Implementation of life cycle assessment and environmental footprint. Annex IV: 4, Country fiche : France.
Date: 2021-11-08
Institutions: Directorate-General for Environment
Subjects: European Environment Agency, France, directive (EU), eco-label, ecological footprint, green public procurement, product life, regulation (EU)

Implementation of Life Cycle 
Assessment 
based instruments in 
Public Procurement

ANNEX IV: 4. Country Fiche - France

Environment

The European Commission is not liable for any consequence stemming from the reuse of this publication. 

Luxembourg: Publications Office of the European Union, 2021

© European Union, 2021

The  reuse  policy  of  European  Commission  documents  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 
is  authorised  under  a  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. 

this  document 

For any use or reproduction of elements that are not owned by the European Union, permission may need to be sought 
directly from the respective rightholders.  

PDF 

ISBN 978-92-76-42640-0

doi:10.2779/94871

KH-07-21-036-EN-N 

GETTING IN TOUCH WITH THE EU 

In person 
All over the European Union there are hundreds of Europe Direct information centres. 
You can find the address of the centre nearest you at: https://europa.eu/european-
union/contact_en 

On the phone or by email 
Europe Direct is a service that answers your questions about the European Union. You 
can contact this service: 
- by Freephone: 00 800 6 7 8 9 10 11 (certain operators may charge for these calls),
- at the following standard number: +32 22999696, or
- by email via: https://europa.eu/european-union/contact_en

FINDING INFORMATION ABOUT THE EU 

Online 
Information about the European Union in all the official languages of the EU is available 
on the Europa website at: https://europa.eu/european-union/index_en 

EU publications 
You can download or order free and priced EU publications from: 
https://publications.europa.eu/en/publications. Multiple copies of free publications may 
be obtained by contacting Europe Direct or your local information centre (see 
https://europa.eu/european-union/contact_en ). 

EU law and related documents 
For access to legal information from the EU, including all EU law since 1952 in all the 
official language versions, go to EUR-Lex at: http://eur-lex.europa.eu  

Open data from the EU 
The EU Open Data Portal (http://data.europa.eu/euodp/en) provides access to datasets 
from the EU. Data can be downloaded and reused for free, for both commercial and non-
commercial purposes. 

Implementation of Life Cycle Assessment based  
instruments in Public Procurement – Country Fiche: France 

Contact: DG Environment 
European Commission 
B-1049 Brussel 

Factsheet completed in XXXX 2021. 

© European Union, 2021 

 
 
Country Fiche: France 

The main  objective  of this project is to identify and assess Life  Cycle  Assessment (LCA) 
based  instruments  and  criteria  that  nine  selected  EEA  countries,  their  regions  and 
contracting authorities have implemented in public procurement procedures. 

LCA-based  criteria  in  public  procurement  procedures  focus  on  the  environmental  impact  of  the 
tendered products, services or works. It can cover the whole life cycle or only certain of its elements, 
such as the environmental impact of transport. As with all environmental criteria, there are different 
options for the implementation of LCA-based criteria in the public procurement process. They may 
be used in the design and planning stage, the tender (via inclusion as award criteria or other types 
of  criteria)  or  in  the  post-tendering  stage  (e.g.  monitoring).  LCA-based  criteria  might  come  in 
different shapes: 

  Criteria  accompanied  by  an  LCA-based  instrument  to  quantify  the  respective 

environmental impact(s). 

  Criteria that require Life Cycle Costs (LCC) including the calculation of costs resulting 
from environmental externalities – which are based on the environmental impact(s). 

  Criteria  that  specify  a  certain  Ecolabel  (Type  I),  whose  underlying  criteria  include 

quantified LCA-based information. 

  Criteria that require an Environmental Product Declaration (EPD) as proof that the 
tendered  products,  services  or  works  meet  certain  limit  values  for  environmental 
impact(s). 

  Criteria that require a certain level of a Building Certification Scheme, which is based 

on EPD-results according to EN 15804 or another LCA-based instrument.

The  study  tries  to  capture  the  currently  used  LCA-based  criteria  as  comprehensively  as  possible. 
Nevertheless,  it  does  not  aim  to  present  an  exhaustive  overview  of  existing  instruments  
per country.

1 

 
 
 
Specific framework addressing 
environmental criteria and LCA-based 
information  

In  response  to  the  obligation  to  transpose  the  European  directives  in  2014,  the  French  law  on  
public procurement policy was radically amended in July 2015, with the publication of an ordinance 
on 23 July (Ordonnance n° 2015-899 du 23 juillet 2015 relative aux marchés publics) replacing the 
various codes and references regulating public procurement in France until that point in time. The 
ordinance introduced novelties and aimed for simplification by significantly reducing the amount of 
various  documents  and  provisions  in  public  procurement  legislation.  Moreover,  it  ensured  the 
inclusion  of  sustainable  (including  environmental)  considerations  at  all  stages  of  the  public 
procurement procedure.  This ordinance  was abrogated  in  September  2019  and  replaced by a still 
applicable legal act (Ordonnance n° 2018-1074 du 26 novembre 2018 portant partie législative du 
code de la commande publique). This procurement law offers several options for using environmental 
criteria in public tenders.  

The Ministry of the Ecological Transition is responsible for the program’s environmental areas of focus 
and for the National Action Plan for Sustainable  Public Procurement (PNAAPD). The second 
PNAAPD 2015-2020 describes the inclusion of ecolabels and LCC (incl. environmental externalities) 
and  focuses  on  strengthening  the  uptake  of  sustainable  public  procurement  across  France.  The 
upcoming  third  PNAAPD  will  cover  the  period  2021-2026  and  is  currently  (April  2021)  under 
consultation. According to the French General Commission for Sustainable Development (CGDD) the 
new  PNAAPD  will  not  refer  to  specific  paragraphs  in  respective  regulations,  but  will  speak  of 
environmental  considerations  instead.  The  scope  will  therefore  be  broader  as  it  will  include,  for 
example, also guidance for inclusion of environmental aspects also to award criteria. The link to LCA-
based  information  will  probably  get  strengthened  including  actions  related  to  the  development  of 
instruments and tools within the French network of public procurers.  

The  new  PNAAPD  will  contextually  address  the  requirements  of  the  National  Assembly’s  legal 
amendment on fighting against climate change and strengthening resilience in the face of its effects 
adopted in February 2021. Under the title “Greening the economy”, Article 15 of this law requires 
public procurers to take into account considerations related to environmental aspects of the works, 
supplies  or  services  purchased.  It  is  now  required  that  all  public  contracts  contain  at  least  one 
environmental  criterion  and  at  least  one  environmental  clause  related  to  the  execution  of  the 
contract. 

Another  strategic  development  of  the  federal  administration  is  the  focus  on 
environmental  sound  public  services,  accelerating  the  environmental  transition  of 
public  services  with  a  guidance  document,  where  20  mandatory  measures  are 
described. An example is the required development of a strategy to reduce the digital 
carbon  footprint  of  public  administrations,  including  the  purchase  of  reconditioned 
equipment.  Another  example  is  that  French  public  authorities  have  to  procure 
sustainable products in their collective catering services, when contracts are renewed 
(at least 50 % of which at least 20 % come from organic farming) since July 2020 and 
at the time of the renewal of contracts. They also offer a vegetarian menu at least once 
a week. 

The RAPIDD platform (Network of public administrations integrating sustainable development) aims 
to  bring  together  resources  and  disseminate  information  relating  to  both  mechanisms:  eco-
responsible public services and sustainable public purchasing. 

2 

 
 
“In a nutshell”: Description of LCA-based 
instruments identified as relevant for public 
procurement procedures

LCA-studies in pre-tendering phase: 

The State Procurement Directorate - Direction des Achats de l’État (DAE) uses the LCA 
approach  for  all  kind  of  products  from  the  4  product  groups  for  which  they  directly 
write contracts and lead procedures, namely IT-products, office supplies, buildings and 
housing,  vehicles.  This  applies  also  to  every  procurement  by  ministries  and  state 
agencies because they are all acting under the responsible procurement state policy. 
The impacts attached to  a type  of product  or  service is reflected with respect to all 
phases  of  the  life  cycle:  from  the  raw  material  acquisition  to  anticipation  of  the 
product’s end of life (waste management and waste prevention). 

LCA-based tool with focus on carbon footprint and energy performance: 

The survey revealed only one example of direct use of LCA-based instruments in France. In 2006, 
Ville  de  Malaunay  embarked  on  a  comprehensive  and  progressive  approach  to  energy  transition. 
From  the start,  the municipal  team aimed  for  driving  the transition throughout its territory. As of 
2012, the approach extended to all stakeholders in the territory and is deployed in a long-term vision 
for  the  city,  combining  cooperation,  renovation,  innovation  and  experimentation.  In  2014  the 
contracting  authority  of  Ville  de  Malaunay  started  to  use  the  LCA  approach  with  focus  on  carbon 
footprinting in the planning and design phase for the restructuring of a sports center, compared two 
options - renovating or demolition and new building. Since this experience, the city’s government 
has pushed for further development of this approach to be implemented in tendering.  

An external consultancy was hired to set up an excel-based spreadsheet model (mostly 
based  on  data  from  the  French  INIES  database)  for  the  direct  and  comparative 
quantification of GHG effects and energy performance according to construction and 
restructuring projects  tendered by Malaunay’s responsible procurement department. 
The  data  entry  for  tenderers  consists  of  two  data  sheets:  one  corresponds  to  the 
restructuring/construction work to be carried out and the other to the operation of the 
building  during  use.  Since  then,  this  approach  has  been  followed  through  for  each 
respective tendering process. 

 “In a nutshell”: Integration of these 
instruments within the procurement process

There are several ways to integrate LCA-based information in the procurement process. In France 
the following options were identified based on actual implementation examples: 

LCA-studies  in  the  pre-tendering  phase  -  Planning  and  designing  the  procurement 
procedure: 
Interviews  with  procurement  experts  from  DAE,  several  regional  GPP  networks1  and  local 

1 Auvergne Rhône-Alpes & RESECO 

3 

 
 
                                                
governments2 revealed that LCA-based information is mainly used as input to market analyses in the 
pre-tendering stage in order to design and plan new tendering procedures.  

LCA-based tool with focus on carbon footprint and energy efficiency – Implementation in 
technical specifications, award criteria, and as part of the contract performance 
evaluation: 

The tender documents for the restructuring project of the city’s swimming pool in 20173 included an 
explanation of the procedure and mechanism for a carbon footprint and energy efficiency tool, as 
well as a template in their annex.  The tenderer had to provide extensive and detailed inventory data 
according to the actual proposed planning of the project under contract. The Excel-based tool stays 
in full possession of Ville de Malaunay and the responsible procurers have to quantify and compare 
the  results  based  on  the  data  provided  in  the  templates  accompanying  the  offers.  The  external 
consultants who developed the tool, are also part of the team supporting the tenders’ preparation 
and evaluating the offers. 

The results provided by the tool are translated into a score for contract awarding. 15% of the results 
are  adjudicated  to  the  analysis  of  overall  costs  and  results  to  carbon  footprint  and  energy 
performance of the whole project during its construction/restructuring and use.  

Next to the approach’s implementation as award criterion, the tool is also directly used during the 
evaluation of the contract’s performance. The contractor has to plan a certain and accurate energy 
performance  for  the  building’s  use.  This  scenario  is  compared  to  the  actual  yearly  energy 
performance. If the actual energy performance does not meet the planned scenario within a certain 
threshold, penalties for non-approval may apply. 

Benefits and limits of LCA-based criteria – 
perspective of contracting authorities 

The  Ministry  of  Economy  and  Finance  has  primary  responsibility  for  the  conditions  governing  the 
public procurement system. Its Department of Legal Affairs (DAJ) as State Procurement Direction is 
in charge of analysing regulations regarding public contracts, as well as providing support, strategic 
guidelines and legal advice to state departments. According to interviews conducted in this study, 
two working groups of the DAJ already pointed out, the difficulties of specific evaluation methods (on 
quantitative and qualitative environmental aspects) in 2016. These methods were being used by both 
buyers and tenderers (in particular SMEs). The interviewee mentioned the specific need for robust 
and transparent methods for the evaluation of GHG emissions, as input for assessing costs attributed 
to  environmental  externalities.  According  to  Directive  2014/24/EU,  specific  rules  apply  regarding 
methods for assigning costs to environmental externalities, which aim to ensure that these methods 
are fair and transparent but no specification is given on the actual methodology for the assessment 
of environmental impacts and their respective costs. 

The second PNAAPD (2015-2020) introduced a joint task force aiming at establishing precise criteria 
for LCC (which now focuses on CO₂ emissions from wood building materials). However, no concrete 
development happened so far. 

2 Conseil départemental du Cher - Bourges  

3 Tender documents not publicly available anymore – information received directly from contracting authority from Ville de Malaunay 

4 

 
 
                                                
All respondents from contracting authorities highlighted the high effort underlying the application of 
LCA-based  instruments  in  pre-/tendering  or  post-tendering  phases  of  procurement  procedures. 
Experienced  experts  stressed  the  time  and  resource  consuming  processes  and  the  responsible 
procurers’ general lack of expertise in environmental evaluation.  

Benefits and limits of LCA-based criteria – 
perspective of tenderers 

No tenderers with experience with regard to identified LCA-based instruments were directly available 
for interviews or replied to a preparatory questionnaire sent by the consultants. 

A procurement expert from DAE described the LCA-based tool focusing on product carbon footprinting 
- Bilan produit, developed by the French Agency for ecological transition (ADEME) which seemed to 
be used once in a tender process as an award criterion. Due to the high complexity for the tenderers 
and to the challenges they encountered to deliver the required information, they took the decision 
to cancel the criterion out. 

It was mentioned in several interviews that suppliers and service providers are not (yet) familiar with 
addressing LCA-based information and data in their offers. They see it as a serious potential barrier 
for  certain  tenderers  and  fear  a  reduced  number  of  offers  when  applying  instruments  or  criteria 
containing high level of complexity and uncertainty. The contracting authority from Ville de Malaunay 
faced this issue and experienced around half of the replies to their tenders since the implementation 
of the data template and of strong criteria regarding carbon footprint and energy performance into 
their tenders. 

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Conclusion 

The  following  table  offers  information  about  the  identified  LCA-based  instruments  and  shows  the 
number of identified tenders that referenced to these instruments. 

Name of the 
LCA-based 
instrument 

LCA-studies in 
pre-tendering 
phase for 
planning and 
design of 
procurement 
procedures 

LCA-based 
tool: Carbon 
Footprint and 
Energy 
Efficiency 
Quantification 
Tool - Ville de 
Malaunay  

LCA-based 
tool: Product 
Carbon 
Footrint tool 
by ADEME – 
“bilan produit” 

Product group 

Link 

References 
in tender 
screening 

Stage of 
Development 

Various 
products/services 

n/a 

n/a 

n/a 

Construction and 
restructuring 
works  

1 

Link 

- 

Developed since 
2014 and in 
possession and 
current use for 
procurement 
procedures of the 
municipality 
Malaunay 

Experimental 
implementation in 
award criteria 
once, without 
success due to 
high complexity 

Politically  and  strategically,  there  is  support  for  the  European  and  French  green  agenda.  Among 
public institutions and contracting authorities, there is also a growing desire to include climate-related 
and  environmental  requirements  directly  in  their  tenders.  All  respondents  demanded  harmonised 
methods, practicable and easy to apply and clear guidance and trainings for procurers to implement 
these instruments and criteria in their daily procurement situations. Supporting the combination of 
LCA-based  information  and  LCC  approaches,  the  development  of  robust  methods  translating 
environmental impacts into environmental external costs and the access to tools free of charge is 
seen  as  an  opportunity  to  mobilise  reluctant  procurers  to  address  LCA-based  criteria  in  their 
tendering procedures. 

6