Evaluation of the Public Procurement Directives

The Social Union for Housing, which represents the various federations of social housing organisations in France, i.e. 559 social landlords and more than 5 million housing units, wishes to participate in the recently launched consultation on the evaluation of the public procurement directives.

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Dear European Commission representatives, colleagues, and partners, On behalf of the procurement expert team of the Ministry of Economy of Ukraine and SoE "Prozorro," we would like to present proposals for improving the EU Directives and general procurement practices for your consideration. Please see the attached file for detailed information, and we are always open to further discussion.

Mutualité Française welcomes the European Commission’s initiative to revise the European public procurement directives. With the following proposals, we call on the Commission to take into account the potential for long-term growth, which a greater involvement of mutual societies and other ESS stakeholders in public procurement can represent for the prosperity and sustainability of the European internal market: 1.

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Confartigianato Imprese is Italy’s most representative organisation of crafts and micro and SMEs and one of the most important social partners in Italy. At national level, it has 104 local associations, 21 regional federations, 1.206 offices and 10.700 employees, offering different types of services to more than 1.5 million craftsmen and small entrepreneurs and almost 700.000 enterprises.

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NOTE: The full explanations for the following points can be found in the enclosed annex ‘ZDB_konsult_zu_den_EU-Richtlinien_04032025’. Preliminary remarks The European Court of Auditors, in its 2023 report on public procurement in the EU, found that the latest reform of the EU public procurement directives in 2014 did not increase competition and SME participation in public procurement.

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ICLEI Europe, as a network of local governments, welcomes the opportunity to reflect upon the 2014 EU Procurement Directives, and in particular their effectiveness in promoting strategic and sustainable public procurement (SPP). Our submission highlights both the impact achieved by SPP in the period 2016-24, and challenges associated with the current regulatory framework.

1. Increase thresholds (are not in line with indexation and increase the administrative burden of the contracting authority, as there is an earlier need for European procurement); 2. Promoting greater focus on sustainability and thus promoting local demand for certain contracts (placing sustainability over open European market); 3.

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The 'Public Contracts in Legal Globalisation' network is a prominent academic network in the field of public procurement law, comprising over 50 academics from numerous countries and universities. With over 15 years of experience, the network is well-positioned to provide a comprehensive evaluation of Directive 2014/24, including a thorough analysis of each article.

Federacciai welcomes the Commission initiative to assess and revise the EU rules on Public Procurement. This process has to be aligned with the objectives of the Clean Industrial Deal to boost the demand for green and sustainable products made in EU.

On behalf of our network of European public water operators, Aqua Publica Europea welcomes the opportunity presented by the revision of the Public Procurement Directives to address a specific discrepancy in the rules governing the water sector.

EIT Urban Mobility is Europes leading network for transport innovation in cities. Our experience in connecting startups, cities, and procurement processes aims to ensure that innovation-friendly policies support SMEs and public sector transformation for a healthier and more competitive Europe. Public procurement is key to driving innovation, ensuring fair competition, and deploying sustainable mobility solutions.

I am writing to you as a public procurement lawyer who has practised and practises these rules as a contracting authority and as an economic operator. The new EU directive could become more effective, in particular by requiring the centralisation by Member State of checks linked to the grounds for mandatory exclusion (1) by improving the ESPD ecosystem (2) by correcting the e-forms (3) by allowing the selection…

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With this feedback from Koopompel VZW, central purchasing body focused on its members active in the care and welfare sector in Flanders and the Brussels-Capital Region: 1. A thorough analysis and review of the current regulatory framework in order to eliminate any ambiguities, inconsistencies or ambiguities in the regulatory environment.

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In order to boost domestic production and the deployment of clean technologies at the heart of the green transition, T&E supports the development of lead market standards in the EU Single Market. The revision of the EU Public Procurement directives is a golden opportunity to introduce sustainability and resilience criteria in the future public procurement framework.

Autodesk, a global leader in design & make technology, welcomes the European Commissions call for input on the EU Public Procurement Directives. Autodesk is committed to ensuring digital solutions are leveraged for the EUs competitiveness and resilience and views public procurement as a powerful tool to drive the adoption of best practices and tools to achieve this.

Almega is Swedens leading employers organization for companies within the service sector. Almega's member surveys on public procurement (see attached file) show that the following are the most important reasons why service companies refrain from participating in public procurement: Too much focus on the lowest price Too time-consuming formalities Too many and irrelevant requirements to fulfil It is important that…

Public procurement represents approximately one-third of government spending and over 16% of the EUs gross domestic product (GDP). When implemented effectively, it serves as a powerful mechanism to foster lead markets, drive innovation, and accelerate the adoption of low-carbon, European-made products while promoting circularity in supply chains.

IndustriAll European Trade Union welcomes this consultation process on the revision of the legislative framework for public procurement. Our feedback is in the attached document. Please note that this document has been prepared to answer the public consultation and reflects the preliminary analysis of industriAll Europes secretariat and industriAll Europe affiliates.

Medicines for Europe welcomes the opportunity to contribute to this call for evidence, as the revision of the Public Procurement Directive 2014/24/EU (PPD) provides a framework for the public procurement of medicines (PPM). The off-patent pharmaceutical sector is operating in a highly regulated pricing framework, which does not allow for the adjustment of prices to increasing costs (e.g.

In view of the process of revising the Public Procurement Directives, CERMI encourages the European Commission to further strengthen the social dimension of public procurement across the EU, together with environmental aspects. In general terms, the revised public procurement directives should give more prominence to social aspects of contract award criteria.

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In order to make the EU procurement directive more flexible and efficient, mechanisms are needed to speed up procedures while preserving permeability and competition principles. It is essential to reduce the bureaucratic burden on all parties involved. One of the main contributors to the burden is the verification of exclusion grounds, which can extend over several months.

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The potential of public procurement is especially significant for the cement industry, where 40-45% of all contracts in Europe are publicly tendered. This makes it a powerful lever for increasing demand for low-carbon products. Public procurement policies play a key role in setting demand signals. A streamlined, horizontal mandate would boost the development of cleantech and drive industrial transformation at scale.

For Dansk Erhverv, uniform and well-functioning regulation is essential to ensure efficient and value-adding public procurement. The purpose of regulation is to strengthen competition, increase transparency and promote innovation, not to create unnecessary complexity and administrative burdens for businesses and contracting entities.

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Public procurement is an underexploited source of innovation, growth and strategic autonomy for Europe. Less than 10% of startup revenue in France comes from public buyers, despite its benefits compared to grants and investments. Public procurement means in fact customers: this sends a strong signal to other potential clients, but also to lenders and investors.

Article 6 of the Directive, which lays down the procedures for reviewing the thresholds and the list of central government authorities, provides that, as from 30 June 2013, the Commission shall examine every two years whether the thresholds set out in Article 4(a), (b) and (c) comply with the thresholds laid down in the World Trade Organisation Agreement on Government Procurement (GPA) and shall, if necessary…

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The Centre of Excellence in Procurement at Kyiv School of Economics (CEP KSE) has prepared proposals for amendments to the EU Public Procurement Directives, based on modern challenges. We strive for the updated EU legislation to meet modern market challenges, stimulate innovation and become an effective tool for the economic development of member states.

The Associations of French Societies of Motorways and Toll Works (ASFA) and its members wish to contribute, which will focus on an evaluation of Directive 2014/23/EU on the award of concession contracts. The ASFA and its members are convinced that this text meets its objectives and is fit for the current challenges.

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Our full feedback is attached as a pdf, with main recommendations being: An adjustment to tender processes to not only consider price, but also experience, sustainability, reliability and a track record of contributions to the health of the Open Source projects being bid on. 2.

Opinion on the public consultation on Directive 2014/24/EU The direct marketing of farmers plays a key role not only in terms of food supply, but also creates jobs in the region and ensures the survival of family farms as an alternative source of income. The direct supply of food from farmers also means short transport distances, the promotion of the regional value chain and the purchase of high-quality food.

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Promote throughout public procurement (including purchases and concessions) the means of rebalancing the lowest/best bidder in favour of the second. This, on the basis of the consideration of positive environmental externalities, MAIS AUSSI social. In other words, like the schemes for promoting socially responsible purchases (SPASER) in France, preference must be given to the overall cost of proposing applicants.

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The BNA (Branchevereniging Nederlandse Architectenbureaus) is the Royal Institute of Dutch Architects, the professional organisation of architecture firms in the Netherlands, which has been advocating for the role of architects in Dutch society for more than 175 years.

The General Secretariat for Catholic Education (SeGEC) represents and coordinates the schools of the Free Catholic Network in French-speaking and German-speaking Belgium. These establishments, managed by ASBL Organising Authorities, are subject to public procurement rules, despite their voluntary nature and their general interest mission.

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NVRD’s view on the evaluation of the European public procurement Directive 2014/24/EU Introduction De NVRD represents municipalities and public undertakings in the Netherlands responsible for waste collection, treatment and recycling. The European Public Procurement Directive 2014/24/EU has a major impact on the way public tasks are organised and carried out.

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In order to make procedures faster and more efficient, the time limits for participation in procurement procedures should be shorter and the threshold should be raised. For example, an authority plans purchases and, over a year, for similar services with a similar range of suppliers, their total estimated contract price exceeds that threshold, with the result that the highest procurement method is applied to each…

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The public procurement law – grant law interface proves to be a heavy burden for beneficiaries who are not contracting authorities themselves but receive funding from the ESF programmes, for example. As a general rule, the grant law transfers unmodified requirements to them that are tailored to contracting authorities. Unlike these, private beneficiaries are largely left alone with these requirements.

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SSEs assessment: Overall, Directive 2014/24/EU establishes a broadly appropriate legal framework for public procurement across the broad range of economic sectors and across the EU. There are, however, at least three caveats/limitations to this general statement above which applies when looking at the main purposes and objectives of public procurement markets and procedures.

The principle of subsidiarity needs to be pursued decisively by investing public resources for the acquisition of new skills and new models of work organisation. A strategic policy of awarding private contracts, with the aim of creating a system of more competitive companies with more skilled workers, thus better paid, as well as adequate services.

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In the Annex: Federal Government’s opinion on the revision of the EU public procurement directives: Directive 2014/23/EU on the award of concession contracts; Directive 2014/24/EU on public procurement; Directive 2014/25/EU on the procurement procedures of entities operating in the water, energy, transport and postal services sectors.

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Unsere Mitgliedsverbände und deren Mitgliedsunternehmen erleben Auftragsvergaben aus zwei unterschiedlichen Perspektiven. Zum einen organisieren Leistungsträger soziale Dienstleistungen zunehmend als öffentlichen Auftrag. In diesem Fall müssen sich die Mitgliedsunternehmen als Bieter an Ausschreibungen beteiligen. Daneben bewerben sich Sozialunternehmen um Fördermittel von Bund, Ländern und Kommunen.

As a global leader in structural heart diseases, Edwards Lifesciences strongly supports the objectives of the EU Public Procurement Directive to improve quality access to healthcare technologies. After more than 10 years of application, and many challenges in its rightful execution, the revision of the EU Directive on Public Procurement provides an important opportunity to ensure that breakthrough implantable…

Dear commission, Please find attached the feedback from Energie Samen (the Dutch federation of energy cooperatives). We call for attention to the status of Energy Communities (as introduced by the commission in the IEMD and RED II) in the procurement framework. Kind regards, on behalf of Energie Samen, ilonka marselis

The public procurement law – grant law interface proves to be a heavy burden for beneficiaries who are not contracting authorities themselves but receive funding from the ESF programmes, for example. As a general rule, the grant law transfers unmodified requirements to them that are tailored to contracting authorities. Unlike these, private beneficiaries are largely left alone with these requirements.

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Dear Sir/Madam, this letter contains two annexes: Annex 1 contains an opinion from the umbrella municipal associations of Bavaria, the Bavarian Association of Municipalities, the Bayerischer Landkreistag and the Bayerischer Bezirketag, which represent 2.056 towns and municipalities, 71 rural districts and 7 districts, on an evaluation and possible reform of EU public procurement law.

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On behalf of the Municipal Council of the Mayor and Aldermen of the Municipality of Amsterdam, on behalf of the Municipal Executive for the Coordination of Procurement, Ms H. van Buren, I am sending you the reply of the Municipality of Amsterdam. This contribution was also added to the digital survey on 5-03-2025. Yours faithfully, [name removed]

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The Fair Trade Advocacy Office (FTAO) recognises the progress enabled by the EUs 2014/24 Directive in promoting strategic public procurement for social and environmental objectives. However, its effectiveness remains limited, and further action is needed to ensure public authorities procure wisely, enhance Small and Medium Entreprises (SMEs) access, support fair supply chains and drive greater social and…

The planned reform of EU public procurement law must not further complicate the framework conditions for municipalities, towns and rural districts. The key demands of Baden-Württemberg local government associations therefore include: (1) a significant increase in the EU thresholds (2) the rejection of mandatory ESG criteria (environmental, social, governance) (3) exemptions for inter-municipal cooperation (4) fewer…

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The Global Ecolabelling Network (GEN) welcomes the opportunity to provide input on the EU Public Procurement Directives. GEN is a nonprofit organisation setting the global benchmark for ecolabel excellence, helping governments and businesses cut through greenwashing, make informed decisions, and drive the market for sustainable goods and services.

1. The Commissions proposals regarding review of the Public Procurement Framework are very welcome, as such revision is much needed in order to ensure realization of both competitiveness and sustainability goals within the European market. 2. However, the scope of the Public Procurement Framework review overlooks the role of the local governments, in particular cities, as active participants of the energy market. 3.

ESMIG, the European association of smart energy solution providers, welcomes the evaluation of the Public Procurement Directives in view of their revision in 2026. This is a key opportunity to take bold actions which will contribute to ensuring fair competition and a level playing field for EU and non-EU competitors in the internal market.

The Confederation of Norwegian Enterprise, Virke, represents approximately 25,000 businesses with more than 300,000 employees in the trade and service industries. We support the goal of the revision but believe that Directive 2014/24/EU functions rather well, and any changes should be well justified.

Ladies and gentlemen, as a result of a public procurement seminar, has learned from an EU study that more and more public tenders have only one supplier. This impression is also confirmed by the contracting authority and can only be linked to the fact that both the European Public Procurement Directives and the national procurement laws are too complex, formalistic and overbordend (AT: Sections 382 and XXI.

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As a company participating in public tenders in the health sector, in order to strengthen and harmonise the single market for public procurement in the EU, we consider it crucial that the new Directives address two fundamental aspects that are already provided for in the 4th generation Directives but which are not uniformly applied in the countries that are part of the EU.

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Public procurement could serve as an effective tool for the European Union to promote the integration of animal welfare into food production. The current Directive does not impose any obligation to take into account sustainability or quality in public procurement; the choice on the basis of price alone is still allowed.

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‘The public procurement law interface – grant law is a heavy burden for beneficiaries who are not contracting authorities themselves but receive funding from the ESF programmes, for example. As a general rule, the grant law transfers unmodified requirements to them that are tailored to contracting authorities. Unlike these, private beneficiaries are largely left alone with these requirements.

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Ref: Italian Fair Trade movements feedback to Public Procurement directives - Call of Evidence Date: 6 March 2025 Link:https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14427-Public-procurement-directives-evaluation_en The Italian network of Fair Trade organisations, represented by Fairtrade Italia and Equo Garantito, welcomes the European Parliament and Council Directive 2014/24/EU on public…

Ladies and Gentlemen, thank you very much for the opportunity to position us on this important issue. The Bundesinnungsverband des Buildingreiniger-Handwerk (BIV) is the leading association of undertakings in the building cleaning industry in Germany.

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The Architects Council of Europe (ACE) is the representative organisation for the architectural profession at European level. Through its 52 Member Organisations, ACE represents the interests of over half a million architects from 36 countries in Europe. Effectiveness - The Public Procurement Directive (PPD) allows for price competition at the expense of quality.

On the occasion of the European Commission’s consultation on the procurement directives, the Austrian Trade Union Confederation is making the following proposals to improve the rules on public procurement. Every year, public authorities in the EU spend around 14 % of GDP (over EUR 2.4 trillion) on procurement of works, services and goods. The Directives lay down minimum rules on public procurement.

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(1) Improving the functioning of the eNotices2 system, which has shortcomings affecting its usefulness and efficiency: (a) users encounter difficulties in navigating and understanding the logic of the system, which leads to errors, (b) inaccurate and unclear translation makes it difficult to understand and use the system, (c) a lack of consistency in the different sections of notices may result in incorrect data or…

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The public works sector has complex and dynamic interactions with public policies and social-economic communities in living environments (cities, rural areas, landscapes, mobility infrastructures). Land transformation projects are multidisciplinary technical-cultural processes with strong environmental, social, spatial and financial impacts.

Fair opportunities for regional food in public procurement The Landjugend Lower Austria, the largest youth organisation in rural areas, promotes the future of young farmers and sustainable regional development. In order to ensure a sustainable and sustainable food supply, there is a need to create a framework that takes regional products more into account in public procurement without excessive bureaucratic hurdles.

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Please note that the European Federation of Engineering Consultancy Associations (EFCA)s reply to this call for evidence only targets Directive 2014/24/EU on public procurement, since this is in scope of our members. EFCA underlines that the preference for low rates/prices in tenders and the preference for the lowest bidder must the curtailed as much as possible in the updated Directive.

Opinion agreed with the Public Procurement Adviser. With regard to Directive 2014/24/EU of the European Parliament and of the Council of 26 February 2014 on public procurement (so-called classical Directive). (1) Increasing the thresholds for the application of the Classical Directive.

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The exemption under Section 19(3) of Act No 134/2016 on public procurement also applied to above-threshold public contracts prior to the entry into force of the amendment. However, this legislation was amended following a warning from the European Commission that the Czech Republic had incorrectly transposed the relevant Directive, i.e.

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EurEau represents Europes drinking water (DW) and wastewater (WW) sector. It encompasses 38 national water services associations from 33 countries. With regard to the foreseen evaluation of the public procurement directives, EurEau requests to consider the following observations. - Improve efficient use of public funds.

Nevi would like to provide its response to the public consultation with the aim of evaluating the public procurement directives. Nevi believes that European legislation and regulations should encourage, facilitate and anchor professional procurement by: 1. Strengthen governance (i.e.

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Rural Youth opinion on Directive 2014/24/EU: Prospects for the future of Styrian agriculture through regional food marketing The Landjugend Styria, as the largest youth organisation in rural areas, is committed to the future of young farmers, sustainable regional development and the strengthening of all rural youth.

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The main suggestions include the following: — overall simplification of procurement procedures towards the unification of procurement procedures, – raising the thresholds for public contracts, both at European and national level, – shortening time limits in the procurement procedure, – possibility to negotiate with tenderers at all times, – reducing the administrative burden for contracting authorities.

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The Chamber of Agriculture of Carinthia, as the representative of the interests of domestic agricultural and forestry holdings, puts stable and sustainable food supplies at the heart of the revision of Directive 2014/24/EU on public procurement. Anchoring security of supply in public procurement law would be an important approach to strengthening agriculture.

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We are pleased to have the opportunity to comment as part of the consultation process on the revision of the Public Procurement Directive 2014/24/EU. As a key player in the process of administrative digitalisation in Germany, we are following with great interest the reform of European public procurement law.

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The present public consultation on the evaluation of the EU public procurement directives provides an opportunity to draw attention to the need to adapt public procurement law in order to promote the procurement of regional food and to strengthen local agriculture.

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As part of the public consultation initiated by the European Commission on the award of concession and public procurement contracts, we would like to contribute our analysis and recommendations on this topic, which is essential to the sector's competitiveness and economic efficiency. 1.

Positioning on the reform of EU public procurement law, municipalities invest in local social cohesion. This is about basics, such as kindergartens, schools and sports halls, and thus a municipal inf structure that directly benefits local people. Local authorities are also making this infrastructure ready for new needs and needs in the field of energy efficiency and digital equipment.

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The procurement rules aim to ensure competition, transparency and equal treatment. However, these objectives can also be achieved by less procedural rules than currently laid down in the Public Procurement Directive. The rules are perceived as unnecessarily restrictive and inflexible and it can be difficult to see who benefits from them.

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New sector for intellectual (including engineering) services: Due to the specific nature of intellectual services, the complexity of interactions, and the interdependencies among participants, a special chapter for intellectual services is required in the Public Procurement Directive.

SEFA Policy Recommendations for Enhancing Sustainable Public Procurement 1.Streamline Procurement Processes Simplifying tender documentation and shortening approval procedures can reduce administrative burdens and make it easier for contracting authorities to prioritize sustainability. Excessive documentation requirements create unnecessary costs for applicants, particularly SMEs.

As a contracting entity making 97% of its purchases in France from 3,700 suppliers and service providers50% of which are micro, small and medium-size enterprises. Enedis plays a key role in local economic development. The company promotes responsible purchasing and incorporates environmental and social criteria that carry significant weight in its public procurement tenders.

Tender People is a public procurement specialist with 15 years’ experience. Our feedback focuses on the following points, which are explained in the attached PDF document. 1. Sustainability and Social Responsible Procurement (SRPP) 2. Boosting circularity through one-to-one awards 3. More flexibility within procurement procedures 4. Maximum value and duration of framework agreements 5.

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Contribution relating to a call for contributions for an assessment/contribution of the adequacy of the Public Procurement Directive 2014/24 With regard to Directive 2014/24: Effectiveness – The Directive (PPD) promotes competition, but places more emphasis on prices than on quality. At the same time, procurement processes across the EU are heterogeneous and complex.

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ABB welcomes the opportunity to provide input on the revision of the EU legislative framework on public procurement. As a company committed to innovation, sustainability, and high quality, ABB supports measures that enhance the efficiency, transparency, and sustainability of public procurement processes. Please see recommendations attached.

Euclid Network (EN) is the European network for social enterprise intermediary organisations. This includes 54 members working across more than 77 countries. They are national associations for social entrepreneurship, incubators and accelerators - all of whom are working to support social entrepreneurs to start and scale their social enterprises to create positive impacts for communities across Europe.

Public procurement can be a powerful tool to promote better animal welfare and greater sustainability. With its high purchasing power, public affairs can contribute to positive societal change by setting requirements that drive better animal welfare and environmental responsibility.

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EU directive reform on public procurement law – comments on the sections of the questionnaire: Section 1: Simpler and more flexible rules, value for money, transparency, integrity need to be improved in particular: E-Forms: Clearly formulated forms, – publicity requirement: Data requested in notices too extensive and detailed – ESPD is not used (market does not accept) – rules on conflict of interest are not…

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In the light of the unfortunate experience of around ten or so rigged public contracts, it would seem appropriate to require the publication of ALL award decisions, even modest contracts (between 10 000 and 143 000), in order to have effective transparency, and to significantly facilitate the challenge processes (in Belgium, an action for annulment before the Council of State may take 5 years).

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Ladies and Gentlemen, we have two points that we would like to share with your say. 1. The current scheme (e.g. from EU Grants: AGA Annotated Grant Agreement: V1.0 1.5.2024) does not seem to us to be disproportionate. Extract: 1.3.

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Challenges: Regionality and non-discrimination The current European competition legislation, in particular the principles of equal treatment and non-discrimination, prevents targeted promotion of regional food in public procurement. This puts local farms at a disadvantage and favours large, supra-regional providers.

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The Norwegian Association of Interpreters is a professional association of qualified interpreters who work in the public sector. Our field is greatly affected by public procurement directives, as many public bodies choose to buy interpreting services externally, and thus are obligated to adhere to these directives.

Taylor Wessing Netherlands organised a survey to gather feedback from stakeholders. The results are summarised below: Tenderers: Explain better why a certain offer won Provide better (legal) protection and support for (SME) tenderers (also supported by Contracting Authorities) Improve evaluation methods Contracting Authorities: Reconsider thresholds TWBNL suggestions: Level playing field in terms of feedback Prevent…

The 'Public Contracts in Legal Globalisation' network is a prominent academic network in the field of public procurement law, comprising over 50 academics from numerous countries and universities. With over 15 years of experience, the network is well-positioned to provide a comprehensive evaluation of Directive 2014/24, including a thorough analysis of each article.

EDP welcomes the opportunity to contribute to the discussion on the EU Public Procurement Directives. One of the main challenges in procurement processes stems from additional requirements imposed at the Member State level, resulting in overly prescriptive rules that go beyond the Directives' intent.

Europe is trapped in a linear economy, including in its procurement. Together, public authorities in Europe spend over 2 000 billion per year on public procurement, with 14 % of Europe’s GDP spending on this path. An amount with great potential and potential to work towards a circular and social future of Europe.

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The Network of Territorial Authorities for a Solidarity Economy (RTES) brings together almost 200 French local and regional authorities at all levels (municipalities, groupings, departments and regions) which are committed to the development of the social and solidarity economy (ESS) on their territory.

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Suggestions: (1) Under the current framework of the Directive, negotiations with tenderers are possible in the case of a competitive procedure with negotiation or a competitive dialogue. At the same time, in order for the contracting authority to be entitled to apply those procedures, the conditions laid down in the directive for their operation must be met, and the application of those procedures is much more…

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Despite the existence of directive 2014/25/EU in public railway infrastructure tenders the main criteria is still the direct purchasing price. As a consequence, innovation, optimisation of Life Cycle Cost and sustainability are losing out and long-term OPEX for the contracting authorities (and the taxpayer) increases.

Opinion on the EU Procurement Directives KRAV welcomes the opportunity to provide input on the EU Public procurement directives. Introduction The EU Procurement Directives are crucial tools for promoting a better environment and sustainable procurement within the EU.

EURATEX acknowledges the progress made by EU public procurement directives but highlights persistent challenges, particularly for SMEs and specialized industries like textiles. Simpler and more flexible rules for SMEs Achievements: ESPD and digitalization have reduced administrative burdens. Challenges: Complex procedures and rigid selection criteria still hinder SMEs.

BDA is the umbrella organisation representing the social and economic policy interests of the German business sector, encompassing one million companies with around 30.5 million employees. Public procurement is already socially responsible under the existing framework (cf. directive on public procurement 2014/24/EU: art. 18(2), 20(1), 43(1), 67(2a), 70).

Dear European Commission, Graag would like to provide input on the evaluation of the Public Procurement Directives, specifically in relation to the development of software by public authorities and the possible impact on market distortion. In recent years, there has been a growing trend where governments develop software in-house or through public entities.

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Innovation Procurement has the potential to accelerate Europes green and digital transitions while improving public services. However, despite this potential, its uptake across EU Member States remains limited due to legal uncertainty, fragmented national approaches, and lack of administrative capacity and incentives for risk-taking.

By Dr.Trevino-Lozano and Dr. Martin-Ortega The Procurement Directive allows and encourages contracting bodies to procure goods, services, and works from competitive tenderers in a global market, many of whom operate within multi-tiered supply chains tied to third-party countries where human rights abuses are prevalent.

Public procurement in the EU accounts for 14% of GDP but remains underutilized in advancing environmental and social goals. Most contracts prioritize price over sustainability, despite procurement being responsible for at least 11% of the EUs greenhouse gas emissions. CAN Europe advocates for revising public procurement rules to prioritize high-quality, environmentally friendly products and services.

Dear Commission Reviewer, The Open Source Initiative (OSI) is a global charity central to the Open Source Community for over 25 years, recognized as the authority defining Open Source. We are pleased to provide input on the European Unions procurement legislation, focusing on digital solutions.

Public procurement should be more flexible and facilitated to access in order to ensure a high level of competition as well as the reasonable use of public means. Simplification, more flexibility and less formal requirements of the procurement procedure are necessary. This is to ensure competition and the efficient use of public funds. Participation in the procurement procedure is a barrier for participants.

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Public procurement law is challenging for administrative units of our size, as tasks and procedures are becoming increasingly complex, procurement law is an increasingly difficult objective to achieve, and the resources for efficient management are also lacking (including at the higher advisory level).

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The upcoming reform should reinforce the role of public procurement as a strategic policy tool, supporting the EU in achieving its environmental and social objectives while promoting sustainable economic practices. Currently, Directives allow for the consideration of qualitative, environmental, and social criteria in public tenders, provided they do not hinder competition in the internal market.

The opinion of the ARGE Bäuerinnen Kärnten on Directive 2014/24/EU Regionality in public procurement promotes healthy food, environmental and economic strengthening of regional agricultural holdings in the current European competition legislation. It benefits mainly large suppliers and local producers are definitely disadvantaged.

Filed in German · English published by the European Commission

This feedback document contains a collection of proposals and recommendations for the European Commission to improve or reform the existing Public Procurement Directive (Directive 2014/24/EU). A key issue is the introduction of facilitations for legally established central purchasing bodies.

Filed in German · English published by the European Commission

The Association of Finnish Cities and Municipalities (AFCM) considers that the most important goal in the revision of the Public Procurement Directives shall be to simplify the current procedural rules. Firstly, the rules on the application of the different directives, the procedures and the announcement of procurements shall be made easier for both the con-tracting authorities and tenderers.

Experience in planning services: The content of mental (creative) services is to solve a complex task through intellectual performance in areas such as architecture, urban planning, spatial planning and infrastructure planning. It is not possible to give a clear and complete prior description of the performance and harms the building culture.

Filed in German · English published by the European Commission

Public procurement in Portugal is the main source of problems in the sector of the provision of cleaning services. The lack of competence of the public administration to deal with the procedure, from the launch of tenders to the criterion used for the award of tenders, has led to the removal of the best companies from the public procurement sector.

Filed in Portuguese · English published by the European Commission

— Sector procurement law for public procurement is intended to allow flexibility due to the heterogeneity of contracting entities. However, the current requirements do not comply with this, as they are too closely aligned with the public procurement law of the contracting authorities. In general, the procurement of energy (i.e. also gas, oil and consumables) should be exempt from public procurement law.

Filed in German · English published by the European Commission

The detailed version of CEMR's contribution is available attached. The Council of European Municipalities and Regions (CEMR) is the broadest European association of local and regional governments. Local and Regional Governments (LRGs) play a significant role in this area as they are the largest investors and contracting authorities in the EU, both in terms of numbers of contracts and contract volume.

On behalf of the Baden-Württemberg City Council, please find enclosed the coordinated position paper on the award of planning and engineering services in public procurement law. The position paper was drawn up in the circle of our regular working group of Baden-Württemberg building Mayors (WG BauBM) from January to March 2025.

Filed in German · English published by the European Commission

The public procurement law – grant law interface proves to be a heavy burden for beneficiaries who are not contracting authorities themselves but receive funding from the ESF programmes, for example. As a general rule, the grant law transfers unmodified requirements to them that are tailored to contracting authorities. Unlike these, private beneficiaries are largely left alone with these requirements.

Filed in German · English published by the European Commission

The opening up of European public markets is the strongest in the world as a member of the GPA (Government Procurement Agreement), the European Union has fully opened up its public markets to competition from its partner countries.

Filed in Spanish · English published by the European Commission

Planning services are subject to specific national regulations and standards relating to the design and execution of construction projects. Therefore, when tendering for planning services in the construction sector, it should be noted that, in the case of pan-European tenders, foreign bidders usually do not participate.

Filed in German · English published by the European Commission

Opinion on the Consultation of the EU Public Procurement Directives The European Union’s public procurement directives aim to make public procurement more transparent, efficient and fair. The current consultation on the evaluation and possible adaptation of these Directives provides an important opportunity to analyse existing regulations, identify potential for improvement and address future challenges.

Filed in German · English published by the European Commission

Technology agency of the Czech Republic proposes that European legislation on public procurement (Directive 2014/24/EU) is in the form of a regulation and not a directive. The incorporation of the directive on public procurement causes large differences in individual national legislation in EU and allows more room for inaccurate transformation of objectives and purposes into national legislation.

The opinion concerns the functioning of Directive 2014/24/EU of the European Parliament and of the Council of 26 February 2014 on public procurement (so-called ‘classical Directive’) in relation to contracts performed by entities in the public finance sector (Part 2 of 2): 1.

Filed in Polish · English published by the European Commission

The opinion concerns the functioning of Directive 2014/24/EU of the European Parliament and of the Council of 26 February 2014 on public procurement (so-called ‘classical Directive’) in relation to contracts performed by entities in the public finance sector (Part 1 of 2): 1.

Filed in Polish · English published by the European Commission

The public procurement law – grant law interface proves to be a heavy burden for beneficiaries who are not contracting authorities themselves but receive funding from the ESF programmes, for example. As a general rule, the grant law transfers unmodified requirements to them that are tailored to contracting authorities. Unlike these, private beneficiaries are largely left alone with these requirements.

Filed in German · English published by the European Commission

We recognize the crucial role of public procurement directives in ensuring fair competition, sustainability, and innovation. However, to create a level playing field, it is essential to strengthen reciprocity and strategic purchasing clauses, ensuring that European companies can compete fairly while maintaining high standards.

As a representative of the interests of agricultural and forestry holdings in Lower Austria, we consider it essential to strengthen agriculture in order to ensure a safe and sustainable food supply. The aim of a revised directive should be to prioritise the availability of regionally produced products in public institutions.

Filed in German · English published by the European Commission

We appreciate the opportunity to provide feedback on the Public Procurement Act, which is crucial to making the procurement process more accessible and efficient. The current system is overly bureaucratic and costly, particularly for SMEs. Complex tendering procedures and excessive documentation discourage participation, creating a market dominated by large corporations.

The PPD aimed to promote sustainability, stating in the second recital that public procurement should serve as an instrument for achieving smart and sustainable growth while ensuring the most efficient use of public funds. However, its complexity has led to interpretations that hinder public authorities from leveraging its potential.

Proposals from our Legal Affairs Unit: 1. Under the eligibility requirements and the grounds for exclusion, give all candidates/tenderers the possibility of incorrect repair once, including missing documents and new reference projects. 2. Changes to the Information Note do not require the publication of a corrigendum (unless the nature of the contract changes). 3.

Filed in Dutch · English published by the European Commission

We would also like to inform you that we also see the following areas of simplification: 5. Self-cleaning By reference to the German provision in Section 125(1)(2) of the GWB and the findings of the Court of Justice in Case C-124/17 Vossloh Laeis, we suggest that it be made clear in the Public Procurement Directives that, in addition to active cooperation with the investigating authorities, active cooperation with…

Filed in German · English published by the European Commission

There is considerable potential to better achieve the objectives (promoting competition, increasing SME participation, simplifying procurement processes, efficient use of public funds). The high level of formality is a heavy burden for bidders. It also restricts competition because suitable bidders often have to be eliminated only because of formality.

Filed in German · English published by the European Commission

The EU public procurement legal framework can be more innovation-friendly and give public buyers clarity on how to better implement innovation procurement. Although the current EU legal framework already allows flexibility to apply innovation-friendly approaches and techniques, future amendments to the EU legal framework should clarify the definition of innovation procurement and reinforce the legal measures that…

ARTICLES 4 & 6 THRESHOLDS SME & Microenterprises Further EMBED the ability to participate for smaller businesses. Increase the threshold to double threshold particularly for goods and services over the lifetime of the contract from the current 221k, Insist that national central purchasing bodies do the same.

Logitech sees the upcoming review of the Public Procurement Directives as yet another opportunity to promote responsible sustainable consumption in Europe. Accounting for around 14% of GDP in the EU, public procurement is an important force which can influence market trends and can promote the uptake of green and innovative technologies and products and support the twin transition, while also supporting sustainable…

The Danish Public Transport Authorities encourage the Commission to use this evaluation to correct the misunderstanding that the use of price as award criteria in tenders leads to lower quality. We encourge the Commission to secure the contracting authorities the right to plan and execute the tender process including the right to choose award criteria between either price or best price-quality ratio.

* Proposals concerning Directive 2014/23/EU on the award of concession contracts: Abolition of the launch and award deliberation – Strengthening the role of the Public Service Delegation Committee (PSDC) – Unify CGCTs and CPCs – Simplifying overly complex advertising notices and sources of error – Request applications and tenders in the same envelope – Permit to impose electronic replies * Proposals concerning…

Filed in French · English published by the European Commission

Software vendors achatpublic.com, Atline Services, Avenue Web Systèmes and Dematis, a provider specialising in connecting the public and private sectors, see in our daily activity recurring difficulties that buyers of all sizes may face.

Filed in French · English published by the European Commission

WorldGBC and the Europe Regional Network welcome this consultation on the Directive 2014/24/EU on public procurement. We support a comprehensive revision of the Directive and call on the European Commission to acknowledge that procurement is a crucial way to drive an energy efficient, low emission, regenerative and just transition in the built environment.

The attached policy brief summarises some of the key learnings from the ENERGATE project, co-funded by the LIFE programme, and includes recommendations, relevant to the public procurement process, which can enable public authorities benefit from one-stop shops and platforms that facilitate the design, financing and implementation of energy efficiency interventions in public buildings.

CECOP, the European Confederation of Industrial and Service Cooperatives, welcomes the opportunity to provide feedback to the European Commission in evaluating the Directives on public procurement. Cooperatives are people-centred enterprises owned, controlled and run by and for their members, who share equal voting rights and reinvest the profit generated in the enterprise.

Since the UN Global Compact Spain, we consider public procurement to be a key strategic tool to boost sustainable business models. As one of the European Union’s biggest economic drivers, it has the potential to transform the market by setting high sustainability standards that boost competitiveness, foster innovation and enhance transparency.

Filed in Spanish · English published by the European Commission

Evaluation of the European Procurement Directive: Proposed Amendment on Open Standards. The current European Procurement Directive mandates that when requesting specific standards or specifications in a tender, the contracting authority must include the phrase "or equivalent." While this provision aims to ensure fairness and prevent unjustified exclusions, it does not adequately reflect the role of open (semantic)…

CSL Behring welcomes the opportunity to contribute to the evaluation of the public procurement Directive 2014/24/EU. While public procurement of medicinal products is widely used by Member States, the implementation of EU procurement rules varies.

The objectives of the EU public procurement directives remain correct: Competition, transparency, efficiency and economy, non-discrimination and prevention of corruption. These objectives are very important for companies as bidders and must not be weakened.

Filed in German · English published by the European Commission

Ladies and gentlemen, the German Book Trade Exchange Association, is grateful for the opportunity to provide feedback on the evaluation of the public procurement rules. Our member bookshops often encounter difficulties in schoolbook shops, although, as a result of the statutory price maintenance for books, all offers must always include identical prices.

Filed in German · English published by the European Commission

There is a lack of data on implementation of socially responsible public procurement (SRPP) which is a barrier in assessing the effectiveness and efficiency of existing measures in addressing impacts on society of the goods, services, and works purchased, such as promoting employment opportunities, decent work, social inclusion, accessibility, and compliance with social and labour rights.

Public procurement in the power and heat production sector, as well as in the wholesale and retail electricity and gas sectors, has undergone significant changes since the first EU-wide regulation of the rules for the purchase of goods, services and works. The integration of markets and the strengthening of the Energy Union have contributed significantly to increased competition in the relevant markets.

The Swedish Society for Nature Conservation (SSNC) welcomes the opportunity to provide input on the EU Public procurement directives. SSNC is a non-profit environmental organisation, working with more than 40 organisations around the world, with almost a quarter of a million members and more than 270 local associations. SSNC also runs the ecolabel Good Environmental Choice.

(1) raising the amounts of the thresholds for the application of the provisions of the Directive, particularly in relation to supply and service contracts. The use of threshold quotas ensures transparency and transparency in the public procurement process, but if these thresholds are set at an inappropriate level and do not correspond to the realities of the market, this may have a negative impact on the…

Filed in Polish · English published by the European Commission

Further draws attention to the assessment factors that refer to social aspects (classification with an employment contract for the indefinite period of time for disadvantaged/disabled persons and classification with an employment contract for the indefinite period of time of persons coming from the notice) as well as to aspects with an environmental impact (vehicle/machine with minimum pollution class EUR…

Filed in Romanian · English published by the European Commission

Set up in 2015, the Fédération Française des Indications Géographiques Industrielles et Artisanales (FFIGIA) brings together renowned traditional products, which are economically rooted in their territories, such as Granit de Bretagne, Bourgogne stone or Limoges porcelain. To date, 20 member sectors and 19 of the 21 AI GIs approved by the INPI are members of our Federation.

Filed in French · English published by the European Commission

Currently, the rules on public procurement of food are not suitable to enable final consumers to be supplied in a sustainable, short-chain and thus crisis-proof manner. The opinion is attached as a document. It is written from one hand on behalf of the owners’ representatives of the first Farmers’ Supply Network for Food for Public Utilities, which is considered to be a Role Model in Austria: BVN – Bäuerliches…

Filed in German · English published by the European Commission

As an adviser from a medium-sized municipality (approx. 44.000 inhabitants), I would like to see the Directives amended as follows: (1) raising the thresholds for supplies and services. (2) less strict separation between eligibility requirements and award criteria. (3) prohibition of award models with the possibility of ‘Rank reversal’.

Filed in Dutch · English published by the European Commission

The most pressing issue we observe in public procurement is the continuous decline in the number of bidders. In many cases, only one bidder participates, and in some instances, there are none at all. This lack of competition puts pressure on the price-quality ratio and reduces market incentives to innovate and improve.

In essence, to ensure truly socially responsible public procurement, the competitiveness in EUs public procurement procedures and their simple and smooth functioning, the Red Cross EU Office encourages the Commission to: 1. make the Most Economically Advantageous Tender (MEAT) criteria the default standard instead of the lowest price or cost; 2.

1. The eNotice system, while the shortening of the deadline for the publication of notices was right and the idea of digitalising procedures for the publication of a contract notice and standardising public procurement forms using electronic tools, is no longer the same execution of the eNotice2 system: the service is complicated, the vocabulary in many places is incomprehensible, and the quality of the translation…

Filed in Polish · English published by the European Commission

From the point of view of the European Network of Social Economy Cities and Regions, the refitted directives The new directives should address some critical points of the current directives, which we summarize below.

Public procurement procedures need to be simplified and standardised. The requirements for access to invitations to tender must be uniform for the Member States of the European Union, favouring transactions and the common market. In order to speed up procurement procedures, it would be advisable to create the same single reference master’s degrees.

Filed in Italian · English published by the European Commission

Animal Equality urges the European Commission to reform public procurement regulations by adopting a mandatory approach integrating animal welfare as a key factor in procurement decisions. This can be achieved by incorporating assessable criteria in tender specifications, such as using eggs from cage-free hens, and incentivizing suppliers who invest in technologies that eliminate cruel practices, such as killing…

Europacable, the voice of Europes leading wire and cable manufacturers, welcomes this opportunity to share its recommendations and urges the European Commission to place underground and subsea cable infrastructure at the heart of the upcoming revision of the EU Public Procurement Directives.

For an optimal outcome of public policies through strategic procurement, the possible delays and differences in interpretation and uncertainty resulting from the implementation of Community directives in this area must be reduced, as the experience of all these years has not been entirely satisfactory.

Filed in Spanish · English published by the European Commission

Hosmoz is the new brand resulting from the merger of the Gesat Network and Handeco. Hosmoz is the head of the national economic network of the 2400 ESAT and adapted businesses and aims to support the professional integration of the 170 000 people with disabilities who acquire daily skills in more than 200 occupational sectors.

Filed in French · English published by the European Commission

In order to create a level playing field for businesses across Europe, EU law lays down minimum rules on public procurement, including generally applicable rules, specific rules for entities active in the water, energy, transport and postal services sectors. These areas, part of the critical infrastructure, should operate with particularly high-quality systems and products.

Filed in German · English published by the European Commission

Opening up European public markets is one of the strongest in the world, thanks to the European Union’s accession to the Government Procurement Agreement (GPA), which has made it possible to fully open up its public markets to competition from partner countries. However, some of these countries have put in place restrictive clauses in strategic sectors, limiting the full opening of their markets.

Filed in Spanish · English published by the European Commission

We are delighted to see the opportunity to share with you our perception of the correct implementation of the public procurement directives, and in particular the approach to best value for money, towards the most advantageous combination of cost, quality and sustainability.

Filed in Portuguese · English published by the European Commission

Fellesforbundet, the largest trade union in private sector in Norway, supports a revision of the public procurement directives that strengthen the social requirements and that promote sustainable procurement through efficient use of societys resources. The directives must focus on sustainable procurement in a broad sense (social, environmental and economic).

1.In view of the importance of various medicines and medical supplies for saving the lives of patients, the purchase of which must be made immediately at times, we ask the EC to review 14. Annex (74. The services referred to in Article 6), supplemented by the relevant CPV codes when it comes to the purchase of medicinal products and medical supplies; (2) Given that in public procurement contracts may be awarded not…

Filed in Latvian · English published by the European Commission

Feedback Cradle to Cradle NGO on Directive 2014/24/EU on public procurement and Directive 2014/23/EU on the award of concession contracts In the view of Cradle to Cradle NGO, mandatory requirements should be added to Directive 2014/24/EU on public procurement in order to promote the procurement of circular and healthy products with environmental, economic and social added value for people and the environment.

Filed in German · English published by the European Commission

The Danish Trade Union Confederation (FH) considers that EU procurement directives should promote fair competition based on decent pay and working conditions. However, Fh’s experience has been that it has not been possible to address within the existing rules the challenges of social dumping, health and safety at work and work-related crime.

Filed in Danish · English published by the European Commission

The Urban Agenda Partnership on Innovative and Responsible Public Procurement shares with you key recommendations as input for revision of the EU Public Procurement Directives. Your adjustments in the legislation could enable transformative progress fuelling sustainable economic growth, circular economy, energy transition, sustainabillity, gender equality, social responsibility, and innovation.

In the opinion of the Provincial Police Headquarters in Olsztyn, the Classical Directive meets the expectations of the Contracting Authorities. Implementing national rules also allow for the award of contracts that meet the needs of the Contracting Parties.

Filed in Polish · English published by the European Commission

When assessing the content of the Classical Directive, Directive 2014/24/EU of the European Parliament and of the Council, when carrying out tendering procedures, sees the need to amend the following provisions by the Provincial Police Headquarters in Wrocław: 1. Above all, the possibility of raising the thresholds for the application of the Classical Directive.

Filed in Polish · English published by the European Commission

Implementing Regulation (EU) 2019/1780 of 23 September 2019 establishing standard forms for the publication of notices in the field of public procurement and repealing Implementing Regulation (EU) 2015/1986 raises a number of problems for contracting authorities. Minus: from the point of view of the contracting authority, eNotices2 is a very extensive tool with a very large number of data, e.g.

Filed in Polish · English published by the European Commission

Public procurement is a strategic tool to support European industry and strengthen its position in the face of international competition. However, European companies often face asymmetric access to foreign public procurement markets, especially in some large economies that apply national restrictions or preferences. 1.

Filed in French · English published by the European Commission

Samaritan International welcomes the opportunity to give feedback to the call for evidence on the functioning of Directive 2014/24/EU on public procurement. The detailed position is in attachment to this statement.

The biggest problem for procurers is currently the eNotices2- nightmare advertising process. The need to simplify the publication of notices through eNotices2. The new version of the tool is more complex, time-consuming, less intuitive, and the lack of clear answers and transparent navigation leads to the need to correct notices several times before final validation.

Filed in Polish · English published by the European Commission

Please find enclosed the position of the Permanent Conference of Social Economics (Poland) and the Polish National Revision Association of Social Cooperatives (Poland) containing proposals for amendments to the Classical Directive concerning the integration of social and environmental aspects.

Filed in Polish · English published by the European Commission

Regulation of electricity and gas activities. It is proposed to clarify the scope of Directive 2014/25/EU by providing that it does not apply to the relevant sectors of activities directly exposed to competition.

Tenders comprising products originating in third countries. It is proposed to unify the regulation of the Directives and also to introduce in the Directive 2014/24/EU the regulation of the tenders comprising products originating in third countries. The possibility to restrict products originating in third countries is limited to Directive 2014/25/EU.

Framework agreements. It is proposed to abolish buyers' reporting for contracts concluded on the basis of framework agreements. The Directives provide that procurement procedures end at the conclusion of the framework contracts, but also provide that the procedure reports on procedures for the award of contracts are to be submitted not only on the conclusion of the framework contract, but also on the contracts…

Modification of contracts during their term. It is proposed to clarify and supplement the regulation set out in the Directives. It is proposed to simplify the requirements and grounds for modifying the contracts set out in the Directives: 1. remove the limits set for the amendment values; 2. increase the thresholds for minor (de minimis) variations set by the Directives (e.g.

Contracts awarded to an affiliated undertaking. It is proposed to unify the regulation of the procurement of affiliated undertakings and to provide for the possibility of entering into affiliated undertaking transactions in the Directive 2014/24/EU as well.

Qualification systems. It is proposed to unify the regulation of procurements through a qualification system and to provide for the possibility to apply a qualification system in Directive 2014/24/EU as well. Given that the contracting authorities also have a need to apply a qualification system, as it saves time in procedures, verifies suppliers' qualifications in advance and maintain its validity at all times, we…

Contracts awarded for purposes of resale or lease to third parties. It is proposed to align the regulation and to also provide for the possibility of excluding the contracts for the purpose of resale or leasing to third parties from the Directive 2014/24/EU.

The minimum time limit for receipt of tenders in the dynamic purchasing system and setting or extending deadlines for providing additional information to suppliers. The Directives stipulate that, in the case of a dynamic purchasing system, the minimum period for the receipt of tenders shall be at least 10 days from the date of dispatch of the invitation to tender.

Threshold amounts. It is proposed to align and increase the threshold amounts set out in the Directives. Contracting authorities and contracting entities usually purchase identical items (goods or services) at a price that depends on the market and its participants, i.e.

Grounds for exclusion or rejection of tenders. It is proposed to allow Member States to provide for additional grounds for exclusion and/or rejection of tenders, e.g. related to the requirements of compliance with national security interests in the Member State concerned, as well as related to the situation of mobilisation, war or state of emergency in different Member States.

Issues relating to the declaration of an oath or the solemn declaration in Member States or countries where there are no provisions on the declaration of an oath. In many cases, contracting authorities and contracting entities are faced with the problem of not being able to check the regulations and practices applied in different Member States (which declarations are used in the different Member States), and the…

Negotiated procedure without prior publication. Elimination of differences between the conditions for the use of the negotiated procedure without prior publication laid down in the Directives. The use of the negotiated procedure without prior publication is limited to exceptional and detailed cases, and it is not efficient or proportionate to restrict subjects in one sector (classical contracting authorities) more…

An exclusion for purchases through public platforms, auctions, exchanges (e.g. Nordpool, etc.) and for joining such public platforms. The preambles to the Directives provide that a procurement procedure is not useful where supplies are purchased directly on a commodity market, including trading platforms for commodities such as agricultural products, raw materials and energy exchanges, where the regulated and…

Specific exclusions for contracts. Additional exclusions from the Directives are proposed. Given the nature and specificity of the services/goods or the relationship between the parties, it is proposed to provide for additional exclusions for (i) bank deposit procurements, (ii) association contracts (procurements of association membership services), (iii) procurements for guarantees of origin for green electricity…

Procedure with negotiation. Article 26 of Directive 2014/24/EU sets out an exhaustive list of conditions under which procedure with negotiation may be carried out. The negotiated procedure is in line with the principles of public procurement and, in practice, facilitates the achievement of the objective of the procurement - the award of a contract through the rational use of the funds allocated to the procurement.

Candidate. It is proposed to abolish the obligation for the buyer to inform the candidates of the outcome of the procurement. The Directives provide that a candidate is an economic operator that has sought an invitation or has been invited to take part in a restricted procedure, in a competitive procedure with negotiation, in a negotiated procedure without prior publication, in a competitive dialogue or in an…

The request to participate. We propose to retain the possibility for Member States to opt out the separate stage for submitting the requests to participate, but to provide for a single requests to participate + tender phase. The submission of the requests to participate as a separate stage of the procurement could be an optional rather than a mandatory stage of the procurement.

The minimum time limits to submit the requests to participate. We propose to shorten the minimum time limit for submitting the requests to participate to 15 days or to leave it to Member States to set the mandatory minimum time limits.

In the context of the revision of the European public procurement directives, the Walloon Public Service, through the representatives appointed by the Walloon Government to sit on the Walloon Public Procurement Commission, responds to the public consultation launched by the European Commission and wishes to draw its attention to the following points: Simplification of rules and reduction of administrative burden…

Filed in French · English published by the European Commission

In the opinion of the Coalition for Timber Construction, the following suggestions should be made: The Coalition for Timber Construction is in favour of maintaining the role of public authorities as a model in sustainable procurement.

Filed in German · English published by the European Commission

FinMobility, representing Finnish road transport, mobility and logistics employers and entrepreneurs, would like to highlight the following three key issues at this stage of the consultation: The contractual thresholds for contract variation should take into account the impact of inflationary effects, i.e.

oriGIn EU would like to provide its views concerning the evaluation of the public procurement directives. OriGIn EU supports the European Commissions objective to make full use of the potential of the European Unions (EU) public procurement market and to give preference to European products in public procurement for certain strategic sectors.

Public procurement related to spatial design, such as architecture, urban planning and landscape architecture, requires a particular approach. General procurement rules no longer meet current insights regarding qualitative processes for these very specific assignments. A shared concern: There is a broad consensus in Europe regarding the pursuit of a qualitative architectural culture.

Der GdW ist der Dachverband der wohnungs- und immobilienwirtschaftlichen Regionalverbände in der Bundesrepublik Deutschland. Er vertritt rund 3.000 Wohnungsunternehmen. Der Hauptverband der Deutschen Bauindustrie e. V. und seine Mitgliedsverbände vertreten rund 2.000 Unternehmer, die lokal, regional, bundes-, europa- sowie weltweit tätig sind.

Europes approach to tackling road safety is in trouble. According to the current trend, deaths are set to fall by only a quarter by 2030. There were 20,400 road deaths in the EU last year down just 1% on the previous year, falling far short of the 6.1% annual reduction needed to reach the EU target.1 While this represents a 10% reduction since 2019 - the baseline for the 2030 target - the downward trend has…

The EU Public Procurement Directive aims to foster competition within the single market. However, its current framework does not always support local economies or environmental sustainability. In mountain areas, agriculture is a key pillar of the local economy.

Nokia is a B2B technology innovation leader in networking, bringing together the world's people, machines and devices to realize the potential of digital in every industry. Nokia welcomes the opportunity to provide feedback to this consultation.

The opening up of European public markets is the strongest in the world as a member of the GPA (Government Procurement Agreement), the European Union has fully opened up its public markets to competition from its partner countries.

Filed in Spanish · English published by the European Commission

> Startups as a Key Source of Innovation for the Public Sector Startups play a crucial role in driving innovation and improving the efficiency, accessibility, and modernization of public institutions. However, the current public procurement framework presents significant barriers to startup participation, making it difficult for them to contribute effectively.

Comments for the Public Procurement Directives We welcome the opportunity to share our perspective on the proper implementation of public procurement directives, particularly regarding the Best Value for Money principle, which balances cost, quality, and sustainability to achieve the most beneficial outcomes.

The position of the municipal umbrella associations on the reform of EU public procurement law of 20 February 2025 calls, inter alia, for projects carried out to meet basic local needs (services, services of general economic interest) to be exempted from the Europe-wide tendering obligation.

Filed in German · English published by the European Commission

The current texts still lack simplification and easy access to public procurement. Certain areas (maintenance of computer software or technical equipment for peaks with embedded artificial intelligence) are not dealt with separately and the choice of procedure to be carried out often proves to be the negotiated contract without advertising or competitive tendering.

Filed in French · English published by the European Commission

— Level of thresholds: Overall, the thresholds could be higher to allow for faster procurement procedures. This relates in particular to the thresholds for supplies and services. Overall, EU procurement procedures are very time-consuming, leading to frequent delays in projects.

Filed in German · English published by the European Commission

CLECE, S.A., www.clece.es is a Spanish service company committed to the company, with more than 81.000 professionals serving 1.5 million users and customers. With regard to the EU Commission’s call for evidence on the evaluation of the Public Procurement Directives, in particular in relation to Directive 2014/24/EU, I would like to make the following comments, as set out in the attached document: 1.

Filed in Spanish · English published by the European Commission

Social enterprises active in reuse, repair, and recycling are key partners for contracting authorities as they contribute to local and socially inclusive green employment through their circular economy waste management activities. Reusing can carry a high job creation potential, higher than recycling, and significantly lowers the environmental impact of items.

I am responding on behalf of the municipality of Dordrecht. We agree with the input from Rijksinkoop Cooperation (RIS) and Gemeente Apeldoorn. In particular, from their input, we call for attention to be paid to: (1) the level of the thresholds. Excessive differences between inflation and limited increases in thresholds. (2) lack of clarity as to the estimation of repeating services and supplies.

Filed in Dutch · English published by the European Commission

In our view, European public procurement markets are too open to competition from third countries, compared to the increasing isolation of EU producers in other regions/economic areas. Especially in the context of the current geopolitical challenges, it is unacceptable to open up our market to countries such as Türkiye, India and China, which do not apply any embargo in favour of Putin’s Russia and freely buy cheap…

Filed in Polish · English published by the European Commission

As a global company with operations and production sites worldwide, Knorr-Bremse Systeme für Schienenfahrzeuge GmbH strongly supports a level playing field that fosters healthy competition and innovation. At the same time, it recognizes the need for thoughtful regulations to address evolving global challenges.

Europe needs to improve its innovative and competitive edge, and therefore the EU Commission has launched several initiatives to achieve these goals. According to the EU Commission public authorities yearly spend 2,4 trillion euros and 48% of European Structural and Investment Funds via public procurement.

The regulation that is binding on contracting entities in their procurement processes should be more clearly focused on the procurement directives and not on a large number of directives and regulations in various sectors. Alternatively, the EU should implement a database per procurement category, where all obligations binding on contracting entities in a given procurement category could easily be found.

Filed in Finnish · English published by the European Commission

The municipality of Santa Lucia de Tirajana made the following discussions on administrative recruitment: Although the transposition of European directives at national level in the field of public procurement is considered to be correct, it could be improved at the level of local administration, without once again affecting the inclusion of social and environmental criteria as a means of meeting the governmental…

Filed in Spanish · English published by the European Commission

Practically all construction and renovation of public infrastructure for water supply and sewage is financed through public procurement. From a social and economic perspective, we should strive to purchase and install as much material as possible produced in the EU.

The public procurement law grant law interface proves to be a heavy burden for beneficiaries who are not contracting authorities themselves but receive funding from the ESF programmes, for example. As a general rule, the grant law transfers unmodified requirements to them that are tailored to contracting authorities. Unlike these, private beneficiaries are largely left alone with these requirements.

Filed in German · English published by the European Commission

Hello! I recommend an explicit consideration of more collaborative arrangements and procedures towards building innovative and sustainable solutions. Collaboration is a key to implementing sustainable public procurement and procurement regulation is an important driver for implementing collaborative arrangements (https://doi.org/10.1002/csr.3117).

WELFARM is a French association set up in 1994 with the task of protecting animals removed at all stages of their lives (rearing, transport, slaughter). Mr WELFARM proposed the ETICA approach, which provided support to local and regional authorities to improve the inclusion of animal welfare in their public catering contracts.

Filed in French · English published by the European Commission

In Germany, private-law entities receiving State funds for pro rata financing are obliged to apply public procurement law to their own procurement procedures, even if they are not contracting authorities within the meaning of European public procurement law.

Filed in German · English published by the European Commission

the portal (belgian partal) is absolutely not user friendly. It is not clear which fields need to be filled, and error messages are only understandable by the programmers. A usability study and implemntation of basic user friendly interface would promote the use of the portal very much. Of course, the ever changing rules and regulations make maintenance difficult

1. The current procurement framework consists of three directives. A key recommendation is to consolidate these into a single directive, taking the more flexible and less detailed Concessions Directive as a basis. 2. A fundamental reconsideration of what should be regulated at the directive level versus what can be managed through sectoral laws and standards is needed.

The opening up of European public markets is the strongest in the world as a member of the GPA (Government Procurement Agreement), the European Union has fully opened up its public markets to competition from its partner countries.

Filed in Spanish · English published by the European Commission

It is concerning that European public institutions continue to award contracts to non-European industrial players without demanding fair reciprocity. While Europe has adopted an open market approach, other major economies impose restrictions to protect their strategic sectors, creating an uneven playing field. This imbalance is not just unfairit raises economic, social, and security concerns.

The European and International Booksellers Federation (EIBF) is the voice of booksellers in the European Union and globally. EIBFs members are national Booksellers Associations, who represent all kinds of book retailers, a majority of those being small and medium-sized independent and family-owned bookshops.

1. Increasing the thresholds for awards 2014/24/EU, Article 4 Proposal: Increase the thresholds for EU procurement in order to carry out smaller procurements faster and more flexibly in accordance with national laws. Advantage: Reducing the administrative burden by shortening deadlines for low-value contracts and thus speeding up procedures. 2.

Filed in German · English published by the European Commission

The public procurement law – grant law interface proves to be a heavy burden for beneficiaries who are not contracting authorities themselves but receive funding from the ESF programmes, for example. As a general rule, the grant law transfers unmodified requirements to them that are tailored to contracting authorities. Unlike these, private beneficiaries are largely left alone with these requirements.

Filed in German · English published by the European Commission

— On the basis of the public procurement directives and national rules, numerous evidence must be requested and provided by contractors, in particular as regards the absence of grounds for exclusion by contracting authorities.

Filed in German · English published by the European Commission

Since we use the e-procurement platform in PNSPP, we have difficulties in having offers. This is because it is easier for small SMEs to quote on paper. The use of the platform creates red tape for society in addition to the specifications. Many of the companies we usually work with no longer want to participate in public procurement.

Filed in French · English published by the European Commission

I deal with public procurement in our administration and find it difficult for self-employed and small and medium-sized enterprises to work with the e-procurement platform. I have many calls from them that they are not able to log in, that they have not received the invitation email, etc.

Filed in French · English published by the European Commission

From a practical perspective, it is useful for legislators to examine several issues. — Above all, the possibility of raising the thresholds for the application of the Classical Directive. In view of the significant increase in the prices of goods and services in recent years, it would be justified to adjust the threshold values of the contracts from which its provisions start to apply.

Filed in Polish · English published by the European Commission

AMENDMENTS TO DIRECTIVE 2014/25/EU 1. Significantly increasing the thresholds for the application of the Directive set out in Article 15, including those for the award of lots that may be exempted from the Directive’s provisions (paragraph 10). 2.

Filed in Polish · English published by the European Commission

With regard to the rule of law contained in Article 42(1) 4 of the Classical Directive. The performance of scientific research requires the use of specific products, inter alia, because of the continuation of the research carried out, the unique knowledge and experience of the researcher and the need for comparative analyses.

Filed in Polish · English published by the European Commission

The EU Public Procurement Directive has enormous potential to foster inclusion for persons with disabilities. Here we point out why it does not currently reach its full potential, and identify the gaps to address. The directive underserves persons with disabilities in a number of areas, particularly when it comes to support services.

Attached a note on the problems and solutions relating to public procurement, drawn up by Network Architecten Vlaanderen VZW. The largest interest organisation for architects in Flanders and Brussels. The greatest concern for architects is the viability of participation in and quality of public procurement.

Filed in Dutch · English published by the European Commission

The Bundesarchitektenkammer e.V. (BAK) represents, on behalf of the 16 chambers of regional architects, the interests of around 140.000 architects of all disciplines vis-à-vis politics and the public at national and international level.

Filed in German · English published by the European Commission

Our REFORM REFORM requests from the point of view of sustainability and European added value are three key points in the revision of the EU public procurement directives: The principle of the best bid rather than the lowest bidder: The obligation for contracting authorities to take into account social and environmental criteria and thus to strengthen the quality of public procurement in terms of social, labour and…

Filed in German · English published by the European Commission

EADIPS represents the interests of European manufacturers of cast iron products for water supply and wastewater disposal. The customers of EADIPS members are contracting authorities and operators of critical infrastructures to which Directive 2014/25 EU or the respective national procurement regulations apply.

I have two personal experiences in public procurement in the Czech Republic and Slovakia, which may overlap in other regions. Topics are: 1) proving the basic qualification requirements 2) evaluation criterion price In discussions in the region with the relevant ministry (Ministry of regional development CZ), the Office for the Protection of Competition, individual companies within the Confederation of Industry of…

Ladies and Gentlemen, I would like to take the opportunity, from the point of view of a municipality, to take a position on the current situation with regard to public procurement law. As a city with a population of around 15.000, procurement of construction works or the commissioning of services or professional services is very often carried out in areas just above the applicable thresholds.

Filed in German · English published by the European Commission

SAFE Food Advocacy Europe intervenes on Green Public Procurement: Based on 10 years of experience in sustainable consumption advocacy, we only respond to the aspects related to Green Public Procurement, which should: - Provide healthy diets free from NGTs/GMOs and ultra-processed foods, based on WHO dietary guidelines. - Include the calculation of food waste by type of dish.

The main problem is that the EU thresholds for works contracts at EUR 5.538.000 and for supply and service contracts in the sector at EUR 443.000 are significantly too low. Contracts in this area are not relevant to the European market as a whole. In addition, raising the thresholds would create more room for manoeuvre for national legislators and significantly reduce the bureaucracy of procurement.

Filed in German · English published by the European Commission

The parties do not unnecessarily incur costs: — successful candidates all multi-stage procedures: no less than 3 (instead of 5 in some cases) Simplify wherever possible, e.g.: — threshold amounts reviewed no more than four years – reduce ESPD text; ...

Filed in Dutch · English published by the European Commission

We hereby wish to provide input on the public consultation on the Concession Directive 2014/23/EU. 1/Présentation of our Group The Hydrocop Group is today the 4th French hydroelectrician. It has 39 plants with an annual production capacity of approximately 450 GWh. Of this fleet, 15 power plants are operated under concession arrangements under 8 “concessional” concessions and an authorised concession.

Filed in French · English published by the European Commission

Social enterprises active in reuse, repair, and recycling are key partners for contracting authorities as they contribute to local and socially inclusive green employment through their circular economy waste management activities. Reusing can carry a high job creation potential, higher than recycling, and significantly lowers the environmental impact of items.

Incorporating non-price criteria in public procurement can stimulate demand for low-carbon and circular products from parts of the EU chemical industry by incentivising downstream companies to use these materials in their final products when participating in tenders. Cefics feedback outlines the sectors perspective.

For strong municipalities! The Bavarian municipal umbrella associations make concrete proposals to reduce unnecessary red tape and strengthen the performance of municipal tasks. Municipalities invest in local social cohesion. This is about basics, such as kindergartens, schools and sports halls, and therefore municipal infrastructure that directly benefits local people.

Filed in German · English published by the European Commission

As a member of the GPA, the European Union has fully opened its public markets to competition from the GPA partner countries. However, some of these countries joined the GPA by including restrictive clauses for certain sectors considered strategic.

Filed in Czech · English published by the European Commission

The drafting of tenders is becoming increasingly complex due to increasingly complex legislation. For tenderers, this also applies to the preparation and submission of tenders. This is an important reason why there is a decrease in the level of competition. Here are a number of examples and recommendations that could simplify the work of procurers and bidders.

Filed in Dutch · English published by the European Commission

Under the current legal framework, the award of contracts in connection with ESF procedures is time-consuming and complex. It is therefore proposed, on the one hand, to allow for accelerated and simplified procurement procedures for European Social Fund projects and, on the other hand, to facilitate the participation of small and medium-sized enterprises (SMEs) in procurement procedures.

Filed in German · English published by the European Commission