Introduction
Environmental requirements in medicines procurement are increasingly expressed as eligibility conditions, scored award criteria, and ongoing contract obligations. As these requirements become more formalised, purchasers need evidence that is comparable between suppliers and can be verified. This has led to a shift from narrative statements towards structured disclosures, third-party ratings, and auditable management systems, which can be checked at bid stage and revisited during contract performance.
Procurement as a verification problem
Procurement frameworks typically distinguish between what a supplier commits to do and what can be verified within tender and contract processes. Verification commonly relies on one or more of the following approaches: a declared metric with a defined calculation method, certification against a recognised standard, or independent assurance of reported information. The European Commission’s green public procurement guidance explicitly emphasises that criteria should identify verification methods, and that requirements should be usable across different stages of tendering.
For pharmaceutical suppliers, this tends to create a practical hierarchy of evidence. At the base are descriptive statements and policies, which may still be requested but are hard to compare. Higher up are structured datasets and management system artefacts that can be audited, such as documented processes, internal controls, and records of monitoring. At the top are third-party attestations, including certification or assurance, which can reduce the verification burden for purchasers when applied consistently.
Standardised disclosures that feed procurement
A major driver of structured evidence is the expansion of mandatory sustainability reporting in some jurisdictions, and the growing expectation that disclosed information should be decision-useful for external parties. In the European Union, the Corporate Sustainability Reporting Directive requires in-scope undertakings to report using European Sustainability Reporting Standards, and is explicitly designed to increase consistency of disclosures across companies.
Although procurement exercises rarely rely solely on corporate-level reports, these disclosures influence procurement in two ways. First, they create a baseline set of defined metrics and internal controls that suppliers can re-use when responding to purchaser questionnaires. Second, they increase scrutiny of the traceability of claims, which encourages companies to build evidence chains from site-level data to consolidated reporting. In parallel, assurance standards for sustainability information continue to develop, including dedicated sustainability assurance standards intended to strengthen credibility of sustainability disclosures.
Environmental management systems as auditable proof
Environmental management systems are widely used as procurement-ready evidence because they translate broad environmental aims into repeatable processes, responsibilities, monitoring, and corrective actions. Certification to recognised standards can provide purchasers with a shorthand indicator that a supplier has implemented defined controls and is subject to external audit. ISO 14001 is frequently used in this way, as it is positioned as a recognised environmental management system standard and is supported by an established certification ecosystem.
A related procurement-oriented standard is ISO 20400, which provides guidance on integrating sustainability into procurement itself. While ISO 20400 is guidance rather than a requirements standard, it is used to structure how organisations configure procurement policies, risk assessment, supplier engagement, and follow-up, which aligns closely with how purchasers operationalise environmental requirements in contracting.
Ratings, questionnaires, and supplier assessment platforms
Where purchasers need more granular differentiation than a binary certification can provide, supplier assessment platforms and structured questionnaires are used to score maturity and track progress over time. These mechanisms are increasingly designed to be repeatable across many customers, reducing the burden of bespoke evidence requests. In practice, they may combine self-reported data, document review, and risk-based follow-up.
Two widely used models illustrate how these systems are positioned. EcoVadis describes a methodology that produces sustainability ratings used in supplier assessment, and CDP operates a supply chain disclosure model focused on environmental reporting to customers. These tools can become de facto evidence channels when large purchasers adopt them, because they standardise the format in which suppliers provide information and they create audit trails of updates and remediation.
For manufacturers, this often means procurement evidence becomes partly “platform-mediated”. Supplier guidance published by companies may explicitly reference such ratings as part of supplier engagement, which can indirectly shape what procurement-ready evidence looks like across the sector.
Product and process labels used in procurement
In some procurement categories, purchasers reference ecolabels as a way to specify environmental performance and verification conditions. The European Commission notes that public buyers can indicate that goods and services procured should be certified under the EU Ecolabel, or can reference EU Ecolabel criteria within technical specifications and award criteria. While medicines are not generally addressed through ecolabels in the same way as some other product groups, this illustrates a broader procurement logic: labels can be used either as direct eligibility evidence or as a structured source of verifiable criteria.
Contract monitoring and auditability over time
A key change associated with environmental procurement requirements is that evidence is not only collected at tender submission. Contract management increasingly requires periodic updates, responses to corrective actions, and re-validation of metrics. This shifts evidence from a one-off dossier to an operational dataset. Supplier assessment tools used by health systems, including structured supplier assessment approaches, reflect this direction by focusing on measurable progress and ongoing engagement rather than a single declaration.
The resulting expectation is that suppliers can reproduce the same results under scrutiny, explain methods, and show governance around data quality. Where external assurance is used, it typically seeks to increase confidence that reported information aligns with defined criteria and is supported by appropriate evidence.
Tools and service providers supporting compliance and assurance
As procurement evidence requirements mature, manufacturers commonly use external support for certification, audits, supplier assurance programmes, and sustainability assurance of disclosed information. Examples of service providers include:
- Bureau Veritas, which positions services around sustainable procurement and ISO 20400-aligned approaches.
- BSI, which provides ISO 14001 environmental management system support and broader healthcare sustainability resources.
- DNV, which provides accredited management system certification services, including ISO 14001 certification support.
- SGS, which provides supply chain assurance services and sustainability report assurance aligned to reporting and assurance requirements.
- TÜV SÜD, which positions ISO 20400-related services to support adoption of sustainable procurement approaches.
Summary
Environmental procurement requirements increasingly depend on evidence that can be compared between suppliers and verified within tender and contract processes. Standardised disclosures, including mandatory sustainability reporting in some jurisdictions, are creating baseline definitions and controls that suppliers can re-use in procurement evidence packages. Auditable environmental management systems, particularly those aligned to recognised standards, provide procurement-ready proof because they translate commitments into documented processes and monitoring. Supplier assessment platforms and structured questionnaires are becoming common channels for scoring and tracking progress, and can shape what “acceptable evidence” looks like across purchasers. Over time, contract management is driving a shift from one-off statements towards continuously maintained datasets, with increasing use of certification and assurance services to support credibility.
Links
European Commission: Corporate sustainability reporting. 9 December 2025.
European Commission: Green Public Procurement, criteria and requirements.
European Commission: EU Ecolabel, green procurement.
International Organization for Standardization: ISO 20400:2017 Sustainable procurement guidance.
NHS England: Evergreen sustainable supplier assessment.
Scientific publications
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