Introduction
Environmental requirements are increasingly being translated into operational procurement controls for medicines, including tender eligibility rules, award scoring, and contract monitoring. Where this occurs, environmental performance becomes a supplier attribute alongside quality, security of supply, and price, and may influence contracting outcomes even for clinically comparable products.
The practical change is a shift from narrative commitments to evidence that can be verified and compared across bidders. In tender settings this commonly means structured disclosures, assurance by third parties, and the use of recognised management system standards that support audit and follow-up.
How environmental criteria enter tender decisions
Environmental criteria are being applied at three points in the procurement cycle. First, as participation conditions where a bidder must submit specified evidence by a set date. Second, as award criteria, where environmental performance is scored against defined requirements. Third, as contract management conditions, where suppliers are expected to maintain disclosures, accept audit rights, and report progress during contract life.
This structure matters because it determines whether environmental controls create a threshold effect, a competitive differentiator, or an ongoing compliance obligation. It also determines whether access-facing contracting messages can be limited to tender stage, or must be sustained through periodic reporting and assurance.
What purchasers tend to ask for as evidence
Where environmental criteria are applied, purchasers commonly prefer evidence that is standardised and auditable. Examples include an environmental management system (EMS) aligned to International Organization for Standardization standard 14001 (ISO 14001), product and corporate greenhouse gas (GHG) accounting structured by recognised frameworks, and independent certification or verification for defined claims.
Some schemes are “meta-evidence” mechanisms, used to reduce the burden of bespoke tender documentation. Supplier sustainability ratings are used in some sectors to support screening and monitoring, and product carbon labels and assurance models are used to provide externally verified signals of measurement and reduction activity.
Antibiotics as a procurement-led environmental and public health issue
Antibiotic manufacturing emissions and residues are being addressed not only as environmental externalities but also as a driver of antimicrobial resistance (AMR). This framing supports purchaser intervention because it links supply chain controls to the preservation of antibiotic effectiveness and to broader public health commitments.
In practice, antibiotic tenders are beginning to reference structured manufacturing standards and third-party assurance. The AMR Industry Alliance Antibiotic Manufacturing Standard provides a defined expectation set for minimising AMR risk and aquatic ecotoxicity from antibiotic manufacturing, and procurement bodies in Nordic collaborations have signalled its use in tender procedures, with certification routes highlighted via British Standards Institution assurance.
Regional patterns and convergence
In Europe and the Nordic countries, the strongest operational signal is the integration of net zero, social value, and sustainability requirements into public procurement processes, including medicines tenders, supported by specific supplier assessments and tender guidance.
In the United States, environmental considerations are increasingly positioned within federal procurement decarbonisation and environmentally preferable purchasing approaches. The direction of travel is towards supply chain sustainability requirements and the use of recognised standards and labels to guide purchasing, although the application will vary by purchaser and product class.
In Japan, green procurement is underpinned by national policy frameworks that define evaluation criteria for designated procurement categories and are updated through a formal process led by the Ministry of the Environment. The extent to which these frameworks translate into medicines-specific requirements depends on purchasing scope and category definitions, but they provide an established pathway for environmental criteria to be operationalised in public procurement.
Implications for manufacturer readiness
As environmental criteria become embedded in tender mechanics, manufacturers are likely to need an evidence pack that can be reused across purchasers but adapted to local templates. This typically requires clarity on manufacturing site controls, supplier transparency for active pharmaceutical ingredient and finished dose supply chains, and governance for assurance and audit response.
A further implication is that procurement requirements may operate alongside, rather than instead of, environmental legislation, with tender evidence acting as a pragmatic proxy for compliance, risk management, and continuous improvement when purchasers cannot directly enforce upstream regulation.
Summary
Environmental requirements in medicines procurement are increasingly appearing as eligibility conditions, award scoring elements, and contract management obligations, shifting environmental performance from a corporate narrative to a tender-relevant supplier attribute. Evidence expectations tend to favour auditable mechanisms such as ISO 14001 environmental management systems, verified disclosures, and third-party certification rather than descriptive commitments. Antibiotic procurement is a prominent early application area because manufacturing emissions and residues are framed as contributors to antimicrobial resistance risk, supporting the use of defined manufacturing standards and assurance routes. Europe and the Nordic countries show clear operationalisation through net zero and sustainability tender tools, while the United States and Japan have procurement policy frameworks that can drive wider uptake across public purchasing categories. For manufacturers, readiness increasingly depends on reusable documentation, supply chain transparency, and governance for verification and audit response.
Links
AMGROS: Amgros announces tendering procedure with new environmental criteria. 10 June 2024.
European Commission: Green public procurement, criteria and requirements.
Japan Ministry of the Environment: Basic Policy on Promoting Green Procurement. February 2019.
NHS England: Evergreen sustainable supplier assessment for NHS England medicines tenders.
Swedish National Agency for Public Procurement: Sustainability criteria for medicinal products.
United States Government: Net-zero emissions procurement by 2050, Federal Sustainability Plan.
Scientific publications
Anderson M, Panteli D, van Kessel R, Ljungqvist G, Colombo F, Mossialos E. Challenges and opportunities for incentivising antibiotic research and development in Europe. Lancet Reg Health Eur. 2023;33:100705. Published 2023 Jul 26. doi: 10.1016/j.lanepe.2023.100705
Bhullar L. Green public procurement of pharmaceuticals as a regulatory response to antimicrobial resistance and its compatibility with the WTO Agreement on Government Procurement. RECIEL. 2024; 33(2): 291-302. doi:10.1111/reel.12543
Cameron, A., Connolly, J., Esiovwa, R., Henriquez, F. L., Hursthouse, A., Mukherji, S., & Mukherji, S. (2025). ‘Mind the gaps’: stakeholder perspectives on addressing antimicrobial resistance in the environment in the Indian context. Global Health Action, 18(1). https://doi.org/10.1080/16549716.2025.2491200
Jahre M, van Oorschot K, Årdal C, Sverrisson E, Pettersen MS, Wangen A. Sustainable pharmaceutical procurement: Environmental tendering criteria for better or worse? J Purch Supply Manag. 2025;101081. doi:10.1016/j.pursup.2025.101081
Panteli, D., Anderson, M., Fieldman, T. et al. Policy options for sustainable access to off-patent antibiotics in Europe. npj Antimicrob Resist 2, 40 (2024). doi:10.1038/s44259-024-00061-4