Green Public Procurement in Public Administration: Perceptions and Challenges in Practice

ABSTRACT

The implementation of green public procurement (GPP) in the Maltese public administration was perceived as an important step that supports the achievement of environmental policies. Institutions are in place for the application of GPP. However, there are difficulties in practice, and more needs to be done in terms of training and capacity development. This study concludes that managerial decisions are taken to legitimize actions, so that the administrator appears to be doing the right thing in the eyes of the stakeholders. Institutions intentionally adopt GPP to adhere to the norms and values of society. Whether GPP has a positive effect on the environment is a secondary objective.

KEYWORDS:

• Bureaucratic safety
• GPP criteria
• legitimation
• stakeholder theory
• institutional theory

Introduction

Public Procurement (PP) is the purchase of products and services necessary for public institutions to achieve both their functional (Kristensen et al., 2021) and policy goals (Harland et al., 2019). PP can affect socio-economic circumstances through employment creation and economic growth (Uyarra et al., 2020), and therefore can address wider sustainability concerns (Sönnichsen & Clement, 2020), including climate change and green activities (Marron, 2003).

The literature refers to sustainable PP (SPP), green PP (GPP) and circular PP (CPP). SPP comprises a combination of practices, policies and laws intended to integrate economic, social and environmental risks in PP activities and decisions, in order to maximize profitability across the whole product life cycle (Romodina & Silin, 2016). On the other hand, GPP focuses on the environmental dimension of sustainability, and how green purchasing can facilitate the achievement of environmental goals (Cheng et al., 2018; Malatinec, 2019). Sönnichsen and Clement (2020) define CPP as the process by which governments acquire products and services with the goal of developing closed material and energy loops and reducing or eliminating their negative effects on the environment and the generation of waste over their entire lifecycle. Sönnichsen and Clement (2020) find similarities between SPP, GPP and CPP, and referred to them collectively as “CPP.” Similarly, this article uses the three terms interchangeably.

According to Rejeb et al. (2023), organizations need to take a strategic approach to SPP/GPP if they want to maintain their competitive edge while also ensuring that PP achieves environmental and social objectives. This means that SPP/GPP implications have to be integrated within all levels of planning and decision-making of an organisation—both long term and short term.

There are expectations for green purchasing to facilitate the achievement of environmental goals (Malatinec, 2019), but research appears undecided about this link (Rejeb et al., 2023) due to lack of evidence (Cheng et al., 2018). While it is possible for GPP to target multiple objectives, some researchers concluded that GPP is neither cost-effective nor objectively effective as an environmental policy instrument (Lundberg & Marklund, 2018).

The United Nations [UN]’s Sustainable Development Goal (SDG) 12 relates to ensuring sustainable consumption and production patterns, with SDG 7 promoting SPP practices (UN, 2015). The European Union (EU)’s Circular Economy Action Plan of 2015 highlights the importance of GPP to acquire goods and services with a reduced environmental impact throughout their lifecycle (EC, 2008a). The Organisation for Economic Co-operation and Development (OECD) has also been advocating GPP as a sustainability tool capable of reducing environmental effects by preserving resources through the PP of green products and innovative technologies (Testa et al., 2016).

Given that public administrations are expected by their stakeholders to demonstrate concern for climate change and the environment (UN, 2015), green practices should be integrated in decision-making, including PP practices. Green practices would make an organization align to the organizational field and thus increase its legitimacy in the eyes of relevant stakeholders, like the EU, the IMF, the OECD and the citizens. Thus, the theoretical framework consists of legitimacy, institutional and stakeholder theories. These three theories have complementary overlaps (Martens & Bui, 2023).

The overall aim of this study is to analyze whether GPP is considered effective to support environmental policy or a fad that is followed for the sake of legitimacy. This study provides insights into the complexities and challenges of implementing GPP. The perceptions of the contracting authorities (CAs) on GPP and its effectiveness in supporting environmental policies are explored through the lens of the theoretical framework.

The context of the study is at the central government level in Malta. Malta is the smallest EU member state. It is a unitary state with an uncomplicated public administration structure; providing a context that simplifies the research process. The procurers are identifiable and accessible to participate in research. Malta’s “GPP National Action Plan (NAP) 2022–2027” stated that “the Maltese Government is silently but surely committing itself to a greener modus operandi not least through its PP.” This highlights the importance of GPP across government ministries, which are the CAs. The limitation of the study is that Malta’s first GPP NAP was published in 2011, with the second implemented in January 2022. The findings may be affected by the fact that the latter was implemented during the course of this research.

The theoretical-conceptual framework presents the underlying theories and a selection of PP literature that guides the development of the research questions. The Research methodology describes the research methodology and methods used. The Research results presents the findings from the interviews and the documentary research, which are then analysed in the Discussion through the lens of the theoretical-conceptual framework. The Conclusion includes recommendations for future research and PP policy.

The theoretical-conceptual framework

Legitimacy, stakeholder and institutional theories

Prior literature has discussed legitimacy theory in detail (for example, Deegan, 2019; Suchman, 1995). Legitimacy theory does not prescribe how organizations should behave but seeks to explain their behavior and decision-making processes. Martens and Bui (2023) explored the use of legitimacy theory over time in social and environmental accounting, identifying complementary overlaps between legitimacy, stakeholder and institutional theories. GPP practices are perceived as the right thing to do by society and are widely accepted as the norm (institutional theory). They are also promoted and required by stakeholders (stakeholder theory). Practices are adopted by organizations so that they appear to be doing the right thing in the eyes of their stakeholders, regardless of the extent of their effectiveness (legitimacy theory).

Stakeholder theory examines the relationship between an organization and its constituents. A stakeholder is any person who may influence the organization’s goals or can be affected by them (Freeman, 2010). Various literature has attempted to define stakeholders, with Friedman and Miles (2002) distinguishing between legitimate stakeholders and those whose claims are deemed unworthy. Establishing and maintaining legitimacy in the eyes of influential stakeholders is one of legitimacy theory’s most pressing concerns (Suchman, 1995). Legitimacy is ultimately granted by the stakeholders with whom the organization interacts (Martens & Bui, 2023).

The legitimacy of a relationship with a stakeholder increases if institutional connections can be established. Institutional theory investigates organizational structures and attempts to explain why organizations with similar characteristics belong to the same organization field (DiMaggio & Powell, 1983). Organizations adapt to fit their organizational field, because they are rewarded with increased legitimacy, resources and survival capabilities (Meyer & Rowan, 1977). By adhering with the norms and values of society, such as paying attention to environmental issues, relationships with stakeholders would ultimately compel an organization to seek, acquire and reclaim legitimacy (Deegan, 2019). To gain legitimacy, organizations would intentionally align their practices with environmental expectations (Fernandez-Alles et al., 2006).

In the public sector, it has long been accepted that organizations are pressured by external stakeholders to conform with a set of expectations to gain legitimacy and secure access to vital resources (Beckert, 1999; Crossan et al., 1999). Such strategic alignment also applies to PP practices and green concerns. It is expected that a public administration demonstrates concern for the environment. Green practices would make it align to the organizational field and thus increase its legitimacy in the eyes of relevant stakeholders, like the citizens and international organizations. When presented as an established legal framework, the sustainable development demands of public procurers would be legitimized, as in the case of French public hospitals examined by Oruezabala and Rico (2012).

Institutional theory is a useful lens to explore challenges of implementing procurement practices because it highlights the tensions between achieving legitimacy and achieving efficiency (Ashworth et al., 2009; Meehan et al., 2016). Studying major IT PP projects in the UK, Russell and Meehan (2014) concluded that the survival of a project depends on there being sufficient belief in its legitimacy. Powerful rhetoric creates legitimacy, which is further fueled by the scrutiny process of major PPs and projects. However, legitimacy is maintained not through efficient delivery but through taken-for-granted adherence to legitimating activities (Russell & Meehan, 2014).

Practices and behaviors are institutionalized when they are widely followed, accepted without debate and appear permanent (Tolbert & Zucker, 1983). Stakeholder groups consider legitimate activities as acceptable standards of performance, and in regulated environments like PP, legitimacy can take a more dominant role than enhancing economic performance (Zucker, 1987). Erridge (2007) pointed out that the need for public bodies to comply with regulations (such as, the EU Public Procurement Directives) can result in propriety and transparency requirements to be considered as more important than economic goals.

Given the popular rhetoric that GPP practices are fundamental for improving the impact of PP on the environment, it is natural to question this link. Are GPP practices adopted just for the sake of stakeholders or to appear to be doing the right thing for society? Are GPP practices effective to support environmental policies? Or does legitimation drive GPP decision-making? The following section presents a selection of prior studies on GPP implementation.

An insight into GPP implementation research

This section contains a selection of studies relating to GPP, intended to reveal the gaps that can be targeted by this study.

Cheng et al. (2018) highlighted that GPP literature had focused on the specific effects of GPP adoption, neglecting efficiency and innovation implications. On the other hand, SPP literature focuses on technological and green production instead of social sustainability themes (Hamilton, 2022). Sönnichsen and Clement (2020) reviewed articles on SPP and GPP, concluding that awareness and comprehension of CPP characteristics are essential for its realization.

Cheng et al. (2018) noted that GPP has the potential to play a significant role in modifying unsustainable consumption and production patterns because it incorporates environmental concerns into the procurement of public products and services. However, Sönnichsen and Clement (2020) pointed out that SPP and GPP have characteristics that make PP more complicated than tendering and buying situations based on the lowest upfront price.

Circular economic principles address the UN’s SDGs, particularly, Goals 6–9 and 11–17 (Sachs et al., 2017). Cheng et al. (2018) claim that there is lack of evidence of any such link and that future research should study the process of including circular economy principles into PP, the barriers to CPP implementation and the collaborative approaches necessary for the success of GPP and CPP. Since then, various studies have analyzed the barriers to GPP implementation, for example, Rosell (2021), Nemec et al. (2023), Špaček et al. (2024), and the suitability of collaboration mechanisms (for example, Dimand, 2024). However, according to Rejeb et al. (2023), research is still undecided about the effect of CPP on green market development and sustainable innovation. Sönnichsen and Clement (2020) point out that studies are lacking with regard to how managerial and institutional dynamics can support and implement CPP practices. Their literature review analysis was carried out over three broad themes, namely: organizational aspects; individual behavior and practices; and operational tools.

Focusing on the organizational aspects, Sönnichsen and Clement (2020) concluded that the implementation of CPP practices needs to be organized and not haphazard; highlighting the importance of staff training to raise awareness and to develop cultural, managerial and operational structures. The CPP objectives need to be integrated at strategic decision-making level, with full political and administrative support. Policymakers need to consciously make an effort to include CPP values in their communications.

With regard to individual behavior and practices, Sönnichsen and Clement (2020) once again highlighted the importance of staff training because lack of awareness and knowledge has been found to be the weakest link in the shift from short-sighted PP practices toward PP with a long-term life cycle costing (LCC) perspective. In such a transition, the lowest cost is not the only variable to be considered. The decision should rely on the best relation between quality and price. However, higher PP costs are not always balanced by a lower LCC (Bauer et al., 2009).

At the end of the day, linear and CPP are based on the same requirements of a purchasing system; however, the latter is of a more complex nature and rather risky. Therefore, procurers tend to overlook the cyclical PP requirements to have a smoother process and avoid legal conflicts (Sönnichsen & Clement, 2020). Another obstacle is the commonly held perception that products and services obtained in this way are more expensive and would therefore further constrain budget allowances for public sector organizations.

On examining the behavior of public procurers in the Czech Republic, Plaček et al. (2021) found that their decision-making is in fact a trade-off between stewardship and administrative compliance, which are conflicting goals. According to prior literature, the trade-off between the lowest price criteria and ecological sustainability criteria should depend on the quality of stakeholders’ collaboration. For example, Lerusse and Van de Walle (2021) had found that public managers in Belgium, Norway, Estonia and Germany are willing to pay more for the support of innovative ecological and social PP goals. On the contrary, the minimization of risks and administrative compliance appear to be of a higher priority for Czech public administrators. Nemec et al. (2020, 2023) call it “bureaucratic safety,” where purchasing without risk means that procurers use the lowest price criterion instead of MEAT or LCC. Such insensitive decision-making would undermine the positive potential effects of GPP (as also noted by Erridge, 2007). Training in and awareness of GPP practices is one way of overcoming this hurdle on the part of the procurers (Nemec et al., 2023).

This selection of papers on GPP reveals two gaps. First, implementing GPP is not straightforward and public administrations face several challenges. For example, the quality vs price issue when judging tenders and the trade-off between lowest price criteria and sustainable environmental criteria; the relevance of LCC; decision-making that seeks to minimize risks and administrative compliance rather than seeking to fulfil policies; the importance of staff training to enhance awareness and understanding. Secondly, despite the intensive rhetoric propagated by public administrations and stakeholders that promotes GPP as accepted practice, it is not clear whether GPP is perceived as an effective environmental policy. This study explores these gaps in the context of one EU member state, namely, Malta. Based on the issues raised in the literature, as perceived through the lens of the theoretical framework, the overall aim of this paper is to see whether GPP is perceived as more than a legitimation exercise and considered effective to support the achievement of environmental targets. More specifically, this study aims to answer the following research questions:

1. What are the challenges and difficulties of GPP in practice?

2. What are the perceptions of public procurers on GPP processes and their effectiveness in supporting environmental policies?

Research methodology

Due to the exploratory nature of the research questions, a qualitative research methodological approach was adopted to enable an in-depth investigation and interpretation of the data (Flick, 2009).

The research methods used were documentary research and interviews.

The documentary research was carried out between January 2021 and March 2022. Table 1 lists the documents analyzed.

Table 1. Documentary research.

Reference	Document title	Address (where applicable)
Circular Economy Malta (2021)	Towards a Circular Economy	https://cemalta.gov.mt/circular-economy/
Contract Circulars	No 22/2014 No 13/2015 No 20/2015	Maltese Department of Contracts (DoC)
EC (2001)	GREEN PAPER: Promoting a European Framework for Corporate Social Responsibility	Brussels, European Commission
EC (2006)	Barriers to the take-up of GPP	https://ec.europa.eu/environment/gpp/barriers_en.htm
EC (2008a)	Communication from the Commission to the European parliament, the Council, the European Economic and Social Committee and the Committee of the Regions: Public procurement for a better environment	https://eur-lex.europa.eu/legal
EC (2008b)	Benefits of GPP	https://ec.europa.eu/environment/gpp/benefits_en.htm
EC (2012)	Green Public Procurement: A collection of good practices	https://ec.europa.eu/environment/gpp/pdf/GPP_Good_Practices_Brochure.pdf
EC (2014)	Life-cycle costing	https://ec.europa.eu/environment/gpp/lcc.htm
EC (2017)	Public Procurement for a Circular Economy	https://ec.europa.eu/environment/gpp/pdf/Public_procurement_circular_economy_brochure.pdf
EC (2019)	GPP Training Toolkit	https://ec.europa.eu/environment/gpp/toolkit_en.htm
EC (2019)	2019/1161: Clean Vehicles Directive	https://ec.europa.eu/
EC (2020)	Europe 2020: A European Strategy for Smart, Sustainable and Inclusive Growth	https://ec.europa.eu/eu2020/pdf/COMPLET%20EN%20BARROSO%20%20%20007%20-%20Europe%202020%20-%20EN%20version.pdf
EC (2021)	EU GPPcriteria	https://ec.europa.eu/environment/gpp/eu_gpp_criteria_en.htm
EC (2021)	Collaborative economy	https://ec.europa.eu/growth/single-market/single-market-services/collaborative-economy_en
EU (2016)	Buying green! A handbook on green public procurement	Third edition. Belgium: European Union
MECP (2018)	Malta’s Sustainable Development Vision for 2050	Ministry for the Environment, Climate Change and Planning
MECP (2018)	Green Public Procurement National Action Plan 2019–2025	Ministry for the Environment, Climate Change and Planning.
MECP (2021)	Green Public Procurement National Action Plan 2022–2027	Ministry for the Environment, Climate Change and Planning
National Audit Office (2019)	National Audit Office Strategy 2019–2023: Improving Governance and Performance across the Public Sector	National Audit Office
Procurement Policy Notes (PPN)	PPN 33 Eligibility to include GPP criteria	DoC
Public Procurement Regulations (2016)	Subsidiary Legislation 601.03	https://legislation.mt/
UN (2012)	United Nations Conference on Sustainable Development, Rio + 20	https://sustainabledevelopment.un.org/rio20
UN (2018)	Malta’s Main Messages in preparation of the Voluntary National Review	https://sustainabledevelopment.un.org/index.php?page=view&type=30022&nr=969&menu=3170
UN (2021)	Voluntary National Reviews	https://sustainabledevelopment.un.org/vnrs/
United Nations Environment Programme (2017)	Global review of sustainable public procurement	Available at. https://wedocs.unep.org/bitstream/handle/20.500.11822/20919/GlobalReview_Sust_Procurement.pdf?sequence¼1&isAllowed¼y

Semi-structured interviews were conducted between December 2021 and February 2022. The interview questions were based on the literature and divided into two sections consistent with the research questions identified previously.

The focus of the study was to analyze GPP across Maltese Government Ministries falling within the scope of Schedule 2 and 16 of the PP Regulations. Therefore, 21 GPP coordinators from the Ministries, being CAs, were contacted and invited to participate in an interview. Only six accepted. However, the number of interviews conducted was enough to reach a conclusion because the interviewees were providing similar answers. This indicated that saturation was achieved.

Two directors from the GPP Office and the DoC, and two auditors from the NAO, were also contacted and interviewed. Table 2 is a schedule of all nine interviews held and their respective code.

Table 2. Interviews and research participants.

Research participant’s codes	Ministry code	Ministry	Characteristics
I-01	DoC	Department of Contracts (within the Ministry for Finance)	This department is responsible for PP processes, but only has a minor role in GPP. For example, it publishes Contract Circulars regarding GPP, because the GPP Office does not have the power to issue them.
I-02	Ministry A	Ministry for Gozo	Each Government Ministry has its own GPP Co-Ordinator. Their role includes: (a) giving clearance to tenders/quotations with an estimated procurement value of Eur 5,000 and over, and (b) checking that draft tender documents are greened in compliance with the GPP criteria.
I-03	Ministry B	Ministry for Home Affairs, National Security and Law Enforcement
I-04	Ministry C	Ministry for the Economy and Industry
I-05	Ministry D	Ministry for Foreign and European Affairs
I-06	Ministry E	Office of the Prime Minister
I-07	Ministry F	Ministry for Social Justice and Solidarity, the Family and Children’s Rights
I-08	GPP Office	GPP Office (within the Ministry for Environment, Climate Change and Planning)	The role of the GPP Office is similar to a regulator. It oversees the uptake of GPP and ensures compliance by the GPP co-ordinators within the Ministries. The Office provides training for CAs and EOs, and consults with them.
I-09	NAO	National Audit Office	This Office is not involved in the PP process or making regulations. The NAO examines extent of adherence with regulations by the Ministries and the DoC. The Office can carry out VFM studies on particular PP processes or parts thereof.

The qualitative methodology used has limitations, including bias in interviewees’ responses and the inherent subjectivity in interpretation (Saunders et al., 2019).

Research results

The documents analyzed were helpful to outline the current GPP practices in Malta, and to highlight the underlying normative pronouncements regarding GPP. In this section, the results from the document analysis are integrated with those from the interviews. The results are presented in two sub-sections, with each sub-section representing the results relating to a research question.

The challenges and difficulties of implementing GPP in practice

The findings from this study point to challenges in implementing GPP which are like those identified in the literature, covering organizational aspects, individual behavior and practices, and operational tools (Sönnichsen & Clement, 2020). Complications arise in practice due to the implications of a circular and collaborative economy, LCC, and pricing criteria for assessing tenders. But perhaps the most daunting task for the CAs is the identification of the GPP criteria targets themselves, which complicates the GPP process right from the start.

GPP criteria targets: mandatory vs non-mandatory criteria

The level of greenness of a tender is measured by the extent to which green criteria are included (Testa et al., 2016). The EU GPP criteria include twenty products and services, which are divided into mandatory and non-mandatory. Although GPP is a voluntary instrument, nearly all Member States, including Malta, have developed an NAP, where the EU criteria are adopted according to their political framework. Malta’s first NAP 2012–2014 included criteria for eighteen products and services. These were reduced to seventeen in the second NAP 2022–2027 (EC, 2021; MECP, 2021).

In the first NAP, the GPP coordinators stated that they were not including non-mandatory criteria because they found them difficult to implement. Most of the non-mandatory criteria of the first NAP were either excluded from the second NAP or became mandatory.

“The second NAP has completely changed the existing criteria, making them more challenging” (I-03).

The increased mandatory criteria in the second NAP push for more environmentally friendly products and services. Therefore, the CA does not have a choice whether to include it or not. Furthermore, exclusion of non-mandatory criteria needs to be explained. Such reasons have to fall under one of the three categories, namely, that the market is limited; the market does not offer the product; or it is too expensive to procure it. Then, the GPP Office has to approve the reason (MECP, 2021).

In the first two years of the implementation of the first NAP, the 50% target of tenders that fell within the remit of GPP was not reached. According to MECP (2021), the market was not ready since it is mostly characterized by SMEs, which find it more difficult to comply with GPP because of higher costs incurred when buying sustainable products. Another reason for not meeting the 50% target is due to CAs being overwhelmed with new PP regulations as well as the ePPS, and thus GPP was perceived as a burden (MECP, 2021).

Initially this was expected since GPP was a new concept and there will always be some form of resistance. (I-08)

Unfortunately, in the beginning, drafters and evaluators perceived GPP as a burden, and thus, the easy way out for them was to not include non-mandatory criteria. (I-03)

I-02 believed that the market was still not fully ready for GPP. However, the GPP Office stated they are confident to achieve a 90% target of tenders that fall within the remit of GPP, for the second NAP. They are aiming to achieve this target after the first year of implementation, given that most of the criteria have become mandatory and the market is now accustomed to GPP.

I think people will prefer to green the tender immediately instead of giving a reason for not including the non-mandatory criteria. What justification are you going to give for not including it? (I-04)

The GPP coordinators think that all the criteria will become mandatory, with the GPP Office stating that this is its aim as it pushes for a greener government procurement which also helps reach international targets. One of these targets is the Clean Vehicles Directive (EU, 2019/1161) which states that energy and environmental impacts should be considered in the technical specifications, award criteria, operational lifecycle cost or a mix of these options. Malta adopted this directive in the second NAP—the transport criteria require that when passenger cars, buses or public transport are procured, the targets set by the directive should be considered in the technical specifications and/or award criteria if BPQR is used.

The aim is to make all criteria mandatory, however, one must consider that the market evolves and thus, the criteria should change accordingly. (I-03)

With regard to the greening award criteria initiative, some GPP criteria have become mandatory to award using BPQR, where 15% of the total points must be allocated to GPP. For the remaining GPP criteria, it is up to the CA to allocate points as it deems fit (MECP, 2021). BPQR encourages bidders to offer more environmentally friendly products (I-01). However, as shall be mentioned later, most GPP coordinators find BPQR difficult to apply.

Innovative forms of consumption—circular and collaborative

GPP aids in improving the quality of life through enhancing the public services and establishing high-level environmental performance criteria for products and services. GPP preserves resources through life-cycle costing, incentivizes innovation and reduces prices for green technologies. Ultimately, GPP is a valuable tool in establishing the public sector’s commitment to environmental preservation and sustainability (EC, 2008b).

All interviewees agreed that innovative forms of consumption suggested by the EC (2015) encourage the development of the circular economy, which aims at reducing the waste of resources through the principles of sharing and reusing. This increases worldwide competitiveness, creates new jobs, and stimulates sustainable economic growth.

Circular Economy Malta (2021) was established by MECP to implement actions that encourage a circular economy. Since Malta is highly dependent on importation, a circular economic system will only be successful if entrepreneurs develop circular business models focusing mainly on reusing and recycling. Such models consider the products’ lifecycle process, where the waste at the end of the lifecycle is not disposed but considered as a resource for new products (Circular Economy Malta, 2021).

The collaborative economy encourages sharing of resources which creates new opportunities for citizens and entrepreneurs. However, conflicts between existing entrepreneurs and new ones have been created. Thus, the EC is still researching how it can encourage a collaborative economy without compromising social and customer protection (EC, 2021). Consuming services rather than products and exploiting technology to improve performance are some of the characteristics of the collaborative economy. This study found that some Ministries were already consuming more services than products.

Life-cycle costing (LCC)

Most interviewees recognized the importance of LCC, but never used it. They find LCC similar to the cheapest award criterion, and they prefer the latter. The selection of the winning EO is based on the lowest price if only the price, mandatory qualification and exclusion criteria are taken into consideration during the evaluation stage. Conversely, the selection is based on the most economically advantageous tender (MEAT), if green criteria are optional and are awarded according to the best price–quality ratio (BPQR). MEAT is often combined with mandatory criteria to achieve the most transparent result.

BPQR is more beneficial for green targets than LCC as an award criterion. Both BPQR and cheapest award criteria have an element of LCC. (I-01)

Nevertheless, I-08 explained that LCC is included in the GPP technical specifications. Therefore, indirectly, all GPP coordinators utilize LCC. In fact, in the “Office IT Equipment” criteria, technical specifications include a minimum guarantee period of three years and removable batteries and memories. Thus, the manufacturer must be able to provide spare parts and after-sales services, which ensures that a laptop is not used for a short period and scrapped. The CA guarantees that the product will remain in the market for a longer time, making better use of its resources, which is the environmental benefit behind LCC.

I-08 also noted that LCC does not necessarily increase the price. When demand for a product increases, there is a fluctuation in price which is not necessarily dependent on whether the product is environmentally friendly or not. For instance, electric vehicles are more expensive than regular cars. However, the environmental benefit of electric vehicles is much higher.

The NAO stated that the best way for CAs to reach VFM in their tendering is to view the procurement cost from an LCC perspective. However, it was noted that most public officials associate VFM with the cheapest, which is not technically correct since VFM also considers quality.

BPQR vs lowest price

Although BPQR is more difficult to audit, it is the award criteria leading to the best VFM. This is because BPQR considers factors other than the initial price such as the whole life cycle and the quality of the product or service. (I-09)

The GPP coordinators believe that GPP lengthens the tendering process, making it unfeasible for low-value tenders. CAs would find loopholes to buy products that are not GPP-compliant—thus undermining GPP (I-03). Most GPP coordinators find it harder to implement BPQR than the cheapest price. This results in the cheapest award criteria being used to award GPP-compliant tenders. However, BPQR leads to the best VFM according to the NAO. In fact, BPQR results in the consideration of LCC and not only the initial price.

The cheapest award criterion is easier to implement and when GPP is mandatory, it is the preferred option. However, BPQR allows giving points even when GPP criteria are non- mandatory. (I-04)

BPQR encourages EOs to become greener (I-04). For example, the minimum green criterion when procuring cars is Euro-5. However, with BPQR, the bidder has the motivation to provide a Euro-6 car or even an electric one. With the cheapest award criteria, green criteria can be included in the technical specifications. However, it was noted that this does not increase the chance of the bidder winning the tender. Thus, the bidder is not actually encouraged to be greener, as satisfying the minimum green criteria is enough.

According to MECP (2021), a tender based on the cheapest price makes it even more difficult for SMEs. BPQR attracts more competition since some companies may find it hard to bid on price alone. Thus, the element of quality encourages them to bid.

GPP-compliant tenders vs normal tenders

The common perception of the interviewees is that GPP-compliant tenders are more expensive because certain green products are certified with a standard of environmental friendliness.

EOs complain that certain industries are more expensive than others since they have fairly new technology, which, although efficient, necessitates certain investments to start supplying the new products. (I-01)

I-03 stated that GPP-compliant products without GPP certification may still cost more. For example, microfibre cloths are GPP-compliant but do not have certification. However, such cloths still cost more than cotton cloths. Although cotton cloths are cheaper, they must be changed frequently. Conversely, cotton is a natural fiber that dematerializes faster than microfibre. Thus, the cotton cloth leaves a smaller environmental footprint than the microfibre, even though it is cheaper.

What are the perceptions of public procurers on GPP processes and their effectiveness on supporting environmental policies?

GPP safeguards our environment by being cautious of the consumables that we procure. Malta is conscious of climate change, thus GPP is a sensible move towards sustainability, being implemented by not only the government but also by private households.

(I-02)

GPP processes

It appears that the institutions required to support GPP processes have been strengthened. The second NAP established new initiatives, comprising the reinforcement of the Ministry GPP coordinator and the greening award criteria (MECP, 2021). All GPP coordinators agreed with increasing training and constant refresher courses. They also agreed with the pooling of green advisory experts’ initiative to deal with technical GPP criteria, which would reduce the pressure on the GPP Office (MECP 2021).

Although GPP is about being more concerned about procurement, it complicates the tendering process.

(I-04)

According to two interviewees (I-01 and I-03), it is difficult to make GPP regulations since there are no EU Directives about GPP. GPP is very technical, and the market is constantly changing.

The common perception of the GPP coordinators is to have something easier than the GPP guidelines which simplify the GPP criteria. They perceive GPP criteria as a regulation since most of them are mandatorily enforced by Contract Circulars and PPNs. For example, PPN 33 states that, where tenders fall under the remit of mandatory criteria, CAs must include this in their tender document.

The interviewees highlighted that simplified guidelines would make it easier for drafters and evaluators who are not experts on GPP to become more fluent in its implementation, whilst also shortening the tendering process. Currently, if a GPP coordinator is reviewing a tender that should include GPP criteria but does not, it is his/her responsibility to either include the criteria him/herself or else refer back to the CA and instruct it to include them.

GPP requires more preparation even though the criteria are established since one must decide whether to include them or not.

(I-04)

The new ePPS enhancements, although helpful for the GPP Office for collecting statistics, are still perceived by some GPP coordinators as lengthening the tendering process. This is mostly due to having to publish the data online and having to set a budget separately for the GPP criteria. For instance, when procuring a passenger vehicle, the transport GPP criteria are 100%; thus, the GPP cost would be the full cost. However, if concrete slabs are being procured, only their disposal falls under GPP criteria. Thus, a separate GPP budget needs to be estimated.

The ePPS has made the procurement process rigid and bureaucratic where, although fewer mistakes are being made, Ministries and entities are being discouraged from following the PP Regulations and are instead procuring through direct orders.

(I-09)

Effectiveness

All interviewees believed that GPP aids the government reach its policies related to the environment.

The “2030 Agenda for Sustainable Development” encourages EU Member States to conduct voluntary regular reviews of the national level progress. The Voluntary National Reviews (VNRs) aim at accelerating the implementation of the 2030 Agenda by portraying the accomplishments and challenges faced and seek to reinforce policies and government institutions for the implementation of the SDGs. Malta’s VNR portrayed ways by which it was increasing SDG implementation, referring to SDG 12 as vital in enhancing economic growth and safeguarding the environment.

“Vision 2050” recognizes that circular consumption and production patterns can aid in achieving sustainable development through managing and preventing waste, reusing resources and GPP. Since public authorities are the main customers of commodities, if they use their purchasing power to consume goods, services and works which have a reduced environmental impact, they will be making an important contribution toward both national and global sustainability goals (MECP, 2018).

GPP can only influence the government’s spending. However, one of GPP’s main scope is to encourage the private sector to also become more environmentally friendly.

(I-08)

As an example, the GPP Office referred to the change of the government’s fleet of vehicles to electric ones. This initiative not only benefits the environment but also serves as an example for the private sector to follow suit. With the government buying electric vehicles, the electric charging points will be increased which continues to encourage private sector investment. More schemes are being implemented to encourage the buying of electric vehicles. Thus, GPP has created new markets where suppliers are encouraged to import electric vehicles and consumers are encouraged to buy them.

GPP is one of the major green and economic recovery drivers (I-01).

Discussion

PP is heavily regulated because it concerns handling of public funds. Probity and accountability are paramount. These characteristics create a context for legitimating decision-making (Zucker, 1987). Despite the intense rhetoric on climate change concerns, GPP is not universally treated with the same level of importance (de Leonardis, 2011; Rosell, 2021). In Malta, the CAs have to sift through mandatory and optional green criteria, which becomes more complicated due to EU regulations (as also noted by Nemec et al., 2023, for other smaller-sized EU member states). Besides undermining the whole scope of GPP, it complicates the work of the CAs. And it also makes the tendering process difficult for EOs because their tender could easily be non-compliant. Thus, GPP is perceived as a burden rather than an effective tool to achieve environmental goals (Erridge, 2007).

The result is that the Maltese public administration chose to reduce the number of green criteria in the second NAP, while also increasing the number of mandatory criteria. This was an attempt to simplify the PP process, which is crucial if the effectiveness of GPP is to be upheld. Similar to the Czeck administrators in Plaček et al. (2021) study, and other “post-socialist” countries in Nemec et al. (2020, 2023) studies, the Maltese administrators prefer to minimize risk by complying to administrative rules. Procurement officials demonstrate a reluctance to bear the risks and extra work of using complicated criteria, especially when the criteria are not clear. GPP practices are perceived as legitimate because they are widely followed (Tolbert & Zucker, 1983). However, this study confirms that a tension exists between legitimacy and the actual achievement of objectives (Erridge, 2007; Russell & Meehan, 2014) because of difficulties and challenges in GPP implementation (Testa et al., 2016). Thus, formal implementation may occur especially when there is external pressure, like EU rules and foreign donors (Nemec et al., 2023)

Powerful rhetoric creates legitimacy (Russell & Meehan, 2014). As expected, Maltese policy makers specifically mention GPP and demonstrate concern for the environment mainly due to stakeholders’ pressure, for example, EU regulations. However, implementation seems to encounter a bottleneck in the final decisions taken by CAs. The need to simplify the process is emphasized by the CAs’ demand for more training and the access to green advisory experts. This is in line with Sönnichsen and Clement’s (2020) suggestions to develop cultural, managerial and operational structures. Nemec et al. (2023) also suggest government intervention to stimulate the production of economic products (like the Maltese Government’s policy on electric vehicles) and using the media to raise awareness of politicians and the public about GPP.

One important reason that may have led to the low achievement of criteria in the first NAP is the undeniable fact that the Maltese economy is small (both at EU and international level). This means that the tendering opportunities for EOs would be limited in size (quantity and value), which could impede the feasibility of adhering to green criteria (Nemec et al., 2023). This is an organizational aspect relating to individual characteristics that was overlooked in Sönnichsen and Clement’s (2020) conclusions. Collaborative mechanisms could jump over this barrier (Dimand, 2024).

The role of EOs in the successful implementation of GPP cannot be emphasized enough. The importance of a circular economy is recognized for fulfilling environmental policies (Sachs et al., 2017); however, it can only be successful if EOs develop circular business models that focus on reuse and recycling. As highlighted by Cheng et al. (2018), a collaborative approach is required for success—an approach that unifies the CAs and the EOs. After all, GPP practices are highly supported as being the norm for society which need to be followed by all institutions in the same sphere.

The price of GPP-compliant products is normally higher than non-compliant products. It is not just a perception as stated in the literature. And it proves to be an actual obstacle for SMEs that do not have the required capacity. This is contrary to what the policy makers expect. According to MECP (2021), besides resulting in the best VFM, BPQR allows SMEs to compete with other EOs. The reasoning is that other environmental and health advantages should balance the added costs. The purchase cost should not be the only consideration; instead, the LCC should be estimated, by considering usage, maintenance, and disposal expenses (de Leonardis, 2011). This is because most of the time, a higher purchasing price is compensated by the lower operating cost and increased environmental benefits. According to Bauer et al. (2009), alas, this is not always the case.

The Maltese CAs apply MEAT for a tender with optional green criteria, which are awarded according to BPQR. Indirectly, then, LCC is included in the technical specifications, even though the CAs claim that they never use LCC. However, the CAs think that the cheapest price leads to VFM, which is not a correct view, according to both the NAO interviewed and the literature. In LCC, the lowest cost is not the only variable. As already stated, the findings from this study point to the need for training and the development of human and organizational capacity with regard to LCC, as emphasized by Sönnichsen and Clement (2020), Nemec et al. (2023) and Špaček et al. (2024).

The research participants agree with the literature that, when the public sector promotes a greener market, it influences the private sector to become greener (Bauer et al., 2009; Lundberg & Marklund, 2018). GPP expands the local green economy, effectively creating more jobs and strengthening both the environment and the economy. Therefore, GPP attains environmental objectives whilst also considering social and economic aspects. This makes GPP a necessary cog in the process of a government’s execution of environmental policies.

However, there are also obstacles (Cheng et al., 2018; Testa et al., 2016). The findings from this study confirm that GPP is perceived as a burden that lengthens the tendering process. This perception is exacerbated with the complexity of the ePPS. Although ePPS increases transparency, it discourages users because it is too bureaucratic. Therefore, besides training the users (i.e., the CAs) in the technical aspects of GPP and LCC, the process itself needs to be refined so that it becomes more user-friendly and effective. Therefore, success can only be achieved by investing in human resources and systems and develop strong cultural, managerial and operational structures (Nemec et al., 2023; Sönnichsen & Clement, 2020).

One can conclude that the present state-of-play in Malta’s GPP practices are more like “expectations” to contribute toward the fulfillment of environmental policies (Malatinec, 2019). There is actually no tangible link. The study illustrates how tension is created between effectiveness and legitimacy—adhering to legitimating activities is more important than achieving one’s objectives (Ashworth et al., 2009; Meehan et al., 2016). Having said this, the authors still believe that GPP is necessary. The legitimacy of the discourse lies in the fact that environmental concerns are real. And such concerns are not going away on their own.

Conclusion

This study fills a gap in the literature regarding GPP by providing insights into the complexities that CAs face when implementing GPP. It then explores perceptions on the effectiveness of GPP processes to support the fulfillment of environmental policies.

This paper presented a study about GPP processes at central government level. The implementation of GPP in the Maltese public administration was perceived as an important step toward the execution of environmental policies. The overall aim of this study was to assess the effectiveness of GPP in this respect. To achieve this aim, the perceptions of Government Ministries (being CAs) on GPP was explored, together with the attendant challenges in implementation.

Legal barriers, motivation and organizational structure (amongst the challenges to GPP-use identified by Rosell, 2021) can somehow be circumvented; but capacity (know-how) and financial constraints (on the budget) to the use of GPP are endemic for a small nation, like Malta. It is difficult to find a country that is comparable with Malta when it comes to size; however, we can look at the other smaller EU member states. For example, Nemec et al. (2023) examined four “post-socialist” countries, including the Czech Republic and Slovakia. Their study confirmed that, on top of adhering to EU regulations, the national legislation included the relevant provisions for the use of GPP and sometimes promoted its use. Still, the actual scale of GPP was marginal due to barriers, especially with regard to budget constraints, human skills and expertise and other capacities. Similar results were obtained by Špaček et al. (2024) when concentrating on the Czech Republic. Despite legal requirements, GPP is not automatically included in tender documents. In practice, technical specifications may require compliance with environmental-friendly criteria (for example, an eco-label), but still, the ultimate decision is based on the lowest price. These findings are very similar to this Maltese study. Even with regard to the risk-averse attitude of the officials responsible for public procurement. Simplifying the process to purchase without delay is also considered critical—especially for purchases financed from EU funds. In these circumstances, the lowest price criterion is preferred to MEAT and LCC (Nemec et al., 2023).

Given that environmental issues may arise at various stages in a procurement contract (de Leonardis, 2011), one cannot just consider the lowest purchasing price, but needs to employ GPP practices throughout the entire process. The expertise and awareness required for LCC in practice appears weak in the Maltese environment. Small governments lack the necessary resources to pursue and implement policy innovations like GPP (Dimand, 2024). Collaboration between organizations can provide access to required resources, including, financial and technical. Public procurers may thus consider collaboration mechanisms (as suggested by Dimand, 2024)—either public–public (horizontal mechanisms) and/or private–public (vertical mechanisms). The latter would involve EOs in the process. The former may involve twinning projects with local governments in other EU member states. Such collaborations may result in higher priced contracts, which may lead to more extensive use of GPP (Rosell, 2021).

Similar to the Maltese results, the Czech public procurers in Špaček et al. (2024) study criticized the national legislation as to lack of clarity on the use of GPP elements and requested further guidance and training. Contrary to the Maltese results, the training provided was unstructured and inadequate. Špaček et al. (2024) thus highlight the importance of collaboration within the institution itself and with external bodies, even to help identify reasonable GPP criteria. On its own, a small nation would need to rely on the role of a central authority in disseminating GPP (Cheng et al., 2018; Liu et al., 2021; Špaček et al., 2024). In this respect, the Maltese administration appears to have established suitable institutional structures.

GPP is one of the various measures being taken by the Maltese Government to push for sustainability, as required by its stakeholders (Deegan, 2019; Nemec et al., 2023) and its environment (Fernandez-Alles et al., 2006). The study showed that GPP coordinators have a positive perception of GPP. However, they are finding the second GPP NAP harder to understand, especially when implementing its green criteria. The green aspect of PP is seen as a burden that lengthens the PP process and makes it complicated (Cheng et al., 2018; Testa et al., 2016). The findings point to the need for GPP criteria to be simplified, while the frequency of training on GPP should be increased (Sönnichsen & Clement, 2020; Špaček et al., 2024).

Making all GPP criteria compulsory is one way of simplifying the process (Liu et al., 2021; Špaček et al., 2024). But the extent of including mandatory GPP criteria in tenders should be a national decision, according to the circumstances of the country and the requirements of the citizens as the more important stakeholders. This would enhance the legitimacy of the regulations (Russell & Meehan, 2014), while reducing the negative effects of insensitive decision-making by CAs (Erridge, 2007; Nemec et al., 2020, 2023; Plaček et al., 2021).

The findings indicate that green products are still perceived to cost more than others, which is an unresolved issue even in the literature. This is a challenge to proper implementation of GPP, as is the fact that there is no conventional method of estimating the procurement value, with the cheapest award criterion being preferred. There is awareness of LCC, but it is not integrated into decision-making, as suggested by Sönnichsen and Clement (2020).

Finally, it is perceived that GPP helps the government to execute its environmental policies since greener products are always beneficial. GPP is also an economic tool that influences the private sector to become more sustainable. However, there is no hard evidence that GPP actually contributes toward a better environment. The existence of the link is taken for granted and may be just a perception.

This study concludes that managerial decisions are taken to legitimize actions, so that the administrator appears to be doing the right thing in the eyes of the stakeholders. Institutions intentionally adopt GPP to follow the norms and values of society. The practice of GPP appears to be carried out for legitimacy purposes, that is, it is seen as the right thing to do, believing that it effectively promotes societal welfare (Sachs et al., 2017). Mainly due to the strict legal context, public sector entities are more susceptible to adhere to established practices to obtain legitimacy (Beckert, 1999; Crossan et al., 1999). Whether GPP has a positive effect on the environment is a secondary objective.

The implications of this study are that there are still many challenges being faced with regard to GPP implementation, which need to be overcome through investment in education about GPP, training GPP officers, and promoting GPP to increase its awareness across the commercial sector and private households (Nemec et al., 2023; Špaček et al., 2024). Despite this, the authors still believe that small steps are better than no steps at all. If GPP practices are a “fad,” then they are a crucially relevant trend, making GPP practices a necessary move by public administrations—legitimating activities prevail over effectiveness (Russell & Meehan, 2014).

The conclusion is limited to the GPP coordinators’ perceptions of GPP, that is, the CAs. GPP is a process that involves both the CAs and the EOs. While this study has highlighted some of the implications of GPP for EOs, future research could focus on their perceptions.

Disclosure statement

No potential conflict of interest was reported by the author(s).