Circular Public Procurement (CPP)

Circular Public Procurement (CPP) applies the principles of the circular economy directly to public contracting. Instead of buying linear products that are used once and then discarded, contracting authorities using CPP specify goods and services that are designed to stay in use longer, be repaired and upgraded, be remanufactured into new products, or be recovered as secondary raw materials at end of life. European public authorities collectively spend more than 2 trillion euros annually, making procurement a powerful lever to accelerate Europe's transition away from a take-make-waste economy.

What is Circular Public Procurement (CPP)?

CPP sits within the broader Green Public Procurement (GPP) framework but focuses specifically on resource efficiency and waste prevention rather than carbon alone. Key principles include:

Durability and repairability. Specifications that require minimum product lifetimes, available spare parts, or manufacturer-backed repair schemes. The EU Ecodesign for Sustainable Products Regulation (2024/1781) is beginning to set minimum durability and repairability requirements that feed directly into CPP technical specifications.

Recycled content. Requirements that products contain a minimum percentage of post-consumer recycled material. This is common in CPP criteria for office paper, plastic packaging, and construction aggregates.

Product-as-a-Service. Contracting for performance or availability rather than ownership, for example leasing office equipment rather than buying it. The supplier retains ownership and an incentive to design for durability and recovery. This model is expressly accommodated by Directive 2014/24/EU's flexibility on contract structure.

Take-back and end-of-life. Contract performance conditions requiring suppliers to collect and responsibly manage products or materials at end of life, preventing landfill and enabling secondary material recovery.

Life-Cycle Assessment (LCA). Using whole-life cost and environmental impact data under Article 68 of Directive 2014/24/EU to capture material extraction, manufacturing, use-phase, and disposal impacts in award criteria.

The European Commission's Circular Economy Action Plan (2020) explicitly calls for CPP to be mainstreamed across EU member states. The EU taxonomy on sustainable finance (see EU Taxonomy in Procurement) identifies circular economy activities as one of its six environmental objectives, reinforcing the policy coherence between financial and procurement regulation.

Why CPP matters for bidders

CPP creates new competitive dynamics. Suppliers who invest in circular business models, such as take-back schemes, remanufactured product ranges, or product-as-a-service offerings, can present differentiated bids that score well on environmental criteria without competing purely on price. Conversely, suppliers whose products are single-use or have no end-of-life recovery pathway may find themselves excluded from CPP-heavy markets.

Providing an Environmental Product Declaration (EPD) is increasingly the expected baseline for demonstrating circular credentials. Authorities using Comprehensive GPP Criteria may require EPDs covering multiple life-cycle stages, including end-of-life.

Example

A Belgian federal authority procures IT equipment under a CPP framework. Its technical specification requires all laptops to carry an EU Ecolabel or equivalent, with a minimum guaranteed spare-parts availability period of seven years. The award criteria allocate 15 points for recycled content above 30% by weight and 10 points for a manufacturer-operated take-back programme covering both hardware and packaging. A supplier offering commodity laptops with no recycled content and no take-back scheme scores poorly on environmental criteria and may lose despite competitive pricing.

Frequently Asked Questions

Is CPP legally required in Europe?

CPP is currently voluntary in most European countries, embedded within the voluntary GPP framework. However, the European Commission's Green Public Procurement criteria for specific product categories already include circular economy elements, and several member states have adopted national CPP targets. The EU's proposed revision of the Procurement Directives is expected to strengthen mandatory circular requirements for selected categories.

How do I prove circular credentials in a bid?

Evidence depends on what the buyer specifies. Common accepted proofs include EPDs covering end-of-life stages, recognised ecolabels with circular criteria (such as the EU Ecolabel for IT equipment), third-party audited take-back programme certifications, and manufacturer declarations on recycled content with supporting audit trails. Buyers must accept equivalent evidence under Article 44 of Directive 2014/24/EU, so a product-specific LCA report can substitute for a label where the underlying data is equivalent.

Does CPP apply to construction?

Yes. CPP in construction focuses on recycled aggregate use, design for deconstruction, embodied carbon measurement, and waste management plans. The EU GPP criteria for new office buildings and major renovations include circularity elements. The UK's Procurement Policy Note on construction requires whole-life carbon assessment, which captures embodied carbon in materials and thus incentivises circular material choices.