Public Procurement and the EU’s Path to Climate Neutrality: Retooling the Principle of Environmental Integration?

Abstract

The European Union’s legally binding objective of climate neutrality by 2050 represents its most ambitious response to the escalating global climate crisis and a central expression of its commitments under the 2015 Paris Agreement. This originates in the European Green Deal’s agenda, which placed climate and environmental challenges as this generation’s defining task. More recently, the European Commission has advanced an intermediate 2040 target of a 90% net reduction in greenhouse gas (GHG) emissions compared to 1990 levels, in line with the Clean Industrial Deal agenda for a fully decarbonized economy.

Public procurement emerges as a key instrument in the EU’s climate transition within this evolving framework. However, its potential remains constrained by legal, structural, and practical barriers that hinder the full integration of environmental objectives. This article explores these limitations to demonstrate that, in spite of the several solutions undertaken, a fully-fledged commitment demands taking the principle of environmental integration seriously, a principle which is long recognized but underutilized in EU environmental law as well as in the public procurement sector. This article argues that taking the principle of integration seriously is a necessary step toward aligning public procurement law with the EU’s broader climate commitments and anchors its argument on scrutinizing the procurement legislative framework and developing pathways to operationalize the Environmental Integration Principle (EIP). Ultimately, this analysis underscores the EIP’s potential as a catalyst for embedding climate objectives into procurement law and policy, thereby contributing to the transformative changes required to achieve EU climate neutrality.