Unit A: In General

The European Commission taking into account the fact that Public Procurement comprises about 14% of the G.D.P of member states and the plan of actions for the enhancement of a more efficient, in the use of resources, and environment-friendlier model of circular economy, has enacted criteria, which member-states are highly recommended to use, so as Public Procurement become “greener”. (Green Public Procurement and the E.U action plan for the circular Economy – Study for the ENVI Committee – upd 2017)

Those criteria aim to direct public organizations in environment- friendlier products procurement, and as a result in support of recycling, products with reduced ecological footprint and more efficient use of resources and energy.

The only member-states that, at the moment, has not obtained even some of those criteria related to Green Public Procurement, are Luxembourg, Estonia, Hungary, Romania and Greece.

In full contrast to above-mentioned, it is observed that in Greek example there are exclusions from tendering procedures, related to procurement of recycled materials regardless if they fulfill or not the technical standards required per occasion.


General principles applicable to Green Public Procurement


As general principles for the adoption of Green Public Procurement by the Hellenic Single Public Procurement Authority it is believed that they must be:

  1. Application of free competition principles and equal use of primary and recycled material. This shall be achieved by:
    1. Mandatory integration of a standard rate of recycled materials in the Public Procurement based on certain standards.
    2. The mandatory integration of recycled materials must not result in intentional increase in their acquisition cost.
  2. The integration of technical standards is imperative and must be met, regardless if the materials are primary or recycled, so as the quality of those materials will not be downgraded.

Involved Public Authorities:

  1. Hellenic Ministry of the Environment and Energy/Hellenic Recycling Agency – Services which are involved in the process of production of recycled materials.
  2. Green Public Contracts Commission which was established by M.D. 63955/239/13-6-2017 and whose goal is to draw up a national action plan for the promotion of Green Public Contracts, based on the regulations of Union legislation.
  3. Hellenic Single Public Procurement Authority, which is the regulating authority regarding the enact of criteria which have been suggested by the European Commission on the Green Public Procurement.


Principles applicable to Green Public Procurement:

  1. Lifting the ban of recycled materials in Public Procurement.
  2. Integration of minimum rates of materials energy in Public Procurement.
  3. Integration of certain technical requirements which must be fulfilled by every procured material regardless if they are primary or recycled.
  4. Acceleration of the procedure of drawing up a national action plan for the promotion of Green Public Contracts.

Unit B

  • The exclusion of regenerated lubricating oils from Public Procurement is in contrast with the recently-voted by the parliament Joint Ministerial Decision 62952/5384/30-12-16 (Approval of national action plan for the management of dangerous waste) which states: “The use of lubricating oils which come up with processing will be promoted (R 9), mainly by lifting any kind of obstacle which acts as a deterrent in their positioning in the market.”
  • Procurement of lubricating oils which come by minimum rate of 25% from regenerated base lubricating oils must be prescribed in both the National Action Plan for the Green Public Contracts and the Public Procurement Regulation.

The size of the market of lubricating oils, that are consumed by public organizations in Greece, is estimated in 10.000 tons annually.

If we replace 25% of the quantity above (2.500 tons), with regenerated lubricating oils the benefits that αrise, are:

  • Reduction of Greenhouse effect gases by 12,6%
  • Mineral resources saving by 22%

Source: Study IFEU Life Cycle Analysis, June 2017

  • Public tendering procedures must be carried out on the basis of certain technical standards of products according to the use in which they are intended.
  • No analytical method can distinguish the origin of a base lubricating oil. The regenerated base lubricating oil ought to cover the same requirements with the primary, as they are intended for the same use. As a consequence, a requirement for the base lubricating oils (regenerated and primary) and the lubricating oils which are produced by them, are their lack of classification due to their lack of risk. The risk of those substances is a result of the possible presence of polycyclic aromatic hydrocarbon (P.A.H) in concentration greater than 3%. This limit is sufficiently documented by a number of studies (API, CONCAWE etc) The suggested requirement IP 346 (standard extract refractive index method DMSO), < 3%. is applied regardless the origin of the base lubricating oil and the technology of its production and is a general rule for the classification or not of it. Sealing of this requirement, is the registration of the regenerated base lubricating oils according to the REACH legislation, as it happens with the primary ones.