MAKING RESPONSIBLE PUBLIC PROCUREMENT THE NORM: LESSONS FROM EU MEMBER STATES
Public buyers across Europe are already using their purchasing power to advance human rights and environmental responsibility in global supply chains. A new policy paper by Swedwatch and the Fair Trade Advocacy Office (FTAO) highlights practical experiences from Germany, Belgium and Sweden, and how these can inform the EU’s proposed Public Procurement Act.
Public procurement represents around 14% of the EU’s GDP, giving public authorities significant opportunities to influence business practices. Yet human rights and environmental risks remain widespread in public supply chains, while responsible procurement practices are still unevenly implemented.
Drawing on interviews with procurement practitioners, policy advisors and researchers, the new policy paper examines how public buyers are integrating human rights and environmental due diligence into procurement – from risk-based requirements and supplier engagement to contract clauses and monitoring.
The findings highlight the need for clearer rules and stronger support, and call on EU decision-makers to strengthen the proposed Public Procurement Act by clarifying how due diligence can be required and monitored, improving supply-chain transparency, and providing practical guidance and model contract clauses for public buyers and suppliers.
Responsible procurement in practice: Four examples from EU Member States
Experiences from Germany, Belgium and Sweden illustrate how public authorities are addressing human rights and environmental risks in procurement, using different approaches adapted to their needs and capacities.
Targeting human rights risks in high-risk products
Friedrichshain-Kreuzberg, Berlin
The Berlin district of Friedrichshain-Kreuzberg applies social requirements to products with identified human rights risks, including textiles, food and natural stone. It has also developed approaches to addressing forced labour risks in solar panel supply chains, including template clauses and requirements concerning polysilicon sourcing.
By targeting high-risk products and using certifications and other evidence of compliance, the district demonstrates how public buyers can take action even with limited resources.
Using supplier engagement to improve working conditions
City of Dortmund
Dortmund has included social requirements in municipal procurement contracts since 2012, initially focusing on issues such as child labour, living wages and human rights.
Building on this experience, the city has introduced pilot initiatives that go beyond certification, seeking greater transparency about production sites, materials and working conditions. Its approach illustrates both the potential of supplier engagement and the challenges of monitoring and enforcing requirements across complex global supply chains.
Turning due diligence into contractual requirements
Swedish Regions
Sweden’s 21 regions have developed a common framework for integrating human rights and environmental due diligence into public procurement, using shared contract clauses, risk assessments and supplier monitoring.
The framework focuses on high-risk products and requires suppliers to identify and address risks throughout their supply chains. Rather than relying primarily on penalties, the regions prioritise dialogue and corrective action. According to the national coordinator, there is no evidence that these requirements have reduced competition, increased costs or discouraged smaller suppliers.
Making due diligence proportionate and practical
Flanders – Facilitair Bedrijf
The Flemish government’s central purchasing body is developing more targeted approaches to human rights and environmental due diligence, including tailored requirements for high-risk sectors such as natural stone, electronics and textiles.
A proposed “due diligence light” clause would allow public buyers to request greater supply-chain transparency and supplier cooperation where risks are highest, without imposing disproportionate administrative burdens on smaller suppliers.
The approach shows how risk-based requirements can make responsible procurement more practical and accessible.
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