
to  be  considered  in  relation  ot  the  overall  environmental 
impacts of food products and their source of origin:  
- the main contribution to the overall environmental impact 
of  food  products  seems  to  be  the  production  phase  rather 
than  the  transportation.  In  this  sense,  local  products  can 
score a higher environmental impact that imported products 
or products that are grown in other climatic areas 
-  the  impact  of  the  transportation  largely  depends  on  the 
mean of transport used. Shipments and train transportation 
have  lower  environment  impacts  that  products  transported 
by  airplane  or  even by  road  transportation.  Indeed most  of 
the  literature  points  out  that  the  higher  contribution  to  the 
environmental  impacts  of  transportation  is  due  to  the 
transport  from  the  warehouse  of  the  retailers  to the  shops 
and from the shops to the consumers' houses. This impact is 

285 

 
 
 
JRC-Directorate B5 assessment 
the same for both local and non-local products. 
-  the  origin  of  the  products  are  very difficult  to be  verified 
when  purchasing  in  a  large  scale.  Feedback  from  the 
stakeholders indicated that even if it is stated that a product 
should  be  bought  when  the  local  calendar  indicates,  this  is 
not  a  guarantee  that  the  product  will  be  locally  produced. 
The purchase will depend on their prices.  

For  these  reasons,  a  criterion  on  seasonal  locally  products 
has not been re-introduced.  
However, an Explanatory note is proposed to be included in 
the  criteria  document  on  this  issue.The  explanatory  notes 
indicates  that  the  contracting  authorities  can  require 
indicating "what  food  and when  the  food  and  drink  products 
must  be  bought".  This  quotation  makes  reference  to  some 
tools such local calendars for fruits and vegetables 
See above 

Topic 

In  favour  on 
re-introducing 
seasonal 
products 

Feedback from stakeholders 
post: https://theconversation.com/when-it-comes-to-food-could-reactive-sometimes-be-best-66463 
In case it is considered the "globally seasonal" (i.e. produced in the natural production season but 
consumed anywhere in the world) definition in the final criteria, we recommend the provision of 
some guidelines for procurers about the different calendars and/or which information they have 
to ask to their supplier, who sometimes also unknown the season in those countries. 
It  is  important  to  grow  fruits  and  vegetables  on  the  right  soil  and  in  the  right  climate  (avoid 
depletion of water source etc). On the other hand as a procurer you want fruit and vegetables of 
good  quality.  Freshness  and  nutritional  value  should  be  taken  into  account  when  fruit  and 
vegetables are harvested. Buying out of season lowers the quality and raises the price. You can 
add it as a contract performance clause and describe what kind of fruit and vegetables you want 
to procure/on the menu at what time of the year. It wouldn't harm to raise awareness on how 
fruit and vegetables are grown/transported. There are greenhouses that are energy sufficient and 
there are better (by land/sea) and worse (by air) ways to transport. 

I do not agree on removing the criterion "seasonal produce" from the GPP. It takes less energy to 
produce  free  range  seasonal  products,  and  the  taste,  quality  and  vitamins  in of  sun  grown 
products are also better. Also, many wishes and expectations from the public, when it comes to 
meals  produced  in  the  public  catering  system,  is  based  in  cultural  and  culinary traditions  that 
revolve around seasonal produce.  
It is important to distinguish between catering procurement and food procurement as mentioned 
in the minutes from the 2nd AHWG meeting. "This requirement is very different in food 
procurement from catering service procurement. For example, strawberries grown in season can be 
purchased all year (depending on the part of the world in which they were grown) while the 
procurer can require by means of menu planning that strawberries must be purchased and served 
in June. In this second example, the procurer adapts purchase to each month, choosing different 
products depending on the seasons."  
In both types of tenders it is important to ask for fruit and vegetables in season to make sure 
that wherever the crops are grown is done in the most sustainable way - saving energy by 
prioritizing crops grown in fields, without the use of hothouses or heating that is often powered 
by fossil fuels. 
In catering procurements you can describe that the food served should be traditional food, using 

286 

 
 
Topic 

In  favour  on 
re-introducing 
seasonal 
products 

Feedback from stakeholders 
the crops that are in season. 
In food tenders you should only ask for the fruit and vegetables when you know that there is a 
demand for them in the kitchens. (In our kitchens in Copenhagen tomatoes and cucumber are 
used all year, but strawberries and asparagus are mainly used in May, June and July.)  
By taking this into account in the tender, we minimize food waste from the suppliers, who this 
way, will only be obliged to have strawberries in stock in the months where the kitchens are 
actually demanding them. As our contracts have been made so far, we have sought strawberries 
when the supplier thought they were in season somewhere in the world. As a result, the supplier 
should calculate with wholesaler sometimes experience a major shrinkage of their stock, because 
maybe the kitchens do not want to buy the strawberries even though they are available  since 
culinary traditions might not incorporate the use of strawberries in typical December menus.  I 
think that by offering the new way proposed in the minutes from the 2nd AHWG meeting, we 
minimize food waste at the supplier side, and by that save resources. 
This may seem logical, but for the procurement officers, it is illogical to procure for specific 
goods only in certain months of the year, as they will be nervous that it will be misunderstood as 
an attempt to act locally, and not as an attempt to specify what time of year we want to buy a 
given product. I think this would really be a help to underline that it of cause is legal to ask for 
the wanted goods only when you historically know that they are used industrial the kitchens. 
Another thing that might be good to focus on is the biodiversity of fruits and vegetables in public 
tender. It could be beneficial to the resilience of our environment if the public procurement could 
support the demand for different varieties of apples, plums, pears, carrots and potatoes. 
A monotonous and large production of e.g. apples can keep long in stock and thus might be 
economically favourable, but the sensory quality of monocultures can sometimes be 
questionable. There is a strong case to be made for maintaining a broad variety of different fruits 
and vegetables on the market, both because of the diversity in flavours and sensory qualities, 
which directly enriches the diet and experiences of the citizens and end users, as well as the 
spectrum of different culinary properties that adhere to different varieties of the same family of 
vegetables (for instance, only some types of plums lend themselves well to poaching and 
canning, others lack the texture and disintegrate when they are heated even slightly). 
If seasonal produce is removed it should remain as a technical criterion for menu planning (i.e. 
for individual ingredients). 
In the EEB’s opinion the GPP criteria should give incentives to avoid unnecessary environmental 
impacts caused by using fruit and vegetable imported via aircraft. Catering can be used to 

JRC-Directorate B5 assessment 

See above 

287 

 
Topic 

re-

Against 
introducing 
seasonal 
products 

re-

Against 
introducing 
seasonal 
products 

Feedback from stakeholders 
demonstrate how seasonal grown fruit and vegetable can be prepared in a tasty way. 
The EEB urges the JRC to reintroduce an AC for catering services on using seasonal calendars for 
purchase of most frequently used fresh fruits and vegetables as part of their menu planning. 
That’s what several procurers at local level have already implemented, e.g. in Copenhagen. This 
criterion has also been integrated in the sustainability criteria for meal services and catering, 
published by The National Agency for Public Procurement in Sweden. 
In the Netherlands we are currently discussing the impact of for seasonal products and whether 
we should develop criteria for this. They are important if they have an environmental impact. We 
don’t see practical problems to implement this in menu planning and we do not support the 
statement that seasonal products would lead to a reduction of fruit and vegetables. We do see a 
challenge to develop general criteria for criteria and making sure it will lead to the right choices. 
This however should not be a reason the delete it as a topic in the criteria. 
There is a need for clarity on how the EU defines seasonal / local food without creating trade 
barriers. If a definition can be agreed, we could support keeping seasonality as an intention under 
3.2.3 Promotion of vegetarian (plant-based) menus. 
In that section, a point could be added: “Make use of fruits and vegetables in season when 
available and affordable, and while ensuring variety and nutritional balance.”  
We would not want this to be limited to only seasonal fruits and vegetables as variety and 
nutritional balance would be limited in Northern Europe particularly. 
We recommend maintaining the deletion of the ban on refrigerated food from the previous 
version, as restricting the use of refrigerated and frozen food would increase food waste since 
fresh food is wasted more often than processed food and refrigeration helps to keep food 
fresher for longer.    
In agreement with seasonal produce removal 
We welcome the elimination of the seasonal criteria and the related rationale provided 
considering global and local seasonality of products. 

JRC-Directorate B5 assessment 

See above 

See above 

Packaging 
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 73. Feedback from the stakeholders on the removal of packaging criterion 
Topic 

Feedback from stakeholders 

JRC-Directorate B5 assessment 

288 

 
 
 
JRC-Directorate B5 assessment 
Comment accepted 
The GPP criterion on packaging has been removed from the 
Food  procurement  criteria  set.  Some  of  the  sub-criteria 
proposed  have  been  integrated  however  in  some  of  the 
Catering  services  criteria  such  as 
"disposable  and 
consumable goods" or "other waste: prevention, sorting and 
disposal". 
With these two criteria, we try to prevent the generation of 
waste  due  to  packaging  and  other  materials  that  can  be 
avoided  without  decreasing  the  quality  of  the  product  or 
replaced by reusable goods.  
Additionally,  these  criteria  aim  at  ensuring  that  those 
disposable  items  used  are  made  of  materials  that  can  be 
easily treated during their EoL. . 

Topic 
In  favour  of 
removing 
packaging 
criteria 

Feedback from stakeholders 
We support the removal of the packaging criterion for the reasons listed by the JRC. 
We support the removal of the packaging criterion. 
EUROPEN welcomes the JRC proposal to remove this section on packaging, based on a life-cycle 
approach (LCA) reasoning. 
EUROPEN fully agrees with the arguments put forward by the JRC to support this removal, 
including that the GPP should not “favour/penalise the choice of packaging material since this is 
dependent on the situation in which they are being used”. The JRC also rightly puts forward the 
“difficulties to assess the distance for returning the reusable packaging (e.g. to wash and refill the 
bottles)”, “the lack of infrastructure for sorting, collecting and composting biodegradable and 
compostable packaging” or the “trade-offs in the use of single unit packaging”. 
The JRC argumentation in favour of this section’s removal also positively highlights that 
packaging should be considered as an integral part of the product and “hence cannot be assessed 
in isolation”. 
Although EUROPEN welcomes that the packaging section is proposed to be removed for LCA 
reasons (see our comments under section 2.1.7), we deplore that this report still includes some 
restrictive requirements on certain types of packaging (e.g. calls to avoid single-use, single-
portion and unnecessary or excessive packaging in this waste prevention section. Based on the 
same LCA reasoning which applied for section 2.1.7 on packaging, EUROPEN urges to remove 
these restrictive requirements on certain types of packaging in the Waste Prevention section. 
These restrictive requirements on certain packaging as laid down in this Waste Prevention section 
seem inconsistent with the JRC explanation provided for the removal of the packaging criteria, i.e. 
“GPP should not favour/penalise the choice of packaging material since this is dependent on the 
situation in which they are being used” which EUROPEN fully supports. Also, as the JRC rightly 
stresses under section 2.1.7., packaging should be considered as an integral part of the product 
and “hence cannot be assessed in isolation”. 
We also caution against the promotion in this waste prevention section of reusable packaging 
and packaging made of recycled content, without any regard to packaging’s functionalities. We 
support the life-cycle approach as we are painfully aware that a one size fits all measure does 
not work for all packaging materials and will distort the market and create winners and losers 
unfairly, while not necessarily leading to net environmental improvements. 
Packaging is an integral and essential part of the food and drink supply chain, from the 
production stage to the consumption stage. Its primary function is to contain, preserve and 
protect the product throughout the manufacturing, transport, storage and consumption chain, 
enabling the proper and safe delivery of the product from the producer to the final user. It 

289 

 
 
JRC-Directorate B5 assessment 

See above 

Topic 

In  favour  of 
removing 
packaging 
criteria 

Feedback from stakeholders 
protects goods from damage, allows efficient transport distribution, offers convenience, prolongs 
shelf-life, enables easy use, informs the consumer and helps to promote goods in a competitive 
market place. 
Packaging’s roles and functionalities, but also its environmental performance, are relevant at 
different stages of a packaged product’s lifecycle and are different for each packaging type. 
For example dry products, whether coffee powder or washing powder, need packaging that keeps 
moisture out. Meat products require packaging that keeps moisture in. Other functionalities can 
keep light out (e.g. wine and beer), keep carbonation in (beer and carbonated soft drinks), keep 
microbes out (all food) as well as the obvious ones of protecting the product from physical 
damage or protecting the product user from the product (household cleaning fluids). 
Thanks to appropriate protection and format matching the needs of consumers, packaging helps 
to prevent food waste, at all stages of the supply chain. Smart and innovative packaging 
solutions play in particular a key supporting role (see in Annex EUROPEN’s Good Practices 
Examples on how Packaging contributes to food waste prevention). By protecting the product, 
packaging also prevents waste of the energy, fertilizer, raw materials and water that went into 
growing or making goods and the energy used to transport the goods from the producer to the 
retailer.  Hence, we would like to see this link more explicit in the JRC study. 
We welcome this removal as packaging environmental aspect has to be addressed and assessed 
together with the product it protects/serves 
We endorse the complete removal of the packaging criteria from the report 
Please find attached the copy a study offering tangible evidence of the beneficial role of single 
serve packaging to help reduce food waste in food services. 
The study carried out in French school canteens was commissioned by global cheese maker Bel 
Group and conducted by IFOP research institute. It covered nearly 60,000 meals in 33 French 
schools. 
The conclusions from this large-scale study highlighted that the waste rate of cheese is 60% 
lower for individually packed portions compared to cheese sliced on site and openly displayed. 
Overall the measured waste rate for individually packed cheese is only 6% compared to 15% for 
cheese slices prepared on site, according to the study findings. 
The study highlighted that, at all stages of meal delivery, single serve portions can significantly 
minimize the risk of waste. First, the leftover cheese on the tray is reduced (6% for single serve 
packed portions versus 9% for sliced cheese) due in part to the appropriate and adjusted serving 
size. Additionally, there are no losses during preparation (compared to 3% for cheeses sliced on 

290 

 
 
JRC-Directorate B5 assessment 

See above 

Topic 

Feedback from stakeholders 
site). Finally, there is no waste after service, as unused pre-packed portions can easily be returned 
to the fridge unlike un-packed cheese which is possibly discarded (3% of sliced cheese is wasted 
in this way). 
Avoiding single-use and individually wrapped items can also lead to increased food waste (as per 
the results of the large-scale study on cheese waste conducted in French school canteens), the 
environmental impact of which is generally much higher than the additional resources invested in 
the appropriate packaging. We would therefore ask for the removal of this sentence.  
The selection of packaging based on the only recyclability aspect may be counterproductive and 
lead to worsened environmental impact as demonstrated in this peer reviewed LCA 
(http://www.flexpack-europe.org/tl_files/FPE/sustainability/IFEU_exec_summary_%20Waste_Prevention.pdf). (See 
attached summary of the study) 
We would therefore ask for the removal of this sentence, or at least for specifying "when it makes 
sense on a sustainability point of view (supported by an LCA assessment) 
We welcome the elimination of packaging as proposed criteria. We support JRCs assessment that 
packaging is a complex subject from the environmental point of view. Such revision is aligned 
with the written comments provided by FoodDrinkEurope to the first Technical Report (March 
2016). Such reasoning should be applied equally to the Catering Services Criteria 3.2.5 on Waste 
prevention as these relate as well to the packaging of food served by catering services. 
European consumers expect to be able to consume healthy food and drinks, out of safe practical 
packaging that guarantees hygiene and safety. Reusable packaging and other alternatives does 
not always provide this guarantee. It is essential to avoid undermining food hygiene, consumer 
safety and public health by narrow pursuit of environmental objectives when procuring food and 
catering services. As stated during the Ad Hoc Working Group Meeting on 23 February, Pack2Go 
Europe supports the removal of the criterion on packaging. The report should acknowledge that 
packaging plays an important role (1) in guaranteeing consumer hygiene, food safety and public 
health; (2) in preventing food waste; and (3) in helping reduce environmental footprints. The 
report should have for basis tangible LCA studies and, therefore, it should not favour nor penalise 
the choice of packaging since this is heavily dependent on the situation in which the packaging is 
being used (see attached the comparative life cycle assessment study of tableware for 
alimentary use). 
Packaging Helps Reduce Food Waste 
Several LCA studies have demonstrated that using packaging significantly reduces food waste 
through  
(1) portioning and  

291 

 
Topic 

the 
of 

Against 
removal 
packaging 
criterion  

Feedback from stakeholders 
(2) an extension of the product life.  
The 2nd technical report acknowledged it by mentioning that “single unit packaging can reduce 
food/drink waste and indirectly improve water and energy efficiency during the preparation stage”. 
Packaging Protects Food Hygiene, Consumer Safety and Public Health  
Single use service packaging for food and drinks is vital to hygiene and public health in catering 
facilities, hospitals, retirement & care homes, as well as in public and private organisations, like 
prisons, educational establishments, and company canteens. 
Packaging Helps Reduce Environmental Impact  
Most single use packaging is recyclable. Innovative sorting technologies are being developed and 
used to address also the more complex and often very thin packaging items. In addition, single 
use packaging is the very best way to ensure the integrity of the products they contain and 
protect them, such as in transport and logistics and optimise overall environmental impact. Of 
course, in some situations, re-usable packs make most sense and offer truly valued solutions. Yet 
such packaging also has a particular environmental impact because water, chemicals and energy 
are needed to clean it for re-use. The Commission’s ongoing initiative to develop ways to assess 
product environmental footprints recognizes this. We need to minimize the impact of the whole, 
not just one element. In many cases, food packaging has a relatively small negative impact on 
the environment compared to the overall life-cycle impact of the products it protects and 
delivers. The most important thing to ensure is that we use the most appropriate packs for 
specific applications and do all we can to improve collection, recovery and recycling of as much 
packaging as possible once it has been used. 
Is there a possibility to add advice about packaging instead of completely removing the topic? 
You can put this advice in the TS or in CPC. For example: 
- packaging prevents food loss but too much packaging is unnecessary 
- minimise transport packaging where possible and ask suppliers to switch to reusable transport 
packaging 
- choose biodegradable/compostable packaging if there is the necessary recycling infrastructure 
- choose reusable packaging if the distance between cleaning/refilling facilities and place of use 
does not exceed 100km 
- keep on looking for new sorts of packaging that have a lower environmental impact. 

JRC-Directorate B5 assessment 

Comment partially accepted 

The criterion on packaging is proposed to keep out. However, 
tenders should be aware that packaging has an influence in 
one of the goals of the waste management plan: "Reduction 
of waste in the procurement of food and consumables" 

The  statement  "Select  the  appropriate  packaging  (format, 
protection,  preservation,  serving  portions,  etc)"  aims  to 
encourage the use of the packaging type that simultaneously 
fits  the  product  and  generates  the  least  amount  of 
packaging possible 

To me it is a shame that packaging is removed as a criterion.  

Acknowledged 

292 

 
Topic 

Feedback from stakeholders 
I will address this issue again under item # 2.1.8, below. 
To some  extent I agree that a packaging criterion is difficult one to handle, but I think that is 
because it is isolated as a product packaging criterion – i.e. we only talk about the packaging that 
the products are filled in (bottled) or the “wrapping” that is around the products to protect it 
during transportation. It we extend or restrict the criterion to cover transport packaging, it would 
maybe make more sense to have a packaging criterion. A lot of products are “over-packaged” 
because  
[1] the products are packaged in larger units,  
[2] for handling at warehouses  
[3] “misunderstood” protection etc.  
I believe that a lot of benefits could be obtained for the environment if producers, wholesalers 
and contract catering firms / kitchen etc. agreed on a system of reusable transportation 
packaging. e.g. wholesalers receive meat products from the meat industry in reusable 
transportation boxes. The wholesaler cleans the boxes and delivers the meat products on to the 
catering firms in reusable boxes, who return the boxes to the wholesaler, who again returns the 
boxes to the meat industry (prime producer). This eliminates the use of carton packaging in the 
entire supply chain. 
We are not in favour of removing of the packaging criteria for environmental performance as AC 
for packaging and for catering services. If packaging would be removed as a criterion, then there 
should be a recommendation for re-usable packaging material. Keeping such a criterion can act 
as a means of incentivising environmental performance by controlling and improving the use of 
resources (energy, water etc.), avoiding pollution and limiting climate change impact. Food 
packaging requirements should also be able to meet the needs of the user. Single packed 
products should be avoided. 
With regards to packaging, referring specifically to the technical report, some improvements 
could be made. Firstly, a wider spectrum of stages in food supply chain should be considered. 
This includes packaging exceptions for juice and soft drinks e.g. milk, juice, soft drinks and water. 
If bottled water could be replaced with tap water when it is possible, the environmental impact 
would be quite relevant. In many countries the quality of tap water is the same as the bottled one 
but not everywhere. 
The EEB disagrees with dropping any requirements on packaging in the criteria procurement. 
Instead we suggest reintroducing an AC for using refillable and reusable packaging at least for 
catering services in regions where sustainable return systems exist. This could be easily 

JRC-Directorate B5 assessment 

Comment rejected 
See above 
The recommendation on the packaging to be used has been 
integrated in the waste management plan 

Comment partially accepted 
Even  if  the  packaging  criterion  itself  is  proposed  to  be 
removed,  there  are  aspects  in  other  criteria  that  address  a 
reduction of the waste generated in the catering services.  
For example, there is a CPC that ensures the access to tap 
waste  using  reusable  cups  or  the  Other  waste  criteria  that 
requires the prevention of waste.  
The use of re-usable packaging is in line with this objective 

Comment accepted 
See the three statements included in the waste management 
plan proposed:  

293 

 
Topic 

the 
of 

Against 
removal 
packaging 
criterion 

Feedback from stakeholders 
integrated into the existing criteria on waste prevention for catering services along with 
prevention of single use trays, individual portion packaging etc. 
The previous JRC proposal on awarding fully (100%) compostable materials (according to 
standard EN 13432) for food-contaminated packaging or single use items could also be 
integrated into the TS8 criterion on environmental management measures and practices for 
catering services, if an effective separate collection of organics and their treatment in an 
industrial composting facility are established. 
These types of criteria have also been integrated in the sustainability criteria for meal services 
and catering, published by The National Agency for Public Procurement in Sweden. 
http://www.upphandlingsmyndigheten.se/en/sustainable-public-procurement/sustainable-procurement-criteria/food/meal-
services-and-catering/packaging/ 
JRC has decided to remove the criterion on packaging. Several examples were provided of the 
environmental benefits achieved by this removal. In the Netherlands we prefer the inclusion of 
packaging in the Catering criteria. The importance of packaging is supported by the ambitions in 
the Circular Economic package. Packaging does not seem important at first, but considering the 
high number and in fact the ease with which this can be changed this aspect should be high on 
the list of low risk measures. 

JRC-Directorate B5 assessment 

-  Select  the  appropriate  packaging  (format,  protection, 
preservation, serving portions, etc)  

- Select recyclable packaging where possible and provide the 
packaging  guarantees  for  food  safety  and  hygiene. 
Recyclable packaging includes compostable packaging.  

- Packaging return: return packaging for reuse when possible 

Comment partially accepted 
The inclusion of requirements on packaging has been moved 
to the catering service criteria set. However, it is not a stand-
alone  criterion  but  a  fundamental  part  of  the  Waste 
management plan criteria 

4.3. Table of stakeholder's comments on the propose criteria for EU GPP criteria for CATERING SERVICES 

This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  

Competences of the tenderer 
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 74. Feedback from the stakeholders on the TR1.0: Competences of the tender  
Topic 
Tasty 
vegetarian 
food 
Differences 
between 
criteria 

Feedback from stakeholders 
The criteria should be objective. Therefore, the word “tasty” should be removed from “method 
statement for the preparation of tasty vegetarian dishes”. 

There should be a difference made between selection criteria, technical specification and award 
criteria. 
SC: method statements about waste, energy, cleaning, driving, policies and management systems 
(as a translation of EMAS/ISO14001? This way it will be very usable for SME's) 

the 

JRC-Directorate B5 assessment 
Comment accepted 

Comment partially accepted 
As the criteria were proposed in the TR2.0 already followed 
the requirement of this comment. 
The  new  suggestions  will be  included  in  the  list  of  possible 

294 

 
 
 
 
Topic 

Feedback from stakeholders 
TS menu planning, promotion vegetables, vegetarian dishes. 
AC: organoleptic test of the meals, menu examples 
see attachment for example organoleptic test. 

Staff training 

Verification 

As a SC you can exclude a tenderer whether the training program is added or not to their bid.  
I think it will be a lot more difficult if you will judge the content/quality in your SC. How will you 
motivate this? 
For example you can put it in like this: 
SC: add the training program 
TS: minimum training (legally/habits in a sector) 
AC: extra useful training on specific subjects 
CPC: reports on who is trained, when, on what,... 
The EEB recommends using different means of verification for the competence of the tenderer 
such  as  test  meals,  references  for  vegetarian  menu  planning,  documented  feedback  from 
customers,  building  on  the  examples  that  front  running  public  procurers  have  already 
implemented to green their catering services.  
It is quite important that the customer accepts vegetarian dishes as a very tasty alternative to 
reduce  the  meat  proportion  in  public  food  services  and  catering  and  that  also  new  small  and 
innovative caterer should be given a chance. 

JRC-Directorate B5 assessment 
measures  to  be  selected  as  long  as  they  concern  with 
environmental aspects.  
The inclusion of organoleptic tests of the meals has not been 
included  due  to  the  subjectivity  of  the  test:  "The  primary 
drawback  of  organoleptic  testing  is  subjectivity.  The  tests 
depend on personal opinion, and researchers struggle to find 
subject pools large enough to accurately represent their target 
demographic. To compensate for this, organoleptic test results 
often  appear  alongside  data  obtained  by  more  objective 
means."  (source:  https://www.reference.com/health/organoleptic-testing-
55fb32bb6a9a5a8a#)  
An  AC  criterion  has  however  been  proposed  for  the  plant-
based menu that awards the effort made to go beyond the 
requirements set in the TS criteria  
Comment accepted 

Comment accepted 

Promotion of plant-based  
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 75. Feedback from the stakeholders on the Promotion of vegetarian dishes 

295 

 
 
 
Topic 
Wording of the 
criteria 

Feedback from stakeholders 
The term "promotion" implies some kind of activity to increase the "acceptance" and "palatability" 
of  the  vegetarian  menu  (e.g.  in  schools).  How  is  the  promotion  supposed  to  happen? 
Promoting  vegetarian  menus  might  require,  in  some  context,  "training  and  education"  or 
sensitization  of  recipients/clients,  in  order  to  make  them  aware  that  vegetarian  meals  are  not 
"imposed" nor "suffered" by anybody. 
In  order  to  encourage  the  production  and  consumption  of  pulses  in  Europe  and  fight  against 
climate  change,  we  call  for  the  specific  inclusion  of  them  in  these  criteria  by  establishing  a 
"minimum  percentage  of  pulses  per  day  or  total  of  plates  offered".  Please,  see  attachment  for 
understanding our reasons behind this proposal. 
We really welcomed these criteria, but we also believe vegetarian menus should be planned with 
the help of a dietician/nutritionist in order to supervise better alternatives, potential allergies and 
balance portion sizes.   

Plant based protein is important, because cheese and eggs also have their footprint. Don't forget 
that some meat substitutes can be unhealthy (too much saturated fats, salt, etc) and expensive. 
The  EEB  recommends  formulating  more  precise  recommendations  for  food  procurement  to 
favour  vegetarian  alternatives  like  e.g.  offering  a  number  of  vegetarian  dishes  per  week  or 
reducing the meat proportions to a level that is recommended by national nutrition guidelines.  
In addition, the contractor should have an instrument in place to optimize its  vegetarian offers 
according to customers’ preferences. Therefore, we propose to require mandatory implementation 
of  a  feedback  mechanism  where  customers  can  comment  on  the  size  of  food  portions,  the 
quality of the meal and the overall menu planning as a contract performance clause. 

TS vs AC 

We agree with the need to change consumption habits within health and nutritional 
recommendations, but we would suggest making this an Award Criterion rather than a Technical 
Specification to ensure that caterers who offer the most to cater for vegetarians are rewarded 
for their efforts. 

JRC-Directorate B5 assessment 
Comment accepted 
The word "promotion" has been removed from the criterion 

Comment accepted 
The  suggestion  has  been  included  in  the  list  of  possible 
measures  to  be  introduced  in  the  criterion  when  the  public 
authorities draft their own criteria 
Comment accepted 
The  clause  reading 
"whilst  maintaining  the  nutritional 
composition recommended  for  the  clients" is proposed to be 
reworded  as  "whilst  making  the  same  contribution  to 
recommended nutrient intake for the client" 
Comment accepted 

Comment rejected 
Food procurement criterion is based on the characteristics of 
the products but not in the relative proportions of those.  
Comment partially accepted 
The  implementation  of  an  instrument  to  optimize  its  offers 
and  also  the  vegetarian  offers  will  be  part  of  the  revised 
"CPC"  where  the  indicators  B2B  and  B2client  will  be 
introduced 
Comment partially accepted 
The  idea  of  including  an  award  criteria  for  rewarding  the 
efforts  of  the  tenders  is  very  welcomed  and  has  been 
introduced in this revision 
However,  it  is  still  relevant  to  keep  this  criterion  as  TS  to 
ensure that at least a minimum number of menus/dishes will 
be  cooked  by  using  pulses,  vegetables  and  fruits  and  the 
that a minimum consumption of these types of food will be 
reached.  

296 

 
 
 
Topic 

Re-introduction 
of 
menu 
planning 
criteria 

Feedback from stakeholders 
We  recommend  that  this  document  avoid  giving  the  impression  that  the  overall  price  of  the 
tender  will  decrease  because of  vegetarian  menus  because  there  should  be  the  opportunity  to 
reinvest the savings from reducing meat consumption into improving the quality of the food and 
service. 
Menu planning is an essential aspect of catering and a tool to control whether the criteria are 
met.  Promoting  vegetables  is just  one  aspect.  Every  tender should  have  guidelines  on how  the 
menu planning should be made and how there will be a follow-up on the menu planning. Menu 
planning  is  the  basis  to  incorporate  seasonality,  meat  reduction,  prevention  of  food  waste, 
nutrition, ... 

JRC-Directorate B5 assessment 
Comment accepted 

Comment accepted 
Menu planning is included in the "competences of the tender" 
criteria and it is required that the tenderer has experience on 
menu planning. Additionally, the promotion of vegetables is 
remarked as one important aspect of this requirement. The 
text  reads:  "menu  planning  observing  when  appropriate  the 
increasing consumption of plant-based food" .  
The follow-up of the menu planning is requested by means 
of  several  indicators,  one  of  which  is  the  grams  of 
vegetables  per  meal.  Other 
indicators  address  other 
mentioned  aspects  such  as  the  grams  of  food  waste  per 
meal or the kg of total waste per meal.  

WASTE: Food waste and food redistribution and Other waste: prevention and sorting 
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 76. Feedback from the stakeholders  
Topic 
Food Donation 
or food 
redistribution  

Feedback from stakeholders 
Donation of food should be taken into consideration in calculating end of life cost.   

Food Donation 
or food 
redistribution  

For  this  criterion,  we  do  recommend  collaborating  with  the  European  Platform  on  Food  Losses 
and Food Waste, which is drafting some guidelines for donation and redistribution of food. 
If food can still be eaten it is still food, so this section should refer to “Food redistribution” and 
“avoidable” and “waste” should be removed from the title. 
We would recommend adding more conditions: “where it is under national regulation possible 
without undue additional cost burden, requested by the client and of sufficient quantity to be of 
interest for local charities”, because these pre-conditions need to be in place and are beyond the 
control of the caterer. Sometimes charities do not have the logistics and capability to collect food 

JRC-Directorate B5 assessment 
Comment accepted 
It  is  agreed  that  donation  of  food  should  be  taken  into 
consideration in  the  LCC  and the end  of  life  cost. However, 
accurate data are still missing. 
Comment accepted 

Comment accepted 

Comment accepted 
Criteria wording includes the clause proposed 

297 

 
 
 
 
Topic 

Feedback from stakeholders 
from a caterer and serve it the same day.     
Considering that these other conditions need to be in place and food donation is not something 
that is entirely dependent on the volition of the contract caterer, we would recommend specifying 
that using this criterion should only apply if it is part of a broader, holistic national policy on food 
waste prevention and food surplus redistribution. 
Italy is a positive example of how food redistribution can be promoted by the government in a 
holistic way. 
We would recommend making this an AC instead of a TS because there is an additional labour 
cost associated with food redistribution so companies should be rewarded extra points in 
proportion to the procedures they put in place for food redistribution. For instance, if a caterer 
has procedures in place for all three of the procedures suggested by the JRC, they should receive 
more points than a caterer that only has one of the procedures in place.  
Is it opened for food distribution outside the organization also? 

This point requires the contracting authority to have special equipment available that allows for 
the fast cooling down of food (e.g. blast chiller).  
We recommend adding "when equipment to do so is available". 
I think it may be a good idea to consult the Russian born, Danish resident Selina Juul, who 
founded the Danish organisation Stop Spild af Mad (http://www.stopspildafmad.dk/) on this issue. 
Selina is very knowledgably within this field. 
The Danish Veterinarian Authorities are very strict about compliance with the current regulation 
on distribution of food, and no exemptions have to my knowledge so far been made for 
donations of food waste. Everything has to be registered in order to be able to make back calls – 
also for donated food items.    
In Hørkram Foodservice (a Danish wholesaler) we work closely together with Fødevarebanken (a 
non-profit organisation that fight food waste and food poverty in Denmark). They collect surplus 
food (approx. 18 tonnes food) from our two annual food fairs. 
I think incentives to avoid overproduction (better supply chain management – in all links of the 
chain), reduction of food waste, measures to prevent collection of food waste from being 

JRC-Directorate B5 assessment 

Comment rejected 
The  three  points 
included 
redistribution do not as stand-alone requirements 

in  the  criterion  for  food 

Comment partially accepted 
The food redistribution criteria has been also open to other 
organizations which main purpose is not the redistribution of 
the  food  (such  as  a  Food  bank)  but  those  that  can  directly 
consumed  the  food  (such  as  charitable  organizations) 
provided they can demonstrate the donation  
Comment accepted 

Acknowledged  
See below 

298 

 
Topic 

General 
comments  on 
waste 
prevention  

Feedback from stakeholders 
secondary food waste, should be rewarded, i.e. a criterion.    
Requirements from catering firms / kitchens for longer and longer durability of the food items on 
delivery result in massive food waste. This could be an item for an entire report / study on its 
own, but it could also be put down as a criterion – that tenders in favour of GPP do not ask for 
longer durability than necessary, that food items are ordered e.g. two days before planned use / 
consumption, in order for the wholesaler to make better estimates for storage keeping, with 
better production planning also for the producers. Tenderers could also monitor their demands for 
number of deliveries (possible to some extent admittedly) to take into account the durability of 
the food items ordered. This could reduce food waste in the wholesale part of the supply chain 
considerably – and possibly also in the production part. 
Drinks to be considered. Title should be: Avoidable food and beverages waste prevention 
The EEB welcomes the additional criteria, including provisions to promote both food and 
packaging waste prevention. 
The EEB asks the JRC to prioritize food waste prevention as a technical specification in the core 
criteria including the mandatory implementation of a system that allows customers to provide 
their feedback on food portions and the quality of prepared meals (see above). In addition the 
comprehensive criteria set could define options to promote food redistribution only as an award 
criterion as measures for preventing food waste in the first place should prevail. 

Beverages should be considered 
Develop a waste inventory: survey all areas and processes to identify types and sources of on-
site waste generation  INCLUDING BEVERAGES 
As stated in the report section 1.1.2 page 9: "The key environmental hotspots and their relation to 
the proposed criteria are explained here in detail. The majority of the environmental impacts from 
food products (including catering service activities) arise at the primary production stage and in 
some cases also at the processing stage." 
Packaging is not one of the identified environmental hotspot 
We are fine with addressing this second criterion (other waste) separately from the first one on 
food waste. However, we would like to stress that both criteria are linked together as for example 

General 
comments  on 

JRC-Directorate B5 assessment 

Comment accepted 
Comment accepted 

Comment accepted 
In order to prioritize the food waste prevention actions over 
the food redistribution, the first part of the crition has been 
proposed as a TS for core and comprehensive criteria while 
the second one is proposed just as a comprehensive level  
The inclusion of food redistribution as AC does not fulfil our 
aim  as  additional  points  would  be  awarded  to  those  that 
overproduced food 
A  rewording  of  the  clause  asking  for  the  feedback  of  the 
clients has also been included.  
Comment accepted 

Comment accepted 

Comment accepted 

299 

 
 
 
 
 
 
Topic 
waste 
prevention 
References 
the 
report 
(rationale) 

in 
technical 

Links  to  other 
criteria 

Feedback from stakeholders 
packaging (generating packaging waste) has also the ability to reduce food waste (e.g. portion 
packs) 
"The good Samaritan law, 2016": This is not exact.  
In Italy the Good Samarian Law was adopted in 2003. This rule equated the "final consumer" to 
the non-profit organization which carries out, for charitable purposes, free distribution to the 
needy. This allowed relieving non-profit entities from all those bureaucratic procedures that, in 
fact, complicate the assistance to the needy. 
Indeed, the identification and application of the proper procedures for the recovery of 
maintenance is of the responsibility each one of those involved, but with a new and higher 
morale as it derives from the free and spontaneous adherence to the culture of gift and recovery 
of food.  
In 2016, Law n. 166 was published ("Provisions concerning the donation and distribution of food 
and pharmaceutical products for social solidarity and for limiting waste"), the provisions of which 
entered into force September 14th, 2016. This law reinforces the previous one, which was left not 
fully exploited in ten years. This new law clarifies aspects such as expiration dates of food for 
recoverability for social purposes, contributes to  bureaucratic simplification. Moreover it provides 
incentives (e.g. tax benefit) to donors of surplus edible food. 
For this criterion, we do recommend collaborating with the European Platform on Food Losses 
and Food Waste, which is drafting some guidelines for the catering sector specifically on 
measuring and reducing food waste. Even though, of course, prevention should be encouraged as 
the most preferred option. 
The contract catering sector takes food waste prevention very seriously. Our members are 
actively involved in national initiatives to reduce food waste, such as the UK Hospitality and Food 
Service Agreement, "Flemish Samen tegen voedselverlies" declaration, and French "Pacte national 
de lute contre le gaspillage alimentaire". 
At EU level, we contribute to food waste prevention as a signatory of the Every Crumb Counts 
declaration and a member of the EU Platform on Food Losses and Food Waste. 
The starting point for all the actions listed under TS 3.1 is to first measure food waste and 
identify the main sources. The actions listed are then a consequence of that exercise. 

JRC-Directorate B5 assessment 

Acknowledged 

Comment accepted 

Acknowledged 

Comment accepted 
The  measure  of  food  waste  is  included  in  the  criterion 
"Environmental management measures and practices", where 
indicators  to  monitor  and  evaluate  the  performance  of  the 
tender along the contract are defined.  

Suggested 

Single portion could be better to reduce waste and to answer in certain case to ethnic or religious  Comment accepted 

300 

 
Topic 
measures: 
avoidance of 
single 
units/portions  
or single 
packaging 

Suggested 

Feedback from stakeholders 
demands. 
Considering that the packaging criteria were taken out and it is acknowledged in the report that 
“single unit packaging can reduce food/drink waste and indirectly improve water and energy 
efficiency during the preparation stage”, we are surprised to see the suggestion here that caterers 
must implement a plan to “avoid single-portion as far as possible” (we assume this refers to 
single-portion packs since food in a restaurant is always served as a single portion). 
In hospitals where meals need to be brought to each patient in their rooms, it is necessary to use 
single portion packaging, for instance, for salt and pepper, butter, juice, water, etc. 
Single portion packaging in a self-serve buffet setting can also help prevent food waste because 
unwrapped food that is put out has to be thrown away at the end of the service. Wrapped food, 
however, can be served again. 
Also in a contract catering context, what does single-portion packaging mean? For instance, would 
a sandwich wrapped in special paper be caught up in that definition? If so, getting rid of that 
packaging would certainly lead to an increase in food waste. 
Based on the same logic for removing this from the packaging criteria, we would strongly 
recommend removing this first point under ‘catering’. 
Single-portion contributes to food waste prevention: around 17% of food bought for collective 
catering is wasted. A study conducted in French school canteens showed that individually 
packaged cheese generates 60% less food waste than large format cheese sliced on-sit. 
Measured waste rate for individually packed cheese is 6% (leftovers on the meal tray) as 
compared to 15% (3% left-over during preparation + 9% leftovers on the meal tray+3% surplus 
thrown away at the end of service) for large format cheese cut on-site (Source: IFOP Study for 
Bel 2015 – see in annex). 
Food hygiene rules require that unwrapped items from a self-serve buffet/canteens/hospitals are 
thrown out, while the leftover of individually wrapped items can be served again. 
Individually wrapped items can extend shelf-life and conservation (e.g. a cucumber wrapped in 
plastic can last 14 days while it only last 3 days when unpacked). 
Single unit also contributes to meet new consumer trends (smaller households, more urban). They 
can be consumed out of home for instance. 
Individual portions are a good tool for balanced diet and often help to implement national 
objectives/criteria. In the case of children, portions allow them to eat the adequate amount to get 
the nutritional elements needed and to avoid overconsumption. 
other advantages to be specified: 

JRC-Directorate B5 assessment 

Comment accepted 
The  clause  on  single  units  or  portion  packaging  has  been 
removed  and  the  rationale  has  been  modified  to  recognize 
the possible benefits of using this type of packaging.  

An additional clause has however been added recommended 
the  most  suitable  packaging  for  each  use  'Select  the 
appropriate  packaging 
(format,  protection,  preservation, 
serving portions, etc)' 

Comment accepted 
See above 

Comment accepted 

301 

 
 
Topic 
measures: 
avoidance of 
single 
units/portions  
or single 
packaging 

Feedback from stakeholders 
provide adequate quantity, for e.g. to limit calories income 
prevent over dosing, e.g. rice preparation and therefore prevent food wastage 
Single-use products will indeed generate more packaging than bulk, but bring some benefits as 
stated in 2.1.7 Page 29, and especially over-dosing and over preparation. 
As an example, during the 2nd adHoc GPP Feb 23rd workshop held in Albert Broschette: 
during the afternoon coffee break, 5 liters of coffee have been prepared for circa 50 persons in 
the room. 
At the end of the coffee break, there was 3 liters of coffee left. This means that around 20 cups 
of 100ml have been drunk during the coffee break. The production of these 5 liters have required: 
350g of coffee and the packaging associated, 5 liters of water, around 500Wh of electricity to 
brew the 5 liters. All of this generated 2.6kgCO2eq, This also generated 3 liters of hot coffee (and 
the components used to prepare them) as waste and 350g of used coffee grounds as waste. 
if these 20 cups would have been prepared with a  single portioned coffee system, only 20 cups 
of 100ml would have been prepared. These 20 cups would have required 140g of coffee, 10g of 
packaging, 160Wh of electricity. All of this generated 1.5kgCO2eq. This also generated 140g of 
coffee grounds as waste and 10g of packaging, both are in some cases recycled (packaging) and 
transformed into bio gas (coffee grounds)  
This is demonstrating that "avoiding single-use and individually wrapped times can prevent a 
considerable quantity of waste" ifs not ALWAYS right. 
The sentence should therefore be removed. On top, waste (food, beverages, packaging, ...) 
identification is very important and the type of products delivered (bulk or single use) should be 
based on an analysis on the whole life cycle and not at all limited to packaging waste. 
Please find attached the copy a study offering tangible evidence of the beneficial role of single 
serve packaging to help reduce food waste in food services. 
The study carried out in French school canteens was commissioned by global cheese maker Bel 
Group and conducted by IFOP research institute. It covered nearly 60,000 meals in 33 French 
schools. 
The conclusions from this large-scale study highlighted that the waste rate of cheese is 60% 
lower for individually packed portions compared to cheese sliced on site and openly displayed. 
Overall the measured waste rate for individually packed cheese is only 6% compared to 15% for 
cheese slices prepared on site, according to the study findings. 
The study highlighted that, at all stages of meal delivery, single serve portions can significantly 
minimize the risk of waste. First, the leftover cheese on the tray is reduced (6% for single serve 

JRC-Directorate B5 assessment 
Comments will be included in the rationale 

Comment accepted 
See above 

Comment accepted 
See above 

302 

 
Topic 

Suggested 
measures: 
avoidance of 
single 
units/portions  
or single 
packaging 

Suggested 
measures: 
avoidance of 
single 

Feedback from stakeholders 
packed portions versus 9% for sliced cheese) due in part to the appropriate and adjusted serving 
size. Additionally, there are no losses during preparation (compared to 3% for cheeses sliced on 
site). Finally, there is no waste after service, as unused pre-packed portions can easily be returned 
to the fridge unlike un-packed cheese which is possibly discarded (3% of sliced cheese is wasted 
in this way). 
"Avoid single-portion as far as possible within hygiene constrains and cook to order". We ask to 
remove this from the list. 
The attached study on cheese waste in school canteens is providing evidences of the beneficial 
role of single serve packaging to significantly reduce food waste in food services (and also 
reduce total waste including packaging). 
The conclusions from this large-scale study highlighted that the waste rate of cheese is 60% 
lower for individually packed portions than for cheese sliced on site (no losses during preparation, 
reduced leftover on the tray and no waste after service as the packed portions can return to the 
refrigerator). The study also revealed that the total waste rate (taking also into account the 
packaging waste) is significantly reduced (11% for packed portions as compared to 16% for 
cheese sliced on site).   
French school canteens is providing evidences of the beneficial role of single serve packaging to 
significantly reduce food waste in food services (and also reduce total waste including 
packaging). 
The conclusions highlighted that the waste rate of cheese is 60% lower for individually packed 
portions than for cheese sliced on site (no losses during preparation, reduced leftover on the tray 
and no waste after service as the packed portions can return to the refrigerator). The study also 
revealed that the total waste rate (taking into account both food and packaging waste) is 
significantly reduced (11% for packed portions as compared to 16% for cheese sliced on site). 
In that case an indicator taking into account only packaging waste would be misleading.   
Avoiding single-use and individually wrapped items can also lead to increased food waste (as per 
the results of the large-scale study on cheese waste conducted in French school canteens), the 
environmental impact of which is generally much higher than the additional resources invested in 
the appropriate packaging. 
We would therefore ask for the removal of this sentence.   
The whole purpose of this section is to focus on prevention and avoidable food waste in 
particular. Therefore, the suggestion that caterers should “avoid single portion as far as possible 
within hygiene constraints and cook to order” is neither coherent nor appropriate in regards to the 
benefits of single use packaging acknowledged by various stakeholders and the European 

JRC-Directorate B5 assessment 

Comment accepted 
See above 

Comment accepted 
See above 

Comment accepted 
See above 

Comment accepted 
See above 

303 

 
JRC-Directorate B5 assessment 

Comment partially accepted 
See above 

Topic 
units/portions  
or single 
packaging 

Feedback from stakeholders 
Commission throughout the present text. This assertion takes no account of operational, 
economic and even environmental realities in practice. 
Pack2Go Europe wishes to see some clarification in the language used in this section and within 
the catering paragraph in particular (e.g. use of single portion or hygiene constraints). In addition, 
due to the various benefits/risks associated with both refillable/reusable packaging and single use 
pack, a general statement should be introduced to the present section to ensure the most 
appropriate packs is used for specific applications without compromising food hygiene, consumer 
safety and public health. 
The most important thing to ensure is that the most appropriate packs are used for specific 
applications. If we assume that the suggestion to “avoid single portion” is in fact, to avoid single-
use packaging, then we should consider the benefits/risks of both the alternative (reusable and 
refillable packaging) and the use of single use packaging. In some circumstances, reusable 
packaging is a good choice but it should only be promoted where it is appropriate and proven to 
be the better option – on all counts. Let’s not forget that cleaning reusable packs uses water, 
chemicals and energy. Above all, the key element here is food hygiene, consumer safety and 
public health. Use of Refillable packs can, if not closely supervised compromise food hygiene, for 
example. A much more nuanced approach is required in setting criteria. 
Single-use packaging (here stated as disposable items) is vital to preserve food hygiene, 
consumer safety and public health in many situations and this must be specified. 
General Comment: It is worth noting that the 2nd Technical Report loosely uses various terms 
such as non-disposable items, single unit packaging, single portion, non-refillable packaging, 
reusable packaging without a clear definition of those terms and thus no coherence. When 
discussing a specific matter such as packaging, the use of identified terms with a clear definition 
is preferable for both understanding and coherence of the present text. Over-simple, blanket 
assertions of what is preferable are not appropriate. 
Please add under “TS 5.1 Disposable items” the following: "Where food hygiene, consumer safety 
and public health considerations justify use of disposable items." 
Within the section comprehensive criteria “TS 5.1 verification” please re-write accordingly: 
"The tender must supply a list of disposable and non-disposable items that will be used in the 
execution of the contract, explaining which disposable items are justified in order to guarantee food 
hygiene, consumer safety and public health. 
Apart from reducing waste in the food chain, packaging is also vital to ensure food hygiene and 
consumer safety – and, by extension, public health. This is also one of the main reasons why 
most packaging is, in practice, single use. In certain applications, there really is no choice at all – 

304 

 
Topic 

Suggested 
measures: 
Refilling 
containers 

Feedback from stakeholders 
single use packs are very often the most all round sustainable option when taking appropriate 
account of all relevant considerations in catering facilities, hospitals, retirement & care homes, as 
well as in public (e.g. sports events) and private organisations, like prisons, educational 
establishments, and company canteens. 
We have to be careful in not refilling containers or small devices with sensitive products. It could 
lead to major food safety issues. 

Regarding putting condiments in refillable containers, sometimes it may make sense but other 
times it does not. It depends on the available labour, washing facilities and waste streams. For 
instance, you might have a refillable container for ketchup but you just end up emptying small 
bottles into your refillable container. 
Since ordering non-perishable products in bulk is already mentioned in the procurement of food 
and consumables list, and identifying reuse possibilities is on the catering list, we believe the 
point on refillable containers is redundant and would recommend removing it. We recommend 
removing this item. 
The rational for this point, reported at page 24 ("" the use of reusable packaging such as 
returnable bottles only brings environmental benefits if the distance between the cleaning and re-
filling facilities and the catering facilities does not exceed 100km"), is not repeated in the TS.  
Indeed, this rationale does not show any scientific reference, thus we suggest either to provide 
the reference and include the rationale in the TS, or to remove the rationale at page 24 
The Commission has pointed out that reusable beverage container systems have proven 
environmentally disadvantageous for distances beyond about 100 km (Source: Communication (2009) 
from the Commission: Beverage packaging, deposit systems and free movement of goods (2009/C 107/01); European 
Commission (1999) on reuse of primary packaging). Localisation of packaging system has already proven 
to have an impact on the Internal Market and its EU/global supply chains. EUROPEN supports 
reuse where it makes sense. We are concerned on imposing reusable packaging systems, 
especially for the beverage packaging, where not appropriate and where it could potentially 
undermine the existing Extended Producer Responsibility (EPR) systems. 
Put condiments and food servings in refillable containers. As this criteria referring to packaging 
features would require an LCA before making a blanket statement like that, we ask to remove 
them from the list.(cid:13) With regard to refillable containers, please find here below a link to a LCA 
study comparing sandwich packed in disposable aluminium foil as compared to refillable/reusable 
lunch box.  The LCA study reveals that the environmental impacts due to the foil are lower than 
those of the plastic box in most relevant environmental impact categories: Link: 

JRC-Directorate B5 assessment 

Comment accepted 
An indication of the food safety issues will be added to this 
suggestion 
Comment rejected 

Comment accepted 
Reference will be added 

Comment accepted 

Comment partially accepted 
Since the environmental performance of refillable containers 
is  linked  to  how  they  are  cleaned,  due  to  the  energy  and 
water  consumption,  an  exemption  is  added:  "where  food 
hygiene,  consumer  safety  and  public  health  considerations 
allow their use" 

305 

 
 
 
Topic 

Suggested 
measures: 
range of 
menus 

Suggested 
measures: 
communicating 
on food waste 
Suggested 
measures: 
unnecessary or 
excessive 
packaging 

Suggested 
measures: 
unnecessary or 

Feedback from stakeholders 
http://sandwich.alufoil.org/tl_files/HHF/EAFA_Sandwich_Executive_Summary_EN.pdf 
"Not requiring the full range of menu options to be available from the start to the end of the 
service". This action is not for the caterer to decide. While it is true that this would help to reduce 
food waste if the contracting authority were to allow fewer menu options at the beginning and 
end of the service, it is the contracting authority who decides this, so caterers cannot develop 
best practices for this on their own.  
This point should be removed from this list, but we would welcome it if there could be another 
way in the Commission's document to raise awareness among contracting authorities that they 
should consider allowing fewer menu options to be available at the beginning and end of the 
service as a way to prevent food waste. 
Regarding communicating the food waste prevention policy to guests, we would recommend 
leaving some flexibility for caterers to decide which parts of the food waste prevention policy are 
communicated to guests to avoid overloading guests with too much information. 

Has “unnecessary or excessive” packaging been defined? The GPP criteria need to be objective in 
order for our sector to be able to implement it and verify compliance with suppliers. We 
recommend deleting this point because there is no EU harmonised definition of what this means, 
so there would be an uneven playing field and legal uncertainty if we had to implement this.      
What is meant by “unnecessary” or “excessive” packaging? Packaging is a cost. Producers use as 
little as possible but as much as necessary, in line with the Essential Requirements in the Annex II 
of the Directive 94/62/EC on Packaging and Packaging Waste. 
In the sentence, It is important to add that packaging is NECESSARY.  
It is ok to select products with less packaging (e.g. cleaning products in concentrate form).  
But users must be informed of the dosage of these kind of products to prevent over dosing and 
pollution 
Excessive packaging is not easy to assess. 
Portioned products might be identified as part of this category, however, from a scientific point of 
view, this packaging might prevent over-dosing and over preparation 
it should be highlighted that such assessment have to be thought with a product life cycle 
perspective, and not only the packaging side 
We see the TR1.0 award criterion (AC6) about single unit packaging has been criticized by many 
stakeholders. The current point in TS 4.1 looks broader and less stringent. However, the example 
reported about cleaning products was not included in TR1.0, was not part of the stakeholder 

JRC-Directorate B5 assessment 

Comment accepted 
Note  has  been  added  prior  the  criteria  text  indicating  that 
some  of  these  proposed  measures  can  be  in  the  hands  of 
the  public  authorities  and  then,  this  measure  cannot  be 
proposed by the tenderers 

Comment accepted 
Text  has  been  modified  highlighting  that  only  key  parts  of 
the food waste prevention policy must be communicated 

Comment accepted 
See below 

Comment accepted 
See below 

Comment accepted 
Comment accepted 
See below 

Comment accepted 
See below 

Comment accepted 
The  clause  that  prevented  the  use  of  unnecessary  or 

306 

 
 
Topic 
excessive 
packaging 

Suggested 
measures: 
other 

On-site  waste 
treatment 

Feedback from stakeholders 
consultation and could bring some other controversies in case some stakeholders bring counter-
examples. Remove the example in brackets, just for caution.  
We see the need to introduce another point about recyclable products in the TS, or to include the 
issue in the AC. in fact, we want to stress that all respecting the "waste hierarchy" management, 
many EC policies support the need of recycled materials: the Circular economy communication, 
the plastic strategy, the waste legislation (WFC, PPWD, Landfill Directive) 
Add to the TS: "Select recyclable packaging where possible and provide the packaging guarantees 
food safety and hygiene""  
"Select low packaging products: select products with less packaging where possible (e.g. purchase 
routine cleaning products in concentrate form)".  
As this criterion referring to packaging features would require an LCA before making a blanket 
statement like that, we ask to remove it from the list. 
We recommend to add here another bullet point of good practice as follows: 
- "Select the appropriate packaging (format, protection, preservation, serving portions, etc.) 
As per the results of the attached study carried out in French school canteens on cheese waste, 
appropriate packaging like single serve portion can help to significantly reduce food waste in food 
services" 
The conclusions from this large-scale study (covering 60000 meals in 33 French schools) 
highlighted that the waste rate of cheese is 60% lower for individually packed portions compared 
to cheese sliced on site and openly displayed. 
Overall the measured waste rate for individually packed cheese is only 6% compared to 15% for 
cheese slices prepared on site, according to the study findings. 
The study highlighted that, at all stages of meal delivery, single serve portions can significantly 
minimize the risk of waste. First, the leftover cheese on the tray is reduced (6% for single serve 
packed portions versus 9% for sliced cheese) due in part to the appropriate and adjusted serving 
size. Additionally, there are no losses during preparation (compared to 3% for cheeses sliced on 
site). Finally, there is no waste after service, as unused pre-packed portions can easily be returned 
to the refrigerator, unlike un-packed cheese which is possibly discarded (3% of sliced cheese is 
wasted in this way 
The requirements related to waste treatment depend on the client. In some cases, the caterer 
organises waste collection. But in many other cases, like in Belgium for instance, waste from the 
kitchen and restaurant is collected and treated along with other waste from the client, and the 
client makes the arrangements for waste collection and treatment. 
Requiring a caterer to ensure on-site waste treatment at the client’s site (e.g. investing in building 

JRC-Directorate B5 assessment 
excessive  packaging  has  been  removed  due  to  the  reasons 
highlighted by the stakeholders.  
A  new  clause  has  been  introduced  indicating  that  the 
packaging  should  be  fit  and  appropriate  for  its  use.  The 
clause  reads:  'Select  the  appropriate  packaging  (format, 
protection, preservation, serving portions, etc)  

Comment accepted 

Comment accepted 
The  clauses  and  notes  suggested  have  been  introduced  in 
the criterion wording to make clear what must be required in 
each  of  the  cases  or  preferred  options  for  the  waste 

307 

 
 
 
 
Topic 

Recycled 
material 
recycling 
material 

and 

Feedback from stakeholders 
an anaerobic digester, maintaining a compost heap) would not make sense for the caterer. Space 
on the client’s site, the volume of waste generated, labour requirements and cost would be 
important factors to consider.   
It is important to note that some companies offer both catering services and waste management 
services to take care of waste treatment, while other companies only offer catering services. 
Therefore, we would recommend perhaps separating the sorting requirements from the treatment 
requirements, and including a disclaimer like in other sections. For instance, “this criterion only 
applies where sorted waste is separately collected” and “this criterion only applies where organising 
waste treatment is part of the service contracted by the caterer”.          
This is very material specific and also difficult to measure. For instance, for metals, recycled 
content material threshold is technically impossible as one cannot distinct virgin from recycled 
metals. Paper will have other issues related to this pull measure, e.g. a certain amount of 
recycled content would potentially degrade the quality of the paper/board packaging and would 
even risk consumer health and safety if the paper packaging is intended for food application. 
Hence there is not always an environmental benefit. With some other materials the availability of 
recycled material far exceeds demand (e.g. mixed plastics).    
The selection of packaging based on the only recyclability aspect may be counterproductive and 
lead to worsened environmental impact as demonstrated in this peer reviewed LCA 
(http://www.flexpack-europe.org/tl_files/FPE/sustainability/IFEU_exec_summary_%20Waste_Prevention.pdf ). (See 
attached summary of the study) 
We would therefore ask for the removal of this sentence, or at least for specifying "when it makes 
sense on a sustainability point of view (supported by an LCA assessment) 
Not considering recycling will result in a severe missing opportunity for actual policy making. In 
fact, using recyclable plastic products increases the options of the end-of-life treatment of those 
products. Also composting, which is considered a way of organic recycling (see the definition of 
"recycling" in the WFD, Art 3) becomes a valuable waste management option: this is a clear 
benefit when plastic items are mixed with food waste 
We suggest to (re-introduce) a TS about compostable packaging (se also the following TS about 
"waste sorting and disposal"). The use of compostable plastics makes the mixed waste, 
plastic/food, suitable for organic recycling, enabling the shift from energy recovery to recycling. 
Bio-waste, in terms of unavoidable food waste and packaging contaminated with food, is easily 
separately collected and diverted from landfill. This is for example, the position of the EU 
Parliament amending the revised PPWD proposed by the Commission.  
Several national public tenders have already introduced the use of biodegradable /compostable 

JRC-Directorate B5 assessment 
treatment (either on-site, or by an authorised collector or a 
combination of both) 

Comment accepted 
The  most  appropriate  packaging  is  recommended  to  be 
selected  according  to  the  food  product  characteristics  and 
where it is going to be consumed. 

Comment accepted 
The  most  appropriate  packaging  is  recommended  to  be 
selected  according  to  the  food  product  characteristics  and 
where it is going to be consumed.  

Comment accepted 
A clause has been included that indicates the preference of 
recyclable packaging, including bio-waste 

Comment accepted 
See above 

308 

 
 
 
Topic 

Waste 
management 
plan 

Feedback from stakeholders 
packaging and cutlery material on their selection criterial. This is the case of for example 
INNOCAT or London Olympics 
INNOCAT (2015b) is a three years project which began in March 2013. It is supported by the EU 
commission's competitiveness and innovation framework programme (CIP). INNOCAT aims to 
bring together a group of public and private buyers to publish a series of tenders for eco-
innovative catering products, services and solutions. The aim is to help encourage eco-innovation 
in the catering sector by providing a sizeable launch market for new solutions. The main 
environmental and social hotspots addressed by this project are (INNOCAT 2015e)  
- transport 
- waste reuse and recycling 
- bio-based products 
- energy efficient equipment 
The purchasing sectors targeted by INNOCAT are School catering services, vending machines, bio-
waste disposal systems, health and welfare catering services. INNOCAT tenders cover 
biodegradable/compostable packaging and cutlery material.  
We welcome this TS. However, waste is a relevant issue and the tenderers should be called on to 
ensure the respect of the "waste hierarchy " management, explained in the WD, Art 5:  
"1. The following waste hierarchy must apply as a priority order in waste prevention and 
management legislation and policy: a) prevention, b) preparing for re-use, c) recycling, d) other 
recovery, e.g. energy recovery and e) disposal".  
We see the opportunity to extend the waste plan to all those actions related to waste 
management that involve tenderers, thus prevention and sorting, at least. In case tenderers treat 
(some of) the waste streams on-site, the waste plan should include that part as well.  
Suggestion: Add a part of the waste plan dedicated to the waste management, or add a waste 
plan in the following section "waste sorting and disposal" as well.  
The tenderer must supply the waste reduction plan. We think waste reduction plan should be 
developed holistically including both food waste and packaging waste as both kinds of waste are 
linked together. (See rationale).  

The management of unavoidable waste is a relevant issue that must satisfy the 'waste hierarchy' 
set in the WFD.  
We see the opportunity/need to require a waste plan describing all those actions related to waste 
management that involve tenders. Preventing and sorting waste, at least, should be described, in 

JRC-Directorate B5 assessment 

Comment accepted 

Comment accepted 
The prevention of food waste is indeed a part of the waste 
management plan. Due to the importance of the food waste 
in this sector, it is separated as specific requirement. 
Comment accepted 

309 

 
 
 
 
 
Topic 

Feedback from stakeholders 
the same plan, or if required, in separate documents; in case tenderers treat (some of) the waste 
streams on-site, the waste plan should include that part as well.  
However, tenderers are not the only actors involved in waste management. Especially in case 
they will not perform any waste streams, it must be clear from the contracting authority or by 
the authorised collector which treatments of waste streams are locally available. Based on this 
information, waste sorting management should be organized and described in the waste 
management plan 
Add a 'waste management' plan as a TS: 'the tenderer must implement a plan for sorting and 
disposal of waste,, based also on locally available treatments of waste streams' 
'- if the collection by an authorised collector is the preferred option the tender […] , points may be 
awarded' 
- the second list of waste streams includes streams from the first one. This is incoherent with the 
fact that the first list identifies a TS and the second one a AC 
- bio-waste, as defined in the WFC, should be considered as well for separate collection: 
'compliance with the obligation to set up separate collection systems for paper, metal, plastic and 
glass is essential in order to increase preparing for re-use and recycling rates in Member States. In 
addition bio-waste should be collected separately to contribute to an increase in preparing for re-
use and recycling rates and the prevention of contamination of dry recyclable materials.  
Bio-waste in this directive includes 'biodegrable, food and kitchen waste from restaurants, caterers 
and retail premises directly' which are directly under the remit of this GPP 
Suggestion, replace TS 4.2 with: 'when the collection by an authorised collector allows for bio-
waste collection, the tenderer must sort bio-waste separately' 

JRC-Directorate B5 assessment 

Comment accepted 

Energy and water consumed in the kitchen 
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 77. Feedback from the stakeholders on "energy and water consumed in the kitchen" 
Topic 
Applicability of 
the criterion 

Feedback from stakeholders 
We  support  the  proposal  for  tenderers  to  have  written  procedures  describing  best  practices  to 
save energy and water consumption in the kitchen, depending on the infrastructure of the client. 
Add [to be selected depending on the contracting authority's infrastructure] 
We  recommend  either  removing  or  qualifying  the  inclusion  of  energy  and  water  consumption 
because 99% of the time there is not a separate meter for the kitchen or restaurant, so it is not 
accounted for separately and if it is, it is usually the client that has access to the information, not 

Monitoring of 
the energy 
consumption 

JRC-Directorate B5 assessment 
Comment accepted 

Comment rejected 
Separated  counters  have,  generally  speaking  a  reasonable 
price and provide important benefits (e.g. information on the 

310 

 
 
 
Topic 

Feedback from stakeholders 
the caterer. It is the client, not the caterer, who can decide whether to install separate counters. 

Thresholds 

We  wonder  why  a  reference  is  made  to the  US  Standard green seal here, because  it  does  not 
seem appropriate for a contract catering setting. Regarding the “Gold” criterion, it is important to 
bear  in  mind  that  investing  in  equipment  to  make  purified  tap  water  available  is  not  for  the 
caterer to decide, it is for the contracting authority. Since the applicability to contract catering is 
limited,  we  recommend  removing  the  reference  to  the  US  Standard  green  seal’s  levels  of 
compliance  and  the  bronze,  silver  and  gold  table,  which  has  limited  applicability  to  public 
procurement catering contracts. 
Core criteria energy class D: isn't that very low? 

Is energy class D no a little too low? 

Simplification 
of the criterion 

The EEB recommends simplifying these criteria. Beyond the TS on best practices for minimizing 
energy and water consumption, they should only apply to the comprehensive criteria set. 

What is meant by this? If you don't rinse when necessary the water in the dishwasher will get 
polluted faster and the washing result will be less good. So you will have to wash the item again. 

JRC-Directorate B5 assessment 
points  where  there 
is  excessive  energy  consumption). 
Therefore,  this  requirement  must  be  from  the  cost-benefit 
point of view to be included/kept 
Comment rejected 
The  criteria  proposal  does  not  include  any  mention  to  US 
Green seal 

The market segmentation of the professional refrigeration in 
Europe has been analysed by TopTen.eu the project ProCold, 
whose main goals are showcasing best products, supporting 
green  procurement  and  helping  to  implement  effective 
policies  (ProCold,  2016).  In  their  publication  focusing  on 
refrigerated  storage  cabinets  and  blast 
professional 
cabinets, it is provided data of the energy classes available 
in  the  European  market,  according  to  the  Regulation 
Comment rejected 
The  proposal  is  based  on  TopTen  recommendation  for 
professional  refrigeration.  The  product  lists  on  Topten.eu 
represent  7  different  brands  (Gram,  Desmon,  Electrolux, 
Foster, Liebherr, Porkka, Snowflake) with 65 model types .  
Comment partially accepted 
The  award  criteria  on  appliances  for  which  there  is  not 
energy label are set just at comprehensive level, in order to 
simplify the core criteria. 
Comment accepted 
The sentence has been clarified. 

Food transportation  
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 78. Feedback from the stakeholders on food transportation  

311 

 
 
Topic 
Functional unit  How  many  meals  are  transported  per  km  could  also  be  added  to  measure  if  the  logistics  are 

Feedback from stakeholders 

Logistic 
information 
Thresholds 

efficient or not? 
Fully loaded trucks have a much better performance than the empty ones. The logistic 
management is a key factor for improving environmental performance of transport. 
Overall, the EEB agrees with the minimum requirements (TS7.2): Euro 5 for LCV/ Euro V for HDV: 
it means that the vehicles should not be older than 7 years for LCVs and 9 years for HDVs. 
On AC.4.1 (wrong numbering in the main text! It should be AC.3.1): we think the bonus for the 
tenderer offering service delivery fleet totally composed of Euro 6/VI is good, since it is important 
to have a mechanism providing incentives for fleet renewal in GPP criteria. 
On AC.4.2 (wrong numbering in the main text! It should be AC.3.2): The 50g CO2/km limit is set in 
the NEDC test cycle. Since the new WLTP test cycle will enter into force in September 2017, we 
recommend translating this value to make the criteria future proof: this would mean ca. 35g 
CO2/km on WLTP. 
If it comes to prioritizing certain environmental aspects in the core criteria set, one option could 
be to apply these requirements only to the comprehensive criteria set. 
This should be achievable by most service providers, especially since the criterion specifies that 
the requirement applies only to the vehicles "used in carrying out the service," not to the entire 
fleet of the service provider. 

The EEB supports the proposals both for the core and comprehensive criteria sets. 

JRC-Directorate B5 assessment 
Comment accepted 
This function unit has been added as an example to the TS8 
Acknowledged 

Comment rejected 
According  to  (Fontaras  et  al,  2017),  the  average  ratio 
WLTP/NEDC  is  1.2,  so  the  WLTP  threshold  cannot  be  lower 
than the NEDC. However, the threshold has been lowered to 
45  g/km  in  order  to  harmonise  it  with  the  criteria  for 
transport. Currently, the type approval values are determined 
by  the  NEDC  test  cycle.  In  the  near  future  (between  2017 
and  2019)  the  type  approval  will  change  to  WLTP.  From 
2019  onward,  only  the  CO2  type  approval  measured  with 
WLTP  will  be  communicated  to  consumers.  Therefore,  the 
thresholds  proposed  in  the  technical  specification  for  2019 
and onwards, which are based on the current type approval 
in  force  (NEDC)  will  have  to  be  transformed  into  WLTP 
values  as  soon  as  reliable  information  on  the  WLTP/NEDC 
ratios becomes available. 
. 

Disposable items and consumable goods 
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 79. Feedback from the stakeholders  
Topic 
Disposable 
Items excepted  

Feedback from stakeholders 
This could be misinterpreted as a restriction on all disposable items. The study you refer to on 
page 49 (Packer, 2009) concludes that overall environmental impacts are context specific. For 
instance, bin bags are disposable by definition, so it would be impossible to replace them with 
non-disposable items. 
Disposable gloves are important for food safety and hygiene, especially for food preparation and 
cleaning operations. It is hard to see how we could eliminate their use. 
For using washable napkins and tableware, it’s important to bear in mind that there is an 

JRC-Directorate B5 assessment 
Comment partially accepted 
Exceptions  for  big  bags  and  gloves  will  be  included  in  the 
criterion 

312 

 
 
 
Topic 

Feedback from stakeholders 
additional labour cost, as someone needs to collect, wash, fold and put away these items. This 
labour cost should be reflected in the life-cycle costs. 
Bin bags are disposable by definition, so it would be impossible to replace them with non-
disposable items. 
Disposable gloves are important for food safety and hygiene, especially for food preparation and 
cleaning operations. It is hard to see how we could eliminate their use. 
An exception should be added for events. 
If including environmental requirements for materials for events, please keep in mind that these 
items can be considered packaging since they are used to give food to the final consumer. The EU 
Packaging and Packaging Waste Directive sets recycling targets for packaging, so recyclable 
materials should also be considered, not only compostable or biodegradable materials. 
We restate our previous comment as well that when a contracting authority selects which kind of 
material to privilege, the waste streams that are locally available for dealing with that material 
should be taken into consideration. 
Just a thought, but couldn't it be interesting when the catering on the premises that also makes 
take away possible to offer reusable items that the customer can purchase (customer is 
responsible for hygiene of the item).  
This way you can try to lower the use of disposable items in a staff restaurant. 

The EEB welcomes the criteria on avoidance of disposable items. 
We would recommend adding a list of standards that are considered by the European 
Commission to be equivalent to the EU Ecolabel would be helpful to have in the Explanatory 
Notes. 

We suggest to (re-introduce) a TS about compostable packaging (see also the following TS about 
"waste sorting and disposal"). The use of compostable plastics makes the mixed waste, 
plastic/food, suitable for organic recycling, enabling the shift from energy recovery to recycling. 
Bio-waste, in terms of unavoidable food waste and packaging contaminated with food, is easily 
separately collected and diverted from landfill. This is for example, the position of the EU 
Parliament amending the revised PPWD proposed by the Commission.  
Several national public tenders have already introduced the use of biodegradable /compostable 
packaging and cutlery material on their selection criterial. This is the case of for example 

JRC-Directorate B5 assessment 

Comment accepted 
Exceptions  for  events  will  be  included.  Additionally  some 
requirements on the materials the excepted items are made 
of will be added 

This criterion aims to restrict the use of disposable items as 
much as possible. Those that are still used are proposed to 
be  recyclable  or  if  in  contact  with  food  and  possible 
compostable. Being compostable items, there is no need for 
separation of the food waste and the dishware items.   
Comment accepted 
Comment rejected 
Even if a list of schemes is not provided in the explanatory 
notes  as  requested,  a  note  has  been  added  reminding  the 
contracting  authorities  that  this  possibility  of  verifying  the 
criteria by means of other schemes is included.  
Comment accepted 

313 

 
 
Topic 

Coherence 
between 
criteria 

Automatic 
dosage 

Feedback from stakeholders 
INNOCAT or London Olympics.  
The suggestion is: 'Select compostable packaging aligned to the locally available treatments of 
waste streams and provide the packaging guarantees for food safety and hygiene' 
INNOCAT (2015b) is a three years project which began in March 2013. It is supported by the EU 
commission's competitiveness and innovation framework programme (CIP). INNOCAT aims to 
bring together a group of public and private buyers to publish a series of tenders for eco-
innovative catering products, services and solutions. The aim is to help encourage eco-innovation 
in the catering sector by providing a sizeable launch market for new solutions. The main 
environmental and social hotspots addressed by this project are (INNOCAT 2015e)  
- transport 
- waste reuse and recycling 
- bio-based products 
- energy efficient equipment 
The purchasing sectors targeted by INNOCAT are School catering services, vending machines, bio-
waste disposal systems, health and welfare catering services. INNOCAT tenders cover 
biodegradable/compostable packaging and cutlery material. 
There seems to be an overall tension between this and the previous criterion on waste prevention. 
On the one hand, there is a desire to use more reusable (washable) items, which will result in an 
increase in the use of chemical cleaning products. On the other hand, this Award Criterion gives 
extra points to caterers for taking actions “to reduce significantly the consumption of chemical 
products”.   
In addition, the rationale on page 42 notes that chemical products for washing “cause several 
environmental impacts such as aquatoxicity, eutrophication or acidification of the water streams”. 
Therefore, we believe that adding some caveats to the use of non-disposable items is necessary. 
In the future, perhaps the European Commission’s Product Environmental Footprint can help 
public authorities to weigh the environmental impacts and science-based criteria that make sense 
for their particular site. 
We welcome the inclusion of Award Criteria for using automatic dosage and dispensers.  
The use of concentrated products should also be evaluated for inclusion.        

An  automatic  dosage  should be  a  TS  and  not  an  AC.  For  professional  dishwashers  this  is  very 
common.  Even  a  lot  of  semi-professional  dishwashers  have  this  possibility.  Household 
dishwashers can work with the tablets what is also a very controlled dosage of cleaning product. 

JRC-Directorate B5 assessment 

Acknowledged 

Comment partially accepted 
The  use  of  concentrated  products  must  be  considered  as  a 
measure for preventing the waste generation.  
Comment accepted 

314 

 
 
Topic 

Cleaning 
products and 
paper products 

Feedback from stakeholders 
We recommend deleting this text. 
We  agree  with  moving  the  criteria  relating  to  cleaning  products  and  kitchen  rolls  to  the 
comprehensive criteria.  
On  chemical  products,  kitchen  rolls  and  paper,  the  EEB  recommends  that  the  comprehensive 
criteria  TS  5.2  and  TS  5.3  should  also  apply  as  TS  in  the  core  criteria  set  with  a  minimum 
threshold of at least 50%. 

? 

There should be an “environment oriented” cleaning and disinfectant strategy set-up and 
implemented. 

JRC-Directorate B5 assessment 

Comment accepted 

Comment rejected.  
The market availability of these products is wide in most of 
the  market,  therefore  the  threshold  of  100%  could  be 
recommended.  
Even  though,  a  note  is  included  in  the  explanatory  notes 
indicating that the threshold should be set up considering the 
market availability of those products.  
Comment rejected 
The  criterion  on  chemicals  refers  to  routine  cleaning,  and 
disinfection is not part of routine cleaning 

CPC: Provision of low impact water  
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 80. Feedback from the stakeholders  
Topic 
Scope  of  the 
criterion 

Feedback from stakeholders 
We really welcome the introduction of this criteria, and as such more mechanisms for its 
inclusion/facilitation in all catering services (including hospitals, nurseries or kinder 
gardens) should be encouraged 
The EEB recommends keeping the proposed contract performance clause on mandatory 
promotion of tap water. 
This is an unacceptable discrimination statement. People should have the choice for tap or 
bottled water. 
Criteria set 3.3.1 proposes to avoid bought-in bottled water as core criteria. We believe that 
eliminating a specific type of product of the variety of products a caterer can offer is first of all 
discriminatory against, in this case, other types of beverages that can be offered by the catering 
service. 
In addition bottled water fulfils very specific dietary requirements for customers of specific 
catering services such as hospitals and nurseries. We therefore suggest to remove at least the 
criteria avoiding the supply of bought-in bottled water. 

Discrimination 
requirement 
in-
against 
bought  bottle 
water 

JRC-Directorate B5 assessment 
Comment accepted 

Comment accepted 
The  discrimination  statement  has  been  removed.    The 
criterion  ensures  that  customers  have  access  to  the  tap 
water for free but with no restriction to the provision of in-
bought bottle water 

315 

 
 
 
 
 
 
 
Topic 

Note of the 
criterion  

Water 
dispenser 
definition 
Cleaning of tap 
water point 
Rationale 

Feedback from stakeholders 
We do not consider it desirable to allow customers to use their own bottles when purchasing 
beverages from a vending machine because of the risk of contamination. When such 
contamination occurs, it creates a liability issue for the contract caterer if they are the one 
renting the vending machine. 
As it was mentioned in the minutes of the 2nd AHWG (23rd February) the sentence “Bought-in 
bottled water must be avoided where possible” will be deleted. Consequently, EFBW believes that 
the US inspired rationale (US Standard green seal) of page 54 should also be deleted. EFBW 
agrees with those amendments. 
Regarding the wording “bought-in bottled water must be avoided where possible”, we believe in 
giving customers the choice to select tap or bottled water, depending on their preference. 
From a nutritional perspective, if you remove bottled water as an option for customers who don’t 
like to drink tap water, they have limited options that are as healthy as pure water. 
EUROPEN supports the removal of this discriminative requirement against bottled water, which is 
not supported by a life-cycle approach. The availability of water should not be restricted in 
catering services.  
We can support making tap water available for customers where appropriate. The “where 
appropriate” is very important because in some settings it would not be appropriate. Examples 
are:  
1) in hospitals where food is served to patients in their rooms,  
2) in nurseries where the tap water has a high mineral content and no water purifier is available, 
3) when take-away service is offered. 

Maybe it is not relevant for the definition but water dispensers can also deliver sparkling water. 
They can be connected to the water service pipes or used with large bottles. 

JRC-Directorate B5 assessment 

Comment rejected 
The  note  above  the  criterion  already  flags  the  situations 
where the inclusion of this criterion could be a barrier for the 
tenders 
"Note: This criterion only applies to those cases where it is 
possible to supply or get access to tap drinking water" 
Acknowledged 

It is important to also ask for the cleaning and disinfection of the tap water point. 

Comment rejected 

EFBW also believes that the sentence at the end of page 54 “The aim of this Contract 
Performance Clause is to avoid or diminish bottled water in the catering services” is discriminatory 
and should be deleted. 
EFBW suggests that the page 54 should be rewritten because it discriminates against a product 
which has low environmental footprint and is the healthiest way to hydrate. 
EFBW supports every effort towards facilitating healthy hydration and increasing access to water 
for European citizens, whether from the tap or from bottled water. 

Comment accepted 

Comment rejected 

316 

 
 
 
 
 
JRC-Directorate B5 assessment 

Topic 

Feedback from stakeholders 
The reduction of bottled water choice goes against public health interest. Studies show that 
people do not drink enough and thus not meeting EFSA guidelines for water intake. Also in the 
context of the obesity/ diabetes epidemic, all stakeholders (JRC included) advocate in favour of 
increased water consumption (bottled water has a key role to play towards healthy hydration). 
There is no scientific support for the proposal to boycott bottled water. On the contrary, bottled 
water has the lowest environmental footprint amongst all beverages (single ingredient, no 
chemical treatment, very high recycling rate including in close loop) – as acknowledged in the 
report under stakeholders’ feedback and accepted by JRC (page 156). 
JRC is involved in DG ENV’s Product Environmental Footprint where the packed water sector 
proactively contributes with a pilot. As the GPP is about environmental performance we would 
suggest that the PEF work is considered when judging bottled water. EFBW strongly believes that 
GPP rules should always be based on sound scientific LCAs. 
It should be also mentioned that in Europe, contrary to other continents, bottled water refers to 
Natural Mineral Water (84%) and Spring Water (13%) which means purity at source, no chemical 
treatment and unique mineral water composition as stated on label (consumer information). In 
other words, as underlined by CODEX standards 108-1981 (WHO, FAO) and EU legislation 
(Directive 2009/54/EC) natural mineral water is distinguishable from ordinary drinking water. 
Consumers appreciate the naturalness of this product and the possibility to make a choice based 
on taste and mineral composition. European bottled water producers were pioneers in 
contributing to the collection and recycling efforts in MS (via Extended Producer Responsibility 
schemes) while using only 100% recyclable materials. They also massively invest in protecting 
the environment around the water sources thus ameliorating the biodiversity of those areas.   

CPC: Purchase of new kitchen equipment 
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 81. Feedback from the stakeholders on CPC: purchase of new kitchen equipment 
Topic 
purchase of 
new kitchen 
equipment 

Feedback from stakeholders 
In general, the EEB agrees with the JRC’s proposal although the references to the very detailed 
AC make it hard to understand. According to us, catering services should be asked to purchase 
only kitchen appliances that are eligible to the highest populated efficiency class on the EU 
energy label. For some professional machines (e.g. professional dishwashers) no Energy label 
may exist. In these cases, we support the JRC’s proposal to associate a list of points or to target 

JRC-Directorate B5 assessment 
Comment accepted 

317 

 
 
Topic 

Feedback from stakeholders 
the benchmark level of respective Ecodesign regulation. 

JRC-Directorate B5 assessment 

CPC and TS: Environmental measures and practices 
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 82. Feedback from the stakeholders on CPC environmental measures and practices 
Topic 
Criterion 

Feedback from stakeholders 
We  really  welcome  the  introduction  of  this  criteria,  and  as  such  more  mechanisms  for  its 
inclusion/facilitation 
in  hospitals,  nurseries  or 
kindergartens) should be encouraged 
As a general comment, the concept of a “meal” differs from one country to another and from one 
type of account to another. If this data is only used within the context of a particular contract, 
then it should be fine. However, the data may not be suitable for comparison to another contract. 

in  all  catering  services 

(including  those 

Function unit 

The amount of grams/meal is fixed in the contract. The caterer has no way to increase this alone 
but  can  of  course  comply  if  an  increase  in  vegetable  consumption  is  foreseen  in  the  contract. 
Measuring vegetable consumption would be difficult for mixed dishes, e.g. chinese stir-fry.  
We recommend removing this item. 
The FUSION method is 1/year for 10 days. Plate waste is often not requested by clients because 
it  is  difficult  to  organise  and  requires  additional  labour  costs  to  ensure  proper  sorting  of  food 
waste from other waste. For instance, it may require having an employee, part of whose job is to 
sort  every  plate  returned  by  consumers  to  ensure  proper  separation  of  food  waste  from  other 
waste, such as napkins and packaging. This should be taken into consideration in the life-cycle 
cost.    

Frequency  of 
for 
measures 
verifying 
this 
criterion 

This  is  possible  1/year,  if  infrastructure  and  organisation  is  possible,  depending  on  the  site. 
In some cases the waste management company of the client would be  better placed to do the 
monitoring and reporting. For instance, in cases where catering waste is collected together with 
client waste, the waste management company that manages the waste of the client would have 
the data on the weight of paper, plastic, glass and residual waste and not the caterer. 

JRC-Directorate B5 assessment 
Comment accepted 

Acknowledged 
The  technical  specification  just  requires  the  tenderers  to 
have  an  indicator  to  monitor  their  performance,  the  results 
of those indicators will not be used to compare offers. 
Comment accepted 
The indicator will be required when the amount of grams per 
meal is not fixed in the contract. 

Comment rejected 
TS8  reads  "monitor  and  record  at  least  twice  a  year  for 
representative  weeks*  the  following  indicators"  This  means 
that  the  indicators  should  be  monitored  for  maximum  14 
days/years and if the catering in an office building or school 
or similar institution, the monitoring will take place only for 
10 days.  
Even if we agree that the cost should be included in the LCC 
the benefits of these actions exceed by far their costs.  
Comment rejected 
If the waste company is in better place to do that, it can be 
done  by  the  waste  management  company  but  the  data 
should be reported to the catering service that management 
and correct the procedures to reduce the waste generation. 
Therefore the catering services, having these data from the 

318 

 
 
Topic 

Feedback from stakeholders 

/ 

ISO 

EMAS 
14001 

LCC 

EMAS/ISO14001 are used in the SC. These certifications will not be used by SME's because they 
are considered to be too expensive. 
How it is written here it is very usable on what measurements you want on the premises by the 
caterer. 
The McKinsey Maxim is “What you can measure you can manage”. Contract caterers already have 
in place processes for measuring many aspects of their operations. Our case studies on food 
waste on DG SANTE’s website give some examples of this in relation to food waste.   
That said, monitoring and recording waste requires additional labour or external support, so there 
is an additional cost associated with this activity. This should be factored into the life-cycle costs. 

JRC-Directorate B5 assessment 
waste management company is in the position to provide the 
data to the purchase authority.  
Acknowledged 
The EMAS or ISO 14001 is just not required, just accepted as 
proof of compliance with criterion TS8 

Comment accepted 

on 

CPC: Staff training 
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 83. Feedback from the stakeholders  
Topic 
Training 
preparing 
vegetarian 
dishes 

Feedback from stakeholders 
"staff  training"  is  mentioned  as  part  of  the  "competence  of  the  tenderer"  selection  criteria. 
However  it  does  not  appear  explicitly  in  the  proposed  formulation  of  the  "competence  of  the 
tenderer" (as it is now in the box). So it may not be undertaken to achieve the objectives.  
My comment concerns particularly the abilities to improve the "tastiness" of the vegetarian meal. 
For  example:  in  Italy  (Florence,  my  personal  experience)  school  are  starting  to  propose 
vegetarian/traditional meals without meat. However this can be used by the caterer as a way to 
decrease  costs  (meat  is  costly)  leaving  poor  quality  vegetarian  meals  (which  go  wasted,  and 
parents disappointed). 
Staff in charge of the preparation of menus, particularly vegetarian menus, should receive some 
guidelines on how to prepare them. 
Staff training should take into consideration competences, and background (both academic and 
professional) in order to adapt the content to them, if appropriate and needed). Saying this, we do 
consider 16 hours is a good base for permanent staff, even though in other countries or cities 
(Ghent or Copenhagen) is higher.   
We would recommend to specify here at the end of the sentence: "where this is relevant according 
the location/country" 

Length  of  the 
training.  

Explanatory 
notes 

JRC-Directorate B5 assessment 
Comment accepted 
The  provision  of  a  staff  training  method  statement  has  
been included in the SC.  
The requirement on the tastiness has been removed and the 
indicators suggested included in the TS8 

Comment accepted 
This point has been included in the explanatory notes 
Acknowledged 

Comment rejected 
The  environmental  education  of  the  staff  is  relevant  in  all 

319 

 
 
 
Topic 

Feedback from stakeholders 

On-site 
training 

Requirements 
of the criterion 

TS vs CPC 

We agree that staff training on environmental considerations is a must. This criterion should 
specify that the training must be “on-site”, but the content and amount of time dedicated to 
environmental training for each company will be dependent on the sustainability programmes 
and policies it has in place and the nature of the contract. 
For instance, a small site might have a minimum of 7 hours/year of general training (not 
specifically on environmental aspects) while a large site might have 14 hours/year. 
We consider that 16 hours/year on environmental aspects alone for all sites regardless of their 
size is excessive. We believe contracting authorities should not be too prescriptive about the 
amount of time that should be dedicated to environmental training. 
It would be difficult to count how many hours are specifically dedicated to environmental 
considerations. For instance, all food safety and hygiene training is effectively training to prevent 
avoidable food waste. 
We believe it should be sufficient for contracting authorities to require caterers to have a method 
statement on on-site staff training covering environmental topics, which is renewed annually. 
As a contract performance clause, the contracting authority could require the tenderer to report 
the number of hours of on-site training provided. 
The labour costs of providing and receiving training should be taken into consideration in the life-
cycle costs, perhaps shown in cost per hour of training. 
I would always have the staff training programs in my tenders, but as a technical specification. 

inclusion  of  on-site  training 

JRC-Directorate B5 assessment 
situations and countries 
Comment partially accepted 
The 
recommended in the explanatory notes  
The duration of the formation is a value that can be taken as 
reference  but  that  can  be  adjusted  to  the  needs  of  the 
catering  service  or  the  tender  conditions.  The  explanatory 
notes read: "….16h per year is a recommended value for the 
duration of the formation" 

in  this  revision 

is 

Comment accepted 
Rewording of the criteria has been done 

Comment accepted 
The indicator has been included in TS8 

4.4. Table of stakeholder's comments on the propose criteria for EU GPP criteria for VENDING MACHINES 

This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  

Vending machines 
This section presents the comments received through BATIS and personal communication from the 2nd AHWG meeting.  
Table 84. Feedback from the stakeholders on the TR2.0 on vending machines 
Topic 
Avoidance  of 
disposable 
cups  /  bottles 

Feedback from stakeholders 
We  do  not  consider  it  desirable  to  allow  customers  to  use  their  own  bottles  when  purchasing 
beverages from a vending machine because of the risk of contamination.  
When such contamination occurs, it creates a liability issue for the contract caterer if they are the 

JRC-Directorate B5 assessment 
Comment accepted 
A  note  has  been  included  in  this  criterion  warning  of  the 
responsibility  of  the  user  to  not  contaminate  the  beverage 

320 

 
 
 
Topic 
or 
use 
reusable cups 

of 

Feedback from stakeholders 
one renting the vending machine. 
Reusable cups are not always possible due to certain usage (e.g. on the go) or technology used by 
the  vending  manufacturers  (e.g.  pre-filled  cups).  The  goal  should  be  to  enable  the  choice on 
vending systems as much as possible to enable the use of reusable or disposal cups.  

Avoidance  of 
disposable 
cups  /  bottles 
or 
of 
use 
reusable cups 

If you want you caterer to use reusable cups than you also have to pay for the time they need to 
clean them. A lot of dishwashers use high temperature water to rinse the dishes. This way it is 
disinfected.  Be  sure  to  dry  these  items  with  clean  towels.  If  the  dishwasher  doesn't  use  high 
temperature water to rinse the dishes, be sure to disinfect the machine frequently. 
A blanket requirement for tenders to provide equipment that systematically enables use of 
reusable cups (instead of disposable cups) in order to meet the criteria is out of touch with reality 
and the wide range of situations in which vending machines are used. Furthermore, this, once 
again, takes zero account of the need to protect food hygiene, consumer safety and public health. 
This criterion should be removed from the Technical Report. 
Whereas  there  may  be  occasions  where  vending  machines  in  controlled  environments  might 
feasibly  make  recourse  to  reusable  cups,  in  the  vast  majority  of  situations  this  will  not  be 
appropriate on grounds of food  hygiene, consumer safety and public health. Even in controlled 
environments (e.g. small offices) there is a significant risk of cross-contamination of equipment 
occurring  from  unclean  reusable  cups.  People  should  not  be  put  at  risk  by  public  authorities. 
Furthermore,  there  are  very  few  systems  available  today that  offer  the  ability  to  use  reusable 
cups effectively and safely given the wide variety of reusable cups in existence. A more relevant 
criterion would be the availability of reliable collection and recycling systems for used cups. 
These  GPP  criteria  will  cover  a  range  of  hot  drinks  machines;  therefore  this  ‘catch  all’  is  not 
appropriate for all machines and situations. While machines on the market do exist which enable 
the  consumer  to  choose  between  the  use  of  a  disposable  and  a  reusable  cup,  these  can  only 
potentially be used in an office environment. Other ‘in cup’ machines, including those who prepare 
the drink in the cup itself, are also widely used and therefore we don’t consider this requirement 
appropriate.  This GPP criteria are designed for all machines under the contract, therefore in cup 
machines will often be required. 
Disposable  cups  are  used  by  a  lot  of  hot  drinks  machines  for  several  key  reasons: 
1.  Hygiene  – the  vending  operator  can  only  guarantee  the  hygienic  requirements  if  safe, clean 
disposable cups are used. 

JRC-Directorate B5 assessment 
provided.  
Comment accepted 
The  wording  of  the  criterion  does  not  excluded  the  use  of 
disposable cups. These cups can be supplied by the machine 
but it must also provide the option of serving the beverage 
without a disposable cup 
Comment rejected 
The criterion wording does not require the caterer to provide 
reusable cups. It requires a vending machine that is able to 
provide the beverage without providing a disposable cup.  
Comment partially accepted 
A note has been included that restricts the application of this 
criterion  to  those  situations  in  which  the  food  hygiene, 
consumer safety and public health are protected as well as 
an  indication  that  tenders  must  not  be  liable  if  cross-
contamination due to the container occurs.  

Comment accepted 
See above 

321 

 
 
 
Topic 

Organic 
products 

Fair Trade 
products 

Environmentall
y responsible 
palm oil  
products 

Energy 
consumption 

Feedback from stakeholders 
2. Safety – if reusable cups are used, this can lead to spillages, scalding, etc. Hot drinks machines 
will deliver a programmed drink volume, if a reusable cup doesn’t fit a certain physical size or 
drink volume, the above problems can occur.  
3. Convenience – as a primarily on-the-go industry, disposable cups are required to facilitate this. 
On  this  basis,  we  would  call  on  the  removal  of  the  GPP  criteria  on  reusable  cups. 
Furthermore, we have concerns over the little justification/evidence used for the insertion of this 
criterion. It seems that the perception that disposable cups are bad of the environment due to 
waste is used, whereas evidence exists showing the life cycle assessment impact of a reusable 
cup versus a disposable cup on their environmental impact, does not appear to favour reusables, 
particularly  taking  into  consideration  the  detergent  and  repetitive  washing  of  reusable  cups.  In 
addition, recycling bins could be used or provided to ensure the recyclability of disposable cups. 
Broadly, vending operators will be able to comply with the requirements to provide organic and 
fairly  traded  products  (providing  they  are  readily  available)  and  to  provide  documentation  to 
substantiate  their  provenance. We  may  have  some  concerns  about  the  practicalities  on  the 
verification requirement to provide evidence of this which could become a bureaucratic burden on 
vending operator companies, most of whom are SMEs without extensive back office staff. 
Broadly, vending operators will be able to comply with the requirements to provide fairly traded 
products (providing they are readily available) and to provide documentation to substantiate their 
provenance.  We may have some concerns about the practicalities on the verification requirement 
to provide evidence of this, which could be a bureaucratic burden on vending operator companies, 
most of whom are SMEs without extensive back office staff. 
Broadly,  vending  operators  will  be  able  to  comply  with  the  requirements  to  provide  products 
containing  environmentally  responsible  palm  oil  (providing  they  are  readily  available)  and  to 
provide documentation to substantiate their provenance.  
We may have some concerns about the practicalities on the verification requirement to provide 
evidence of this which could be a bureaucratic burden on vending operator companies, most of 
whom are SMEs without extensive back office staff. 
Please note that when the EVA EMP 3.0 b is used to compare hot drinks machines, it is crucial 
that different criteria are compared and not just the EMP rating scale. This is because different 
hot drink machines have different capacities (e.g. litres per day) which impact their efficiency. 

JRC-Directorate B5 assessment 

Acknowledged 

Acknowledged 

Acknowledged 

Acknowledged 
For that reason, this provision is specified: The call for tender 
will specify the type of vending machine to be supplied and its 
volume.  This  award  criterion  must  be  only  used  to  compare 
vending machines of the same type and volume. 

322 

 
 
Topic 

Feedback from stakeholders 
We would like to query the justification for the criteria – 10°C for more than half an hour. What 
evidence base does this come from?   

Energy 
consumption. 
Smart energy 
management 
system 

GWP of 

According to the European Vending Association Market Report on Vending and Office Coffee 
Service (OCS) market (2015 data), there are around 3.8 million vending machines. Common 
practise unfortunately is that the machines keep running. For example coffee vending machines 
but they have a stand-by mode. This could be switched of manually, some switch of 
automatically. Be aware if there's water left in the water tubes of the machine that the machine 
runs a cleaning program when started again to avoid contamination. 
A vending machine that offers bottled or canned drinks (sodas) won't be a problem to switch of 
unless the outside temperature rises to high. Machines with perishable food can be switched off 
after you removed the food (to a refrigerator of waste in if necessary), but that will cost extra 
handling by the staff. 
The industry has made great strides in reducing the energy consumption of snack and drink 
machines and all new ranges can be fitted with energy management devices. 
Energy management devices can be based on a simple time clock or on proximity sensors that 
switch the machine on when consumers approach.  The most sophisticated versions learn the 
typical pattern for a site.  The temperatures to which machines are set are a matter for 
agreement between the site and the operating company and it may be that it is better to raise 
the overall temperature than to switch the machine completely on and off.  
The products contained within a glass fronted vending machine fall into two distinct groups: 
chilled food and ambient stable food.   
- Chilled food must be kept chilled for reasons of food safety, and therefore these products 
should be removed if the machine is to be switched off.  
- All other products are stable at room temperature and there will be no health hazards resulting 
from the machine being switched off.  However, please note that chocolate may melt if the air 
conditioning in the building is switched off at the same time, which could lead to some 
dissatisfaction from consumers. 
- In addition, hot drinks machines with powdered ingredients should not be switched on and off 
as this will cause the powders to “cake” leading to powder flow problems and inconsistent drink 
quality. 
On a point of clarification on the GWP of refrigerants, the use of hydrocarbons raises safety 

JRC-Directorate B5 assessment 
Comment accepted 
The  criteria    10°C  for  more  than  half  an  hour  has  been 
replaced  by  the  definition  of  'perishable  food'  according  to 
the Codex Alimentarius 
Comment accepted 
The  criterion  requires  that  the  machines  must  be  provided 
with  a  smart  energy  management  system  and  that  it 
switches  off  when  it  is  foreseen  that  the  machine  is  not 
going to be used (e.g. weekend in an office building).  
The note prior to the criterion text excludes the application of 
this 
that  provide 
perishable  food  or  beverages  that  require  to  keep  the 
products  at  a  certain  temperature  to  avoid  decaying  or 
quality loss.  
Comment accepted 
See above 
Machines  that  provide  hot  drinks  made  of  powdered 
ingredients are not in the scope of this criterion.  

to  vending  machines 

requirement 

Acknowledged 

323 

 
 
Topic 
refrigerants 

Ownership  of 
the 
vending 
machines 

Feedback from stakeholders 
concerns due to its flammability and the moving parts in a glass fronted vending machine. Closed 
front vending machines will adapt the same refrigerant as glass front machines i.e. likely carbon 
dioxide. Currently few vending machines offer refrigerant gases of a GWP under 150, but with 
the EU F Gas Regulation, this will certainly change by 2022 at the latest. 
Most of our coffee machines are rented. The tender is for 4 years and every extra machine rented 
during the contract is until the end date stated by the contract for example year 1 of the contract 
we rent 10 machines for 4 years, in year 2 of the contract we rent another 10 machines and 
those will be rented for 3 years. Our regional government rents machines for 4 years so the end 
date of a machine is variable because every machine is rented for 4 years even if the renting 
starts in year 2 of the contract. 
The ownership of the machine is a matter of contract – all options are possible.   
However, without the forthcoming Ecodesign and Ecolabelling Regulations in place it will be 
difficult to specify that a proposed purchase should be best in class since the energy 
consumption figures for machines will not be publicly available. 

Cleaning of the 
coffee  vending 
machines 

Dispensers, coffee vending machines need to be cleaned/disinfected on daily basis (very 
important). They have to be used very often so water/coffee runs through the tubes frequently. In 
this way, bacteria have less time to develop. If these dispensers/machines aren't used frequently 
enough, remove them and offer another solution. 
If a water dispenser is used it is essential to clean and disinfect the dispenser! If that can't be 
guaranteed don't get the machine. 

JRC-Directorate B5 assessment 

Acknowledged 

Comment rejected 
Although  the  energy  consumption  may  not  be  publicly 
available, this does not prevent the contracting authority to 
request a test report on energy consumption that would be, 
if necessary, kept confidential. 
Acknowledged 

National regulation on vending products in the different Member states (EVA 2017) 

Belgium has no federal legislation, but the region of Flanders and Wallonia set their own polices in terms of vending machines in the schools. In Flanders all offered products 
are to be divided into four different categories  

a.  Products from the encouragement policy: there should be widely available (e.g. water, mil, fresh fruit) 
b.  Product from the policy tolerance. These should be limited. The schools can determine the availability and accessibility of products (juice, yogurt with fruit, etc.) 
c.  Products to be banned by the cut-off date: these should be currently limited and schools are encouraged to reduce supply ahead of year 2020-2021 when they will 

be banned. These products include sugared soft drinks, sausage rolls, etc. 

d.  Products from the prohibition policy: these are not to be offered in schools e.g.  Energy drinks, alcohol.  

324 

 
 
 
For beverages for 2017-2018, the aim is that all products from category 3 are removed in 75% of primary schools and 60% of secondary schools. For snacks for 2017-2018, 
the aim is that all products from category 3 are removed from in 75% of all schools ahead of a complete ban of for drinks and snacks by the 2020-2021 school years.  

In  Brussels  and  Wallonia,  in  late  2004,  it  was  announced  that  soda  and  sweet  vending  machines  were  banned  in  pre-school  or  primary  schools  as  for  the  start  of  2005. 
However, this ban is not strictly enforced and numerous schools felt. Therefore it seems to be the decision of individual primary or pre-primary schools as to their individual 
policy. In September 2018 each school will be obligated to have a plan to promote health and healthy food products.  

Czech Republic 

In 2016, Czech Republic passed a law which sets requirements for food for which advertising is permitted and which can be offered for sale and sold in schools and facilities. 
The food requirements are  

a. 

b. 

in schools and educational establishments, food may be offered for sale and sold or advertising must meet the following requirements:  
i.  they do not contain sweeteners, except for sugarless gum or caffeine, except for tea and non-alcoholic beverages with tea extract 
ii.  they do not contain trans-fatty acids from partially-hydrogenated oils; or 
iii.  They are not energy or stimulate beverages or food intended for athletes or for individual performing increased physical activity. 
in schools and educational establishments, the following can be offered for sale, sold or advertisement 

i.  unprocessed fruit and unprocessed vegetables, defined as fruit and vegetables that have not been subjected to any processing resulting in a substantial change 

to their original condition; such processing does not include washing, peeling, trimming, splitting, cutting, blanching, grinding, crushing or packaging, or 

ii.  fruit and vegetables juices and nectars with no added sugar, which is defined as all monosaccharides and disaccharides with an energy value greater than 3.5 
kcal/g  from  sources  other  than  fruit  and  vegetables,  and  dairy  products  in  the  case  of  lactose;  added  sugar  is  also  defined  as  sugars  contained  in  foods, 
especially honey, malt, molasses, all syrups, or doubly or more concentrated fruit or vegetables juices, if used for their sweetening properties.  

The law also imposes maximum permissible values for the content of salt, fats and sugars in oils and fats, non-fried and non-grilled meat products and egg products, products 
made  from  fishery  and  aquaculture  products,  milk  products,  milled  cereal  products  and  bakery  products,  sandwiches-type  bakery  products  without  mayonnaise,  dressings, 
mustard or ketchup and other foods.  

France  

In France, law 2004-806 bans food and drink vending machines from school premises. Specifically, article 30 of the law states, "automatic vending machines for beverages and 
food products that are chargeable and accessible to pupils are prohibited in schools as from 1 September 2005". However, article 30 also consequently prevents the sale of fruit 
(or vegetables) from vending machines in school premises, despite, it is understood, efforts to clarify this or even to make an exemption for fruit.  

There are no public initiatives in the French market which would encourage operators to place healthier products in their machines, without banning the machines. The promotion 
of healthier vending products is actively encouraged via the "feel Good" label. This label came about as a result of collaboration between the French vending machine association 
and some nutritionists and has currently been awarded to 52 vending operators of varying sizes and total of 1500 labelled vending machines.  

325 

 
The label places the food products into 4 families: cereal products, fruits and vegetables, non-alcoholic drinks and milk products. This voluntary initiative can help companies, 
contracting authorities and organisations drawing up tendering requirements, who wish to have vending machines with a range of "healthier" products, but are unsure of what 
demands in particular to ask for. 

Italy 

Although there are no public initiatives and vending machines, the policy is actively being placed under scrutiny. There are a number of local and regional legislative initiatives 
proposed, which aim at banning or avoiding certain products in schools, i.e. replacing sweets and snacks by ""noble food" to encourage healthier eating habits.  

The Italian Parliament presented a law which aims to ban industrial products in favour of local ones within schools, hospitals, retirement homes and public places. The group that 
presented the proposal stated that vending machines were "the ideal means to promote products that could be identified as being part of the Mediterrean diet catalogue" 

Portugal 

In 2016 Portugal introduced a new regulation, order 7516-A/2016, that regulates what specifically can be sold at the vending machines in the institutions of the national health 
system. The law outlines that the sale of the following products form vending machines in the health system environment is not permitted:  

a.  salted: e.g. patties, croquettes, pies, codfish or savoury puff pastry 
b.  pastries: e.g. cakes or pastries with puff pastry and/or cream and/or topping 
c.  bread with sweet stuffing, cakes with sweet stuffing or croissant with sweet filling 
d.  meats: e.g. sandwiches or other products containing chorizo, sausages, sauerkraut or ham 
e.  Sandwiches or other products containing ketchup, mayonnaise or mustard.  
f.  Waffles and biscuits containing for each 100g a sugar content exceeding 20g e.g. Belgian type biscuits, butter biscuits, chocolate chip cookies, chocolate wafers. Wafers 

stuffed with cream, wafers with topping 

snacks e.g. strips of corn, chips, appetizers and sweet or salty popcorn 
desserts- e.g. chocolate mousse, milk-cream or sweet rice 

g.  Soft drinks e.g. cola drinks, tea extract, flavoured waters, soft drinks or energy drinks 
h.  sweets e.g. sweets, caramels, lollipops or gums 
i. 
j. 
k.  quick meals – e.g. hamburgers, hot dogs or pizza 
l. 
m.  alcoholic drinks 

chocolates in packs of more than 50g 

With regards to hot drinks machines, the maximum level of sugar permitted is a beverage is 5g 

The  contract  with  the  vending  machines  operator  must  include  the  mandatory  provision  of  water  bottles  (i.e.  natural  mineral  water  and  spring  water)  and  must  preferably 
provide the following foods: low-fat/ lean plain milk, low-fat yogurts, preferably no added sugar, fruit juices, low-fat bread, low-fat ham, tuna or other canned fish and fresh 
fruit.  

Romania 

326 

 
The Law 123/2008 provides that the minister is required to identify the foods which are recommended not to be present in pre-schools and schools, and permits a list of banned 
foods for schools, nurseries, homes for students and other students areas (e.g. camps, canteens) to be created. 

The order 1563/2008 has consequently established a list of products prohibited from being commercialised in schools, nurseries and other areas. The products banned are as 
bellow:  

food containing sugar over 15% of product except fruits and vegetables 
food containing fat over 20% of the product of which cumulative: saturated fat over 5% of products and fatty acids over 1% 
food with salt content of more than 1.5g salt in 100g of product and 0.6g sodium in 100g of product 

a. 
b. 
c. 
d.  soft drinks except for bottled still drinking water or bottled mineral water 
e. 
f.  Unpackaged food except bananas and oranges.  
g.  unlabelled food 

foods with caloric content of over 300 kcal per unit of sale 

The legislation is not so clear in regards to coffee and hot drinks. However, Romanian vending operators do not offer coffee in primary school environments. Tea, however, can 
be provided for elementary school children and hot drinks machines can furthermore supply soup.  

Spain 

In July 2010 it was agreed that the food supplied in vending machines, canteens, kiosks or similar premises located inside educational establishments must be consistent with 
nutritional recommendations for the school-age population. In particular, vending machines cannot sell foods and beverages with high fat, salt or sugar content and with poor 
nutritional value, as well as avoiding advertising of this type of food in the least appropriate places. It is recommended that food products should not exceed 200kcal, 10% of 
saturated fats, contain more than 30% of sugars, sweeteners and other stimulants, contain more than 0.5% salt.  

In July 2011 the National Food Safety and Nutrition Act was approved that prohibits sets, salty snacks, industrial bakery and refreshments in cafeterias and vending machines in 
schools and educational centres. A draft law on the promotion of a healthy life and balanced food was also proposed in 2016 in the region of Andalusia. The law foresees 
limitations and restrictions on foods and beverages in schools and would oblige the companies responsible for the installation and maintenance of vending machines for food 
products in public spaces to provide free access to refrigerated drinking water, whether through the vending machine or in close vicinity of it.  

UK 

There are no public encouragement initiatives or schemes in UK working with vending operators encouraging them to place healthier products or a wider range of products in 
machines. However, there are several guidelines for the vending machines in schools and hospitals. 

UK government buying standards food practice guidelines, which apply to all sites in the UK government estate, requires that 

a.  savoury snacks should only be available in pack sizes of 30g or less 
b. 
confectionary and packet sweet should be no more than 250 kcal 
c. 
sugar sweetened drinks should be in packs no bigger than 330 ml. no less than 80% of the drinks in the vending machines should be low calorie or no added sugar 

In Scotland the "healtyliving award' is a national award for the foodservice sector. Amongst others, it requires that:  

327 

 
a.  vending machines selling confectionary or crisps should contain a sweet and a savoury snack that meets the brought-in products criteria 
b.  Drinks and vending machines must contain water, unsweetened fruit juice or low-fat milk. Where soft drinks are served, sugar-free (less than 0.5g sugar per 100ml) 

must also be available.  

The healthy living award plus is a higher level of award, which rewards catering establishments that demonstrate a greater commitment to supporting healthier eating. This 
award requires:  

a.  Snack machines must have 30% of the product rage meeting the healtyliving brought-in criteria. healthyliving items must also be prominently positioned and priced 

competitively 

b.  drinks machines must have at least 70% of soft drinks (by variety/brand) sugar-free (less than 0.5g per 100ml) 

In Wales, the government established  guidance on healthier vending as part of their Change4Life programme, which provides examples of which foods and drinks could be 
considered "healthier" 

328 

 
 
 
 
 
 
Annex 5. 
This section presents the comments received through BATIS and personal communications  

Table of stakeholder's comments from the Technical report v3 

5.1.  Table of stakeholder's general comments on the propose criteria for EU GPP criteria  

General comments 

Table 85. Feedback from the stakeholders on the TR3.0 
Topic 

Feedback from stakeholders 
The tenderers do not know what the Orderer are going to buy during the contract period, 
therefore the sentence "planned to be supplied in the execution ..." does not work. 
This is a general problem with this paragraph. 
Same comment as before - you cannot ask the tenderer to know what the Orderer will buy in the 
future. The tenderer only knows what he is offering. 
FoodDrinkEurope welcomes that a relevant part of the recommendations made our organization 
in March 2017 have been incorporated in the second version of the report. 
General Comments: 
We welcome having Award Criteria that will give extra points in proportion to the amount of 
products exceeding the percentage set by the public authority as this will help to reflect the 
premium costs associated with them. We call on the Commission to include guidance on how to 
allocate points “proportionally” to ensure that additional points are distributed fairly and 
objectively. 

JRC-Directorate B5 assessment 
Comment rejected 
The evaluation of the offers should be done before awarding 
the contract, therefore information about the products to be 
purchased and that complied with the criteria is needed.  

Comment accepted 

Comment rejected 
Guidance on how to allocate points proportionally to ensure 
that additional points are distributed fairly and objectively is 
not provided in any EU GPP. This is because the criteria are 
designed  to  be  adapted  by  the  tenderer  to  the  specific 
location and service.  

329 

 
 
 
 
 
 
 
Topic 

Feedback from stakeholders 
The definition of award criteria in the text recognises that awarding contract on the basis of most 
economically advantageous tender (MEAT) means that it must take into consideration the cost 
element and a wide range of other factors that may influence the value of a tender, such as 
quality or environmental aspects. It is important to emphasize that the lowest cost tenderer is not 
always in the interest of the contracting party and that there is a need to balance out cost 
considerations with other factors like quality of the products and services offered. 
FoodServiceEurope, jointly with EFFAT and thanks to funds of the Commission developed a Guide 
to the Economically Most Advantageous Offer in 2005, which is expected to be updated next year 
to reflect the new legal framework currently in force. Pending its revision, we would recommend 
including a direct mention to this guidance which provides useful recommendations on 
methodology for awarding catering contracts that accounts for both quality and price and 
includes guidance on allocating award points in public tenders, which are still pertinent.   
The fact that the Award Criteria do not set a mandatory threshold to be fulfilled by all the 
tenders should not mean in our view that the criteria laid down for a tender can be unrealistic or 
should not take into account the reality of the markets, as has been argued by the JRC in reply to 
our comments on some of the criteria proposed. At FoodServiceEurope we think that award 
criteria are a good way to promote innovation and competition between operators and an 
important element for the decision not to be based just on price. But to reach that purpose, 
award criteria that are proposed need to be realistic and achievable. Moreover, due to the highly 
competitive nature of the business, any participant to a public tender will want to meet the award 
criteria. It is not perceived as non-mandatory by tenderers who want to win the contract. 

We would like to stress again the need for a life-cycle approach to avoid unintended 
consequences. The overall tension between several of the recommendations across the report 
persists. In particular between TS 5.2 on Chemical products for hand washing, dishwashing and 
routine cleaning and TS 5.1 on disposable items. On the one hand, there is a desire to use more 
washable items, which will result in an increase in the use of chemical cleaning products. On the 
other hand, the Award Criterion gives extra points to caterers for taking actions “to reduce 
significantly the consumption of chemical products”.  In the future, perhaps the European 
Commission can develop tools to help public authorities use the Product Environmental Footprint 
to formulate science-based GPP criteria 

As we have said before, we welcome the chapter on life-cycle costs. We reemphasize our belief 
that it lacks coherence with the criteria and requirements proposed. In order to implement some 

JRC-Directorate B5 assessment 
Commentaccepted rejected 
Authorities should be aware of this document 

Comment rejected 
Even if requiring a LCA  study can provide evidences on the 
best  environmental  performing  action  and  service.  the 
interpretation  of  the  LCA  results  is  not  easy  and  would 
require that the tenderer is qualified for it.  
From our point of view there are no contradictions between 
TS 5.2 and TS 5.1. Both of them try to promote the material 
efficiency, the latter one avoiding whenever possible the use 
items  and  the  first  one  avoiding  the 
of  disposable 
overdosing of detergents.   
Comment accepted 

330 

 
 
 
 
Topic 

Feedback from stakeholders 
of the recommendations (e.g. preparation of organic food separate from conventional dishes, 
food redistribution, using reusable tableware, staff training) there are additional administrative 
and labour costs. There are also some product-related premium costs in the catering services 
section that were not included in the life-cycle costs chapter (e.g. using EU eco-labelled cleaning 
products). FoodServiceEurope submitted some data to the JRC on these extra costs on 30 March 
2017 and we would like these additional costs to be taken into account in the life cycle costs 
section for the final version of the report.    
For instance, the criterion on Staff Training recommends 16h of on-site training. While we agree 
with the importance of training staff to environmental aspects, it has an important labour cost. 
But it has not been included in the list of cost to be taken into account in the labour costs section 
of the life-cycle assessment. It should be taken into consideration in the life-cycle costs, perhaps 
shown in cost per hour of training.   
We have pleaded for the addition of an exception for use of washable napkins and tableware in 
the TS 5.1. on Disposable Items but the JRC has rejected our comment. Again, it would bear 
additional labour costs as someone needs to collect, wash, fold and put away these items. 
Finally, the requirement under the TS8 on Environmental Management Measures and Practices 
requires to monitor and record at least twice a year for representative weeks plate food waste 
where it is sorted out. Plate waste is often not requested by clients because it is difficult to 
organise and requires additional labour costs to ensure proper sorting of food waste from other 
waste. It is often carried out by external companies and those costs should be taken into 
consideration in the life-cycle cost. 
The labour costs of providing and receiving training, of implementing food waste and food 
redistribution measures should be reflected in the life-cycle costs section. 
We reiterate our recommendation to add these considerations to the last chapter on life-cycle 
costs. We would be happy to provide further input if necessary 

We would also suggest including under the recommended values, “The contracting authority will 
have to specify the percentage taking into account availability and cost and how the percentage of 
purchase will be calculated, either in volume, weight or value.” 
The EEB appreciates that some of its recommendations for improvement have been incorporated 
into the final GPP criteria proposal. We welcome particularly: 
The ambition levels proposed for purchasing organic food products (TS1, AC1); 
The ambition levels proposed for purchasing fair and ethical trade products (AC4); 
The ambition levels proposed for purchasing environmentally responsible fats, covering now palm 

JRC-Directorate B5 assessment 
The  impacts  of  the  criteria  will  be  further  explained  in  the 
LCC section  

See replies below on waste prevention 

Comment accepted 

See replies under the respective criteria 

331 

 
 
 
 
 
 
JRC-Directorate B5 assessment 

See replies under the respective criteria 

Topic 

Feedback from stakeholders 
oil, palm kernel oil or their derivatives as well as food and/or drink products containing soybeans 
and/ or soy oil (TS 4). 
The EEB also acknowledges the compromises found on the following issues as acceptable: 
The criteria tackling animal welfare (TS3, AC3); 
The reasons for removing criteria on purchasing food from integrated production. 
Nonetheless, the EEB regrets the following shortcomings: 
The lack of an award criteria for purchasing organic meat (as part of AC1); 
The low ambition on the sustainability of marine and aquaculture food products (TS2, AC2); 
The lack of award criteria for reusable packaging and return systems; 
The lack of guidance on purchasing seasonal produce that would avoid air transportation. 
Therefore, the EEB recommends addressing at least the following issues before the final adoption 
of the revised EU GPP criteria for food and catering services: 
Integrate the purchase of organic meat into AC 1 of the comprehensive criteria proposal; 
Reconsider the formulation of T2 regarding the proposed marking as green in the list coming 
from the yearly fishing quotas and allowable catches of the European Commission; 
Increase the share of sustainable marine and aquaculture food products in AC 2 to 10-30% in the 
core and to 30-60% in the comprehensive criteria; 
Removal of the Red Tractor Farm Assurance scheme from the referenced list of third party 
certified, widely accepted and recognised standards for animal welfare in AC3 

The EEB appreciates that some of its recommendations for improvement have been incorporated 
into the final GPP criteria proposal. We welcome particularly: 
The clarity and ambition provided on the provision of plant-based menus (TS2, AC1); 
The criteria on food/beverage waste prevention, including the recommendation for a system that 
allows customers to provide their feedback on the size of food portions and the quality of 
prepared meals (TS 3.1); 
The criteria on environmental management measures and practices (TS8, C3); 
The provision of low impact drinking water (C1). 
The EEB also acknowledges the compromises found on the following issues as acceptable: 
Competences of the tenderer (SC1); 
Prevention, sorting and disposal of other waste (TS4.1+4.2); 
Use of chemical products and consumable goods (TS 5, AC 2); 
Energy and water consumption in kitchens (TS6, AC3); 
Food transportation (TS7, AC4); 

332 

 
 
Topic 

Feedback from stakeholders 
Purchase of new kitchen equipment (C2); 
Staff training (C4); 
Environmental management measures and practices (TS8). 

The EEB appreciates that some of its recommendations for improvement have been incorporated 
into the final GPP criteria proposal. We welcome particularly: 
The ambition levels proposed for share of organic food products (TS1, AC1); 
The specific measures addressing energy consumption and GWP of refrigerants(TS3, AC3, AC4, 
C1); 
The mandatory provision to allow for reusable cups (TS 4). 
Nonetheless, the EEB regrets the following shortcomings:   
The lower ambition on the share of fair and ethical trade products as well as of environmentally 
responsible fats in comparison with direct food purchases. 
We  are  wondering,  how  the  'production  and  use  of  pesticides'  are  relevant  for  meat  and  egg 
production? 
"Shifting away from meat"  
We can understand the ratio behind this from environmental point of view. However, we would 
like to state, that from nutritional point of view meat belongs to a balanced diet (as it is also a 
source of iron and for certain target groups e.g. children adequate consumption is considered as 
appropriate). 

Table 1 

JRC-Directorate B5 assessment 

See replies under the respective criteria 

Comment accepted 
The  wording  has  been  changed 
consumption 

to 

reducting  meat 

5.2.  Table of stakeholder's comments on the propose criteria for EU GPP criteria for Food procurement 

Organic food products 

Table 86. Feedback from the stakeholders on the TR3.0: Organic food products  
Topic 
Requirements 
and 
verification 

Feedback from stakeholders 
These claims cannot be imposed on the Tenders of the contracts. The Tenders (Food Service 
Suppliers) would in general have both conventional and biological products in their assortments. 
They also offer these foods and drink products to private Orderers who are not subject to the 
provisions of the said regulation. The claims that x% of the total purchase of food and drink must 
comply with the Regulation (EC) No. 834/2007 must per definition lie with the Orderer, because it 
is the Orderer who decides what to buy, and when to buy it. 

JRC-Directorate B5 assessment 

Comment acknowledged 

At the tendering phase, the food supplier offering its service 
is  the  responsible  figure  to  ensure  that  the  offered  organic 
products  will 
environmental 
characteristics. The contract performance clause C1 is asking 

requested 

fulfil 

the 

333 

 
 
 
 
 
 
 
Topic 

Feedback from stakeholders 

Environmental 
impacts of the 
organic food 
products 

Procurers should also be required to check all "documentary evidences" and if applicable, including 
the certificates of the suppliers based on Regulation (EC) 834/2007. Is a reference to the UN 
report A/HRC/34/48 possible? It is a plea for agro ecology as a solution for food 
insecurity.  Organic produce is a way of agro ecology. 
Can the importance of soil management be pointed out in this document? Crop rotation delivers 
high quality soils, higher yields and less/no use of pesticides. (More information can be offered by 
Boris Boincean or his  book: Black earth) 
We would like to re-instate our April 2016 and March 2017 argument on organic products. 
Although organic products and the related manufactured foodstuffs can contribute to the 
sustainability of food systems, from a GPP criteria perspective, organic agriculture as such is not 
by default a guarantee of better environmental performance for all impacts categories related to 
food production. The environmental analysis by the JRC on Organic Food concludes that there is 
insufficient evidence available to suggest that organic products have overall a lower 
environmental impact than conventionally produced products [P. 19 Technical Report]          ].  
Even if the JRC has reportedly acknowledged such comment we regret there is no practical 
affection of such comment to the content of the report. 
It is important to explicitly note that "some environmental benefits" are not either or, and it should 
be specified that the organic rules (Regulation (EC) 834/2007 and (EC) 889/2008) deliver a wide 
range of environmental benefits e.g. respect for natures systems/cycles, contribution to 

JRC-Directorate B5 assessment 
for  data  during  the  contracting  period,  so  that  the 
Orderer/municipality  can  see what  kind  of  food is  delivered 
to them that fulfil the requirements of the TS/AC. A specific 
mention of this issue has been made in the rationale of the 
criteria (Organic, Marine and Animal Welfare). 
To  ease  the  verification  during  the  contract  execution,  the 
text  has  been  changed  now  and  in  Option  A  the  public 
procurer  would  specify  the  products  to  be  supplied  that 
should  be  organically  grown,  for  the  case  they  are  directly 
purchasing  the  food.  Option  B  is  for  the  case  that  public 
procurers  are  requesting  the  catering  service  and  therefore 
they do not have the control on the specific products to be 
supplied, so they may request that at least a percentage of 
them is organically grown. 
Comment rejected 
The  mentioned  report  A/HRC/34/48  does  not  constitute 
evidence of verification that a specific food product complies 
with the criterion 
Comment accepted 

Comment accepted 

Comment accepted 

334 

 
 
 
Feedback from stakeholders 
biodiversity, responsible use of natural resources e.g. energy, water, soil, air climate. This should 
be more clearly accounted for in the TR to avoid the confusion with conventional products. See 
European Commission Evaluation Sanders (ed.) 2013. Evaluation of the EU legislation on organic 
farming. 

JRC-Directorate B5 assessment 

The percentage range for the Core Criteria should be up to 100% because for some specific food 
and drink products it will already be possible to reach 100% when there is availability.  

Considering the diverging levels of development of organic production across the EU-28, we 
believe the considerable increase in ranges for the targets for organic food products in value to 
30-70% for core criteria and 60% for comprehensive criteria are too high to be achievable across 
the EU-28. 
Similarly, we believe 20% as a recommended minimum level for mass is unrealistic and cannot 
be achieved across the EU-28. 
Previous experiences in Europe have shown that a 20% target is not realistic. For instance, in 
France where organic supply are more developed than in most EU countries, there has been an 
obligation to reach a 20% organic food target by cost for some time but it has not been 
achievable for the vast majority of cantines. 
We would reiterate our recommendation to lower the minimum targets in both volumes and 
value. 

Topic 

Thresholds 

Thresholds 

Scope and 
structure 

The lack of an award criteria for purchasing organic meat (as part of AC1); 
Integrate the purchase of organic meat into AC 1 of the comprehensive criteria proposal 

Integrated production  

Table 87. Feedback from the stakeholders on the TR3.0: Integrated production  

Comment rejected 
The  core  criteria  include  thresholds  that  can  be  applied 
across  Europe.  We  are  not  aware  of  any  product  which 
availability and affordability is so to be supplied up to 100% 
all over Europe 
Acknowledged 
As commented the availability of organic products seems to 
differ  largely  among  the  Member  states.  The  values 
expressed  in  the  explanatory  notes  are  in  accordance  with 
the  information  collected  during  the  review  of  these  GPP 
criteria. These values are not mandatory to be implemented 
in the GPP criteria to be drafted by the tenderer. The purpose 
of these values is only to give an idea of possible values that 
can be used.  
Tenderers should evaluate the availability of products, costs 
as well as if those products fulfil his/her needs.   

Comment accepted 
The  purchase  of  organic  meat  is  not  excluded  from  the 
organic food product criteria. If organic meat is purchased it 
accounts  and  raises  up  the  %  of  organic  food  provided  by 
the tenderer.  
The  meat  is  not  listed  as  an  example  because  it  is  not  a 
widely available organic product. however, it should be noted 
that  the  list  includes  examples  of  products  and  purchase 
authorities can modify it  

335 

 
Topic 
Removal of the 
integrated 
production 
criterion 

Feedback from stakeholders 
Can the UN report A/HRC/34/48 on the right to food be pointed at? It speaks of agro ecology as a 
tool for food security. This is about organic, integrated production etc. 
If integrated production gets removed, it should be pointed out that it exists and that it agro 
ecology. The procurer will have to realize there are different national schemes (country of origin 
of the product)  that can be used. 
We welcome the removal of the Integrated Production criterion on the grounds that EU 
harmonised definitions are lacking. It would likely have led to inconsistent application of the 
criteria across the EU. 
At this moment, there is still no unique definition of 'integrated production' across Europe which is 
often a basic requirement for an entire production sector. The fact that different definitions exist, 
there is no EU added value to include any integrated production criterion. 

JRC-Directorate B5 assessment 
Comment accepted 

Comment accepted 

Comment accepted 

Maritime and aquaculture products 

Table 88. Feedback from the stakeholders on the TR3.0: Maritime and aquaculture products 
Topic 
General 

Feedback from stakeholders 
The  tenderer  cannot  provide  data  of  marine  and  aquaculture  food  products,  planned  to  be 
supplied  in  the  execution  of  the  contract  indicating  specifically  the  marine  and  aquaculture 
products  that  comply  with  the  requirements,  because  the  tenderer  is  not  the  one  buying  the 
products, it is the Orderer/municipality/kitchens. The tenderer cannot see into the future, and do 
therefor not know what the orderer is going to buy. 

Maybe it is better if the tenderer specify how many fish on the list they offer that comply with 
the requirements? And ask for data during the contracting period, so that the Orderer/municipality 
can see what kind of fish are delivered to them. 

JRC-Directorate B5 assessment 

Comment acknowledged 

The wording of the criteria does not require specific species 
to  be  purchased,  but  that  those  to  be  supplied  fulfil  the 
environmental  requirements.  At  the  tendering  phase,  the 
tenderer is the responsible figure to ensure that the offered 
marine  and  aquaculture  products  will  fulfil  the  requested 
environmental  characteristics.  The  contract  performance 
clause C1 is asking for data during the contracting period, so 
that  the  Orderer/municipality  can  see  what  kind  of  fish  is 
delivered to them that fulfil the requirements of the TS/AC. A 
specific mention of this issue has been made in the rationale 
of the criteria (Organic, Marine and Animal Welfare). 

Recommended 
values 

The  percentages  for  core  and  comprehensive  are  to  low  - they  be  higher.  Especially  this  is 
surprising for aquaculture.  Go for 50% core and 100% comprehensive. 
The  percentages  for  core  and  comprehensive  remain  very  low.  This  is  especially  surprising  for 

Comment rejected 

The  core  criteria  include  recommended  thresholds  that  can 

336 

 
 
 
 
 
aquaculture. Is 50% for core and 100% for comprehensive possible? 

This proposal lacks in ambition. A minimum number higher than 0 should be recommended. 

0% is no target for a comprehensive criteria in green procurement. The rationale for not including 
a higher minimum percentage it is not logic in comparison to organic criteria 

Increase the share of sustainable marine and aquaculture food products in AC 2 to 10-30% in the 
core and to 30-60% in the comprehensive criteria; 
Regarding  the  recommended  values  for  the  core  criteria  and  comprehensive  criteria  on 
aquaculture  products,  we  reiterate  that  it  could  be  an  issue  to  reach  them  in  some  Eastern 
European  Member  States  where  the  availability  of  certified  aquaculture  products  is  an  issue. 
Buying  aquaculture  products  that  have to  travel  extensively  to  the  consumption  locations  does 
not always make sense from an environmental perspective. In Spain, for instance, there are more 
than 30 different local aquaculture products. However they might not necessarily be certified. The 
environmental footprint of importing certified aquaculture products from further afield needs to 
be weighed against the footprint of using conventional, locally-produced aquaculture. 

fishing tacs and quotas: the website offers a very visual overview until 2015. As this 'poster' is 
very  handy  in  use.  Maybe  2015  is  still  useable  enough  for  the  year  2017?  Will  there  become 
more recent posters? 

There's a very useful guide in dutch and french: http://www.zeevruchtengids.org/nl 

be applied across Europe. The reason to go as low as 0% lies 
in the confirmed fact that in some European Member States 
the availability of certified aquaculture products is an issue. 
The  organic  criteria  is  however  based  on  a  EU  Regulation, 
being therefore widely available and easier the verification. 

Comment rejected 

We  are  very  much  aware  of  the  point  raised.  That  is  the 
reason  behind  the  proposal  of  values.  These  values  can  be 
modified by the contracting authorities if they consider that 
the values are not suitable for that region or service. In the 
rationale  of  the  criterion  (page  19)  there 
is  further 
information regarding this point. 

Comment acknowledged 

The quota maps are renewed periodically. This is a proposal 
to cover those locations where there are no local guides or 
maps, so that local authorities can make use at least of the 
European ones. The public authorities can check the indicated 
website to get the most updated version. 

Aquaculture 
availability 

Criterion 
requirement 

Animal welfare 

Table 89. Feedback from the stakeholders on the TR3.0: Animal welfare 
Topic 
Certified 
schemes 

Feedback from stakeholders 
Removal of the Red Tractor Farm Assurance scheme from the referenced list of third party 
certified, widely accepted and recognised standards for animal welfare in AC3. 
Red Tractor does not require milk cows to have access to pasture during the grazing season.  It 
does reflect EU legislation in prohibiting routine tail docking of pigs. However, this requirement is 
poorly enforced.  A 2017 publication by the UK Agricultural and Horticultural Development Board 
entitled Real Welfare Baseline Report found that 70% of pigs had their tails docked despite the 

JRC-Directorate B5 assessment 

Comment accepted 

Red Tractor farm removed. 

337 

 
  
 
 
Topic 

General 

Feedback from stakeholders 
prohibition on routine tail docking. Red Tractor does not cover slaughter and so does not ensure 
that animals are stunned before slaughter. It does not stipulate maximum transport times for 
pigs or dairy cows. It does lay down a maximum transport for broiler chickens of 12 hours 
between the start of loading and unloading at the slaughterhouse. This is far too long. In contrast 
to this, one of the other schemes referred to in footnote 2, RSPCA Assured, provides a shorter 
maximum transport time of four hours from when the birds leave the farm to arriving at the 
slaughterhouse. 
We believe that the Red Tractor scheme should be removed from footnote 2 as in general it does 
not require welfare that goes beyond the minimum requirements of EU legislation. 
See comment from Organic and Marine. It is not the tenderer that purchases, and therefore this 
cannot be evaluated and given points 

Animal welfare 
vs 
organic 
production 

Organic farming should not be excluded from specific animal welfare tenders and only be limited 
to organic specific tenders. In fact, organic certification is one of the most reliable ways to prove 
that the criteria for this category have been met. Explicitly excluding organic farming from this 
category would give other schemes claiming to be sustainable an unfair advantage. 
Organic certificate can be a sufficient verification that the criteria have been met. 

JRC-Directorate B5 assessment 

Comment acknowledged 

At the tendering phase, the tenderer is the responsible figure 
to ensure that the offered animal welfare products will fulfil 
the  requested  environmental  characteristics.  The  contract 
performance  clause  C1  is  asking  for  data  during  the 
contracting  period,  so  that  the  Orderer/municipality  can  see 
what  kind  of  fish  are  delivered  to  them  that  fulfil  the 
requirements  of  the  TS/AC.  A  specific  mention  of  this  issue 
has  been  made  in  the  rationale  of  the  criteria  (Organic, 
Marine and Animal Welfare). 
Comment rejected 
This  criterion  does  not  exclude/undermine  the  organic 
products but it enhances those that are produced observing 
animal welfare provisions.  
The  EU  organic  regulation  provides  the  requirements  for 
producing  under  the  organic  standards  while  this  criterion 
observes the requirements to produce under animal welfare 
conditions. 

Recommended 
values 

"The core and the comprehensive criteria are the same. It is possible to make a higher % for the 
comprehensive criteria." 

Comment rejected 

Since  there  were  no  conclusive  data  to  make  a  clear 
differentiation between core and comprehensive levels, it is 
here proposed a similar wording for both. Leaving the public 

338 

 
 
Topic 

Feedback from stakeholders 

We would like to reiterate that for the AC 4 and the recommended values, it would be extremely 
difficult to move to 80% free range in the short-term. 
In its comment, the JRC notes that “these values can be modified by the contracting authorities if 
they consider that the values are not suitable for that region or service”[1]. We would be in favour 
of emphasising more clearly in the explanatory notes that local availability of free range eggs is 
an important factor to be kept in mind by public authorities. 
[1] P.261 of the 3nd Technical Report 
Hence, we would recommend including under the recommended values for eggs, meat and dairy 
produce the following note: “The contracting authority will have to specify the percentage taking 
into account availability and cost and how the percentage will be calculated, either in volume, 
weight units or value.” 
As we commented previously for the criterion on meat, we believe that availability of dairy 
products that meet requirements from a certification scheme on animal welfare in all the EU-28 
varies widely, and cost implications would be significant. 

Environmentally responsible fats  
Table 90. Feedback from the stakeholders on the TR 3.0 Environmentally responsible fats  
Topic 
Supporting 
documents 

Feedback from stakeholders 

It would be really helpful if there were a database, where you can  find guides to how 
documentation should look. What to be aware of when you control the documentation for 
sustainable soya and sustainable palm oil. 

Change in the 
scope and 

We specifically welcome that the terms used to describe the environmental performance of a 
product have been reverted from an absolute approach (i.e. environmentally friendly) to a relative 

JRC-Directorate B5 assessment 
procurer the option to choose the most convenient level for 
their tenders. 

Comment accepted 

The  following  text  has  been  included  in  the  Explanatory 
notes in order to select the recommended values to fulfil the 
criterion:  
the 
"The  contracting  authority  will  have 
percentage  of  purchase  taking  into  account  availability  and 
costs and how the percentage of purchase will be calculated, 
either in volume, weight or value." 

to  specify 

JRC-Directorate B5 assessment 
Comment accepted  
The  proposed  criterion  allows  the  verification  of  the  listed 
requirements  by  complying  with  one  out  of  a  number  of 
certification schemes (some of them are listed in a footnote 
accompanying  the  criterion).  Each  certification  scheme  has 
established  a  methodology  for  demonstrating  compliance 
with the requirements of the certification scheme.  
Some  of  these  schemes  provide  also  a  database  with  its 
members or certification holders as well as examples of the 
certifications or chain of custody certificate awarded.  
Comment accepted 

339 

 
 
Topic 
wording of the 
criterion 

Feedback from stakeholders 
approach (comparative) (i.e. environmentally friendlier) in accordance with ISO 14021:1999 and 
Commission’s guidance on the implementation/application of Directive 2005/29/EC on Unfair 
Commercial Practices and EU Guidelines on environmental claims. We think such approach should 
be as well translated to the title of the criteria 2.1.8 on Fats and change it to “More 
environmentally responsible fats”. 
We welcome the modification of the criterion from an Award Criterion to a Technical Specification 
and the improved wording of the criteria that avoids incentivising more use of palm oil. 

Certification of 
soy products 

The change in title proposed for this criterion is not accurate in our view. We would recommend 
changing the name to “Environmentally responsible vegetable oils” since this criterion relates only 
to vegetable oils and not the broader category of fats. 

We understand the intention of the JRC to ensure that when soy oil and soybeans are used, it 
should cause the lowest environmental impact possible. However, the market penetration of 
certified food products for soya is still very low compared to palm oil. As recognised by the JRC in 
the report: “The total production of standard-compliant soybeans (including ProTerra, RTRS and 
organic), represent a small share of the market, at 2.0 %, which is equal to 5 million tons (2012)”[1] 
Certification schemes for sustainable soy products are still in the development phase and not 
easily available. Therefore we would recommend excluding it from this criterion.[1] Page 271 of the 3nd 
Technical Report 
The National Agency of Public Procurement of Sweden comments that soy used as feed for 
livestock can be included in the scope of the criterion. One feasible action to tackle sustainability 
challenges connected to sustainable oil crop production could be to introduce an Award Criteria 
for soy feed at the comprehensive level which can be verified with Pro Terra or RTRS certificate 
at the production level. 
From sustainability perspective in the case of soybean production– the relevance of sustainably 
produced oil crops for animal feed is greater than for any other use of soy, since a clear majority 
of the global soy production is used  as animal feed. The verification may be a challenge due to 
the lack of labelling of the food product but not impossible.  Commonly, procuring agencies are 
encouraged to do regular follow ups at the production level by random sample. In this process, 
they contact the food supplier who in turn is responsible for verifying compliance in the value 
chain. A RTRS or ProTerra certificate is in our view not impossible to deliver from the producers 

JRC-Directorate B5 assessment 

Comment accepted 

Comment partially accepted 
The  criterion  includes  products  that  can  be  made  of 
margarines  coming  from  palm  oil  or  other  vegetable  oils. 
From  our  point  of  view,  the  word  fats  is  broader  and 
therefore  does  not  leave  out  of  the  scope  of  this  criterion 
fats such as margarines. 
Comment rejected 
It is considered important to use soy coming from certified 
sources. However, and at the light of the feedback received 
the  thresholds  suggested  may  be  too  ambitious  for  the 
current market situation.  

Comment rejected 
Criteria  for  soy  feed  seems  to  be  difficult  to  verify,  and 
because of this reason feed for the stock does not belong to 
the scope of the present EU GPP criteria development. 

340 

 
 
 
Topic 

Certification of 
soy products 

Traceability 
systems and 
verification 

Feedback from stakeholders 
point. There is thus scope for verifying and following up this criterion without a product labelling 
requirement. The Agency of Sweden has administer  a criterion for “responsibly produced animal-
feed-soy” which suggests RTRS or ProTerra as verification, taking the approach that verification is 
to be made on production-level and not on product level.  
For GPP of food in general and a criterion on soy production in particular to be effective in public 
procurement, such a criterion should tackle relevant sustainability issues in which public 
purchases can have a significant impact on the sustainability of the food value chain. Excluding 
animal feed from the soy criterion significantly reduces the possibility of GPP of food to 
contribute to a more sustainable soy production.   
The title gives the impression that only these two fats are environmentally responsible, while 
these two cause a lot of environmental problems. 
In the first place palm oil should be avoided because of health issues. Secondly both fats have 
their impact and then we speak of land grab, soil depletion, high use of pesticides, disruption of 
water house holding, etc 
It should be advised not to use these fats and look for more healthy (in case of palm oil) and 
sustainable fats. If it cannot be avoided then these fats have to be sustainable as pointed out 
(RSPO, RTRS). 
Countries that have access to 100% sustainable palm oil and/or soy oil go for 100% sustainable. 
I got advice from several organisations (see origin comment) and they all name the RTRS for soy 
in a positive way. They also mention that soy for human consumption is not considered to be the 
biggest problem, but for animal feed it is a problem. So the impact of reducing the use of animal 
products will be the biggest, as written in the text. But I'm convinced as a procurer that you can 
write about quality and taste and therefore I'm also convinced you can ask for meat from grass 
fed cows, you can ask for butter from grass fed cows, the taste of pork meat gets influenced by 
the food they are offered etc. So I wonder if writing about the animal feed as a procurer would 
lead you to far away from the subject matter when we talk about the effect the animal feed has 
on the taste and quality of the meat? 
The National Agency of Public Procurement of Sweden comments that one feasible action to 
tackle sustainability challenges connected to sustainable oil crop production could be to introduce 
a Technical Specification criterion at the comprehensive level for palm oil which only accepts 
RSPO segregated or identity preserved certification as an accepted verification. 
The certification RSPO exists on various levels. The majority of certified palm oil is produced 
under the green palm certificate procedure of book and claim or mass-balance, which does not 
assure traceability of the palm oil content of the product. RSPO certification also exists for 

JRC-Directorate B5 assessment 

Comment rejected 
As  commented  above,  the  inclusion  of  criteria  for  soy  feed 
seem to be difficult to establish. In addition certifications on 
the quality or taste of the products are not directly linked to 
a  better  environmental  performance.  Finally,  the  promotion 
of certifications on the food product quality may be against 
the principles of the free market.  

Comment rejected 
The  inclusion  of  book&claim  system  to  demonstrate  the 
sustainability of this commodity allows setting requirements 
level  of  compliance.  As  commented  the 
with  higher 
availability of this commodity under the book&claim system 
is much higher than under other stricter traceability systems.  

341 

 
 
  
 
Topic 

Feedback from stakeholders 
Segregated and identity preserved palm oil. These schemes can verify that the palm oil in the 
product originates from sustainable sources, but are currently used to a marginal extent. The path 
forward towards a sustainable development of the palm oil industry is to differentiate traceable 
certified palm oil from non-traceable palm oil. This to be able to premier producers who make 
extra economic and administrative effort to assure sustainable sourcing of palm oil and to 
contribute to the extension of the stock of traceable palm oil, and hence increase production of 
sustainably produced palm oil. Without differentiating the certification schemes based on their 
sustainability performance, the possibility for GPP of food to contribute to a sustainable 
development of the palm oil industry is weakened. 

Fair and ethical trade products (BEFORE Fairly traded products) 
Table 91. Feedback from the stakeholders on the TR2.0: Fair and ethical trade products  
Topic 
Requirements 
and 
verification 

Feedback from stakeholders 
Again I have trouble with the word "purchases" - the tenderer cannot know what the 
Orderer/buyer/municipality wants to buy in the future. But maybe if it was switched to "which 
more than x% of the products offered of each of the following.... " 
We welcome the removal of the Integrated Production criterion on the grounds that EU 
harmonised definitions are lacking. It would likely have led to inconsistent application of the 
criteria across the EU. 
We reiterate that the same reasoning should be applied to Fairly Traded products because it 
makes the objective comparison of offers from one caterer with another very difficult as 
products procured will be complying with different environmental standards. 
It creates too much legal uncertainty and we would recommend again removing the Fairly Traded 
products criterion until the EU has developed harmonised standards for these products. 
The lower ambition on the share of fair and ethical trade products as well as of environmentally 
responsible fats in comparison with direct food purchases. 

JRC-Directorate B5 assessment 

JRC-Directorate B5 assessment 
Comment rejected 
See above 

Comment rejected 
The  preferred  certification  schemes  can  be  detailed  by  the 
tenderer  when  adapting  these  criteria  to  their  own  needs. 
Additionally, the contracting authorities can suggest different 
schemes  for  different  products.  In  this  way,  all  the  offers 
would  have  to  comply  with  the  same  requirements,  if  the 
contracting authorities do so.  

Acknowledged 
There  was  a  mistake  in  the  values  proposed  for  the 
comprehensive criteria for environmentally responsible facts. 
The values should have been 50-100%.  
In the case of the faired trade products, the values proposed 
are in accordance with the information collected during the 
revision.  these  values  can  be  modified  if  the  tenderer  does 
not consider that they fit the local conditions 

342 

 
 
 
 
Topic 

Feedback from stakeholders 
Me dirijo a usted desde de la Federación Europea del Café (ECF).   Nuestra federación se fundó en 
1981, erigiéndose como punto de encuentro del sector, representando a los importadores de café 
verde, tostadores de café, fabricantes de café soluble e industria de descafeinización.   Nuestros 
asociados  representan  un  volumen  total  de  importación  cercano  a  los  40  millones  de  sacos, 
equivalente a la mitad del café mundial comercializado.  
El motivo de mi correo es la reciente actualización del documento “Revision of the EU GPP criteria 
for Food procurement and Catering services”. En concreto, nos gustaría llamar su atención sobre 
la nueva definición de “Comercio Justo”. 
Si bien es cierto que la nueva definición “Fair and Ethical trade Products” es más aglutinadora, 
quisieramos  proponerles  el  uso  de  la  terminología  empleada  por  ISEAL  Alliance.  ISEAL  es  una 
organización auspiciada por la Organización de las Naciones Unidas (ONU) cuya misión es la de 
fortalecer  y  reconocer  certificados  que  reconozcan  el  origen  sostenible  y  de  justicia  social,  al 
tiempo que son respetuosos   con el medio ambiente.  
ISEAL define los productos a los que nos referimos como “sustainably produced”, un término que 
engloba los tres pilares básicos de la sostenibilidad (social, económica y medioambiental) y que 
incluye  a  los  programas  de  certificación  más  representativos.  Para  mayor  información  le 
invitamos  a  que  visite  el  siguiente  enlace:  https://www.isealalliance.org/our-sectors/agriculture-
and-food  

JRC-Directorate B5 assessment 
Comment rejected 
The name of the criteria has been discussed several times. It 
was  agreed  that  the  name  should  not  do  reference  to  one 
certification scheme, as it was initially proposed.  
The  proposed  name  including  the  sustainably  products  was 
also  discussed  in  the  revision  of  this  project  and  not 
agreement could be found.  
Due to the impacts that can have in the implementation of 
this criteria, we are opened to new suggestions for the name 
of the criteria 

Seasonal produces 

Table 92. Feedback from the stakeholders  
Topic 

Feedback from stakeholders 
I understand the JRC reasons for not taking the seasonal products into the GPP again, but I do 
regret it, and hope the JRC will reconsider it once more. 
I think the note on page 272 is very important, and hope that the importance of seasonal 
products will be highlighted in the Explanatory note. I just took the comment "What food and 
when the food and drink products must be bought" to the newly established Danish group of food 
procurement officers, and none of them had thought of the possibility only to ask for the food in 
the certain months when you actually buy it! Therefore this comment contains a VERY important 
message to the procurement officers. This can also help reduce food waist at the wholesaler's 
warehouse. 
The lack of guidance on purchasing seasonal produce that would avoid air transportation. 

JRC-Directorate B5 assessment 
Comment rejected 
The purchase of the seasonal products cannot be enhanced 
in this policy tool for the reasons given above.  
The explanatory note on this kind of products aims to make 
the  contracting  authorities  aware  of  the  existence  of  these 
products  as  well  as  notice 
the  environmental 
performance of the products depends on multiple factors.  

that 

Comment rejected 

343 

 
 
 
 
 
 
Topic 

Feedback from stakeholders 

In Denmark we think this is a very good and important explanatory note 
It is a pity that the 'local' discussion took over the seasonal produce. Is there a possibility that 
there can be written a couple of lines on this subject referring to taste, quality and price because 
that is what seasonality is about. 

Packaging 
Table 93. Feedback from the stakeholders on the removal of packaging criterion 
Topic 

Feedback from stakeholders 
It is important to know that packaging prevents food waste. Is there a possibility that it over-
packaging should be avoided where possible which is not the same as the necessary packaging 
to avoid food waste. 
We welcome this removal, especially as packaging environmental aspect has to be addressed and 
assessed together with the product it protects/serves 
We endorse the complete removal of the packaging criteria from the report 
We welcome the introduction of the recommendation to select the appropriate packaging 
(format, protection. preservation, serving portions, etc.) able to efficiently fulfil the required 
functions (incl. food safety and waste prevention). 
We regret the absence of caveat/provisions about environmental relevance for this 
recommendation on recyclable packaging. Adjust the sentence as follows: 
Packaging return: return packaging for reuse when possible and environmentally relevant 
EUROPEN reiterates its support for the removal of this section on packaging, based on a life-cycle 
approach (LCA) reasoning. 
EUROPEN fully agrees with the arguments put forward by the JRC to support this removal, 
including that the GPP should not “favour/penalise the choice of packaging material since this is 
dependent on the situation in which they are being used”. The JRC also rightly puts forward the 
“difficulties to assess the distance for returning the reusable packaging (e.g. to wash and refill the 
bottles)”, “the lack of infrastructure for sorting, collecting and composting biodegradable and 

JRC-Directorate B5 assessment 
Even if air transportation is avoided in the seasonal products, 
not  all  of  them  score  lower  in  the  transportation  category. 
This is due to the large impact of the vehicles used for short 
distances such as from the field to the retailer or from the 
retailer to consumer's house.  
Comment accepted 
Comment accepted 

JRC-Directorate B5 assessment 
Acknowledged 

Comment accepted 

Comment accepted 
Comment accepted 

Comment accepted 

Comment accepted 

344 

 
 
 
 
 
 
 
 
 
 
Topic 

Feedback from stakeholders 
compostable packaging” or the “trade-offs in the use of single unit packaging”. 
The JRC argumentation in favour of this section’s removal also positively highlights packaging's 
functionalities and hence that packaging should be considered as an integral part of the product 
and “cannot be assessed in isolation”. 
EUROPEN welcomes that most of the discriminative prescriptive/restrictive requirements on 
packaging have been either removed (e.g. the  clause on single units or portion packaging for 
which possible benefits have been acknowledged, the discrimination requirement against in-
bought bottle water, and the clause requiring to select low packaging products “with less 
packaging where possible”) or nuanced by a life-cycle caveat (e.g. “select recyclable packaging 
where possible, provided the packaging guarantees for food safety and hygiene", "return packaging 
for reuse when possible", "put condiments and food servings in refillable containers, where food 
hygiene, consumer safety and public health considerations allow their use") in this third draft report 
the clause.   
We deplore however that the same LCA assessment has not been applied to the requirement 
referring to "unnecessary" or "excessive packaging" for which there is no established definition 
which could lead to misinterpretation. 
EUROPEN supports the nuance added by this life-cycle approach (LCA) caveat, which takes into 
account packaging's roles and functionalities, in line with the product in contains. 
While the clause requiring to "select low packaging products" has been removed, the clause 
requesting to “avoid unnecessary and excessive packaging” however remains, despite EUROPEN’s 
and other stakeholders’ calls to remove it, pointing out the lack of established definition for these 
terms, which could lead to misinterpretation and the existing Essential Requirements. Packaging 
is a cost. Producers use as little as possible but as much as necessary, in line with the Essential 
Requirements in the Annex II of the Directive 94/62/EC on Packaging and Packaging Waste. The 
JRC itself acknowledges in its assessment of stakeholders’ comment in annex that “the use of 
excessive packaging can drive environmental impacts up. Since in other cases, it has been 
demonstrated that may serve to prevent food waste, the criterion has been removed, considering 
also the limitations of the verification.” Hence, based on this life-cycle approach (LCA) reasoning, 
we support the removal of this requirement.   
EUROPEN supports this additional clause which acknowledges packaging’s roles and 
functionalities. 
We take note that it would have been difficult to address the issue of packaging in the context of 
the GPP criteria due to its complexity. However, we would like to reiterate important role which 
packaging plays in protecting food integrity and hence prevention food loss and waste. ce of 

JRC-Directorate B5 assessment 

Comment partially accepted 
A restriction of this requirement to secondary packaging has 
been added.  
Some secondary packaging can be unnecessary to fulfil the 
needs of the specific catering services while it can be useful 
in other cases.  

Comment accepted 

Comment partially accepted 
A restriction of this requirement to secondary packaging has 
been added.  
Some secondary packaging can be unnecessary to fulfil the 
needs of the specific catering services while it can be useful 
in other cases. 

Comment accepted 

Acknowledged 

345 

 
 
 
 
 
 
Topic 

Feedback from stakeholders 
reduction of food waste due to packing.  
See study on calculation of trade-off point between extra packaging and environmental impact of 
food-packaging:  http://www.ovam.be/sites/default/files/atoms/files/2015-Report-OVAM-Food-
loss-and-packaging-DEF.pdf   

JRC-Directorate B5 assessment 

5.3. Table of stakeholder's comments on the propose criteria for EU GPP criteria for CATERING SERVICES 

Competences of the tenderer 
Table 94. Feedback from the stakeholders on the TR3.0: Competences of the tender  
Topic 
Length of the 
experience 

Feedback from stakeholders 
References in our contracts relate to the last previous 3 years. Most of our tenders have a max 
duration of 4 years. 
Under competence, could be prohibitive to smaller, more local suppliers/newer organisations 
based on the minimum length of experience requirement of 5 years 
We welcome the inclusion of food waste prevention and food redistribution under the selection 
criteria. As the European Union is committed to aims at reducing halving half per capita food 
waste at retail and at consumer level by 2030 and reduce food losses along the food supply 
chain, in line with Sustainable Development Goals, it is crucial that the new GPP criteria reflects 
this intention.  
We suggest to change the wording of the second point to "if/where applicable, maximise the safe 
redistribution of surplus food". In this way the wording would be in line with the wording used 
under 'method statement' and would provide more certainty for both contracting parties as 
regards the interpretation 
In  order  to  ensure  consistency,  we  propose  to  include  in  the  last  paragraph  reference  to  food 
redistribution. 

JRC-Directorate B5 assessment 
Comment rejected 
5  years  is  the  average  length  of  the  requirement  in  GPP 
criteria 

Comment accepted 

Comment accepted 

Promotion of plant-based  
Table 95. Feedback from the stakeholders on the Promotion of vegetarian dishes 

346 

 
 
 
 
 
 
Topic 
Wording  of 
the criteria 

Plant-based vs 
vegetarian 

Environmental 
impact of 
plant-based 
menus 

Feedback from stakeholders 
Recommend replacing with the following for accuracy:   
Menus offered must include choices with the goal of increasing the consumption of pulses, 
vegetables, fruits, wholegrains and nuts whilst having the same recommended nutrient intake for 
the clients 
Suggest amending to:  pulses, vegetables, fruits, wholegrains and nuts 
We very much welcome this Technical Specification on ‘plant-based menus’ and would like to 
reinforce the importance of this TS for reducing the environmental impact of catering services. 
We recommend replacing 'vegetarian' with 'plant-based' due to animal products heavier 
environmental impact than plant-based foods, and for consistency with previous sections. 
Recommend replacing with 'plant-based'. 
Recommend replacing the word 'vegetarian' with 'plant-based' as animal products tend to have a 
heavier environmental impact that plant-based food. 
We strongly support the inclusion of plant based meals and various options for plant based 
meals because of the lower environmental impact of a plant based diet, as well as the numerous 
health benefits for people of all ages. As we move forward in the 21st century, it is becoming 
clear that people chose to adopt more nutritional diets and prefer to have numerous  options. We 
expect that this trend will continue, therefore it is important that we provide people with healthy 
and nutritious  alternatives that have as low environmental impact as possible. Plant based diets 
fit this category in the best possible way. 
We strongly support the promotion of vegetarian menus. The limited availability of such menus in 
the past resulted in many environmental and health problems. This should no longer be the case. 
We ought to increase awareness about healthy diets and diets that are good for the 
planet.  Reducing meat consumption therefore should be one of the main goals. 

JRC-Directorate B5 assessment 
Comment accepted 

Comment accepted 
Comment accepted 

Comment rejected 
Depending  on  the  ambition  level  of  the  public  procurer,  if 
they are stricter they may use the option to go plant-based 
and if not the vegetarian one.  

Comment accepted 

Comment accepted 

WASTE: Food waste and food redistribution and Other waste: prevention and sorting 
Table 96. Feedback from the stakeholders  
Topic 
Waste 

Feedback from stakeholders 
I count 5 fractions and not 4 

JRC-Directorate B5 assessment 
Comment accepted.  

347 

 
 
 
 
 
 
 
 
 
 
 
Topic 
streams 

Feedback from stakeholders 
I assume that organic waste is also a part of the residual waste? It would be nice to have the organic 
waste section so there's an extra section. But probably that's only possible if the collector offers the 
possibility. 

We welcome the introduction of the recommendation to "Select the appropriate packaging (format, 
protection, preservation, serving portions, etc.)" in the section 324 (other waste: prevention, sorting and 
disposal). However, we would like to have a similar recommendation also listed here in the food waste 
prevention as follows: "Select the appropriate packaging (format, protection, preservation, serving 
portions, etc.) to minimize the generation of food waste" as it is proven that packaging is part of the 
solution to prevent food waste (see the study on cheese waste conducted in French school canteens) 
Add the following recommendation in the list: "Select the appropriate packaging (format, protection, 
preservation, serving portions, etc.) able to minimize the generation of food waste" 
We welcome the overall update of this section with in particular the introduction of the 
recommendation to select the appropriate packaging able to efficiently fulfil the required functions 
(incl. food safety and waste prevention). However, we generally regret the absence of 
caveat/provisions about environmental relevance for the recommendations on recyclable packaging, 
recycled content, reuse, return packaging, etc. This could be done for example by adding "when 
environmentally relevant" in the recommendation sentences.   
We would recommend taking also into consideration the prevention of food waste when 
recommending the use of refillable containers for condiments. 
We would recommend to add "food waste prevention" in the list of aspects to be considered as 
follows: Put condiments and food servings in refillable containers, where food waste prevention, food 
hygiene, consumer safety and public health considerations allow their use" 
With reference to the comment 'distribution to the ‘need’. Users of redistributed food are not always 
the ’needy’.   
Some of the waste prevention proposed criteria (2.1.8) still refers ultimately to the actual packaging 
in which the food products is procured or catered and thus counter the removal of relate criteria in the 
food products section. Such criteria include: Order non-perishable products in bulk, select recyclable 
packaging and avoid unnecessary or excessive packaging. 
Reasoning applied to remove former food criteria 2.1.8 on packaging must again apply to the section 
on waste prevention for food services as well and therefore such criteria listed above should be 
removed. Packaging cannot be separated from the product together with it is put in the market. 
Setting requirements on packaging would affect the environmental performance of the product the 
packaging is served in, such as increasing food waste. Environmental assessment tools for packaging 

JRC-Directorate B5 assessment 
The  organic  fraction  is  not the  residual  waste.  Although,  as 
commented,  there  are  some  locations  where  the  collector 
does not offer the possibility of having to waste streams and 
therefore the residual waste includes organic waste  
Comment accepted 

Comment accepted 

Comment accepted 

Comment accepted 

Acknowledged 
The recommendation of using the less amount of packaging 
as possible has been complemented by "when possible and 
environmentally  relevant".  This  condition  ensures  that  the 
recommendation is only considered when it should be from 
the environmental point of view.  

348 

 
 
 
 
 
 
 
JRC-Directorate B5 assessment 

Comment rejected 
It  is  considered  that  the  criterion  on  waste  prevention 
includes more aspects than just the waste generated due to 
the packaging of the food products.  
Additionally  the  requirement  of  the  waste  prevention 
criterion referring to packaging have been revised to include 
possible  and  not  to  exclude  packaging  that  can  be 
environmental, social or economically beneficial.  

Topic 

Feedback from stakeholders 
(e.g. Life Cycle Assessment) should also be taken into account for choosing the best material and 
design options for packaging. Packaging design should be assessed through the suitable 
environmental assessment tools (e.g. Life Cycle Assessment) on a case by case basis, depending on 
the actual market situation. This needs to be done as an integral part of the packaged product and its 
value chain. Industry will continue improving both the performance and functionality of packaging 
whilst working towards its optimization so as to minimize the adverse impacts on the environment. 
For example the selection of recyclable packaging does not always provide the best environmental 
performance for a product. In addition the availability of packaging materials for packaging 
production largely depend on external market conditions, e.g.: availability and use of recycled content 
for plastics can be dependent on price relative to virgin as well as material of sufficient quality. 
Finally on there is not established definition by European Law on excessive packaging, thus the 
interpretation of such term can result highly subjective. 
Unfortunately we cannot find FoodDrinkEurope’s March 2017 comments to the second draft Technical 
Report specific to waste prevention criteria in Annex 4.3 - Table 76 of comments on the proposed 
criteria for EU GPP criteria for catering services (version2). We would like that the JRC would provide 
feedback on their assessment of the comments provided. 

"Waste prevention criteria: 
Some of the waste prevention proposed criteria (2.1.8) refer ultimately to the actual packaging in which the 
food  products  is  procured  or  catered  and  thus  counter  the  removal  of  relate  criteria  in  the  food  products 
section.  Such  criteria  include:  purchase  non-perishable  products  in  bulk,  use  returnable/reusable  packaging, 
selection of products with low packaging, avoiding single portion and avoid excessive packaging and refillable 
containers. 
Reasoning applied to remove food criteria 2.1.8 on packaging must therefore apply to the section on waste 
prevention  for  food  services  as  well  and  such  criteria  should  be  removed.  Again  packaging  cannot  be 
separated from the products which it is put in the market and therefore setting requirements on packaging 
would affect the environmental performance of the product the packaging is serve in, such as increasing food 
waste. Additionally if a variety of portion sizes is proposed as criteria 3.2.4 to avoid food waste in Catering 
sizes,  this  contrast  with  the  avoidance  of  offering  one  portion  sizes.  In  addition  there  is  not  established 
definition  by  European  Law  on  excessive  packaging,  thus  the  interpretation  of  such  term  can  result  highly 
subjective 
See  in  Annex  1  of  this  paper  FoodDrinkEurope  2016  arguments  provided  on  Criteria  for  food  products 
packaging  to  the  1st  Draft  of  the  Technical  Report  on  the  Revision  of  the  EU  green  Public  Procurement 

349 

 
 
Topic 

Feedback from stakeholders 

Criteria for Food and Catering Services." 

We welcome the change in the criterion name to “food redistribution” instead of “avoidable food waste 
prevention and distribution”. It avoids giving the impression that food donated is food waste. 
We reiterate our recommendation to add to the condition of applicability that labour and other costs 
generated by food redistribution should be taken into account by the client. 
We propose to reformulate the note introducing the criterion as follows: “Note: applicable in those 
locations where hygiene rules allow, where the surplus food to be donated are of interest for the 
redistribution organizations, and where the client has the capacity to support food redistribution.  
It is important to clarify that it is surplus food that would be donated, so that this requirement would 
not create the expectation that caterers must overproduce food in order to redistribute it to fulfil this 
requirement. 
We  welcome  the  deletion  of  the  previous  mention  to  “avoid  single-portion  as  far  as  possible”  and 
recognition of the possible benefits of using single units packaging. We agree with the new wording 
proposed  instead,  i.e.  'Select  the  appropriate  packaging  (format,  protection,  preservation,  serving 
portions, etc 
We would again recommend deleting “unnecessary or excessive” packaging as per the Commission’s 
response to our comment on page 292 as there are non-objective criteria that are not defined. 
The  GPP  criteria  need to  be  objective  in  order  for  our  sector  to  be  able  to  implement  it and  verify 
compliance  with  suppliers.  We  recommend  deleting  this  point  because  there  is  no  EU  harmonised 
definition of what this means, so there would be an uneven playing field and legal uncertainty if we 
had to implement this.     
Regarding putting condiments in refillable containers, depending on the context in which it take place, 
it might not always make sense or diminish the amount of waste. It depends on the available labour, 
washing  facilities,  waste  streams  and  conditions  of  service  to  the  client.  For  instance,  in  hospitals 
where meals need to be brought to each patient in their rooms, it would be very labour intensive to 
use refillable containers for condiments. 
Since ordering non-perishable products in bulk is already mentioned in the procurement of food and 
consumables  list,  and  identifying  reuse  possibilities  is  on  the  catering  list,  we  believe  the  point  on 
refillable containers is redundant and would reiterate our recommendation to remove it.    
Sorting bio-waste where possible is very important. When a client has arranged for separate waste 
collection,  the  caterer  can  separate  the  waste  in  the  kitchen  and  can  also  help  separate  post-
consumer  waste. 
client. 
We recommend therefore for the text to specify that obligation for the tenderers to sort bio-waste 

post-consumer 

food  waste 

However, 

belongs 

the 

to 

JRC-Directorate B5 assessment 

Comment accepted 

Comment accepted 
Costs received have been introduced in the LCC section 
Comment accepted 
The intention of the food donation criteria is not to prepare a 
surplus  of  food  to  be  redistributed,  but  to  decrease  the 
amount  of  food  that  becomes  food  waste.  For  this  reason, 
this criterion was changed in category: form a TS to an AC 

Comment accepted 

Comment rejected 
Not all the examples should be taken over by the tenderers. 
In order to make clear that only those examples that help to 
reduce the amount of waste generated should be considered, 
a rewording of the sentence has been introduced 

Comment accepted 
The condition has been added  

350 

 
 
 
 
 
 
 
 
Topic 

to 

only 

such 

apply 

exists, 

should 

collection 

Feedback from stakeholders 
separately  where 
kitchen  waste. 
This  is  in  line  with  the  welcomed  addition  made  by  the  JRC  that  the  waste  sorting  and  disposal 
criterion  only  applies  where  sorted  waste  is  separately  collected.  More  generally  we  welcome  the 
clarification  brought  to  what  should  be  required  in  each  cases  or  preferred  options  for  the  waste 
treatment (either on-site, or by an authorised collector or a combination of both). 
We  welcome  the  introduction  of  an  exception  for  “cutlery  for  big  events”’.  We  believe  though  there 
might  have  been  an  error  in  the  word  used  and  that  the  JRC  meant  “tableware”  as  “cutlery”  only 
covers forks, knives and spoons. Tableware covers crockery, cutlery, and glassware used for serving 
and eating meals. We would therefore recommend using the word “tableware” rather than “cutlery”. 
Regarding “Other waste measurements”, we want to emphasize again that it is the client who  owns 
the  data  from  the  waste  management  company.  The  waste  management  company  is  under  no 
obligation to the caterer to provide this data. The caterer would need the client to provide the data 
from the waste management company in order to give the data back to the client to comply with this 
criterion. For instance, in cases where catering waste is collected together with client waste, the waste 
management company that manages the waste of the client would have the data on the weight of 
paper,  plastic, glass  and  residual  waste  and  not  the  caterer.  Therefore,  we  recommend  removing  it 
from the criterion. 

JRC-Directorate B5 assessment 

Comment accepted 

Comment rejected 
The criterion requires the tenderer to monitor his own waste. 
The easiest way to do it would be to measure the waste or 
waste streams generated prior to the final disposal for being 
collected by the waste management company,  

We suggest using instead of 'allow routines' 'use of' doggy bags, which would better reflect that the 
tenderer  should  have  written  procedure  describing  the  best  practices  in  this  context.  In  addition, 
should food redistribution and measurement of food waste not be included under this part. 

Comment accepted 

We  are  wondering  whether  freezing  is  not  more  an  issue  how  we  deal  with  surplus  once  produced 
rather a strategy again overproduction. 

We have the impression it is a definition proposed by FUSION – if this is the case, would it be possible 
to include reference. 
This  part  may  be  updated  eventually  in  accordance  of  the  developments  on  the  Waste  Framework 
Directive. This legislative proposal is under trilogue negations and the final version might provide a 
definition on 'food waste' 
It  is  also  worth  mentioning  that  in  line  with  general  waste  prevention  policy  amount  of  waste 
disposed via bin or sewer should be reduced, regardless whether they are classified as food waste or 
not. 

Comment rejected 
Freezing  of  prepared,  semi-prepared  food  or  even  raw 
materials can be an strategy to prevent food waste at early 
stages 
Comment accepted 

351 

 
 
 
 
 
 
 
Topic 

Feedback from stakeholders 
Nomenclature  issue.  Food  waste  cannot  be  redistributed.  Alternatively,  the  formulations  "uneaten 
food" or "unsold food" or equivalent can be used instead of "food waste". Alternatively, this part could 
refer to surplus food, too.   
Would it not be useful to add some  references eg FUSIONS manual and/or the Global Food Loss & 
Waste Protocol? 

JRC-Directorate B5 assessment 
Comment accepted 

Comment accepted 

Energy and water consumed in the kitchen 
Table 97. Feedback from the stakeholders on "energy and water consumed in the kitchen" 
Topic 

Feedback from stakeholders 
For storage counter refrigerators we strongly suggest to set the minimum energy class to A (EEI < 25). 
Award points should be given for tendering the best available technology. The overview of best 
available technology products on www.topten.eu/storage-counter-refrigerators clearly shows that at 
least 7 class A products and one class A+ product are available on the market for this category. They 
differ in size and style and are thus applicable for different requirements.   
A product of EEI <  35 (B) uses three time as much energy as the best available product on the market. 
For storage refrigerators 1-door we strongly suggest to set the minimum energy class for core award 
points to A (EEI < 25). 
Award points should be given for tendering the best available technology. The overview of currently 
best available technology products on http://www.topten.eu/storage-refrigerators-1-door clearly shows 
that at least 16 class A products (26 models if similar models are included) are available on the market 
for this category. At least 10 manufacturers offer models with this efficient technology, reflecting a 
wide selection potential for tenderers.  Award points should be given out for tendering the most energy 
efficient models on the market 
For storage 2-door refrigerators we strongly suggest to set the minimum energy class to C (EEI < 50). 
Award points should be given for tendering the best available technology. The overview of best 
available technology products on http://www.topten.eu/storage-refrigerators-2-doors  clearly shows that 
several class C products and even two class A products (by different manufacturers) are available on 
the market for this category. They differ in size and style, are offered by at least 4 different 
manufacturers and are thus applicable for different requirements.   
As no class B products and only two class A appliances  on the market are known to us, we suggest to 
set the minimum energy class for storage 2-door refrigerators to class  C (EEI < 50). This still reflects 
the best available technology on the market compared to all other models available on the market. 

JRC-Directorate B5 assessment 
Comment accepted 

Comment accepted 

Comment accepted 

352 

 
 
 
 
 
 
 
Topic 

Feedback from stakeholders 
Class D (EEI < 75) appliances use three times as much energy as the best model (class A) already 
available on the market. 
For GPP core award criteria, we suggest a GWP of 5. 
Award points should be given out to products that go beyond the minimum requirements of the market. 
A GWP of 150 will be the minimum requirement on the market and all products would be applicable for 
award points within the scope of the GPP core criteria in 2022.   
We recommend as comprehensive criteria for award points that "Points must be awarded proportionally 
to tenders in which more than F%1) of the equipment using natural refrigerants with a GWP of 3 or 
below."   
Empa (Materials Science and Technology)  continuously measures halogenated greenhouse gases (CFCs, 
HCFCs, HFCs, PFCs, SF6) at the Alpine station of Jungfraujoch (3580 m asl.) in Switzerland. With the 
help of a statistical trajectory model they measure the European sources of the anthropogenic HFC-
134a, HFC-125 and HFC-152a (source: https://www.empa.ch/web/s503/halclim-ingos-agage). Rising 
concentrations of the new refrigerants have been measured in the atmosphere.   While it is of yet 
unknown what the long-term effects of these artificial components in the air and atmosphere might be, 
the use of natural refrigerant does not carry this unknown risk.   Adjusting the criteria to call for natural 
refrigerants and a GWP of 3 or below still includes appliances with the commonly used natural 
refrigerants R600a and R290 (cf. list of professional refrigeration appliances on www.topten.eu).   

JRC-Directorate B5 assessment 

Comment accepted 

Comment accepted 

353 

 
 
 
 
 
 
Disposable items and consumable goods 
Table 98. Feedback from the stakeholders  
Topic 

Feedback from stakeholders 
Either transform the AC2 core criterion for purchasing 0-50% of eco-labelled chemical products, 
paper products into a technical specification or increase the share towards 50-100%. 
The lack of award criteria for reusable packaging and return systems; 

Nonetheless, the EEB regrets the following shortcomings: 
The list of generic exemptions for the use of disposable items (TS 5.1); 
The award criteria for purchasing a low share (0-50%) of eco-labelled chemical products, paper 
products that are widely available on the European market (AC2 core criterion). 
Either transform the AC2 core criterion for purchasing 0-50% of eco-labelled chemical products, 
paper products into a technical specification or increase the share towards 50-100%. 

JRC-Directorate B5 assessment 
Comment accepted 

Comment rejected 
There is not an award criterion because this requirement is 
proposed  under  the  other  waste:  prevention,  sorting  and 
disposal: " Packaging return: return packaging for reuse when 
possible and environmentally relevant 

Comment accepted 

CPC: Food redistribution  
Table 99. Feedback from the stakeholders  
Topic 

Feedback from stakeholders 
Redistribution includes donation. For this reason, we suggest to use only 'redistribution' as overall 
heading to avoid confusion. Donation is correctly listed below as one of the means of redistribution 
The future EU guideline on food donation explains explicitly what is food redistribution, food donation 
and  surplus  food.  It  is  important  ensure  consistency  in  respect  of  the  wording  to  avoid  different 
interpretation by stakeholders. 
Does this refer to "food donation"? 
Please, note that the legislation requires that retailers put in place mutual agreements with charity 
organisations  in  order  to  facilitate  donation  of  surplus  food.  Conditions  for  hygiene  etc.  are  not 
specified in the legislation per se.  There are several guidance documents available in France outlining 
roles/responsibilities of various actors. We would propose to consider to add a link to our web page 
where national guidance is published: https://ec.europa.eu/food/safety/food_waste/library_en  
Would it be possible to specify which procedures are meant? 

JRC-Directorate B5 assessment 
Comment accepted 

Comment accepted 

Comment accepted 

Comment rejected 

354 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Topic 

Feedback from stakeholders 

We  welcome  the  introduction  of  this  part  on  food  redistribution.  As  general  remark,  to  avoid 
confusion, we would like to mention that food donation is a part of food redistribution and for this 
reason;  we  suggest  keeping  the  reference to  'food  redistribution'  in  general.  Specification  regarding 
food donation can be done at the relevant places.  

We also would like to propose to include reference to the EU guidelines on food donation, which is in 
the last stage of the adoption by the Commission and should help for both, private and public entities 
to  comply  with  the  EU  regulatory  framework.  This  guideline  will  also  provide  clarity  what  to 
understand under food redistribution and surplus food.  

CPC: Provision of low impact water  

Table 100. Feedback from the stakeholders  
Feedback from stakeholders 
Topic 
Is it possible to write 'free drinking water'? 
Water dispensers - where used - should be selected carefully with regards to the annual energy 
consumption and refrigerant used. A study by the projects Topten and ProCold shows saving potential 
of 50% to 80% between efficient and inefficient models on the market. As such, all water coolers 
acquired within the scope of the GPP should follow strict procurement criteria. 
If use of regular tab water is sufficient, water dispensers should not be used. If water dispensers for 
hot or cold water should be necessary, strict procurement criteria should be followed to realize the 
saving potential of 50% to 80% that was found in a study by the projects Topten and ProCold in 
August of 2016. Procurement Guidelines are offered in the same document 
on  http://www.topten.eu/uploads/Water_Coolers_Procurement_Guide_August_2016.pdf   
A study by the projects Topten and ProCold (August 2016) shows saving potential of 50% to 80% 
between efficient and inefficient models on the market. As such, all water coolers acquired within the 
scope of the GPP should follow strict procurement criteria. 
Bottled tap water should be removed. See suggestion in the suggested actions 
Replace with the following:"(direct access to the water tap in a jug or other dispenser)" 
The figures used are not correct. See alternative text in suggested actions and the link below for 
justification: http://www.efbw.org/index.php?id=90 
To replace with the following text:"  With an EU average consumption of 110 litres per person per year, 
bottled water is the first most popular liquid refreshment before carbonated drinks (Canadean, 2016)" 

JRC-Directorate B5 assessment 
No further information on this point was supplied 
Comment accepted 

JRC-Directorate B5 assessment 
Comment accepted 
Comment partially accepted 
Water  dispensers  are  covered  by  the  criterion  "energy 
consumption  and  GWP  of  refrigerants",  where  the  AC  gives 
points  to  dispensers  of  hot/cold  drinks  according  to  their 
annual 
consumption 
benchmarks provided by Topten are based on an US energy 
star method which would be difficult to harmonise with the 
methods  developed  by  the  EU  industry.  However,  water 
coolers  have  been  included  in  the  scope  of  the  TS  Smart 
controls. 

consumption. 

Energy 

energy 

Comment accepted 

Comment accepted 

355 

 
 
 
 
 
 
 
Topic 

Feedback from stakeholders 
We welcome that the discrimination requirement against in-bought bottle water has also been 
removed. 

JRC-Directorate B5 assessment 
Comment accepted 

CPC and TS: Environmental measures and practices 

Table 101. Feedback from the stakeholders on CPC environmental measures and practices 
Topic 

Feedback from stakeholders 
Clarify what is required in terms of the “operational procedure describing the measures to be deployed 
to minimise the environmental indicators listed in point 1) and in accordance with the criteria listed in 
2)” of TS 8. This kind of language is completely incomprehensible to us and the meaning or purpose of 
it might also be unclear to procurers. 
The EEB clearly understands and supports the list in point 1). But the criteria mentioned in 2) overlap 
to a very large extent, excluding basically the last two bullet points under 1) which refer to two crucial 
indicators on satisfaction of both the clients and the contracting authority with the provided services. 
We do not see any reason why those indicators should be dropped or “minimised in the sense of “ 
reduced or kept at the minimum feasible level”??? 
We would like to ask for clarification whether the aim is to include food waste prevention as a 
criteria? The wording might give the impression that it is not always the case. 

JRC-Directorate B5 assessment 
Comment accepted 

Comment acknowledged 
Yes,  the  aim  of  the  environmental  measures  is  to  monitor 
first the indicators and second to reduce those figures.  
That  is  why  food  waste  is  to  be  recorded  as  kitchen  food 
waste, serving food waste and plate food waste 

356 

 
 
 
 
 
 
 
 
Table of stakeholder's comments on the propose criteria for EU GPP criteria for VENDING MACHINES 

Vending machines 

This section presents the comments received through BATIS  
Table 102. Feedback from the stakeholders on the TR3.0 on vending machines 
Topic 

Feedback from stakeholders 
It would be useful to point out that a reusable cup can also be a porcelain cup or glass or... placed 
next to the vending machine for the customer to use. Otherwise procurers could think that the vending 
machine will pop out reusable cups like it does with the disposable ones. 
We suggest that the definition for vending machines for the requirement with reusable cups is clearer. 
This definition would easily appear that cold drinks dispensed as cans (i.e. through a cold beverage 
machine) would be in scope for requiring an option of reusable cups, which is not the intention and 
would not be at all appropriate. 
"Drink machines dispensing hot and/or cold drinks that enable the use of reusable cups instead of 
disposable cups" would be better as "Drink machines dispensing non-prepacked hot and/or cold drinks 
that enable the use of reusable cups instead of disposable cups" to ensure that the correct machines 
are targeted. 
For clarity, this should be 'European' rather than 'EU' as the EVA Market report also covers some non-
EU countries. 
In the paragraph above, the draft report explains that its intention is not to present any health 
proposal, but rather to ensure the machines are more environmentally friendly. However, the report 
then goes on to outline some limited examples from a literature review -This seems to be a 
contradictory position. If a literature review is to be  presented, then surely it should be more complete 
and detailed, particularly with European-specific data, and: 
1) The outlined data comes from USA and Australia. The information presented does not inform what 
types of machines formed part of the studies - snack machine, cold beverage,  hot drinks machines 
etc. This would need clarified first of all to see if it is relevant or appropriate here. Please also be 
aware that USA vending machines and European vending machines are not comparable in  their 
design, function or market demands, and are impacted by  differing policy positions and 
incentives.  Furthermore, snacking habits from American consumers are not directly comparable 
to  European habits. It seems that this paragraph should be either removed, or replaced with Europe-
specific vending machine studies 
2) Regarding the conclusion (last sentence), where is the data for this, or does the report make this 
conclusion based on the limited literature review?   

JRC-Directorate B5 assessment 
Comment accepted 

Comment accepted 

Comment accepted 
Although EU GPP has not been changed 
Comment accepted 

357 

 
 
 
 
 
 
Topic 

Feedback from stakeholders 
1) "Vending machines are characterised by constant  exposure and access to high-fat, high-sugar and 
high-sodium food." This is a very prejudicial statement and ignores the market characteristics and the 
work undertaken by the industry to offer more of a range of healthier products in snack machines. It 
is also worth remembering that for example, over 60% of vending machines sell coffee/hot drinks, 
making this statement irrelevant. Snack vending machines are equivalent to a small shop, selling 
many different products, and as such the same logic of this statement could equally apply to 
convenience stores and canteens - but for these cases the statement would be deemed 
unacceptable.    
2) "Children and adolescents consume nearly 25% of their daily caloric intake from snacks in USA. 
Among adults results from a 2012 systematic review demonstrate an association between snacking and 
excess weight gain. Excess weight gain over many years may contribute to overweight and obesity." 
There are many different causes for obesity in society. This statement is not appropriate to place 
under a section about vending machines. Furthermore, what has the snacking habits of children in the 
USA got to do with EU snacking habits for an  EU GPP guidance document? and how is this linked to 
solely vending machines?   
3) Finally where is the evidence for any of these statements in this paragraph?  It seems as if a lot of 
these sentences are based on negative industry stereotypes, with the odd  causal link  to USA data. 
How are vending machines responsible for the increased snacking culture of teenagers? 
"Revenue from vending sales did not change substantially regardless of measures applied."  
We do not agree with this statement, and its wording could provide the perceived freedom to 
authorities to implement (any range of) harmful measures, which in fact would impact the revenue of 
the industry as well as the tenderer.       
We suggest for consistency and accuracy, that EVA market statistics are used rather than INNOCAT. 
I.e; there are around 3.8 million machines in Europe, and not 3.7 million. 
For accuracy, "Refrigerated closed fronted machines consume less energy than refrigerated glass 
fronted, but their functions are also different." should be "Refrigerated closed fronted machines 
generally consume less energy than refrigerated glass fronted, but their functions are also different." 
We are unsure as to whether this criterion would require freestanding hot drinks vending machines to 
provide this choice for reusable cups? Freestanding hot drinks machines are often placed in public 
places where people would not have their own reusable cup. Take-away would be the only option and 
as such a requirement for this choice does not seem appropriate. 
"The use of disposable cups in drink machines dispensing hot and/or cold drinks entails the generation of 
plastic and paper waste, which can be minimise replacing them by reusable cups." should be "The use of 

JRC-Directorate B5 assessment 
Comment accepted 

Acknowledged 

Comment accepted 

Comment accepted 

Comment rejected 
The  machine  should  enable  the  use  of  reusable  caps.  This 
criterion  however  does  not  exclude  the  use  of  disposable 
caps  
Comment accepted 

358 

 
 
 
 
 
 
 
 
Topic 

Feedback from stakeholders 
disposable cups in drink machines dispensing non-prepacked hot and/or cold drinks entails the 
generation of plastic and paper waste, which can be minimised replacing them by reusable cups."  
This would ensure that this criterion does not mean that cold drinks machines dispensing canned or 
bottled beverages are covered. 
The verification for the technical specification should require that "The tenderer must provide the 
technical sheet of the vending machine to be used to provide the service together with copies of the test 
reports of the vending machines according to the EN 50597, for vending machines from 1 to 4, and 
according to the Energy Measurement Protocol Part B developed by the European Vending Association, 
for drink machines dispensing hot and / or cold drinks where the compliance with this requirement is 
stated." 
Vending machines have a life span of 15 to 30 years. As such, it is important to know the technical 
data of machines installed within the scope of the GPP. As technical sheets often rely on 
manufacturers' in-house norms and thus cannot be truly compared, requiring copies of the test 
reports according to the official EN 50597 will provide product information necessary in the long run.   

JRC-Directorate B5 assessment 

Comment accepted 

359 

 
 
 
 
 
 
References of the annexes 

Aeschelmann F., Carus, M. (2015), Bio-based Building Blocks and Polymers in the World – Capacities, Production and Applications: Status Quo and Trends toward 2020, Hürth, 
Germany. 

Andrinin and Bauen's, Biogene Abfaelle im Kanton Bern, Mengenerhebung. Amt für Gewaesserschutz und Abfallwirtschaft (GSA), 2005 Reiterstrass 11, 3011 Bern CH 

Baldwin, C., Wilberforce, N. and Kapur, A. (2011), Restaurant and food service life cycle assessment and development of sustainability standard, The International Journal of Life 
Cycle Assessment, 16, p. 40-49. 
Beretta S, Stoessel F, Baier U, Hellweg S, (2013), Quantifying food losses and the potential for the reduction in Switzerland. Waste management 33, 2013, 764-773 

Baier and Reinhard (2007), Bewirtschaftung organischer Abfaelle aus Grosskuechen in Kanton Aargu, Hochschule Wadenswill, Unweltbiotechnologie, Einseldlerstr 29, 8820 
Waedenswill (CH) 

Betz, Buchli, Göbel, Müller, food waste in the Swiss food service industry: magnitude and potential for reduction, Waste management 35 (2015) 218-226 

BioPlastic Magazine (2015): Mater-Bi disposable gloves made on new B. Glove machine presented at Plast 2015: 
http://bioplasticsmagazine.com/en/news/meldungen/20150514- 
Mater-Bi-gloves-at-Plast-2015.php  (last  accessed  16-04-11);  Fachagentur  Nachwachsende  Rohstoffe  e.  V.  (FNR)  2013:  Handlungsleitfaden  Nachwachsende  Rohstoffe  in 
Kommunen: https://mediathek.fnr.de/media/downloadable/files/samples/t/h/themenheft-web_neu.pdf (last accessed 16-04-21) 

BMPE, (2013) Best environmental management practice in the tourism sector, 2012 available at: https://ec.europa.eu/jrc/en/publication/eur-scientific-and-technical-research-
reports/best-environmental-management-practice-tourism-sector 

Bonsucro, (2012), Frequently Asked Questions, bonsucro.com/assets/Bonsucro_FAQS_V1_2.pdf. (accessed on the 27th January, 2017) 

Calderón LA,  Iglesias L,  Laca A,  Herrero M,  Díaz M, 2010, The utility of Life Cycle Assessment in the ready meal food industry, 
http://dx.doi.org/10.1016/j.resconrec.2010.03.015 

Cerutti et al. (2016), Carbon footprint in green public procurement: Policy evaluation from a case study in the food sector. Food Policy 58 (2016) 82–93 

Chiffi, & Galli. (2014), A guide to effective strategies for introducing and supporting Cyclelogistics in urban areas. available at: http://cyclelogistics.eu/docs/119/CLA-D2_1-
Guide_to_effective_strategies_for_cyclelogistics.pdf (accessed on 26th Jan 2017) 
CSPO (2017), From Sustainable Palmoil Toolkit 

Deloitte (2014), Comparative Study on the EU Member States legislation and practices on food donation, Executive summary, June 2014 available at 
http://www.eesc.europa.eu/resources/docs/executive-summary_comparative-study-on-eu-member-states-legislation-and-practices-on-food-donation.pdf 

EU GPP 2008 available at http://ec.europa.eu/environment/gpp/gpp_policy_en.htm 

360 

 
Engstrom and Carlsson-Kanyama, (2004), Food losses in food service institutions, Examples from Sweden, Food policy 29, 203-213 

European Commission (2010), Preparatory study on food waste across EU 27, DG Environment. 

European Commission (2013), Report on the progress of implementation of the pest management directive available at 
http://ec.europa.eu/food/plant/pesticides/sustainable_use_pesticides/ipm/index_en.htm. 

European Commission, (2014), Animal Welfare, available at: http://ec.europa.eu/agriculture/organic/consumer-trust/animal-welfare/index_en.htm, (accessed 29th Jul 2015).  

EVA 2017, European initiatives to encourage a wider choice of products in vending machines. Available at: http://www.vending-europe.eu/en/subject-areas/hygiene--nutrition/eu-
platform.html 

FAO (2014), The forest product annual market review 2013-2014, FAO Forestry and Timber Section. Geneva. 

FiBL and IFOAM (2014), The world of organic agriculture: Statistics and emerging trends 2014, available at: https://www.fibl.org/fileadmin/documents/shop/1636-organic-world-
2014.pdf, (accessed 14th May 2015). 

Fusi, A., Guidetti, R. and Azapagic, A. (2015), Evaluation of environmental impacts in the catering sector: the case of pasta, Journal of Cleaner Production, article in press, 
available at: http://dx.doi.org/10.1016/j.jclepro.2015.07.074, (accessed 17th Sep 2015).  

Gobeil et al. (2015), Energy Star Commercial Kitchen Equipment Market Analysis: Phase 1. Report by Dunsky for Energy Star Canada and Natural Resources Canada, available at: 
http://www.dunsky.com/wp-content/uploads/2015/09/OEE-Kitchen-Appliances-Report-_Phase-I.pdf (accessed 5th Feb 2016). 

Good Samaritan Law, (2016), Legge n. 166/2016 

Gustavsson J, Cederberg C, Sonesson U van Otterdijk, Meybeck A, (2011), Global food losses and food waste. Extent, causes and prevention. Swedish Institute for food and 
biotechnology (SIK) 

ICCT (2015). Accelerating progress from Euro 4/IV to Euro 6/VI vehicle emissions standards, available at: 
http://www.theicct.org/sites/default/files/publications/ICCT_EuroVI_briefing_20150304.pdf 

IEEA (2012), Industrial Energy Efficiency Accelerator Sector Guide. Contract Catering Sector. Report for DEFRA and the Carbon Trust, available at: 
https://www.carbontrust.com/media/163491/contract-catering-sector-guide-industrial-energy-efficiency-accelerator.pdf 

INSEPARABLE (2017), European Commission campaign, available at http://ec.europa.eu/fisheries/inseparable/en/find#quicktabs-resources_tabs=0  

ITC (2015). The State of Sustainable Markets: Statistics and Emerging Trends 2015. (International Trade Centre) http://www.intracen.org/publication/The-State-of-Sustainable-
Markets/#sthash.qGlKoAPB.dpuf 

(2016a) 

JRC 
http://susproc.jrc.ec.europa.eu/Food_Catering/docs/EU%20GPP%20Food%20Catering%20services_Preliminary%20report.pdf (accessed 1st December 2016) 

Procurement 

European 

Catering 

Revision 

criteria 

Public 

Green 

Food 

and 

Services 

for 

of 

available 

at 

361 

 
JRC  (2016b)  Revision  of  European  Green  Public  Procurement  criteria  for  Food  and  Catering  Services  TR1.0  available  at  http://susproc.jrc.ec.europa.eu/Food_Catering/docs/  
(accessed 21st December 2016) 

Legge  155-2003 
http://www.parlamento.it/parlam/leggi/03155l.htm 

"Disciplina  della  distribuzione  dei  prodotti  alimentari  a 

fini  di  solidarietà  sociale" 

(detta 

“del  Buon  Samaritano”),  available  at: 

Legge 166 – 2016  Disposizioni concernenti la donazione e la distribuzione di prodotti alimentari e farmaceutici a fini di solidarieta' sociale e per la limitazione degli sprechi, 

available at: http://www.gazzettaufficiale.it/eli/id/2016/08/30/16G00179/sg 

Marthinsen, J. Sundt, P. Kaysen, O., Kirkevaag, K. Prevention of total waste in restaurant, hotels, canteens and catering, doi:10.6027/TN2012-537 

Mass,E. 
http://www.life.ca/naturallife/0908/ecofiber_or_fraud.htm (last accessed, 2015-10-15). 

Rayon,  Modal, 

Fraud?  Are 

Eco-Fiber 

(2015), 

and 

or 

Tencel 

Environmental 

Friends 

or 

Foes?  Natural 

Life  Magazine: 

ÖkoKauf (2012), Ergebnisse und Kriterien beim "ÖkoKauf Wien", available at: https://www.wien.gv.at/umweltschutz/oekokauf/ergebnisse.html (accessed on 26th Jan 
2017) 

ProCold  (2016)  Selection Criteria Storage Refrigerators and Freezers, available at: http://www.pro-cold.eu/english/criteria/professional-storage-refrigerators.html#h20 (accessed 
on 5th Feb 2016) 

Quantis, (2015): Life Cycle Assessment of coffee consumption: comparison of single-serve coffee and bulk coffee brewing http://www.pac.ca/assets/pac0680-full-lca.pdf 

SAI, (2017), Sustainable Agriculture Initiative Platform, http://www.saiplatform.org/ and http://www.fsatool.com/ (accessed on 26th January 2017). 

SSI (2014). The State of Sustainability Initiatives Review Standards and the Green Economy, available at: http://www.iisd.org/library/state-sustainability-initiatives-review-2014-
standards-and-green-economy, (accessed on 26th Jan 2017) 

Shields, S., & Orme-Evans, G. (2015). The Impacts of Climate Change Mitigation Strategies on Animal Welfare. Animals, 5(2), 361-394.  

Shen, 
http://www.lenzing.com/fileadmin/template/pdf/konzern/lenzinger_berichte/ausgabe_88_2010/LB_88_2010_paper_1.pdf (last accessed 16-04-25) 

assessment 

man-made 

Lenzinger 

(2010), 

fibres, 

Patel, 

cycle 

M.K. 

Life 

of 

L., 

Berichte, 

1 

, 

59, 

Skinner et al. (2014). http://www.sciencedirect.com/science/article/pii/S0048969713010255 

Stolze et al., (2016): Organic in European Expanding Beyond a Niche. In: Meredith and Willer (eds.) Organic in Europe: Prospects and Developments. IFOAM EU, Brussels  

STA (2013) Report on fair timber procurement://www.sustainable-timber-action.org/fileadmin/files/STA_Toolkit/Buying_Sustainable_Timber_-_STA_Guide__Nov_2013.pdf 

UTZ (2016), Labeling and trademark policy, For claims and logo use. UTZ. 

Technical report (2010) 054 Preparatory study on food waste across EU-27 doi; 10.2779/85947 

362 

 
TopTen (2016a) Recommendations for professional refrigerated storage cabinets and blast cabinets, available at: 
http://www.topten.eu/uploads/Storage_Refrigerators_Freezers_Procurement_Guide_August_2016.pdf (accessed on 11th October 2016) 

TopTen (2016b) Recommendations Refrigerated Display Cabinets, available at: http://www.topten.eu/?page=commercial-display-cabinets&fromid= (accessed on 5th Feb 2016) 

Universidad de Barcelona (2013), Una guia para reducir el despilfarro alimentario en el sector de la hosteleria, la restauración y el catering, 2013) 

WWF (2015). Cotton Farming – Cotton: a water wasting crop. http://wwf.panda.org/about_our_earth/about_freshwater/freshwater_problems/thirsty_crops/cotton/ last assessed, 
December 2015. 

Wong YCJ (2011) Study of food wastage behaviour and optimization methods in Canteen, unpublished Universitat Stuttgart German. 

363 

 
  
 
List of abbreviations and definitions 

Assembly-serve 

Bio-waste 

Catering service 

Centralised 
production unit 

Contract 
catering firm 

Conventional 
kitchen 
Conventional 
production 

EU Ecolabel 

Green 
procurement 

public 

Integrated 
production 
Life-cycle 
assessment 
Organic 
production 
Private sector 
Public sector 

Ready-prepared 

SMEs 

Type I Ecolabel 

and 

Vending 
hot-drink 
machines 
Water 
dispensers 

The food is delivered pre-processed and cooked. Then the food is reheated (if necessary) and 
assembled on site. 
Biodegradable garden and park waste, food and kitchen waste from households, restaurants, 
caterers and retail premises and comparable waste from food processing plants.  
The preparation, storage and, where appropriate, delivery of food and drinks for consumption 
by  the  consumer/client/patient  at  the  place  of  preparation,  at  a  satellite  unit  or  at  the 
premises/venue of the client. 
Central kitchens or central food factories that send out completed dishes or pre-processed 
ingredients/meals to satellites. Can include both ready-prepared services and assembly-serve 
services. 
A business engaged in (amongst other activities or services) providing a meals service (for 
example by running a staff restaurant or providing school meals) or providing drinks, snacks 
or vending. 
A kitchen (at the place of consumption) where all, or a significant part of, food is prepared 
from raw ingredients. 

Traditional farming methods. 

‘EU Ecolabel’ refers to a voluntary eco-labelling award scheme developed and managed by 
The  European  Commission  intended  to  promote  products  and  services  with  a  reduced 
environmental impact during their entire life cycle and to provide consumers with accurate, 
non-deceptive,  science-based  information  on  the  environmental  impact  of  products  or 
services.  There  are  three  types  of  voluntary  labels  identified  by  ISO  with  the  EU  Ecolabel 
falling under the Type I category. 
‘Green  Public  Procurement  (GPP)'  is  a  voluntary  instrument  defined  in  the  Commission 
Communication  "COM  (2008)  400  -  Public  procurement  for  a  better  environment”  as  "…a 
process whereby public authorities seek to procure goods, services and works with a reduced 
environmental  impact  throughout  their  life  cycle  when  compared  to  goods,  services  and 
works with the same primary function that would otherwise be procured.” 
Farming methods that try to optimise resource use (e.g. pesticides and synthetic fertilisers 
use) and aim to have a low overall impact on the environment. 
Calculating  environmental  impact  for  each  stage  in  a  food  supply  chain,  focusing  on 
determined environmental impact categories. 
Farming  methods  that  aims  to  have  a  low  impact  on  the  environment  (e.g.  no  or  low 
pesticide use and no synthetic fertiliser use). (Working with ecosystems). 
Private companies (restaurants, pubs etc.) 
The cost sector (education, health and social care etc.) 
Preparation on site or at a central facility of large batches of items for consumption that are 
then adequately stored frozen or chilled until required. 
Small and medium-sized enterprises 
‘Type I Ecolabel’ is defined by the ISO 14024 standard as a voluntary multi-criteria-based, 
third party program that awards a license that authorises the use of environmental labels on 
products indicating overall environmental preference of a product within a particular product 
category based on life cycle considerations. 

Machines that are available at all times with snacks, fruit, drinks and/or sandwiches etc. that 
are ready to eat/drink or that can be reheated. 

A  device  specifically  for  dispensing  drinking  water,  which  might  have  the  possibility  of 
heating and/or cooling the drinking water. 

364 

 
 
List of figures 

Figure 1. Relation between the technical specification and the award criteria for food 
procurement. Core level above, comprehensive level below. ..................................... 17 

Figure 2. The ENVIFOOD Protocol represents an intermediate step between ISO standards, the European 
Commission’s Product Environmental Footprint and product-specific rules. .................................... 149 

Figure 3. Member States targets for CSPO 2017. ...................................................................... 199 

365 

 
 
List of tables 

Table 1: Main environmental hotspots and causes from food procurement (the name of the criteria are the ones 
proposed in the present report) ...................................................................................... 10 

Table 2: Main environmental hotspots and causes from catering services ........................................ 11 

Table 3. Criteria set for Food procurement Award Criteria (AC) and Technical Specification (TS). Thresholds in TS 
are included as minimum values (i.e. at least x%) and thresholds in AC are included as the starting point to get 
points awarded (i.e. points awarded from x%). ...................................................................... 16 

Table 4. Criteria set for Catering services Selection Criteria (SC), Technical Specification (TS), Award Criteria 
(AC) and Contract Performance Clauses (C). Thresholds in TS are included as minimum values (i.e. at least x%) 
and thresholds in AC are included as the starting point to get points awarded (i.e. points awarded from x%). . 44 

Table 5. Criteria set for Vending machines Award Criteria (AC) and Technical Specification (TS). Thresholds in TS 
are included as minimum values (i.e. at least x%) and thresholds in AC are included as the starting point to get 
points awarded (i.e. points awarded from x%). ...................................................................... 82 

Table 6. Breakdown of the costs per serving of a catering service (example) .............................................. 95 

Table 7. Breakdown of the costs per serving of a catering service (example) .............................................. 96 

Table 8. Cost structure for catering services in 7 Member stares ......................................................... 96 

Table 9. Cost structure for catering services in 7 Member stares ......................................................... 97 

Table 10. Wholesale increase in price of organic products in comparison to conventional products of different products in 
different member states. ............................................................................................... 97 

Table 11. Cost differences per 1kg of white wild caught fish as standard product or certified product. .................... 97 

Table 12. Costs differences between standard eggs and free range eggs ................................................ 98 

Table 13. Costs differences between standard chicken or pork and certified one ......................................... 98 

Table 14. Fairtrade minimum prices or premium for coffee (Fairtrade, 2011) ............................................ 99 

Table 15. Surplus in the prices of conventional coffee due to the fairly trade (FT) schemes certifications (USD/lb to euro/kg 
factor = 2.11). All the units in euro/kg of coffee .......................................................................... 99 

Table 16. Costs differences between standard and fairly trade products ................................................. 99 

Table 17. Food expenditures on food products for 3 scenarios studied. ................................................ 100 

Table 18. Estimated food waste (in mass and cost) at EU-28 level. .................................................... 102 

Table 19. Possible savings if a food waste prevention policy is applied ................................................ 102 

Table 20. Total estimated cost of food waste generation .............................................................. 103 

Table 21: The cost of avoidable waste in the UK foodservice sector (Source: WRAP 2013) .............................. 103 

Table 22. Summary of the cost-effective business cases for an average site in the catering sector .................... 104 

Table 23. LCC for combi-steamers .................................................................................... 105 

Table 24: Concluding summary table ................................................................................. 107 

Table 25 Example of GPP criteria that could be included in a comprehensive call for tender for FOOD 
procurement ........................................................................................................ 114 

Table 26. Example of the expected purchases indicating those products that are expected to comply with some 
of the above criteria ................................................................................................ 117 

Table 27. Calculations to demonstrate compliance with the technical specification criteria .............................. 121 

Table 28. Calculation related to the awarded points of the awarded criteria ............................................ 121 

366 

 
Table 29. Feedback from the stakeholders on the TR1.0: ......................................................... 123 

Table 30. Feedback from the stakeholders on the TR1.0: Organic food products (TS1 and AC1) ............... 133 

Table 31. Variance in Energy use per tonne of organic produce against conventional produce (www.wwf. org.uk)
....................................................................................................................... 146 

Table 32. Examples of caterings and the mass/cost ratios of the food product types .......................... 148 

Table 33. Feedback from the stakeholders on the TR1.0: Marine and aquaculture food products (TS and AC)  150 

Table 34. Resources to help choosing sustainable fish in EU-28, (INSEPARABLE 2017) ........................ 154 

Table 35. Feedback from the stakeholders on the TR1.0: Integrated Production (TS and AC) .................. 158 

Table 36. Existence of integrated production certified schemes across EU and their state of the art ......... 162 

Table 37. Feedback from the stakeholders on the TR1.0: Animal welfare (AC) .................................. 167 

Table 38. Steps taken for labelling related to animal welfare products, EU Commission. ...................... 173 

Table 39. Feedback from the stakeholders on the TR1.0: Fair traded products (AC) ............................ 175 

Table 40. Average coverage of social indices for each voluntary sustainability scheme. SSI Review 2014. 
International Institute for Sustainable Development (IISD) and the International Institute for Environment and 
Development (IIED) ................................................................................................. 181 

Table 41. Average coverage of environmental indices for each voluntary sustainability scheme. SSI Review 
2014. International Institute for Sustainable Development (IISD) and the International Institute for Environment 
and Development (IIED) ............................................................................................ 182 

Table 42. Feedback from the stakeholders on the TR1.0: Packaging ............................................. 185 

Table 43. Feedback from the stakeholders on the TR1.0: Sustainable palm oil (AC7) ................................... 195 

Table 44. State of the art on the sustainable certified palm oil and vegetable oils. ............................ 200 

Table 45. Comparison of the principal requirements of three certification schemes. ..................................... 204 

Table 46. Feedback from the stakeholders on the TR1.0: Staff training (SC1) ........................................... 206 

Table 47. Feedback from the stakeholders on the TR1.0: Food procurement ............. 211 

Table 48. Feedback from the stakeholders on the TR1.0: Menu planning TS5 ............ 212 

Table 49. Information regarding the date label on the food products. ...................... 223 

Table 50. list of measures to prevent food waste generation in catering services Source: Less food waste more profit 2012
....................................................................................................................... 225 

Table 51. Costs due to the food waste generation ..................................................................... 228 

Table 52. Breakdown of the costs per serving of a catering service (example) .......................................... 229 

Table 53. Possible savings if a food waste prevention policy is applied ................................................. 229 

Table 54. Total estimated cost of food waste generation ............................................................... 230 

Table 55. Feedback from the stakeholders on the TR1.0: Waste sorting and disposal (TS6)) ............................. 233 

Table 56 Estimated costs associated with the implementation of waste collection or alternatives end-of-life ways. ..... 237 

Table 57. Feedback from the stakeholders on the TR1.0: Consumable goods (AC8) ..................................... 240 

Table 58. Feedback from the stakeholders on the TR1.0: Equipment (AC9) .............. 245 

Table 59: Phase out deadlines for refrigerants with a high GWP according to the F-Gas Regulation (Regulation (EU) No 
517/2014) ............................................................................................................ 248 

Table 60. Models for professional refrigeration in Europe for energy classes above G (TopTen, 2016) ................... 249 

367 

 
Table 61: TopTen recommendation for professional refrigeration (TopTen, 2016a) ...................................... 250 

Table 62: Models for household refrigeration in Europe for energy classes above G (TopTen, 2016) ..................... 250 

Table 63. Feedback from the stakeholders on the TR1.0: Vehicle fleet and planning of food delivery (TS7) .............. 252 

Table 64. Feedback from the stakeholders on the TR1.0: Environmental management system (SC2) ..................... 255 

Table 65. Feedback from the stakeholders on the TR2.0: introduction .......................................... 257 

Table 66. Feedback from the stakeholders on the TR1.0: Organic food products (TS1 and AC1) ............... 257 

Table 67. Feedback from the stakeholders on the TR2.0: Integrated production ................................ 263 

Table 68. Feedback from the stakeholders on the TR2.0: Maritime and aquaculture products ................. 265 

Table 69. Feedback from the stakeholders on the TR2.0: Animal welfare ....................................... 275 

Table 70. Feedback from the stakeholders on the TR 2.0 Environmentally responsible palm oil ............... 278 

Table 71. Feedback from the stakeholders on the TR2.0: Fair and ethical trade products ...................... 280 

Table 72. Feedback from the stakeholders ............................................................................ 285 

Table 73. Feedback from the stakeholders on the removal of packaging criterion ...................................... 288 

Table 74. Feedback from the stakeholders on the TR1.0: Competences of the tender .................................. 294 

Table 75. Feedback from the stakeholders on the Promotion of vegetarian dishes ..................................... 295 

Table 76. Feedback from the stakeholders ............................................................................ 297 

Table 77. Feedback from the stakeholders on "energy and water consumed in the kitchen" ............................ 310 

Table 78. Feedback from the stakeholders on food transportation ..................................................... 311 

Table 79. Feedback from the stakeholders ............................................................................ 312 

Table 80. Feedback from the stakeholders ............................................................................ 315 

Table 81. Feedback from the stakeholders on CPC: purchase of new kitchen equipment ................................ 317 

Table 82. Feedback from the stakeholders on CPC environmental measures and practices ............................. 318 

Table 83. Feedback from the stakeholders ............................................................................ 319 

Table 84. Feedback from the stakeholders on the TR2.0 on vending machines ......................................... 320 

368 

 
 
 
Europe Direct is a service to help you find answers  
to your questions about the European Union. 

Freephone number (*): 
00 800 6 7 8 9 10 11 

(*) The information given is free, as are most calls (though some operators, phone boxes or hotels may charge you). 

More information on the European Union is available on the internet (http://europa.eu). 

HOW TO OBTAIN EU PUBLICATIONS 

Free publications: 
•  one copy: 

via EU Bookshop (http://bookshop.europa.eu); 

•  more than one copy or posters/maps: 

from the European Union’s representations (http://ec.europa.eu/represent_en.htm);  
from the delegations in non-EU countries (http://eeas.europa.eu/delegations/index_en.htm);  
by contacting the Europe Direct service (http://europa.eu/europedirect/index_en.htm) or 
calling 00 800 6 7 8 9 10 11 (freephone number from anywhere in the EU) (*). 

(*) The information given is free, as are most calls (though some operators, phone boxes or hotels may charge you). 

Priced publications: 
• 

via EU Bookshop (http://bookshop.europa.eu). 

 
 
 
 
 
 
 
 
K
J
-

N
A
-
2
9
8
8
4
-
E
N
N

-

z 

doi:10.2760/748165 
ISBN 978-92-76-12119-0