Green Procurement Is No Longer Optional: The EUR 2 Trillion Sustainability Shift

Public procurement in the European Union moves EUR 2 trillion every year — roughly 14% of the bloc's GDP. That spending power is responsible for an estimated 10-11% of EU greenhouse gas emissions, making government purchasing one of the single largest levers for climate action on the continent.

Yet today, less than 15% of above-threshold contracts are considered "green." More than 55% of EU tenders are still awarded solely on the lowest price, with no meaningful weight given to environmental criteria. The gap between ambition and practice is enormous — but it is closing fast.

A cascade of regulations that entered into force between 2023 and 2025 is turning Green Public Procurement (GPP) from a voluntary best practice into a legal baseline. Companies that are not preparing now risk being locked out of the largest buyer in Europe.

The Regulatory Wave: Five Laws Changing the Rules

The EU has moved from publishing guidance documents to passing binding legislation. Here are the key regulations already in force:

• Batteries Regulation (EU 2023/1542) — In force since August 2023. Mandates carbon footprint declarations, recycled content targets, and due diligence for battery supply chains. Any company selling batteries into public-sector supply chains must comply.

• Net-Zero Industry Regulation (EU 2024/1735) — In force since June 2024. Introduces sustainability and resilience criteria for public procurement of net-zero technologies. Contracting authorities must now evaluate bids on environmental sustainability, not just price.

• Ecodesign for Sustainable Products Regulation (EU 2024/1781) — In force since July 2024. Extends ecodesign requirements beyond energy-related products to virtually all physical goods. Digital Product Passports will become mandatory for key product categories.

• Construction Products Regulation (EU 2024/3110) — In force since January 2025. Requires Environmental Product Declarations (EPDs) and sets sustainability benchmarks for construction materials entering public works contracts.

• Packaging and Packaging Waste Regulation (EU 2025/40) — In force since February 2025. Sets mandatory recycled content thresholds and reuse targets, directly affecting how packaged goods are scored in procurement evaluations.

These are not future proposals. They are law. And they all feed into how public tenders are written, evaluated, and awarded.

GPP Criteria: Core vs. Comprehensive

The European Commission has developed GPP criteria for 21 product and service groups, spanning construction, transport, IT equipment, textiles, food and catering, cleaning products, and more. These criteria are split into two levels:

• Core criteria represent the minimum environmental performance that contracting authorities should require. They are designed to be achievable by most suppliers without significant cost increases.

• Comprehensive criteria push for best-in-class environmental performance. They are more demanding and target companies that have already invested in sustainability.

As regulations tighten, what was once "comprehensive" is steadily becoming the new "core." Companies that only aim for the minimum today may find themselves below the threshold tomorrow.

MEAT Is the Default — Lowest Price Is on Borrowed Time

The EU's procurement directives already establish MEAT (Most Economically Advantageous Tender) as the default award criterion. MEAT allows — and increasingly requires — contracting authorities to weigh quality, innovation, social value, and environmental performance alongside price.

Critically, life-cycle costing is now an accepted methodology under EU procurement law, and it can include environmental externalities such as carbon emissions, resource depletion, and pollution costs. A bid that looks cheap upfront may score poorly once its full environmental cost is factored in.

Despite this, more than half of EU tenders still default to lowest price. That is changing. The upcoming Public Procurement Act will mainstream sustainability criteria, making it harder for contracting authorities to ignore environmental factors and harder for suppliers to compete on price alone.

"Made in EU" and Strategic Procurement Targets

Beyond environmental sustainability, the EU is tying procurement to industrial policy. New requirements are emerging for "Made in EU" and low-carbon sourcing in strategic sectors, including clean energy, defence, and digital infrastructure.

Concrete procurement targets are already on the table:

• 50% of procurement budgets allocated to EU-produced equipment by 2030
• 60% of procurement budgets by 2035

For suppliers, this means that geographic origin and carbon intensity of manufacturing are becoming bid-evaluation factors. Companies with European production facilities and verified low-carbon processes will have a structural advantage.

The Monitoring Gap — and Why It Matters

Here is a telling statistic: only 3 EU Member States — Malta, Finland, and Germany — systematically monitor GPP implementation. The remaining 24 have limited or no tracking mechanisms in place.

This matters for two reasons. First, it means enforcement is uneven, creating uncertainty for cross-border bidders. Second, it signals that monitoring infrastructure is about to expand dramatically. When the EU sets targets (as it has with the 2030 and 2035 procurement goals), measurement follows. Companies should expect increased reporting requirements and audits in the near future.

What Companies Need to Do Now

The shift to green procurement demands concrete preparation. Here is what forward-looking companies are prioritizing:

1. Get your environmental data in order. Contracting authorities will increasingly require Environmental Product Declarations (EPDs), carbon footprint data, and life-cycle assessments (LCAs) as part of bid submissions. If you do not have these, start now — they take months to prepare.

2. Understand the VSME standards. EFRAG published the Voluntary SME Sustainability Reporting Standards (VSME) in December 2024. While aimed at smaller companies, these standards provide a clear framework for the sustainability disclosures that procurement evaluators will expect.

3. Map your supply chain emissions. With regulations like the Batteries Regulation and the Ecodesign Regulation demanding supply-chain-level data, you need visibility into Scope 3 emissions. Companies that cannot provide this data will lose points — or be disqualified outright.

4. Shift from price-only to value-based bidding. If your tender strategy is built around being the cheapest option, it is time to rethink. Invest in articulating the environmental and life-cycle value of your offer.

5. Monitor tender requirements proactively. Green criteria vary by Member State, by sector, and by contracting authority. Staying on top of evolving requirements is no longer optional — it is a competitive necessity.

The Bottom Line

Green procurement is not a future trend. It is the present regulatory reality across the European Union. With EUR 2 trillion in annual spending shifting toward sustainability criteria, the companies that adapt will access the largest public-sector market in the world. Those that do not will watch opportunities pass them by.

Winly surfaces sustainability requirements embedded in public tenders across Europe, helping companies identify green procurement opportunities, track evolving GPP criteria, and prepare stronger bids. Whether you are responding to TED notices or Portuguese BASE contracts, Winly ensures you see the environmental requirements before your competitors do.