As promised, here’s my take on Circular 17/2025, issued yesterday by the Office of Government Procurement to public bodies in Ireland. The basic obligations reflect those set out last year in the Buying Greener Strategy, with a few tweaks. While Buying Greener set out a total of 54 actions, the Circular only deals with 11 of them.

The GPP mandate:

The Circular reiterates that all public bodies are required to include GPP criteria in all tender documents for contracts valued above the national thresholds (currently €50,000 for supplies/services, and €200,000 for works), where possible. Where national GPP guidance and criteria are available, these must be used, where appropriate and proportionate.

This places emphasis on use of Ireland’s national GPP criteria (published by the EPA, and forming the basis of the GPP criteria search tool), which currently cover 11 priority sectors. The criteria offer a range of different options to address the environmental impacts associated with public contracts. Neither the Circular nor Buying Greener stipulate how many of the criteria should be applied in individual tenders, or whether these should address the main environmental impacts of a purchase or may focus on more tangential considerations such as packaging. There is however a suggestion in Buying Greener that technical specifications should be used to implement GPP.

For contracts where no national GPP criteria (yet) exist, public bodies may consult other sources such as the EU GPP criteria – however many of these are now out of date. The EPA guidance and Buying Greener also provide suggestions for criteria covering categories such as professional services and electricity which may be useful. Under Buying Greener, the EPA is tasked with developing new criteria sets over time.

The reporting obligations:

Government departments will continue to report annually on GPP to the EPA (an arrangement which has been in place since 2020) however the reports will now also need to include information on contracts awarded to social enterprises, voluntary and community organisations where GPP criteria have been applied. They must also include an explanation if GPP criteria have not been included in any tenders within the priority sectors – the most recent EPA reports indicate that there is a particular gap in ICT contracts. These reports will be due in 2026 for contracts awarded in the calendar year 2025.

For the broader public sector, there are two forms of reporting set out. For bodies subject to the Public Sector Climate Mandate (which excludes local authorities, commercial semi state bodies, and schools), data on application of GPP criteria in contracts will be reported via the SEAI Monitoring + Reporting system. In addition, all public bodies must publish information on the use of GPP in individual competitions by answering the relevant eForms questions on eTenders.

 Specific obligations for works contracts: The Circular highlights existing requirements set out in the Climate Action Plan and guidelines issued to public bodies in 2024 on procuring low carbon cement and concrete. It also highlights the incoming requirements under the recast Energy Performance of Buildings Directive, with Ireland’s national methodology for calculating life-cycle GWP currently being finalised by the SEAI (a  brief consultation period closed in May). For all works contracts awarded under the Capital Works Management Framework, life-cycle costing must be applied – meaning such contracts cannot be awarded based on lowest price.

Planning and training:

All public bodies are required to: i) Set out in their Corporate Procurement Plans or other relevant policies/strategies how they will adhere to the applicable obligations under Buying Greener; and

1. ii) Set out and fulfil annual staff training commitments in relation to GPP.

The Circular also addresses the potential impact of GPP on smaller companies – my separate post on that topic is here. While the potential costs for SMEs in complying with GPP criteria are highlighted, there is no reference to the costs which public bodies may incur in implementing GPP. In practice, bidders are likely to pass on some or all of the cost of meeting environmental criteria to public buyers. In some cases, higher purchase prices will be compensated for by lower life-cycle costs, but this is not always the case. There are also the costs and staff time associated with training, planning and evaluating GPP criteria. Acknowledging these costs, and making appropriate budgetary allocations, is essential if we wish the policy to succeed.

How does Ireland’s policy compare to other countries? Many European countries, including France, Italy, the Netherlands and the UK have binding GPP and/or social value requirements for contracting authorities set down in legislation. While the scope of these varies, most focus on higher-value contracts. So Ireland is on the one hand pursuing a more comprehensive course in that GPP requirements apply to contracts starting from a value of €50,000. On the other hand, the requirements are not set down in legislation (outside of sectoral requirements derived from EU legislation, such as the Clean Vehicles Regulations) and the coverage of social issues is tentative at best.

Many public and commercial semi-state bodies in Ireland have already gone further and are starting to see the impact of green and social procurement, while others are moving more slowly. As the reporting requirements kick in, the real question becomes what will we do with the data, and how will we measure the impact of GPP?

Written by: Abby Semple, Procurement Consultant, Greenville Procurement