KezdőlapEnglishCircular Public Procurement: Green Is Not Yet Circular – How the CE-PRINCE...

Circular Public Procurement: Green Is Not Yet Circular – How the CE-PRINCE Criteria Sets Work

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Public procurement accounts for around 14 percent of EU GDP, yet it is rarely used for what it does best: creating a reliable market for products that can be repaired, taken back or made from recycled materials. Circular public procurement targets exactly that gap. In September 2026, the Interreg CENTRAL EUROPE project CE-PRINCE published its Deliverable D.2.2.2, Circular Criteria Sets. Built on procurement practice from seven Central European countries, including Hungary, it scores each tender criterion on a scale of 1 to 5 according to how directly it helps close material loops.

In short: Circular public procurement is not the same as green purchasing – a criterion on energy efficiency or habitat protection can be environmentally valuable without closing a single material loop. CE-PRINCE collected, upgraded and scored existing criteria across four sectors and added a six-step guide for public buyers. The criteria are now being tested in real procurement procedures.

Why green procurement is not enough

In the previous step of the project (D.2.2.1), partners compared EU and national Green Public Procurement (GPP) criteria across agrifood, construction, manufacturing and tourism-related goods and services. The findings cut both ways. Existing frameworks cover environmental protection, resource efficiency, process optimisation and certification schemes well. What is largely missing are the more advanced circular principles: product life extension, maintenance and repair, reverse logistics and take-back systems, value retention, performance-based procurement and circular business models.

The whole deliverable rests on a simple insight that is often overlooked: circularity and environmental sustainability do not coincide. A criterion can improve air quality, cut energy use or protect biodiversity without doing anything to keep materials in the economy. Procuring a low-emission vehicle fleet, for example, is a step forward for the climate, but on its own it says nothing about what happens to the batteries at end of life.

This distinction matters in practice. As our piece on the illusion of circularity in plastic recycling showed, labelling something as recyclable or green does not mean the material actually comes back into use.

What the CE-PRINCE criteria sets contain

The backbone of the criteria sets is a shared Excel workbook that partners populated with European and national practice. For every criterion it records the main circular principle, the thematic cluster, the partner country, the field of application (product or service category), the original wording, the criterion type, a synthesised description merging similar criteria, and a circularity contribution score from 1 to 5.

The criteria are organised into sector-specific thematic clusters across four sectors:

  • Agrifood: reusable tableware and packaging, elimination of single-use plastics, food waste prevention and surplus redistribution, certified and organic sourcing, local supply chains, plant-based menus, low-emission logistics. For a closer look at what makes reuse systems work, see our article on the Wuppertal Institute’s systems map for reusable packaging.
  • Construction: circular and recycled building materials, secondary materials in road construction, construction and demolition waste management, design for adaptability and future recovery, life-cycle assessment and costing, Environmental Product Declarations (EPDs).
  • Manufacturing: durability, maintenance, repair and refurbishment, spare-part availability, take-back systems, traceability, restriction of hazardous substances, ecolabels.
  • Tourism-related goods and services: circular event organisation, waste prevention and composting, circular design of machinery and batteries, water efficiency, green-area management, low- and zero-emission vehicles, biodegradable consumables.

Each criterion is also classified under the four standard EU tendering categories, so procurers can see exactly where a requirement fits:

  • Selection Criteria (SC): the tenderer’s professional, technical and organisational capacity, such as environmental management systems or circular experience.
  • Technical Specifications (TS): the mandatory minimum that the product, service or works must meet.
  • Award Criteria (AC): reward circular performance above the minimum.
  • Contract Performance Clauses (CC): make sure commitments are actually delivered during contract execution.

Importantly, CE-PRINCE has not written a new rulebook. The project treats the upgraded criteria as “indications” that each country can integrate progressively, starting from its own national baseline. This can happen in three ways: by strengthening existing criteria, by transferring a practice already proven in another partner country, or by introducing new circular elements where there were none – typically around durability, repairability, take-back and life-cycle thinking.

The 1–5 score: what it measures, and what it does not

With so many criteria gathered from seven countries, navigation is hard. The Sant’Anna School of Advanced Studies (SSSA) in Pisa therefore developed a single scoring method. It assesses how directly a criterion contributes to closing material loops and to the 10R hierarchy (Refuse, Rethink, Reduce, Reuse, Repair, Refurbish, Remanufacture, Repurpose, Recycle, Recover). The method draws on the frameworks of Potting et al., Kirchherr et al. and the Ellen MacArthur Foundation, and is consistent with the EU Circular Economy Action Plan and Article 13 of the Taxonomy Regulation.

The scale works as follows:

  • 5 – direct circular contribution: implements a specific R-strategy, such as mandatory recycled or reused content, design for disassembly and recycling, take-back systems, waste prevention, on-site reuse, substitution of virgin with secondary materials, organic recovery.
  • 4 – strong circular enabler: durability and service-life extension, structural bio-based substitution, LCA/EPD/LCC frameworks, quality standards for secondary materials, repairability and spare-part availability. Repairability is not only a legal question, as our analysis of the reality of the right to repair explains.
  • 3 – adjacent or supporting contribution: water reuse, restricting hazardous substances that hinder recycling, Type I ecolabels with embedded circular content, monitoring of waste flows, traceable sourcing of renewable materials.
  • 2 – other sustainability dimensions: climate mitigation, air quality, energy efficiency, training – valuable, but not closing material loops.
  • 1 – outside the direct circular economy scope: biodiversity protection, safety compliance, social/ESG aspects, contract enforcement.

Perhaps the most telling lesson of the scale is that biodiversity protection scores 1. That does not make it less important – it simply matters in a different dimension. The authors stress that the score is neither a mandatory ranking nor a verdict on a criterion’s overall value. It is a decision-support tool: criteria scoring 4 or 5 deserve particular consideration, but the final choice must always reflect the subject of the contract, the legal framework, market maturity and feasibility.

Six steps to put circular public procurement into practice

The second half of the deliverable is a practical guide that takes the contracting authority through six consecutive steps:

  1. Define the procurement object and the circular objectives. What resources does it consume over its life cycle, where is waste generated, how long must it last, what maintenance does it need, and is there scope for reuse, refurbishment, recycling or a circular business model?
  2. Select the relevant thematic cluster. Catering typically focuses on food waste and reusable packaging, buildings on circular materials and adaptability, furniture on durability, repairability and take-back, landscaping on biodiversity and resource management, and vehicles on low emissions and life-cycle performance.
  3. Select the criteria. This is where the score helps: criteria scoring 4 and 5 deliver the strongest circular effect, and criteria from several clusters can be combined where appropriate.
  4. Adapt to the national framework. Wording, thresholds and verification methods must be tailored to national law, market conditions and proportionality. Verification is not a formality: recycled content, for instance, cannot currently be measured in a lab and can only be proven by documenting the supply chain, as we explained in our article on the German UBA’s ranking of recycled plastic certification schemes.
  5. Integrate the criteria into the tender documents under one of the four categories (see below).
  6. Monitor and collect lessons learned: checking contractual commitments, reviewing circular indicators, assessing supplier performance, documenting challenges and good practices.

Why award criteria are the recommended entry point

For the pilot testing phase, CE-PRINCE recommends that upgraded criteria be used primarily as award criteria wherever appropriate. The logic is straightforward: contracting authorities can try out more ambitious circular requirements without making them mandatory, which reduces legal, proportionality and market-access risks. If the market is not yet ready, the tender does not fail – bidders who can offer more simply score more points.

The deliverable’s examples show what can be rewarded: recycled content above the minimum, extended warranties, repair and maintenance services, take-back schemes, product-as-a-service solutions, life-cycle performance indicators and innovative circular business models.

There is, however, a crucial caveat. Where an award criterion concerns commitments to be delivered during the contract, those commitments must also be written into the contract performance clauses. Otherwise, a promise that won points remains just a promise. Contract clauses matter most where circular outcomes depend on operational practice rather than product characteristics – reporting on waste prevention, maintenance programmes or end-of-life collection, for instance.

Technical specifications, by contrast, are where the mandatory baseline belongs: minimum recycled content in building materials, reusable packaging in catering, spare-part availability for manufactured products, durability and repairability requirements.

What this means for Hungarian buyers and the waste sector

Hungary takes part in the project through two partners: the South-Transdanubian Regional Innovation Agency and ERI Hungary – European Research Institute Nonprofit Ltd. The criteria sets were therefore built with knowledge of Hungarian practice and offer a ready starting point for Hungarian contracting authorities as well.

From a waste management perspective, the key message is that circular public procurement can reinforce on the demand side what collection and pre-treatment produce on the supply side. If the public sector regularly asks for recycled content, take-back and repairability, secondary raw materials gain a more predictable market, and take-back obligations lead to cleaner, more plannable material flows. The region already shows how this plays out: according to our analysis of the state of Austria’s circular economy, the Austrian circularity rate is well above the EU average, yet legal barriers remain the main brake there too.

What comes next

The criteria sets will now be tested in real procurement procedures across the partner countries. Experience, application examples and challenges will be summarised in Deliverable D.2.2.3, and the criteria will be refined on that basis. The project also plans to publish infographics to make the material more accessible on its website and social media channels. CE-PRINCE started in June 2024 and runs until November 2026; it invites public buyers, suppliers and stakeholders who want to apply the criteria or follow the pilots to get in touch.

The most important takeaway may be that circularity is not decoration for tender documents. It only counts when it becomes a verifiable requirement and an enforceable contractual commitment – and the CE-PRINCE criteria sets now offer a shared, practical starting point for exactly that.


FAQ – circular public procurement

What is the difference between green and circular public procurement?

Green procurement aims to reduce environmental impact, while circular public procurement specifically aims to close material loops. A criterion on energy efficiency or habitat protection can be environmentally valuable without keeping materials in the economy. CE-PRINCE therefore measures separately how far a criterion supports repair, reuse, take-back or recycling.

What does the CE-PRINCE circularity score measure?

The score measures how directly a criterion contributes to closing material loops. A 5 means a direct R-strategy, such as mandatory recycled content or take-back, a 4 a strong enabler such as repairability, and a 1 an objective outside the circular economy scope. The scale is a decision-support tool, not a mandatory ranking.

Which sectors do the CE-PRINCE criteria sets cover?

The criteria sets cover four sectors: agrifood, construction, manufacturing, and tourism-related goods and services. Each sector has its own thematic clusters, such as reusable packaging, construction and demolition waste, spare-part availability or circular event organisation. The criteria were collected from procurement practice in seven Central European countries.

Why does CE-PRINCE recommend using the criteria as award criteria?

As award criteria, contracting authorities can test more ambitious circular requirements without making them mandatory. This lowers legal, proportionality and market-access risks, because the tender will not fail if the market is not ready. If a rewarded commitment applies during contract execution, however, it must also be written into the contract performance clauses.

Where can the full CE-PRINCE criteria set be found?

The full criteria set can be downloaded as a public Excel workbook from the Interreg CENTRAL EUROPE website, attached to Deliverable D.2.2.2. For each criterion, the workbook lists the sector, partner country, criterion type and circularity score, while the deliverable provides a six-step guide for applying them.


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Ladányi Roland
Ladányi Rolandhttp://envilove.hu
Roland Ladányi is an environmental professional and waste management expert dedicated to promoting sustainability and the circular economy. As the founder and driving force behind the dontwasteit.hu platform, he provides up-to-date news, in-depth analysis, and practical solutions aimed at shaping an environmentally conscious mindset. His work focuses on waste reduction and efficient resource management, bridging the gap between technical expertise and clear, accessible public communication.
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