Green Public Procurement: Italy’s “Minimum Environmental Criteria”

The CAM have achieved notable success in transforming Italian public procurement. One of the most significant achievements is their mandatory nature. Unlike many European countries where green procurement remains voluntary, the CAM are compulsory for all relevant tenders in Italy. The National Anti-Corruption Authority (Autorita Nazionale Anti-Corruzione, ANAC) has clarified that no derogations are permitted, making the CAM a non-negotiable element of public contracts.

This mandatory application has created a strong incentive for suppliers to adopt sustainable practices. Companies that fail to comply risk exclusion from lucrative public projects, particularly those funded under the National Recovery and Resilience Plan, which saw a construction and renovation boom in Italy post-pandemic. As a result, there has been a rapid increase in demand for certified products and services, and many companies now choose to develop CAM-compliant components on a voluntary basis. Italy now ranks among the top 3 European countries for green public procurement implementation. According to studies by Fondazione Ecosistemi, billions of euros in public contracts require CAM compliance, particularly in the construction, infrastructure, and energy sectors.

There has also been a significant increase in the availability of certified recycled materials. Environmental certifications such as Environmental Product Declaration (EPD) ReMade in Italy have grown rapidly. Life cycle thinking has become integrated into design and procurement processes, which represents a cultural shift in how projects are conceived and executed.

However, challenges remain. Small and medium-sized enterprises may struggle with certification and compliance costs, which can be a barrier to participation in public tenders. The supply of certified recycled steel is also finite, and growing demand often outpaces availability, creating market pressure. Monitoring and enforcement also present difficulties, as ensuring compliance across thousands of tenders requires robust oversight mechanisms. A challenge that would be true in the Indian case as well.

Overall, the Italian case demonstrates how leveraging procurement as a market-shaping tool can have enormous benefits for both government and industry. The CAM have created strong demand signals for recycled steel and low-carbon materials, accelerating investment in scrap- based production and certification systems. India can use its large public procurement footprint to normalise the “green premium” by allowing ministries to pay modest premiums for verified low-carbon steel. This early-stage demand can de-risk investments in cleaner technologies and signal confidence to private investors.

The CAM do not operate in isolation. They interact with and reinforce several national and European policies. At the European level, CAM align with Green Public Procurement Guidelines, which encourage member states to integrate sustainability into public purchasing. They also support the objectives of the Circular Economy Action Plan by promoting resource efficiency and recycling. CAM criteria reflect the requirements of the European Taxonomy for Sustainable Activities, which defines what constitutes environmentally sustainable economic activity.

At the national level, CAM are integral to Italy’s green transition strategy under the €194- billion-National Recovery and Resilience Plan (PNRR), which is funded by the EU’s Next Generation EU fund. Italian green public procurement also features as key points for other national goals, including the National Strategy for Circular economy and the National Plan for the Ecological Transition.

They also reference international standards such as EN 15804 for Environmental Product Declarations and EN 15978 for building life cycle assessment. This synergy ensures CAM are consistent with broader sustainability frameworks, enhancing their legitimacy and effectiveness. By embedding CAM within a network of complementary policies, Italy has created a coherent approach to sustainable procurement that aligns with both domestic priorities and European objectives.

Sabina Nicolella and Dana Vocino at the Fondazione Ecosistemi commented that “At the moment, life cycle assessment (LCA) is a premium criterion, but over time, premium criteria become mandatory. This gives time for companies to adapt. Currently, LCA are very detailed because the Ministry of the Environment is considering making LCA mandatory for projects.”

There is scope for the Italian Ministry of the Environment to bring in the global warming potential impact as part of LCA for CAM compliance. Such a move would see steel include not just recycled content criteria, but also emissions criteria.

India could consider empowering a single nodal agency to coordinate across ministries, set timelines and publish verified procurement data. This will provide continuity and reduce fragmentation in policy implementation. For Italy, this holistic approach has helped the CAM to remain relevant and targeted on the conditions of market supply and demand. Institutional coordination is therefore key to the success of new “green” steel regulation.

Steel is a critical material in construction and infrastructure, making it a focal point of CAM requirements. The 2022 update introduced stringent recycled content thresholds for steel products. For structural steel produced using the electric arc furnace process, the recycled content must be at least 75 per cent. For alloy steel, the requirement is 60 per cent, while for steel produced through the integrated cycle, the threshold is 12 per cent. For non-structural steel, the requirements are slightly lower but still significant: 65 per cent for electric arc furnace non-alloy steel, 60 per cent for alloy steel, and 12 per cent for integrated cycle steel.

Verification of compliance is rigorous. Self-declaration is no longer accepted. Producers must demonstrate compliance through Environmental Product Declarations of Type III, ReMade in Italy certification, or other accredited third-party certifications. This shift from self-certification to independent verification reflects a broader trend towards transparency and accountability in sustainability reporting.

The implications for producers are profound. They must adjust their supply chains to secure sufficient scrap material and optimise production processes to meet recycled content thresholds. Investment in certification and life cycle assessment documentation is necessary, which adds cost and complexity. However, compliance also offers competitive advantages. Early adopters gain access to public contracts and strengthen their market position. For producers using traditional blast furnace methods, the pressure to innovate is intense, as meeting CAM requirements is challenging within the constraints of the integrated cycle.

CAM also address logistics and carbon footprint. They encourage local sourcing by limiting transport distances to 150 kilometres from production site to construction site. By combining material requirements with transport considerations, CAM promote a holistic approach to sustainability.

Defining clear thresholds for environmental standards is another important lesson for India. Similar specifications relating to recycled steel content in the CAM could be adopted in India, provided this is supported by independent certification. In the CAM, self-declaration is explicitly prohibited. India could adopt a similar approach by setting transparent, performance-based criteria for carbon intensity or recycled content and mandating third-party verification. This will build credibility and prevent greenwashing. Furthermore, striking a balance of ensuring technology neutrality while rewarding performance is highly rewarding. Italy’s CAM apply to all steel routes but set differentiated thresholds that reflect technical realities: electric arc furnace producers must meet higher recycled content levels, while integrated cycle producers have lower yet meaningful requirements. India’s steel sector is diverse, combining large BF-BOF plants, induction furnaces, and emerging EAF producers. A performance-based approach that rewards actual emissions reductions rather than legacy technology choices will avoid distortions and encourage innovation across all routes.

The CAM are dynamic and will continue to evolve. The current recycling focus of the CAM is likely to expand to include emissions-based criteria. Moreover, life-cycle costing (LCC) has already begun to be integrated for the public procurement of both products and services. Italy’s 5 central purchasing body, Consip (Concessionaria Servizi Informativi Pubblici), has developed a unique approach for introducing LCC for selected tenders, with a simplified methodology which is adjusted for each product or service group. For example, the CAM set out thresholds for energy consumption for lamps. As Vocino notes, “at the moment, lifecycle assessment is a premium criterion. The CAM have developed in such a way that over time, premium criteria become mandatory. The CAM introduces premium criteria, then gives time for companies to adapt, and then gradually make these criteria mandatory”.

Other future directions include expansion to new sectors such as information and communication technology, energy services, and road maintenance. Digitalisation of compliance processes is likely, with the development of centralised Environmental Product Declaration (EPD) databases and blockchain-based traceability systems. Stricter carbon benchmarks may be introduced to align with European climate targets, which could include carbon intensity limits for materials.

Support for small and medium-sized enterprises will be essential. As Costanza Scano at ECCO points out, “including ETS emissions will not add any significant administrative burdens for large industries applying for tenders. However, for small and medium enterprises, this burden will be significant.” Simplified compliance tools and training programmes can help reduce barriers to participation. Enhanced monitoring and enforcement mechanisms will also be necessary to ensure that CAM deliver on their promises. ANAC and regional authorities are expected to play a key role in strengthening oversight.

The CAM will remain a cornerstone of Italy’s sustainability strategy. By shaping supply chains and accelerating the transition to a circular economy, they will continue to influence policy, industry, and the broader sustainability agenda.

Italy’s CAM demonstrate that procurement can be a powerful lever for industrial decarbonisation when it combines legal enforceability, transparent standards, institutional clarity, and alignment with wider policy objectives. If India adopts these principles, its forthcoming green procurement framework could accelerate the steel sector’s transition and position the country as a global leader in credible, market-shaping sustainability policy.

The CAM framework demonstrates how public procurement can drive systemic change. By embedding environmental criteria into tenders, Italy has created a powerful incentive for suppliers to innovate and adopt sustainable practices. For steel producers, the CAM requirements on recycled content represent both a challenge and an opportunity. Those who adapt will thrive in a market increasingly defined by green standards. As the CAM evolve, they will continue to influence policy, industry, and the broader sustainability agenda. Italy’s experience with the CAM therefore offers several constructive lessons for India as it develops its own Green Public Procurement framework for low-carbon steel.

Several principles stand out. Italy illustrates the importance of embedding low-carbon requirements across the entire procurement system so that sustainability criteria are consistently applied. Clear and measurable thresholds, supported by independent verification, help to build credibility and prevent greenwashing. Procurement can also serve as a powerful market signal that supports early investment in cleaner technologies by reducing uncertainty for producers.

Italy has also shown the benefit of maintaining technology neutrality while rewarding strong performance. In this way, government regulation targets environmental outcomes and emissions reductions rather than technological methods used by companies. All production routes are considered, but requirements are designed in a way that reflects technical realities and encourages continuous improvement. Stable institutional coordination has helped the CAM remain relevant and up to date, while alignment with broader industrial and climate strategies has ensured that procurement works in tandem with other policy tools.

Italy’s CAM demonstrate that procurement can be a powerful lever for industrial decarbonisation when it combines legal enforceability, transparent standards, institutional clarity, and alignment with wider policy objectives. If India adopts these principles, its forthcoming green procurement framework could accelerate the steel sector’s transition and position the country as a global leader in credible, market-shaping sustainability policy.