Revision of EU rules on public procurement

Back Market is a French unicorn scale-up and the leading online marketplace for refurbished electronics, operating across 13 EU countries. With over 3 billion in revenue in 2025, it has become a circular economy leader aligned with Europe's environmental and competitiveness goals.

The feedback from the Directorate for Competition and the Advocacy Department of Spanish National Commission on Markets and Competition (CNMC) to the review of the EU Public Procurement Directives is based on a clear diagnosis: competition in EU public procurement has declined in recent years.

ClientEarth calls on the Commission to seize the opportunity presented by the revision of the Public Procurement Directives to reinforce strategic public procurement as a means of better aligning and bridging the EUs competitiveness and sustainability objectives. To achieve this, ClientEarth has the following suggestions for a revision of the Public Procurement Directives. 1.

In order to strengthen its competitiveness and sovereignty, the European Union must direct public procurement as much as possible towards supporting innovation. Public procurement should be understood as a “lead market” for innovative solutions. By acting as the first buyer, the public sector allows an industrialist to validate its innovative solution.

Filed in French · English published by the European Commission

CSL is a global biopharma company with a dynamic portfolio of lifesaving medicines, including those that treat hemophilia and other hematological conditions, immune deficiencies, vaccines to prevent influenza, and therapies in iron deficiency and nephrology. CSL welcomes the opportunity to contribute to this consultation.

Position of the Market Neutrality Research Forum (MNRF) on the revision of EU public procurement directives Market Neutrality Research Forum (MNRF) is an independent, interdisciplinary research platform focusing on competitive neutrality, the architecture of regulated markets and the impact of public law instruments on competition in the Single Market.

The Horizon Europe project CLEVERFOOD has contributed to several policy briefs and played a central role in the Danish EU Presidency Conference on Transformative Governance for Food Systems and Biodiversity, confirming the importance of public procurement of food as a practical driver of a more sustainable, competitive and resilient Europe.

The Bouygues Group welcomes this opportunity to contribute to the revision of the EU public procurement directives. As a major actor in building, transport, energy infrastructure and multitechnical services, public procurement is central to our activities.

Pure Storage welcomes the European Commissions initiative to revise the EU public procurement framework and supports the objective of strengthening procurement as a tool for strategic investment. As data centres become increasingly critical to Europes digital economy, public services, and AI ambitions, procurement policy has a clear role to play in aligning growth in digital capacity with sustainability…

Hydro is the largest European aluminium producer and a leading recycler operating in 18 EU countries. With a fully integrated value chain, Hydro supplies certified low-carbon and recycled aluminium with full traceability, helping advance Europes climate, circularity, social, and industrial ambitions.

CEWEP is the European umbrella association representing operators of Waste-to-Energy (WtE) facilities across Europe. Its members provide essential services by treating non-recyclable waste in a safe manner, recovering energy in the form of electricity, heat and steam, and enabling the recovery of secondary raw materials, including metals and mineral fractions from incinerator bottom ash (IBA).

Summary of Input for the Revision of Directives 2014/24/EU and 2014/25/EU Based on 20 years of experience in high-value utility procurement, Bantorget Upphandling AB identifies a critical gap between the Commissions evaluation (SWD(2025) 332) and the operational reality.

In the last 10 years some cities and public authorities have tried to promote sustainable public procurement through public tenders that are 'tax haven free' and declared tax free cities (like the city of Barcelona https://ajuntament.barcelona.cat/contractaciopublica/en/sustainable-procurement/ethical-purchasing ) That has been problematic as there is no mandatory or real clarity at EU level.

EU Public Procurement should reward products that combine verified sustainability performance with a high share of EU-produced and EU-recycled content. Defining Made in Europe with a clear focus on product composition is essential to reflect industrial reality, support circular investments and reinforce Europes strategic autonomy.

The U.S. Chamber of Commerce (the Chamber) welcomes the opportunity to respond to the European Commissions Call for Evidence on the future of EU public procurement policy, including proposals related to European preference and resilience criteria. The U.S.

E-REDES considers that there is room for improvement of these Directives so as to simplify and further harmonize their implementation across the EU, remove existing barriers in the procurement procedures and ensure coherence between general and sectoral rules, namely by: A. Simplifying existing public procurement procedures; B. Revising upwards the value thresholds in Article 15, Directive 2014/25/EU; C.

As an international construction and engineering contractor, which is active in large-scale infrastructure and building projects, including transport infrastructure, energy facilities and complex public works, Kolin İnşaat Turizm Sanayi ve Ticaret A.Ş.

ENSIE represents Work Integration Social Enterprises that combine economic activity with social impact, creating employment opportunities for disadvantaged individuals. ENSIE and WISEs welcomed the opportunities offered by the social considerations linked to employment and the reserved contracts of article 20 but unfortunately delays and insufficient implementation of the Directive in the national laws did not lead…

Award criteria should remain the responsibility of contracting entities. Well designed specifications combined with the lowest-price award criterion can deliver excellent public transport services. Made in EU and other policy objectives should remain voluntary and locally determined. Bus manufacturers could not reliably meet mandatory Made in EU requirements. Smaller countries and buyers would face market failures.

Aena, as manager of critical air transport infrastructures in Europe, welcomes the European Commission's initiative to revise Directives 2014/23/EU, 2014/24/EU and 2014/25/EU. This reform represents a key opportunity to modernise the regulatory framework, simplify procedures and strengthen public procurement as a strategic instrument for European sustainability, resilience and competitiveness.

EU demand-side mechanisms for circular textiles remain underdeveloped. Accounting for approximately 14% of EU GDP1, Public procurement is a powerful yet underused lever to create predictable demand for circular textiles.

Public procurement remains an underutilised strategic policy instrument in the EU, particularly in its capacity to support social enterprises, impact-driven enterprises and innovative startups. As highlighted in Impact Europes contribution to the Commissions evaluation of the Public Procurement Directives in March 2025, these actors continue to face structural barriers to accessing procurement opportunities…

EURATEX welcomes the opportunity to contribute to the Commission consultation on revising the Public Procurement Directives. We strongly support the priorities of simplifying procedures, facilitating SMEs participation in tenders, strengthening green, social, and innovation criteria, and introducing European preferences for strategic sectors, which incentivise EU-based, reliable value chains from fibre to finished…

UNISTOCK Europe is the trade association representing companies whose activity is the handling and storage of agricultural raw materials and ingredients in a large number of ports across the EU. UNISTOCK supports the Commissions ambition to review EU public procurement rules in view of simplifying them, providing greater flexibility, reducing administrative burdens and improving the EUs economic security.

The European Wood Preservative Manufacturers Group (EWPM) and the European Wood Protection Association (EWPA), acting jointly as the Treated Wood for Decarbonisation taskforce, welcome the European Commissions initiative to revise the EU public procurement rules.

ACEA is the voice of the European auto industry representing 17 major car, truck, van and bus makers. ACEA welcomes the Commissions aim to use public procurement to accelerate decarbonisation and strengthen industrial resilience. Our submission addresses the potential use of made in the EU requirements for the heavy duty vehicle segment.

Please find attached Sanofi response to the European Commission Public Consultation on Public Procurement Rules Revision About Sanofi Sanofi is an R&D driven, AI-powered biopharma company committed to improving peoples lives and delivering compelling growth.

Representing over 350,000 members of the Publishing, Printing and Packaging Industry in Europe, through over 40 affiliated graphical national trade unions, UNI Europa Graphical and Packaging also represents unions in the security printing sector, particularly touched by public procurement.

Textile Exchange is a global non-profit driving beneficial outcomes for climate and nature across the fashion, textile, and apparel industry. We guide a growing community of brands, manufacturers, and farmers towards more purposeful production from the very start of the supply chain.

Pointless combination of absolute and relative references in the case of contract modifications Article 72 of DIRECTIVE 2014/24/EU Smaller contract modifications during the term of the contract are referred to in Article 72 (national Germany: § 132 GWB) combines the following (de minimis clause): Paragraph (2) – absolute size (thresholds, (2)i) and – relative size (percentages: 10/15/20 %) This is an unsuitable…

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As one of the largest disability service providers and one of the largest non-governmental employers of people with disabilities in Ireland, Rehab welcomes the opportunity to contribute to the Commissions review of the Procurement Directive 2014/24/EU.

Directive 2014/24/EU of 26.2.2014 on public procurement (Dir 24) Directive 2014/25/EU of 26.2.2014 on procurement by entities operating in the water, energy, transport and postal services sectors (Dir 25) The comments of the Association of European Border Regions (AEBR) representing (cross-) border regions all over Europe in this submission are made in the context of broader organisational perspective on the context…

Below is the summary in English of the feedback prepared by the Public Procurement Law Association. The original feedback is written in Polish and attached. 1. Principle of Proportionality (Article 18 of Directive 2014/24/EU) Current regulations are too vague to counter the culture of legalism, particularly in Central and Eastern Europe.

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OpenForum Europe (OFE) welcomes the opportunity to contribute to the European Commissions public consultation on the revision of the EU Public Procurement rules. OFE has long engaged with European digital, competition, and innovation policy, with a particular focus on the role of open technologies in shaping resilient, competitive, and sovereign digital markets.

Linklaters welcomes the opportunity to comment as part of this consultation. We recognise the EC's efforts to evaluate the effective functioning of the Directives and we welcome reform which simplifies and modernises current public procurement regimes, strengthens EU competitiveness, and drives social, economic and environmental value and innovation.

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) committed to the development of the Social and Solidarity Economy (SSE) on their territory.

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The Programme for the Endorsement of Forest Certification (PEFC International) welcomes the opportunity to participate in the ECs revision of the EU public procurement rules. Public procurement is a key instrument for delivering the Unions environmental, climate and bioeconomy objectives.

Pharma Deutschland represents the interests of the pharmaceutical industry of Germany with around 400 member companies - in including international corporations as well as small and medium-sized enterprises (SMEs) and mid-sized companies.

The Responsible Contracting Project (RCP) welcomes the revision of the EU Public Procurement Directive. This submission sets out a short, targeted set of recommendations to improve legal clarity and operational effectiveness in the Directive, with a specific focus on equipping public buyers to use contracts as a key mechanism for supporting proportionate, risk-based human rights and environmental due diligence…

Please find enclosed the position of the Polish Chamber of the Utility Industry on the revision of the public procurement directives. Our position focuses on issues relevant for SMEs, which are also important for other participants in the public procurement market.

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Aricoma understands the Commissions rationale for Made in Europe approach. Nevertheless, Aricoma emphasises that competitive procurement procedures serve the interest of Member States and their citizens by delivering optimal solutions at most favourable financial terms, and that excluding enterprises with substantial EU operations but with ownership structures in EEA and EFTA countries undermines these objectives…

ZEROs input on public procurement rules revision ZERO strongly supports the use of strategic public procurement as a central policy instrument in the revision of the EU Public Procurement Directives. Public procurement is not only a mechanism for purchasing goods and services, but a powerful tool to deliver broader policy objectives, including climate mitigation, improved air quality and industrial innovation.

Opinion on the revision of the EU public procurement directives Directives 2014/23/EU, 2014/24/EU and 2014/25/EU Focus on sustainable public procurement using established EPD/PCF systems Divergent opinion of the German EAF producer, Max Aicher, on the position of Wirtschaftsvereinigung Stahl on the revision of the EU public procurement directives Max Aicher Stahl AG expressly supports the objective of the revision…

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Please find enclosed the proposal submitted by the Croatian Employers Association Pharmaceutical Wholesalers Coordination, aimed at establishing a more effective, transparent and clearly defined framework for the implementation of public procurement at national level.

Siemens Healthineers welcomes the European Commissions call for evidence on the EU public procurement rules which are key to our ecosystem. In order to secure the healthcare sector competitiveness and foster innovation, we have identified crucial points which we believe should be considered: Moving towards value-based procurement with value criteria being the most prominent aspect of the tenders rather than a…

We are a team of researchers (Emma Kallina, Anna Ida Hudig, Jatinder Singh) that investigate how the potential public procurement as an AI governance mechanism can be realised, i.e. how we can ensure that public sector AI is in line with public interests. Our foundational study has been accepted at the ACM CHI conference on Human Factors in Computing Systems 2026 and will be published in April.

Given the growing political and regulatory focus on encouraging the demand of EU made products in public spending and procurement, Tyres Europe intends to provide additional input to the questionnaire of the public consultation on the upcoming revision of the public procurement directive.

1. Food as a strategic sector in public procurement As recognised in the INI Report 2024/2103 (§61), food is a strategic sector for EU security and prosperity. President Ursula von der Leyen has affirmed that food and farming are the backbone of the European Union. Food is not a commodity like any other, but a fundamental human right that the EU must guarantee.

The Offshore Wind Foundations Alliance (OWFA) strongly supports the Commissions intention to use public procurement more strategically for sustainability, resilience and Made in Europe objectives. In our sector, however, the absence of coherent and enforceable procurement rules risks undermining the EUs wider policy framework, including the NetZero Industry Act (NZIA), the Clean Industrial Deal, trade defence…

The VYV Group supports the integration of a European preference in insurance procurement, in order to strengthen the economic sovereignty, resilience and social cohesion of the European Union. As a mutual and social and solidarity economy (SSE) actor, specialising in risk management and social protection, we affirm the strategic role of public procurement, which accounts for almost 14 % of EU GDP, and the need to…

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ANIVEC National Association of the Clothing, Confection and Fashion Industries welcomes the European Commission’s initiative to subject the Public Procurement Directives to a process of evaluation and thorough revision.

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The EU public procurement framework establishes a common basis for the award of public contracts. From the perspective of a large international infrastructure developer, there is nevertheless room for improvement, particularly regarding procedural simplification, administrative burden and flexibility in complex and long-term projects such as PPPs and concessions.

Bellona welcomes the revision of the EU Public Procurement Directives as a unique opportunity to transform public procurement into a strategic tool for achieving EU climate, circular economy, and industrial objectives.

VinylPlus is the European PVC (Polyvinyl Chloride) value chains voluntary commitment to sustainable development, gathering primary production, transformation and recycling companies. VinylPlus believes that the revision of the EU Public Procurement directives is an opportunity to align procurement with EU priorities and recommends that their includes in particular those changes necessary to: 1.

Eurelectric welcomes the opportunity to respond to the consultation and supports the objective of simplification. The electricity sector acts both as contracting entities (e.g. grids, publicly owned power producers) and as bidders for renewables for public entities. Assessment: For grid operators, procurement delays the speed of modernisation and expansion.

Eurogypsum, representing the European manufacturers of gypsum-based construction products, welcomes the European Commissions initiative to revise the EU Public Procurement Directives. Public procurement is one of the most powerful instruments available to public authorities to steer markets toward strategic societal, industrial, and environmental objectives.

EU public procurement rules should reflect the realities of modern software markets, where open source software underpins a large share of digital infrastructure and functions as long-term public infrastructure rather than a one-time product purchase. Procurement policy is a key lever for reducing vendor lock-in, increasing interoperability, and strengthening Europes control over its digital infrastructure.

Since 2022, the City of Paris has been implementing its third Sustainable Food Plan, with a target of 100 % sustainable food in collective catering by 2027, including 75 % organic products and 50 % local food, produced and processed within a radius of 250 km. With 28.5 million meals served each year in 1300 municipal establishments, the Parisian mass catering service is a major lever for transforming food systems.

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Summary: The Public Procurement Directive is strategic to achieve key EU Objectives such as industrial autonomy (Clean Industrial Deal), as well as a competitive, fair, and sustainable economy. At the same time, it must be accessible to SMEs and social economy entities - including representative bodies. Here are three key recommendations that makes this possible: 1.

As the voice of Cooperatives enterprises in the EU, Cooperatives Europe supports the current revision of the Public Procurement Directives. In view of Europes new competitiveness and strategic autonomy priorities, we advocate for a review of the rules that ensures EU added value while promoting level playing field for small and medium cooperatives.

The revision of the EU public procurement framework represents an important opportunity to further develop procurement practices that support the green transition, industrial competitiveness and economic resilience, while ensuring value for money.

On behalf of the Conseil National du Logiciel Libre (CNLL), which represents the open digital business sector in France, we support the revision of European public procurement rules and call for the immediate adoption of strong measures to ensure the Union’s digital sovereignty.

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The upcoming revision of the EU Public Procurement Act comes at a critical moment for the European energy transition. While the existing Innovation Guidancefrom the Commissionprovides agood first step towardthe public procurement of innovation,a significant gapremainsbetween policy intent and the system operators' reality.As regulated entities responsible for critical infrastructure, system operators are bound by…

North Sea Port welcomes the initiative of the European Commission to review the public procurement directives. This review should reflect the significant pressure on our European competitiveness and deliver on the simplification agenda of the Commission.

This comment recommends that the EU look into incentivising the growing role of the biomanufacturing industry under the EU public procurement rules. This is particularly crucial to incentivise the development of the biobased and biogenic products in the EU and provide a strong market incentive for biomanufacturing investment in the EU.

Please find enclosed our contribution, reflecting the perspective of a business entity and outlining proposals aimed at promoting a more effective, transparent and clearly defined framework for the implementation of public procurement at the national level.

Contribution from FFC Solutrans The Fédération Française de Carrosserie (FFC) Solutrans would like to thank the European Commission for the invitation to contribute to the consultation on public procurement reform. This soft and dialogue approach is essential to ensure that future European orientations respond to the industrial, operational and societal realities faced by Member States and public buyers.

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The revision of the Public Procurement Directives provides a timely opportunity to implement and make mandatory the EU Green Public Procurement (GPP) criteria identified by the Commission, which are currently voluntary.

The GÉANT Association welcomes the European Commission initiative to revise EU Public Procurement rules. Our full Consultation Response is in the attached file. The EU Public Procurement directive should be updated to ensure effective, proportionate, and efficient procurement processes and assume more mature and professional EU contracting authorities who can guarantee legal procurement as a profession and apply…

Lenovo welcomes the European Commissions initiative to evaluate the EU public procurement framework. We support the objective of strengthening European competitiveness and ensuring supply chain resilience. However, based on our experience across the Single Market and available economic modelling, we urge the Commission to reconsider the introduction of horizontal "European Preference" criteria.

Wärtsilä is a global leader in technologies and services that advance the decarbonisation of the marine and energy sectors. With approximately 6.5billion in sales and 18,300 employees in 77 countries, our strategy focuses on helping customers continuously improve both environmental and economic performance. We participate in public procurements across the EU in both energy and marine segments.

In response to the European Commissions call for public consultation on the revision of the EU public procurement rules, this statement sets out Climate Leadership Coalitions (CLC) position on the proposed initiative to revise the public procurement directives, aiming to give preference to European products in public procurement, and to modernise and simplify procurement rules.

BSA supports the EUs ambition to strengthen resilience, security, and performance in public procurement. To meet these objectives, procurement rules must remain open, risk-based, and grounded in internationally recognized standards.

Although the feedback is deepened in the file attached below, we particularly believe that the revision process of the directives should address the following priority issues: 1. A More Economically Advantageous Tender (MEAT) 2.

Associazione Italiana Internet Provider (AIIP) is the oldest and largest association of ICT operators in Italy, representing for over 30 years more than 60 Italian SME operators. These members have been, and continue to be, committed to building an open, distributed, and independent telecom network, including through the establishment of colocation data centres and the provision and/or use of these centres to offer…

CESI welcomes the European Commissions decision to revise the EU Public Procurement Directives 2014/23/EU, 2014/24/EU and 2014/25/EU. With public authorities spending over EUR 2.6 trillion annually around 15% of EU GDP public procurement is one of the EUs most powerful policy tools to shape economic development, support strategic autonomy and deliver tangible social progress for workers .

Please find enclosed the contribution from the public consultation on the revision of the Public Procurement Directives. Yours sincerely, Luciano Gallo, Contact Person for Public Contracts and Social Innovation, Third Sector Law of ANCI Emilia-Romagna

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FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the revision of the public procurement directives in the EU. With the aim of improving competition and the circular economy, we present a number of critical remarks on the functioning of public procurement in the waste management market.

Future Cleantech Architects (FCA) welcomes the opportunity to contribute to the consultation on the revision of the Public Procurement Directives. FCA is an independent, science-based, climate innovation think tank accelerating industrial decarbonization by closing cleantech innovation gaps in energy-intensive sectors. Please see attached our detailed consultation response.

In PGE's opinion, the following issues should be considered: THE EXEMPTION FOR THE ENERGY SECTOR The progress of the liberalization of energy markets, the unbundling of network operations from generation and supply, the introduction of market-based mechanisms enabling non-restricted choice of contractors, has led to a significant increase in the level of competition on the energy sector in the recent years.

Ladies and gentlemen, thank you for the opportunity to submit our comments via the EU consultation procedure on the public procurement directives. Please find our feedback attached. Yours sincerely, Flughafen Dresden GmbH

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The NGI Commons consortium welcomes the opportunity to comment on the revision of the public procurement directives, particularly given evolving geopolitical risks and technological concentration. Digital sovereignty is high on the EU's political agenda. The draft MFF proposal and European Competitiveness Fund make several references to digital autonomy.

Ladies and gentlemen, thank you for the opportunity to submit our comments via the EU consultation procedure on the public procurement directives. Please find our feedback attached. (Complimentary close) Leipzig/Halle Airport GmbH

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Please find enclosed our contribution, reflecting the perspective of a business entity and outlining proposals aimed at promoting a more effective, transparent and clearly defined framework for the implementation of public procurement at the national level.

Social Platform is the leading civil society network advocating for social justice, gathering 41 organisations to raise the voices of thousands of local and national NGOs, not-for-profit social services, and social economy actors (cooperatives, social enterprises, Work Integrations Social Enterprises).

Syensqo supports of the initiative to revise the Public Procurement Directives (Directives 2014/23/EU, 2014/24/EU and 20214/25/EU), and of the ongoing efforts by the Commission to review its industrial and trade policy tools to provide greater economic and supply chain security for European companies.

SAP welcomes the European Commissions review of the EU Public Procurement Directives as a key opportunity to enhance Europes competitiveness, accelerate digital transformation, and strengthen technological resilience. Public procurement, representing around 14% of EU GDP, is a powerful policy lever that directly shapes Europes digital public sector, industrial capacity, and AI adoption.

Enedis, the electricity distribution system operator in France, is a major contracting entity with an annual procurement volume of approximately EUR 6.3 billion, 97 % of which is sourced in Europe from more than 3 000 suppliers and service providers, around half of whom are micro, small and medium-sized enterprises. As an operator of critical infrastructure, Enedis contributes to European industrial value chains.

Public procurement represents a powerful yet underutilised tool in the EUs transition towards a climate-neutral, circular economy. Accounting for approximately 14% of the EU GDP - over 2.4 trillion annually, public procurement holds significant potential to influence market demand, shift production patterns, and accelerate the uptake of recycled materials and circular products, thereby contributing to the EUs…

Teva is a strategic partner of EU healthcare systems, producing 96% of its European generic, biosimilar and innovative portfolio in plants across 13 European countries. In 2024, Teva saved healthcare systems over 2.9billion and supported more than 100,000 jobs. A significant share of our portfolio, especially offpatent medicines, is procured through public tenders.

* Currently, contracting authorities have to spend a disproportionate amount of time in cross-border procurements to check the tax, social security and legal background of bidders registered in different Member States. There is no single system where the necessary checks can be carried out easily, securely and quickly.

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First of all, we would like to thank you for opening this consultation. Demand for local food products is growing sharply, driven by consumer expectations, economic actors and public authorities. Although not formally defined, local products contribute to strengthening the link between producers and territories and to structuring local and resilient sectors.

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The Confederation of European Security Services (CoESS) and UNI Europa, EU Sectoral Social Partners in private security services, strongly welcome the revision of the EU Public Procurement Directive 2014/24. We have therefore come forward with a joint statement on the revision process, which is further supported by a joint statement of sectoral Social Partners in the private security, contract catering, cleaning and…

To Whom It May Concern, Following the open call for contributions, we hereby submit our proposals for the revision of the procurement directives based on our experience both as a contractor and in representing contracting authorities in public procurement. Please find below a summary of our proposals; detailed reasoning for each point is provided in the annex.

* Article 41 provides that the prior involvement of tenderers in the preparation of the procurement must not distort competition. Although the principle is understandable, it remains unclear which participation is actually considered problematic and what are the objective criteria for assessing whether there is a potential distortion of competition.

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The contribution reflects anonymised input from manufacturers active in municipal equipment, cleaning machines, and vehicle wash systems. It addresses key aspects of the consultation, including sustainability and environmental criteria, Total Cost of Ownership (TCO), award criteria and innovation, digital procurement and transparency, cybersecurity alignment with EU digital legislation, and the need for greater EU…

As a contracting entity that is confronted on a daily basis with the implementation of Directive 2014/25/EU and Directive 2014/23/EU, the EDF Group welcomes the revision and simplification announced by the European Commission.

* The current Article 72 of Directive 2014/24 remains too rigid and unclear, which complicates its practical implementation and leads to legal uncertainty. A provision which makes it possible to lay down the grounds for amendments in a contract is particularly problematic, but requires them to be clear, precise and unambiguous.

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The German Bar Association (DAV) welcomes the revision of the EU Public Procurement Directives and, in this context, advocates a simplification of public procurement law as well as a strengthening of the procurement autonomy of contracting authorities. Furthermore, the DAV supports the introduction of a standardised access system to digital procurement platforms.

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* The definition of innovation in Article 2(22) of Directive 2014/24 as it stands is too broad and can be interpreted in a way that also makes it possible to consider as innovation materially insignificant changes, such as the mere purchase of an existing product or service in a different way. This could lead to procurement being mistakenly referred to as innovation procurement without real novelty or added value.

Filed in Estonian · English published by the European Commission

The revision of the EU public procurement framework is an opportunity to modernise the rules - a necessary step for EU public procurement to support Europes green, social and innovation objectives, while delivering better value for money, stronger transparency, and greater economic resilience.

The European Rental Association (ERA) welcomes the opportunity to provide feedback on the EU public procurement rules revision. ERA is calling the European Commission to formally recognise the equipment rental within revised EU Public Procurement rules to better support circular economy objectives.

I. Need for Broad Demand-Creation Policies By leveraging their purchasing power, governments and public institutions can create and support demand for circular and low-carbon materials. Such a contribution to a steady and minimum demand for more sustainable products would not only support the transition of European industries but also foster innovation and economic growth.

Executive summary of Solar Heat Europe's contribution: Public procurement should ensure a level-playing field for all solar technologies. First, when a public building is looking for solarisation, the solar thermal, PVT and PV technologies should all be considered on an equal footing.

1. For contracting authorities, make the procedure with negotiation the procedure in principle for contracts awarded in accordance with a formalised procedure, without any prior condition for review, in the same way as the system already applicable to contracting entities provided for in Directive 2014/25/EU. 2.

Filed in French · English published by the European Commission

We welcome the opportunity to contribute to the European Commissions public consultation on the revision of the EU Public Procurement Directives. As part of the Clean Industrial Deal, this revision represents a key opportunity to accelerate sustainability, circularity, and decarbonisation across emission-intensive sectors, notably steel, buildings and infrastructure.

In the territory of Nantes Métropole, the current arrangements for public procurement constitute a structural obstacle to local producers’ direct access to the mass catering markets. The large volumes, the generalisation of framework agreements, the pooling of production tools and the requirements of legal certainty make it increasingly difficult to conclude direct contracts with local producers, despite a strong…

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Public food procurement should be recognised as a strategic policy tool to advance public health, sustainability and climate objectives. Evidence from across Europe, including lessons learned from EU-funded initiatives such as Joint Action Best-ReMaP and JAPreventNCD, shows that procurement decisions shape food environments, dietary patterns and long-term health outcomes, particularly for children, older people and…

Municipalities have generally relegated public catering service to a cost factor to be included in the budget. It is part of the much bigger paradox of food treated as a mere commodity, produced to be sold rather than eaten, and fundamentally ignoring its deep social, cultural, and environmental dimensions.

Municipal Waste Europe aisbl (MWE) is the voice of European public responsibility for municipal waste management. Our members are municipalities and public waste management companies that play a crucial role in providing this Service of General Interest and in delivering a circular economy in Europe.

Please find attached the key recommendations elaborated by Social Services Europe, of which the European Platform for Rehabilitation is a member. Under the current public procurement regime, non-profit social service providers have successfully participated in public tenders falling within the scope of Directive 2014/24/EU on Public Procurement (PPD).

Abstract and key messages from the Danish PTAs: The President of the European Commission has announced, that the intention with the revision of the public procurement directives is to enable preference to be given to European products in public procurement for certain strategic sectors and to modernise and simplify procurement rules.

EUREFAS, the European Refurbishment Association, welcomes the European Commissions initiative to revise the current public procurement framework. We believe that public procurement must evolve from a simple administrative task into a powerful lever for industrial sovereignty and circular resilience.

As Filiera Italia, we welcome the request for contributions regarding the forthcoming revision of the Public Procurement Code, which we believe could be strategic for the agri-food sector and for the health of citizens, with priority being given to mass catering. Please find our contribution attached.

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The Association of the French Chamber of Commerce, Industry and Agriculture in Romania CCIFER wishes to make the following recommendations for the revision of the public procurement directives in order to ensure a level playing field between EU and third-country tenders, namely: 1.

Filed in Romanian · English published by the European Commission

As Coldiretti, we welcome the call for contributions regarding the forthcoming revision of the Public Procurement Code, which we believe could be strategic for the agri-food sector and for the health of citizens, with priority being given to mass catering. Please find attached the document with our contribution.

Filed in Italian · English published by the European Commission

Strengthening EU Public Procurement to Prioritise Sustainable and Biomass-Derived Products Governments and public institutions can use their significant purchasing power to drive demand for circular and low-carbon materials, including biomass-based chemicals.

The International Federation for the Economy for the Common Good (ECOnGOOD) welcomes the European Commissions Have Your Say consultation on revising EU public procurement rules and submits its position paper, Public Procurement as a Lever for a Resilient, Sustainable and Secure European Economy. Public procurement is one of the most powerful yet underused policy tools to accelerate this transformation.

IRU, representing the commercial road transport industry, strongly supports a more efficient and fair procurement framework that ensures open competition, enhanced quality, and sustainable contracts. Road transport companies are involved in delivering a range of public services, including public transport, school bus operations and (medical) care transport, among others.

The Global Electronics Council (GEC) welcomes the opportunity to provide input regarding revision of the EU Public Procurement Directives and fully supports the Commissions intention to modernise and simplify procurement rules to more closely align with the EUs strategic priorities.

The Confederation of Small and Medium-sized Enterprises strongly supports the idea of facilitating the access of VSEs/SMEs to public procurement, but considers that the current legal framework already has some mechanisms in place to achieve this effectively. The real problem lies less in the absence of devices than in their under-use, as well as in the practical obstacles encountered in their implementation.

Filed in French · English published by the European Commission

Subject: Consultation on the amendment of EU public procurement rules (Directives 2014/23/EU, 2014/24/EU, 2014/25/EU) Dear Sirs, Acting on behalf of the Polish Chamber of Waste Management (PIGO), we hereby submit our position as part of the evaluation of the EU public procurement directives.

Please find attached the statement of Fairtrade Deutschland to the call for evidence for the review of the EU public procurement rules. Fairtrade is one of the best-known sustainability labels in the world and aims to create fairer conditions for those people who grow our food and other raw materials in countries of the Global South.

As a European transport hub and a highly interconnected trading venue, the FrankfurtRheinMain metropolitan area particularly benefits from the European single market. The European office of the FrankfurtRheinMain metropolitan region (European office) is therefore strongly in favour of strengthening and developing the European single market.

Filed in German · English published by the European Commission

Please find attached - the key recommandations elaborated as part of the position paper of the URBAN AGENDA PARTNERSHIP, of which Nantes Metropole is a member of. - the position paper developped by the working group oon public procurement from Eurocities, in which Nantes Métropole takes actively parts. Below, you will find further example of public procurement impat on public policies and circular economy.

We welcome the Commissions initiative to revise the EU public procurement framework with the objectives of simplifying procedures, improving coherence and legal clarity, strengthening governance and data, and enabling procurement to support strategic EU policy priorities better.

Concerning: Consultation on the revision of EU public procurement rules (Directives 2014/23/EU, 2014/24/EU, 2014/25/EU) Honourable Members, acting on behalf of the Polish Chamber of Waste Management (PIGO), we would like to present our position in the evaluation process of the procurement directives.

Filed in Polish · English published by the European Commission

Zentiva is a major European pharmaceutical manufacturer with production sites in Prague (Czech Republic) and Bucharest (Romania), delivering essential medicines to more than 100 million patients across Europe each year. As a company focused on affordable, off-patent and critical medicines, we are committed to strengthening Europes health security and supply chain resilience.

Public procurement is one of the European Unions largest and most powerful economic instruments. When designed and implemented well, it can accelerate innovation, strengthen competitiveness and support the scaling of new solutions across the Single Market. When it is not, it becomes a structural barrier that limits competition and entrenches incumbency.

FEDENE is the French representative federation for energy efficiency services and heat decarbonization, covering the entire value chain, a sector that brings together over 1,500 businesses and 50,000 employees in France. Please find attached FEDENE's contribution to the consultation.

Glass for Europe, the trade association of the flat glass sector, supports a review of the public procurement directives to improve their effectiveness in supporting the sustainability goals, as well as contribute to the EU's resilience and energy security ambitions. Glass for Europe supports the following principles.

The objective of adapting Directives 2014/23/EU, 2014/24/EU and 2014/25/EU should be to allow contracting authorities to design tender conditions in a way that preserves the diversity of suppliers and avoids shortages of supply (in particular pharmaceutical products).

Filed in German · English published by the European Commission

Agricultural cooperation represents more than 2 000 agricultural cooperatives. Public procurement is a major strategic lever, particularly in the food sector. Because of their economic weight, they have a lasting impact on production, supply and consumption patterns. As such, they cannot be seen as mere purchasing tools, but as essential public policy instruments.

Filed in French · English published by the European Commission

Key recommendations: 1) Ensure a coherent legal architecture by preserving the distinction between horizontal and sector-specific rules; 2) Prioritise value-based awarding over lowest-price; 3) Optimise procurement by reducing administrative burden, harmonising rules and strengthening digital architecture; 4) Focus strategic procurement efforts on sectors with the highest societal value (e.g. construction).

Public procurement is a powerful instrument for achieving environmental policy goals. That' s why I would like to draw your attention to the EU Eco-Management and Audit Scheme (EMAS), which has significant potential to support simplification and sustainability in public procurement.

Divergent statement by German EAF manufacturers on the position of the German Steel Association WV Stahl on the revision of the EU Public Procurement Directives Preliminary remark The undersigned companies agree with the basic analysis and objectives of the WV Stahl's statement on the revision of the EU public procurement directives.

EDANA supports the use of public procurement as a strategic tool to encourage the uptake of more sustainable products and materials across the EU internal market. In particular, Green Public Procurement can play an important role in rewarding quality, environmental performance and innovation, notably through the use of quality-based award criteria rather than a sole focus on the lowest price, as it allows…

Fastned welcomes the Commissions revision of the Public Procurement Directives, including Directive 2014/23/EU, to better align procurement and concessions with EU strategic priorities. In the energy and mobility transition, procurement choices can accelerate or hinder the roll-out of essential infrastructure and the development of competitive markets.

Public procurement is a key tool for public authorities to support inclusion of the 20 million people with intellectual disabilities and their families in Europe. Inclusion Europe agrees with the objective of simplifying public procurement. But simplification must never come at the expense of the rights and inclusion of people with intellectual disabilities. 1.

The European Electronic Recyclers Association (EERA) supports the European Commission's initiative to modify the EU's public procurement rules. Public procurement is a key tool for achieving EU goals like environmental sustainability, re-use, the circular economy, innovation, and strategic autonomy.

Efficient Buildings Europe recommends: Limit the lowest-price criterion in favour of the most economically advantageous tender (MEAT), Best-Price Quality Ratio (BPQR), and life cycle costing to guarantee a strategic public procurement. Include all renovation works within the scope of the directives. Include energy efficiency, water efficiency and climate resilience in the award criteria list.

The mission of the Dutch Association for Clinical Physics is to enable the most appropriate medical technology for each patient, now and in the future. Its members, as Subject Matter Experts, are involved in many tenders in the health sector.

Filed in Dutch · English published by the European Commission

Local authorities need a practical set of procurement rules and more flexibility to achieve local objectives. A renewed focus on markets and competition is therefore necessary. For the upcoming revision, the VNG stresses the need to streamline and consolidate public procurement provisions, which are currently scattered over more than 60 EU sectoral legislative acts.

bpost welcomes the Commissions initiative to revise the EU Public Procurement Directive. bpost is leading last-mile postal network for parcels and mail delivery in Belgium and provider of proximity services to the Belgian citizens.

The Global Legal Entity Identifier Foundation (GLEIF) welcomes the European Commissions efforts to revise public procurement rules, with the aim of reducing administrative burdens for both contracting authorities and economic operators while fostering a simpler, more transparent procurement framework.

Innovation in Public procurement is a strong lever for ecological transition and social inclusion. Innovative public procurement, linked to Green PP and social considerations should be facilitated for local authorities, to improve competitiveness of circular economy.

As identified by the Clean Industrial Deal, public procurement is a tool to support EU competitiveness and decarbonisation simultaneously. Furthermore, public procurement is a key lever to boost Europes circular economy, a strategic goal. However, as found by the 2025 evaluation report, its potential is underused.

SOI is a member organization dedicated to promoting the development and efficiency of public procurement. With approximately 1,700 members from national, regional, and municipal levels, SOI works to ensure that public funds are used effectively. SOI welcomes the review of the procurement directives and supports the objective of making the current directives more effective.

ESF Elbe-Stahlwerke Feralpi GmbH welcomes the European Commission’s initiative to revise the EU public procurement framework. We support the objective of making public procurement a tool for strategic investments. With the attached documents, we would like to submit our comments on the draft law.

Filed in German · English published by the European Commission

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.

Hyvil Oy (hereinafter ‘Hyvil’), a welfare region company, thanks the European Commission for the opportunity to contribute to the modernisation of the EU public procurement directives. Hyvil acts as a promoter and guardian of the common interest of the wellbeing services counties, the City of Helsinki’s social, health and rescue services and the HUS Group, and provides expert and advisory services on related issues.

Filed in Finnish · English published by the European Commission

The Spanish Association of Urban Water (DAQUAS) sees the improvement of the public procurement tool as a key enabler for the urban water sector to address the challenges we are currently facing. Urban water operators depend on public procurement for goods and services that are key for ensuring drinking water is provided safely, and wastewater is treated to the highest possible standards.

Nucleareurope, the trade association representing the European nuclear industry, welcomes the European Commissions initiative to revise the EU Public Procurement Rules and appreciates the opportunity to contribute to this consultation, given the strategic importance of the energy sector (and, in particular, nuclear power) in Europes decarbonisation objectives, security of supply, industrial competitiveness and the…

Please find enclosed the full position paper. Summary: A coherent approach to the revision of public procurement legislation is essential. This means simplifying the procedure while avoiding overlapping, vague or disproportionate criteria. Unclear EU rules on scope and coverage lead to risk-averse, box-ticking behaviour and uncertainty.

Outokumpu supports the idea that the revision of the EUs current public procurement rules will allow for sustainability, resilience and European preference criteria in EU public procurement for strategic sectors.

Science Europe (SE) represents 40 major public organisations that fund and/or perform excellent, ground-breaking research in Europe. As bodies governed by public law, the directives on public procurement are of direct relevance to our members operations.

Public procurement represents a major lever for public investment and must be made more efficient through simplification, legal coherence and digitalisation. The current framework remains overly complex, fragmented and burdensome, particularly for local authorities and SMEs, including architectural practices.

Gesamtmetall is the Federation of Employers’ Associations of the Metal and Electrical Industries in Berlin. The metal and electrical industry is Germany’s key sector, employing around 25.600 companies and over 3.9 million people. The M+E industry is thus Germany’s largest industrial employer and a key driver of innovation, investment and competitiveness in Europe.

Filed in German · English published by the European Commission

Please find attached an initial response by DIGITAL SME on the Review of the EU Public Procurement Rules. A full response will be published by DIGITAL SME after further consultations with its members. The European DIGITAL SME Alliance welcomes the revision of EU public procurement rules governing over 600 billion in annual spending.

BioSim, the Spanish Association of Biosimilar Medicines representing companies that research, develop, produce or market biosimilars in Spain, sees this public consultation as an opportunity to make public procurement a strategic instrument and to reflect on how public procurement procedures can contribute to the sustainability of health systems, patient access to medicines and the resilience of the European…

Filed in Spanish · English published by the European Commission

The Computer & Communications Industry Association (CCIA Europe) welcomes the opportunity to contribute to the European Commissions call for evidence regarding the reform of EU public procurement rules. As the European Union accelerates its digital transformation, public procurement serves as a vital strategic lever to enhance the Unions competitiveness, resilience, and innovation.

ETSA, the European Textile Service Association, represents and works on behalf of the textile services industry, which provides laundering and rental services for reusable textile products such as workwear, linen, and uniforms, while also representing textile manufacturers, national associations, machineries and detergents.

EurEau represents Europe's water services sector, bringing together 70,000 public and private drinking water and wastewater service providers across 33 countries. The sector serving more than 550 million citizens and businesses faces a substantial investment gap, estimated at several hundreds of billions of euros across the EU. Public procurement is key for water service operators to bridge this gap.

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…

Relais 2D is a cooperative society located in Strasbourg that promotes sustainable development in sustainable purchasing at the level of the Bas-Rhin department in France. We would like to use this consultation to propose the following recommendations: 1. Incorporate the principle of “sustainable development” as a key principle of the new regulation 2.

Filed in French · English published by the European Commission

ChargeUp Europe welcomes the planned revision of the EU's public procurement rules. Our members collective experience shows that current public procurement and concession practices often slow down deployment, increase administrative burden, and restrict competition in ways that ultimately undermine the quality and availability of public charging for EV drivers.

Reducing Bureaucracy and Enhancing eForms This feedback is based on our experience in the field of public electronic procurement. The public procurement directives serve as the legal foundation for eForms; however, the current technical implementation fails to reflect the need for administrative efficiency.

The European Federation of Premanufactured Building (EFV) welcomes the European Commission's initiative to evaluate Public Procurement rules. Across Europe, the public sector faces a substantial invesment gap, including an annual shortage of approximately 650.000 housing units, as highlighted in the European Affordable Housing Plan and the European Construction Strategy.

The market for large research equipment is highly concentrated in many areas, with few dominant global suppliers (e.g. electron microscopy, MS/NMR spectroscopy). High patent protection and customer loyalty through proprietary software and methodology development further restrict competition.

Filed in German · English published by the European Commission

CO2 Value Europe is the European association representing Carbon Capture and Utilisation (CCU). We fully support the objectives listed in the call for evidence to revise existing EU procurement law to support innovation and social and environmental sustainability and encourage environmentally sustainable procurement practices, contributing to reduced carbon emissions and resource use, aligning with EU environmental…

European Content and Lead Markets for Low-CO2 European Steel: Demand Side Policies for Sustainable Production and Fostering Decarbonisation Investments In the midst of the most profound transformation in history, the European steel industry, and its value chain, is confronted with an existential crisis due to a combination of weak demand, unprecedented import levels resulting from global overcapacity, persistently…

For the Luxembourg Order of Architects and Consulting Engineers (OAI), the future EU public procurement directives should: 1. Simplify rules and procedures (including simplification of thresholds and abolishing differentiation between central public authorities and sub-central contracting authorities); 2. Recognise the specific nature of intellectual services, in particular project design services (e.g.

Filed in French · English published by the European Commission

The Organic Cotton Accelerator (OCA) welcomes the European Commissions initiative to revise the EU public procurement framework and supports its objective to make public procurement a tool for strategic investment. Public procurement can play a pivotal role in advancing the objectives of the European Green Deal, the Clean Industrial Deal, and the Competitiveness Compass.

The considerable resources spent on public procurement across EU member states underlines the importance of aligning public procurement policy with European strategic objectives. Public expenditure on food and food services across the EU has been estimated at approximately 50 billion euros annually, adding up to a significant purchasing power by public institutions.[1] Foods consumed in public canteens, including…

Region Västra Götaland welcomes a development of aligning public procurement policies with strategic EU objectives in the areas of sustainability, social responsibility, and innovation. Public authorities in the EU spend approximately 14% of GDP on procurementaround EUR 1.9 trillion annually.

Contribution from CONFLAVORO PMI Health to the public consultation launched by the European Commission for the revision of the EU Public Procurement Directives 1. Preliminary remark. LASSOCIazione CONFLAVORO PMI Sanità (SME Health) is a body governed by private law that protects the interests of micro, small and medium-sized enterprises active in the medical devices market and, in particular, in supplies to NHS…

Filed in Italian · English published by the European Commission

Preliminary statement: Revision of EU public procurement rules Federation of Finnish Woodworking Industries (Puutuoteteollisuus ry) Federation of Finnish Woodworking Industries (Puutuoteteollisuus ry) is the advocacy organisation for Finlands wood products industry. It represents companies in the sector and promotes the use of wood in construction, industrial applications and exports.

The REMHub -project (Rare Earth and Magnets Hub for a Resilient Europe, coordinated by CLIC Innovation Ltd) welcomes the EUs direction on procurement reform and supports the introduction of Made in EU criteria as a means to reinforce the objectives of the Critical Raw Materials Act (CRMA) and Net-Zero Industry Act (NZIA). Success will depend on a focused and pragmatic approach.

Our municipalities (municipalities, towns, rural districts and districts) are investing heavily in social cohesion at local level. They create and maintain key infrastructure and services as part of municipal services of general interest that directly benefit local people. But for this to happen, the framework conditions must also be right.

Filed in German · English published by the European Commission

ArcelorMittal welcomes the opportunity to contribute to the call for evidence in view of the reform of the EU public procurement rules. We therefore submit our key highlights and proposals in the attached document.

We are convinced that the proposed amendment to EU public procurement rules is an appropriate response to the current economic and geopolitical challenges. Strengthening the EU's autonomy by giving preference to products and services manufactured in Europe can be seen as an important step towards increasing the resilience of the economy and the security of supply chains.

We enclose a SEOPAN document which, in line with the conclusions of the Letta report and the recent Dragui report on the future of competitiveness in Europe, which proposes better regulation, with well-justified impact analyses and the respective consultations with the private sector and social partners, and for their implementation, sets out a broad outline of the essential aspects of amending the Community…

Filed in Spanish · English published by the European Commission

The Physicians Association for Nutrition (PAN) advocates for reforming EU public procurement directives to make food purchasing a strategic public health investment. Currently, procurement practices prioritizing lowest price over nutritional quality contribute to a crisis of 1.8 million preventable deaths annually from non-communicable diseases (NCDs) like cardiovascular disease, cancer, and diabetes, costing…

MSC Submission to the European Commission Public Consultation on the revision of the EU rules on public procurement January 2026 The Marine Stewardship Council (MSC) welcomes the European Commissions initiative to revise the EU public procurement framework with the objectives of (1) increasing the efficiency of public investment through simplification of procedures and (2) better aligning public procurement with EU…

Helsinki Region Transport Authority HSL welcomes the goal of simplifying procurement procedures, reducing the administrative burden on procuring authorities as well as the bidders, and improving the legal clarity and certainty. Unfortunately the proposed changes to European legislation may lead to opposite outcomes.

The European Association for Ductile Iron Pipe Systems (EADIPS®) / Fachgemeinschaft Guss-Rohrsysteme (FGR®) e. V. is a technical and scientific industry association. We represent the interests of our member companies manufacturers of high-quality ductile iron pipe systems (pipes, fittings and fittings) "Made in Europe" and their partners competently, reliably and efficiently.

In its 2023 report on public procurement in the EU, the European Court of Auditors found that the latest reform of European public procurement rules did not lead to increased competition and SME participation in public tenders. Therefore, the planned revision of the EU public procurement directives should not focus solely on a possible reduction in the burden on contracting entities.

Filed in German · English published by the European Commission

The City of Oslo supports the European Commissions ambition to modernise the procurement framework and align it with the Unions objectives on sustainability, social responsibility and the green transition. As one of Norways largest contracting authorities, Oslo uses procurement strategically to reduce emissions, promote responsible business conduct and combat work-related crime.

ARTHUR (Arthurs Legal, Strategies & Systems) is the independent multi- and interdisciplinary global strategic legal advisory and knowledge partner, dedicated to co-create trailblazing, long-lasting partnerships and impact. In that spirit, at ARTHURs we are active since 2001 with advanced, readily available expertise and capabilities.

The Government of Japan appreciates the opportunity to submit its views on the European Commissions Call for Evidence on the revision of the EU Public Procurement Directives (the Initiative), as published on the Commissions Have Your Say portal. With regard to Part 1 of this consultation, Japan does not provide comments at this stage.

Euritas feedback: It is very difficult to set detailed procurement rules in EU-level that are applicable in all countries and sectors. It is also very difficult to implement EU-level digital procurement tools that are better than country level solutions.

RISE, Research Institutes of Sweden AB, is Swedens research institute and innovation partner. In our capacity as a Research and Technology Organisation (RTO), through international collaboration with industry, academia and the public sector we ensure business competitiveness and contribute to a sustainable society.

The German Steel Association welcomes the European Commissions consultation on the revision of the EU Public Procurement Directives. This revision represents a strategic opportunity to transform public procurement from a predominantly price-driven instrument into a value-based policy tool that strengthens Europe’s industrial base, supports strategic autonomy, and accelerates the transition of the steel industry…

Filed in German · English published by the European Commission

Digital (cloud, cybersecurity, data, software and platforms) is a critical infrastructure for public action and the continuity of essential services. In this context, the revision of the EU public procurement directives is a decisive opportunity to translate the EU’s objectives of strategic autonomy, economic security, resilience, competitiveness and data protection into concrete mechanisms.

Filed in French · English published by the European Commission

In the opinion of many authors and economic operators, this revision is now more necessary and appropriate than ever, given that public administrations in the European Union are increasingly using the instrument of concession and public contract, allocating around 14 % of GDP (over EUR 2.400 billion) annually to the acquisition of services, works and supplies.

Filed in Italian · English published by the European Commission

The French ruminant removal sectors are going through a critical phase, marked by a rapid decline in livestock numbers and increasing dependence on imports. This situation weakens food sovereignty, the rural economy and Europe’s environmental objectives.

Filed in French · English published by the European Commission

Please find enclosed the proposal submitted by the Croatian Employers Association Pharmaceutical Wholesalers Coordination, aimed at establishing a more effective, transparent and clearly defined framework for the implementation of public procurement at national level.

The European Sea Ports Organisation (ESPO) welcomes the Commissions objectives for the upcoming revision of the EU public procurement framework, in particular to simplify and modernise the EU rules on public procurement and to pursue an investment strategy that strengthens EU competitiveness, resilience and economic security.

The Fédération Nationale des Transports de Voyageurs (FNTV) thanks the European Commission for opening the public consultation on the revision of the European Union’s legal framework on public procurement, ahead of a legislative proposal expected in 2026. Public procurement is a major strategic lever to support investment, competitiveness, innovation and the sovereignty of the European Union.

Filed in French · English published by the European Commission

Please find enclosed the proposal submitted by the Croatian Employers Association, Pharmaceutical Wholesalers Coordination, Croatian Employers Associatioaimed at establishing a more effective, transparent and clearly defined framework for the implementation of public procurement at national level.

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.

EU public procurement law plays an important role in fostering fair competition, ensuring transparency, and promoting efficiency in the use of public funds. By establishing a harmonized legal framework, it facilitates cross-border market access and enhances value in public sector contracting.

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. Explanation: 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. Explanation: 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…

Modification of contracts during their term. It is proposed to clarify and supplement the regulation set out in the Directives. Explenation: 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.

Baden-Württemberg warmly welcomes the planned reform of EU public procurement law. The objective of the reform must be efficient, low-bureaucratic and legally certain public procurement, which strengthens the capacity of public authorities to act and relieves the burden on businesses and contracting entities. At European level, the key lever for modern procurement law lies in the Member States.

Filed in German · English published by the European Commission

Modification of contracts during their term. It is proposed to clarify and supplement the regulation set out in the Directives. Explanation: 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. Explanation: 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…

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. Explanation: 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.

One of the fundamental pillars of the EU public procurement system is the principle of the Most Economically Advantageous Tender (MEAT). This principle requires that tenders be assessed not solely on price, but on the basis of a combination of criteria, including advantageous pricing, quality, technical capacity, sustainability, life-cycle costs, innovation, and delivery time.

EPEE, the voice of heating and cooling in Europe, representing the refrigeration, air-conditioning and heat pump industry, welcomes the opportunity to provide comments on the consultation on the revision of the public procurement rules. EPEE recommendations: 1.

Threshold amounts. It is proposed to align and increase the threshold amounts set out in the Directives. Explanation: 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. Explanation: 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…

Elimination of differences between the conditions for the use of the negotiated procedure without prior publication laid down in the Directives. Explanation: 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 than those in another sector (public…

An exclusion is proposed for purchases through public platforms, auctions, exchanges (e.g. Nordpool, etc.) and for joining such public platforms. Explanation: 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…

Additional exclusions from the Directives are proposed. Explanation: 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, as the negotiated…

ESMIG welcomes the revision of EU public procurement rules and advocates for a differentiated approach to critical infrastructure tenders. This is essential to strengthen Europe's competitiveness, security, and strategic autonomy.

It is proposed not to restrict (not to limit) the use of the procedure with negotiation. Explanation: Article 26 of Directive 2014/24/EU sets out an exhaustive list of conditions under which procedure with negotiation may be carried out.

The Danish Chamber of Commerce considers that the revision of the EU public procurement directives should focus on strengthening competition, reducing administrative burdens and increasing predictability in public procurement.

Filed in Danish · English published by the European Commission

Iberdrola welcomes the review of the Public Procurement Directives, which offers an opportunity to update the framework to both fulfil its original objectives and align it with the EUs current priorities (e.g., industrial competitiveness). Some of Iberdrolas operating subsidiaries in Spain are DSOs subject to Directive 2014/25/EU.

Almega is Swedens leading employers organization for companies within the service sector. We represent 10 000 companies covering 60 service industries, employing 500,000 individuals. The Swedish private service sector accounts for more than half of Swedens GDP and employs 2,5 million people.The private service sector accounts a third of Swedens exports and generates four out of five new jobs.

VÖWG welcomes the revision of the EU public procurement framework as an opportunity to strengthen practicability, competition and legal certainty. The current system remains overly complex, discouraging participation and leading to reduced bidder numbers, particularly in specialised and critical infrastructure markets.

Smiths Group, a long-established industrial engineering company headquartered in the United Kingdom, and its division John Crane, an engineering leader supplying critical components and services across Europe, welcomes the opportunity to contribute to the European Commission's consultation on the revision of EU public procurement rules.

Diesis Network welcomes the EC initiative to revise the public procurement directive. Public procurement plays a crucial role for social economy enterprises since it can provide stable markets, long-term financial sustainability, and opportunities to scale their impact.

APELL welcomes the revision of public procurement rules and recommends that the Com­mis­sion make use of the framework to shift investments in ICT procurement to Open Source. Only Open Source guarantees independent control over and insight into our digital in­frastructure, including the possibility to modify and adapt it, without being locked in to a single ven­dor. Please find our detailed feedback attached.

Tata Consultancy Services welcomes the Commissions initiative to revise the EU Public Procurement Directive. TCS has a long-standing presence in the European Union and contracts via EU-/based subsidiaries as well as our India-based headquarter, supporting public administrations with secure, privacypreserving digital services.

Tata Consultancy Services welcomes the Commissions initiative to revise the EU Public Procurement Directive. TCS has a long-standing presence in the European Union and contracts via EU-/based subsidiaries as well as our India-based headquarter, supporting public administrations with secure, privacypreserving digital services.

The Global Electronics Association (formerly IPC) welcomes the opportunity to contribute to the revision of the EU public procurement rules through this call for evidence. Public procurement offers a meaningful, strategic instrument for shaping Europes long-term industrial, technological, and security capabilities.

It is proposed to abolish the obligation for the buyer to inform the candidates of the outcome of the procurement. Explanation: 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…

We propose to retain the possibility for Member States to opt out the separate stage for submitting the requests to participate. Explanation: 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.

1. 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. Explanation: The mandatory minimum period to submit the requests to participate (30 days) has become considerably too long with the sophistication and speeding up of information availability and exchange.

SolarPower Europe welcomes the European Commissions initiative to revise the EU public procurement framework, which explicitly covers the three core directives adopted in 2014. Directive 2014/23/EU on the award of concession contracts. Directive 2014/24/EU on public procurement for the public sector.

General public procurement legislation (Directive 2014/24/EU of the European Parliament and of the Council of 26 February 2014 on public procurement and repealing Directive 2004/18/EC (Directive 2014/24)) has proven insufficient for the hospital public purchase of medicinal products, in particular for the purchase of innovative medicinal products subject to exclusive industrial property rights.

Filed in Spanish · English published by the European Commission

From research project FoodCLIC and our experience with the Amsterdam Covenant, we stress the need for a strategic revision of the procurement rules. Food procurement is a crucial lever for system change and the most direct way for public institutions to work towards a healthy, sustainable and equitable food system.

Filed in Dutch · English published by the European Commission

The ONCE Foundation welcomes the European Commission’s initiative to revise EU public procurement rules, recognising their strategic importance for strengthening competitiveness, sustainability and social inclusion across the Single Market.

Filed in Spanish · English published by the European Commission

In line with contributions already submitted by a number of other national competition authorities to the Public Consultation, the Finnish Competition and Consumer Authority wishes to state the following. The FCCA has several years of experience of using statistical screening of tender data, notably the price setting of bidders in public bidding competitions.

From research project FoodCLIC and our experience with the Amsterdam Covenant, we stress the need for a strategic revision of the procurement rules. Food procurement is a crucial lever for system change and the most direct way for public institutions to work towards a healthy, sustainable and equitable food system.

Filed in Dutch · English published by the European Commission

APAG Oleochemicals Europe, a sector group of Cefic, supports a modernised and coherent EU public procurement framework that creates lead markets for sustainable, innovative products and strengthens economic security and contributes towards autonomy while preserving a level playing field across the EU Single Market.

PKEE calls on the European Commission to introduce a sectoral exemption for energysector activities from Directive 2014/25/EU. The energy sector operates today in fully competitive markets, is subject to extensive EU regulation, and plays a central role in delivering the EUs strategic objectives on energy security, decarbonisation and competitiveness.

As the evaluation of the Directives has shown and as this impact assessment shows, the Directives do not appear to have been effective in achieving their objectives. See also the attached input we have provided previously.

Filed in Dutch · English published by the European Commission

A revision of the EU Public Procurement Directive (PPD) presents a critical opportunity to foster a sustainable, competitive, and resilient medicines supply. While the PPD (2014/24/EU) encourages a strategic approach through Most Economically Advantageous Tender (MEAT) criteria and limits reliance on price-only tenders, its adoption in medicines procurement remains limited.

EARTO welcomes the European Commissions initiative to revise the EU Public Procurement Framework, highlighting that public procurement represents over 2.5 trillion annually and can become a strategic tool to strengthen Europes competitiveness and strategic autonomy.

Westenergy Ltd is a circular economy company owned by seven municipal waste management companies operating in Western Finland. Westenergys waste-to-energy plant located in the Vaasa region takes care of the residual waste management of more than 700 000 people by refining non-recyclable municipal waste into district heating, electricity and recovered materials.

The UTPF shares the European Commission’s ambition to revise the framework of the 2014 Directives to achieve the EU’s strategic objectives. The UTPF is the professional organisation representing public urban transport operators (operators of 170 bus, metro and trams networks), rail operators (passengers and freight) and infrastructure and railway station managers in France.

Filed in French · English published by the European Commission

The Japan Business Council in Europe (JBCE) welcomes the opportunity to provide its feedback on the revision of the Public Procurement directives as part of the Call for Evidence launched on 3 November 2025. Indeed, while acknowledging the strategic imperative of the European Union (EU) to secure its own competitiveness and economic security agenda, JBCE has been actively promoting since Spring 2025 a Made with…

This response addresses the revision of EU public procurement directives (2014/24/EU and 2014/25/EU) based on 15 years of research and advisory work across UK and EU public sector digital procurement. The evidence demonstrates that current procurement structures create barriers to achieving best value and strategic objectives, not through explicit prohibition but through frameworks that neither prohibit nor…

The core aim of the revision of the Public Procurement directives should be to reducing the administrative burden by simplifying the current rules. HOPE advocates for clear and simple rules with a reduction in the level of detail and greater reliance upon the general principles of transparency, equal treatment and non-discrimination. 1.