Circular Public Procurement: What 17 EU Research Projects Teach Us Ahead of the Circular Economy Act

Circular public procurement has quietly changed status over the past few years. It is no longer a green purchasing trick in the toolkit of a handful of frontrunner cities; it is one of the most powerful market-creating instruments available for Europe’s secondary raw material economy. In July 2026 the European Commission’s Directorate-General for Research and Innovation (DG RTD) completed an independent expert report reviewing 17 Horizon 2020 and Horizon Europe projects, with one question in mind: which solutions are mature enough to be written into the forthcoming Circular Economy Act (CEA)? The headline finding fits into a single sentence — the problem is no longer a shortage of solutions, but the difficulty of embedding them into routine decision-making.

What did the Commission’s expert report actually examine?

The report is part of a five-part analysis covering five intervention areas, each handled by a dedicated domain expert: refinement of extended producer responsibility (EPR), recovery of critical raw materials from waste electrical and electronic equipment (WEEE), uptake of recycled and bio-based content, transnational and regional initiatives (industrial symbiosis), and public procurement. This instalment covers the last of these.

The underlying logic is simple. EPR pushes supply; procurement pulls demand. The purchasing power of European public authorities amounts to roughly 14% of EU GDP, according to the report — enough to provide the “base load” demand that makes a modern recycling plant or a bio-based production line bankable. The CEA’s own target is ambitious: doubling the Union’s circular material use rate from around 12% to 24% by 2030.

The starting point is far more modest. A recent European Investment Bank analysis found that fewer than 6% of above-threshold tenders incorporate circular economy considerations, while innovative public procurement accounts for less than 1% of contracts in many Member States.

Circular public procurement as a market-shaping instrument, not administration

One of the report’s strongest claims is that circular public procurement cannot be understood as an annex to a tender document. It works as part of a wider market architecture — alongside project development support, financing readiness, territorial coordination, data standardisation and credible verification. On its own, it moves very little.

Legally, the framework has been in place for years. Directives 2014/24/EU, 2014/25/EU and 2014/23/EU allow contracts to be awarded on the Most Economically Advantageous Tender (MEAT) basis rather than lowest price, and Article 68 of Directive 2014/24/EU explicitly opens the door to life-cycle costing (LCC). The problem is not a missing mandate. It is that buyers do not know how, do not dare, or do not have time to use it.

The 17 projects were grouped into three strategic clusters.

Cluster one: life-cycle operationalisation and digital infrastructure

Six projects sit here, most of them in construction. They did not develop technology; they developed usable decision-support instruments.

CINDERELA produced a standardised, PEF-aligned “Sustainability Footprint” reporting document that summarises the LCA, LCC and social LCA results of secondary-material construction products on a single sheet. Its practical advantage is that it shifts the modelling burden to the supplier while keeping evaluation manageable for the contracting authority. The project’s green procurement criteria proposals include minimum recycled-content thresholds, exclusion of hazardous substances via recognised certifications or EPDs, and mandatory pre-demolition plans and end-of-life recovery targets.

CityLoops took an even simpler route: a spreadsheet-based life-cycle CO₂e calculator for demolition and renovation projects, covering concrete, excavated soil and construction and demolition waste. The output plugs straight into a tender — the authority sets a benchmark, bidders document projected emissions, and lower life-cycle emissions become a weighted award criterion. The project’s handbook series embeds circular criteria for bio-waste and construction purchasing into standard, legally safe procedures.

RECONSTRUCT and CIRC-BOOST pushed further into the digital domain, embedding life-cycle assessment into BIM-based digital twins linked to material passports and traceability modules. Embodied carbon, circular concrete content and recovery rates become measurable, performance-based technical requirements.

Beyond construction, WORM carried out comparative life-cycle assessments of bio-based versus fossil-based products for humanitarian procurement and catalogued 41 bio-based products across five priority product groups in an open-access database. XPRESS drew on 27 case studies across ten countries to build a methodology for integrating LCC at the tender definition stage of renewable energy procurement.

Cluster two: innovation procurement and demand-side market creation

The second six projects tackle a different question: what should a public body do when the solution it needs does not yet exist on the market? The instruments are available — pre-commercial procurement (PCP), public procurement of innovative solutions (PPI), innovation partnerships, competitive dialogue and preliminary market consultation (PMC).

PROCEDIN developed legal roadmaps, a market consultation methodology and a decision-support framework for cities, and set up the Innovation Procurement Task Force to pass the experience on. ECLIPSE translated this into a handbook, modular training materials and a risk-based evaluation model, complemented by a digital marketplace on the EuroQuity platform where buyers, startups and investors are matched with AI support.

The most concrete example comes from CLIMABOROUGH. The project launched a call divided into five lots of equal value, with two innovation partnership contracts per city, combining development, negotiation and deployment within a single MEAT-based procedure. The Grenoble lot, for instance, sought a coordinated reuse marketplace for IT equipment — French law requires local authorities to source at least 20% of their IT purchases from reuse, but supply is not yet organised to meet that demand. Cities ran preliminary market consultations in January 2025, then tested winning solutions in nine-month “sandbox” deployments in real urban settings.

In healthcare, three projects launched in 2025 — THERESA, REHEAL and suHCO — build explicitly on PCP: on-site hospital wastewater treatment, digital tools for circular healthcare supply chains, and an AI-enabled sustainability planning platform respectively. All three are still in the R&D and validation phase, so meaningful results are a few years away.

Cluster three: financial and governance preconditions

The final five projects work on the background conditions. HOOP helps cities and regions make circular bioeconomy projects investment-ready through a Project Development Assistance model, a Bio-Circularity Label, a Project Maturity Level framework and a circular valuation method. DEFINITE-CCRI‘s “Deal Engine” combines technical, financial and circular expertise to align projects with EU Taxonomy criteria and unlock private finance.

FRONTSH1P‘s CircuPuncture Model positions procurement as a territorial governance lever, using monitoring indicators and the combined use of environmental and social clauses. TREASoURcE piloted joint procurement of battery energy storage systems with harmonised technical specifications and pooled demand, and is producing a procurement “recipe” booklet for setting bio-based criteria. 3-CO analysed EU labelling and certification frameworks so that contracting authorities can tell verifiable schemes from marketing claims.

Where it stalls: the real bottlenecks

The report does not sugarcoat. Many promising approaches remain at pilot stage, and their success often rests on project-specific expertise or dedicated support that cannot be reproduced across the public sector.

The recurring constraints:

• Limited life-cycle literacy among contracting authorities, combined with fragmented responsibilities.
• Short-term budget logic: annual budgets and accounting practice reward immediate savings, not life-cycle value.
• Legal uncertainty: divergent national interpretations of waste status and End-of-Waste criteria, plus ambiguity around the “link to the subject matter” requirement, encourage caution.
• Data gaps and poor interoperability: without harmonised, mandatory sustainability data formats, every evaluation is expensive and litigable.
• Capacity limits: smaller municipalities and healthcare institutions simply lack the staff to run a PCP procedure or a BIM-based evaluation.
• Fragmented demand: one-off circular tenders do not stabilise secondary raw material markets.

Five recommendations for the legislators

The authors deliberately sequenced their recommendations: the core transformation lever first, then the capacity needed to deliver it, then market scaling.

1. Institutionalise life-cycle-based and circular procurement in high-impact sectors: minimum recycled or secondary-material content thresholds where proportionate and market-ready; LCC as the default cost method under MEAT; harmonised LCA/LCC reporting templates; integration into national procurement toolkits and e-procurement platforms; and interoperability between BIM environments and Digital Product Passports.
2. Strengthen institutional capacity and governance: embed the topic in national procurement strategies with monitoring indicators, establish permanent national competence centres, promote cross-departmental units, provide structured training and encourage life-cycle-based budgeting.
3. Normalise innovation procurement: simplified, EU-standardised PCP/PPI templates, clear market consultation protocols, milestone-based funding, technical assistance for smaller authorities and innovation procurement sandboxes.
4. Enable SME and innovative supplier participation: SME-proportionate templates, lot division, functional specifications, routine preliminary market consultations and phased contracting models.
5. Aggregate demand: an EU-supported Joint CPP Facility, harmonised technical specifications and model governance agreements, and cross-border demand aggregation — including sandboxes with neighbouring non-EU countries that share integrated supply chains.

It is also worth watching the 2026 revision of the EU public procurement framework and the proposed Industrial Accelerator Act under the Clean Industrial Deal, both of which could reshape the picture.

What this means for municipalities and public service operators

The report is written at EU level, but its conclusions will feel uncomfortably familiar to anyone who has seen municipal or utility procurement from the inside. Annual budgets, the safety of the lowest price, fear of legal challenge and a procurement team of three or four people are precisely the factors the experts identify as the main brakes.

What can be picked up and used right now:

• CityLoops’ spreadsheet calculator and handbooks were designed for small teams — a realistic entry point on any demolition or renovation project.
• The CINDERELA approach of leaving the modelling to the bidder substantially reduces the authority’s own workload.
• Preliminary market consultation is the best value-for-money step available: it costs almost nothing and prevents both unachievable and needlessly timid specifications.
• Joint procurement across neighbouring municipalities or associations makes sense in any category where none of them carries real market weight alone.

Conclusion

The combined lesson of the 17 projects is organisational, not technological. Europe already has tested instruments: templates, calculators, digital twins, catalogues, procurement roadmaps and financing models. The question for the next phase of circular public procurement is whether these make it into national procedures, e-procurement systems and internal rulebooks — or remain the private business of frontrunners. The Circular Economy Act can add the most value precisely where it turns an optional practice into a dependable, system-level market force.

Frequently asked questions about circular public procurement

What does circular public procurement mean?

Circular public procurement is public purchasing that builds circular economy objectives into the tender process: recycled or secondary-material content, reuse, repairability, life-cycle costing and end-of-life recovery. It is a narrower, more targeted approach than general green public procurement, which covers the full range of environmental goals.

Why does procurement matter for the circular economy?

The purchasing power of European public authorities amounts to roughly 14% of EU GDP according to the report. At that scale, public demand can become predictable enough to reduce the investment risk facing recycling and bio-based manufacturing capacity. Procurement pulls the market from the demand side, while producer responsibility pushes from the supply side.

How widespread is circular public procurement in the EU today?

Still modest. A European Investment Bank analysis found that fewer than 6% of above-threshold tenders include circular economy considerations, and innovative public procurement accounts for under 1% of contracts in several Member States. The legal framework exists; practical uptake lags well behind it.

What is the main barrier to wider adoption?

Not technology, according to the expert report. The dominant constraints are limited life-cycle literacy among contracting authorities, fragmented responsibilities, annual budgeting logic, divergent national interpretations of waste status, non-interoperable sustainability data, and capacity shortages in smaller organisations.

Which tools can be used right away?

CityLoops’ spreadsheet-based life-cycle CO₂e calculator and handbooks were built for small teams working on demolition and renovation projects. CINDERELA’s Sustainability Footprint sheet shifts the modelling burden to the bidder. Preliminary market consultation costs almost nothing and prevents unachievable specifications. Joint procurement gives small organisations real market weight.

What does the Circular Economy Act propose here?

The report ranks five packages: institutionalising life-cycle-based procurement with minimum recycled-content thresholds, strengthening institutional capacity and governance, simplifying innovation procurement, enabling SME participation, and finally aggregating demand through an EU-supported joint procurement facility.

Source:

European Commission, Directorate-General for Research and Innovation: Research & Innovation projects supporting the Circular Economy Act – Focus Area: Circular public procurement. Independent Expert Report, author: Lise Smed Olsen. Luxembourg: Publications Office of the European Union, 2026. ISBN 978-92-68-39453-3, doi:10.2777/0780739. Reusable under a CC BY 4.0 licence. The contents of the publication do not necessarily reflect the position of the European Commission.