Revision of EU rules on public procurement

14 submissions in the snapshot (11 from organisations), portal total 14. Feedback list on the portal.

11 of 11 organisation submissions analysed; the model reads them as: supports 1 wants changes 10

• Landesregierung Public authority, AUT model reads as: wants changes source
  • Maintain the legal form of directives instead of a regulation.

    However, we are in favour of maintaining the legal form of the directives harmonising procurement law.

    machine translation by the Commission, original in DE
  • Delete the obligation to draw up and publish an annual needs plan.

    The obligation to draw up and publish an annual needs plan is rejected.

    machine translation by the Commission, original in DE
  • Ensure contracting entities have the freedom to choose between lowest price and quality criteria.

    contracting entities should be given the freedom to choose between awarding the contract to the tender offering the lowest price or evaluating tenders on the basis of quality criteria.

    machine translation by the Commission, original in DE
• Micro company, ITA Other, ITA model reads as: supports source
  • Maintain the inclusion of Geographical Indications in the list of considerations for food procurement in Article 53.

    Geographical Indications are included in this list of considerations.

• Micro company, DEU Other, DEU model reads as: wants changes source
  • Include an explicit opening clause in the new regulation that recognises independently verified sectoral qualifications as admissible proof of suitability and quality.

    We therefore call for the new EU Public Procurement Regulation to include an explicit opening clause that recognises independently verified sectoral qualifications as admissible proof of suitability and quality, provided that the following minimum requirements are met: Independence of the audit body from the certified organisation Defined and documented audit scope Regular recertification at specified intervals Public verifiability of the certificate status.

    machine translation by the Commission, original in DE
  • Explicitly safeguard and perpetuate the practice of accepting quality management systems as proof of suitability through a clear opening clause.

    The new regulation should explicitly safeguard and perpetuate this practice through a clear opening clause.

    machine translation by the Commission, original in DE
• Inci Holding A.Ş. Company, TUR model reads as: wants changes source
  • Provide differentiated treatment for highly integrated Customs Union partners in resilience-oriented procurement frameworks.

    Any resilience-oriented procurement framework should therefore provide differentiated treatment for highly integrated Customs Union partners that demonstrably contribute to the Unions industrial security and competitiveness objectives.

  • Ensure European preference measures differentiate between strategic partners and high-risk third countries.

    European preference measures should differentiate between strategic partners and high-risk third countries.

  • Adopt a flexible approach to origin requirements that reflects integrated regional value chains and substantial transformation.

    Origin requirements should reflect the reality of integrated regional value chains rather than relying solely on the final production location.

• Maxion İnci Jant Sanayi A.Ş. Company, TUR model reads as: wants changes source
  • Make a clear distinction between sources of risk and natural extensions of the European industrial ecosystem.

    However, a clear distinction should be made between sources of risk and the natural extensions of the European industrial ecosystem.

  • Base assessments of supply chain resilience on supply reliability, geographical proximity, and integration into European value chains rather than solely on EU membership status.

    Assessments of supply chain resilience should be based on supply reliability, geographical proximity, and integration into European value chains, rather than solely on EU membership status.

  • Ensure European preference mechanisms distinguish Customs Union partners deeply integrated with European industry from high-risk third countries.

    European preference mechanisms should distinguish Customs Union partners that are deeply integrated with European industry from high-risk third countries.

• DigitalTrade4.EU Other, EST; register: Other organisations, public or mixed entities model reads as: wants changes source
  • Ensure technical verification failures are not treated as non-compliance and allow operators to correct data errors.

    Technical verification failures or inconclusive results should not be treated as non-compliance, and economic operators should have a clear route to correct material data errors or use a lawful fallback before an adverse decision is taken.

  • Limit evidence reuse strictly to the information needed for the specific procurement purpose.

    Evidence reuse should be limited to the information actually needed for the procurement purpose rather than requiring unnecessary replication of underlying source data.

  • Ensure that automated risk indicators do not independently establish misconduct or adverse legal conclusions.

    Automated risk indicators should support scrutiny and prioritisation, but should not by themselves establish misconduct or another adverse legal conclusion.

• ANADOLU ISUZU Company, TUR model reads as: wants changes source
  • Recognize Turkiye's unique position within the EU industrial ecosystem and ensure it is not treated as a conventional third country.

    As a long-standing Customs Union partner and an integral part of European automotive supply chains, Türkiye should not be treated as a conventional third country.

  • Establish a clear and transparent pathway for Turkiye to qualify under the IAA criteria.

    We therefore urge policymakers to establish a clear and transparent pathway for Türkiye to qualify under the IAA criteria and to ensure that vehicles and components produced in Türkiye remain eligible for public procurement programs.

• Eti Other, PAK model reads as: wants changes source
  • Ensure simplification is accompanied by stronger planning, evaluation, and contract management.

    Simplification without stronger planning, evaluation and contract management can increase poor purchasing and irregularities.

  • Prevent additional policy objectives from making tenders so complicated that price and quality competition becomes secondary.

    The danger is that a tender becomes so complicated that price/quality competition becomes secondary.

  • Place greater focus on post-award activities such as performance monitoring, variations, and contract completion.

    But obtaining value for money depends enormously on what happens after contract awardperformance monitoring, variations, payments, claims, quality and completion.

• Micro company, GBR Company, GBR model reads as: wants changes source
  • Ensure interoperability between the EU data architecture and established international open-contracting standards like OCDS.

    I would therefore encourage the Commission to make interoperability with established international open-contracting standards an explicit implementation objective.

  • Use the transition period as a practical readiness window for system interfaces, identifiers, testing, and buyer capability.

    I would use that period as a readiness window, with attention to system interfaces, common identifiers, supplier migration, guidance, testing and the capability of buyers to operate the new regime without workarounds.

  • Ensure that derogations regarding minimum quality weightings under Article 98(5) remain a normal and usable part of the regime.

    Where quality is better secured through specifications or contract-performance conditions, the derogation should be a normal and usable part of the regime rather than an exceptional escape route.

• Numera Palvelut Oy Company, FIN model reads as: wants changes source
  • Ensure that the functionality, reliability, and usability of EU-wide information systems are properly taken into account.

    The Procurement Regulation should take into account the functionality, reliability and usability of EU-wide information systems.

    machine translation by the Commission, original in FI
  • Ensure that any required reporting processes by Member States remain smooth and cost-effective.

    If Member States need to provide information on their procurement, the process needs to be smooth and cost-effective.

    machine translation by the Commission, original in FI
  • Harmonise administrative measures and systems relating to processes as the EU internal market opens up.

    The more the EU internal market is opened up (cross-border offerings, ordering, billing, etc.), the more important it is that administrative measures and systems relating to processes are also harmonised.

    machine translation by the Commission, original in FI
• Nevi, Dutch Association of Procurement and Supplymanagement Other, NLD; register: Trade unions and professional associations model reads as: wants changes source
  • Maintain sufficient professional discretion and flexibility for contracting authorities.

    Ten eerste moet voldoende professionele ruimte behouden blijven.

  • Provide structured attention and support for further professionalisation of procurement specialists.

    Ten tweede moet er structureel aandacht zijn voor verdere professionalisering.