Green Public Procurement (“GPP”) is a process whereby public bodies seek to procure goods, services and works with a reduced environmental impact throughout their life-cycle when compared to goods, services and works with the same primary function that would otherwise be procured.
The Government has approved a new Circular, Circular 17/2025, aiming to support GPP across the public sector. This Circular replaces Circular 20/2019 and applies to all public sector bodies.
Content of the Circular
The new Circular includes eleven instructions to the government and public sector regarding Buying Greener: Green Public Procurement Strategy and Action Plan 2024 – 2027 (“Buying Greener Plan”).
The Circular includes eleven distinct GPP actions under five themes:
- Corporate Procurement Plans,
- Accelerating GPP,
- The Built Environment,
- Green Public Procurement Training and Awareness, and
- Monitoring and Reporting.
Examples of GPP actions contained in the Circular include all public bodies including GPP criteria in tender documents for tenders above the national advertising threshold, whole life-cycle costing to be used by all public sector bodies for all works contracts, and public bodies specifying low carbon construction methods and low carbon cement material as far as practicable for directly procured or supported construction projects.
The Circular includes updated reporting requirements, which will cover the period from 1 January 2025 to 31 December 2025 and annually thereafter:
- All public bodies, subject to the Public Sector Climate Action Mandate, to report explanation in the Sustainable Energy Authority of Ireland (SEAI) Monitoring and Reporting system for not including National GPP criteria in published tender documentation for contracts valued over the applicable national procurement thresholds where National GPP criteria are available.
- All government departments to capture data in their annual report to the EPA regarding tenders awarded to social enterprises, voluntary and community organisations where GPP criteria have been applied
- All government departments to report in the annual report to the EPA on GPP implementation in relation to contracts valued over the applicable national procurement thresholds, including explanation for not including GPP criteria in published tender documentation where National GPP criteria are available.
These reporting requirements are largely retained from Circular 20/2019 so no drastic change has occurred but the EPA will update its annual reporting template to take into account these additional reporting requirements.
The EPA has published national GPP criteria sets for priority sectors. Outside of priority sectors, Appendix III of the Buying Greener Plan provides minimum environmental criteria for public procurement of goods and services where no suitable national, EU, or other GPP criteria are available for goods or services being procured.
SMEs
Particular attention is given to SMEs – a section in the Circular dedicated to the impact on SME's advises that due to the fact that there may be additional costs associate with including GPP in public contracts, state bodies should pay particular consideration to any potential impact on SMEs. The Circular notes that a 12-month impact assessment will be undertaken to review its impact on SMEs.
This Circular comes in advance of Ireland's first National Public Procurement Strategy, which is scheduled for recommendation to Government later this year. An FAQ document has been prepared by the Office of Government Procurement for those with any queries on the new Circular.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
