Carbon Footprint Requirement

Carbon footprint requirements in public procurement ask suppliers to measure and disclose the greenhouse gas (GHG) emissions associated with what they are selling to a public body. These requirements can appear at different points in the procurement process and take different forms depending on the contracting authority's ambition and the nature of the contract. As European governments accelerate their net-zero commitments, carbon footprint requirements are moving from innovative practice towards mainstream expectation in high-value public contracts.

What is a Carbon Footprint Requirement?

A carbon footprint requirement sets an obligation on bidders to provide quantified GHG data as part of their tender. The requirement may take several forms:

Disclosure as a selection or award criterion. Bidders are asked to submit a carbon footprint figure for the product, material, or service, calculated to a specified methodology and covering a defined scope (for example, scope 1 and 2 emissions for the supplier's operations, or a cradle-to-gate product carbon footprint for a manufactured good). Bids with a lower carbon footprint score more highly on the environmental award criterion.

Maximum carbon threshold as a technical specification. The buyer sets a ceiling on allowable GHG emissions per unit, excluding bids that exceed it. This approach is most common in construction materials procurement, where embodied carbon limits per square metre are increasingly embedded in specifications for major infrastructure projects.

Carbon reduction plan. Rather than a point-in-time product footprint, the buyer requires the supplier to demonstrate a credible pathway to reducing emissions over the contract period, with milestones and reporting obligations embedded in the contract performance conditions. The UK Procurement Policy Note 06/21 requires suppliers bidding for central government contracts above 5 million pounds to submit a carbon reduction plan covering scope 1 and 2 emissions.

The accepted calculation methodology matters. In European public procurement, accepted standards include ISO 14064 for organisational GHG accounting, ISO 14067 for product carbon footprints, and EN 15978 or EN 15804 for embodied carbon in buildings and construction products. Environmental Product Declarations (EPDs) produced under EN 15804 provide third-party verified product carbon footprint data and are commonly accepted as evidence in construction procurement.

Article 67 of Directive 2014/24/EU authorises environmental characteristics, including carbon footprint, as award criteria. Article 68 permits life-cycle costs to include the costs of greenhouse gas emissions. Together, these provisions give contracting authorities a solid legal basis for carbon footprint requirements, provided criteria are linked to the subject matter of the contract and applied equally to all bidders.

For contracts targeting Net-Zero Procurement Targets, carbon footprint requirements are the primary measurement mechanism. The EU Taxonomy in Procurement is also beginning to influence how carbon footprint thresholds are set, particularly for construction and energy-intensive industries where taxonomy technical screening criteria specify GWP limits.

Why carbon footprint requirements matter for bidders

Carbon footprint requirements transform GHG emissions from an abstract CSR concern into a scored, contractual, and potentially disqualifying factor. Suppliers who have not measured their product or operational carbon footprints face three problems: they cannot submit the required data, they cannot score on the environmental criterion, and they may be excluded at the technical specification gateway if a maximum threshold applies.

Building the internal capability to measure and report carbon footprints, or obtaining third-party verified EPDs, is therefore a commercial necessity for suppliers in sectors where carbon footprint requirements are becoming standard practice, including construction, energy, professional services, food and catering, and transport.

Example

A Danish government agency issues a tender for steel structural components. The technical specification states that all steel supplied must have a declared global warming potential of no more than 1.2 tonnes of CO2 equivalent per tonne of steel, supported by a third-party verified EPD produced under EN 15804. The award criterion allocates 20 points to bids below 0.9 tonnes CO2e per tonne. A steel manufacturer using electric arc furnace technology with a high scrap content can declare 0.7 tonnes CO2e per tonne and achieves the full 20 points. A manufacturer using a basic oxygen furnace with a footprint of 2.0 tonnes CO2e per tonne is excluded at the technical specification stage.

Frequently Asked Questions

Does a carbon footprint requirement cover scope 3 emissions?

Scope depends on what the buyer specifies. UK Procurement Policy Note 06/21 currently requires scope 1 and 2 only. More ambitious procurers are beginning to require material scope 3 categories, particularly purchased goods and services and upstream transport. The European Commission's guidance on life-cycle costing under Article 68 of Directive 2014/24/EU supports including upstream and downstream emissions where a recognised methodology exists, but full scope 3 requirements remain less common due to data availability challenges.

Can carbon footprint requirements disadvantage SMEs?

They can create a disproportionate burden if the verification requirement is expensive and the contract value is low. Proportionality under EU procurement law requires that the evidentiary demand be commensurate with the contract's environmental significance. Buyers are encouraged to accept self-declarations for lower-value contracts and to phase in requirements to allow smaller suppliers time to build capability.

How do carbon footprint requirements interact with price?

Carbon footprint is typically one award criterion among several. A lower carbon footprint earns a higher environmental score, but price and quality criteria also apply. In a 40-price/40-quality/20-environmental split, a supplier with a 10% higher price but the lowest carbon footprint in the field could still win if the carbon score differential is large enough. Bidders should model the award formula with their carbon data before deciding whether to invest in carbon reduction or price competitiveness.