EU Regulation 2026/718: Sustainability Requirements for Net-Zero Public Procurement

What You Need to Know

On March 20, 2026, Implementing Regulation (EU) 2026/718 lays out the application modalities for Regulation (EU) 2024/1735 regarding minimum environmental sustainability requirements during public procurement or concession procedures for certain net-zero technologies.

Key Points

• Enters into force on March 20, 2026 across the European Union.
• Reference: Implementing Regulation (EU) 2026/718, OJ EU L of March 22, 2026.
• Immediate operational impact for international trade operators subject to EU public procurement procedures.

Background and Issues

The transition to a carbon-neutral economy requires the integration of environmental sustainability criteria in European public procurement. On March 20, 2026, the European Commission adopted Implementing Regulation (EU) 2026/718, specifying the modalities of application for Regulation (EU) 2024/1735 of the European Parliament and Council. This regulatory framework mandates the inclusion of minimum environmental requirements in any procurement procedure for the purchase, lease, or concession of technologies categorized as "net-zero" under the European nomenclature. Public procurement thus exerts a driving effect on the industrial sector and the supply chain, strengthening the compliance of all actors (declarants, importers, exporters) with environmental standards of the European Union. The specific references are Implementing Regulation (EU) 2026/718, Regulation (EU) 2024/1735, published in OJ EU L_202600718.

Impact for the Profession

The regulation reinforces environmental compliance obligations for declarants, importers, and exporters involved in the supply or provision of services regarding net-zero technologies in the EU. Freight forwarders must anticipate the collection and provision of required sustainability documentation for tariff classification and customs management. Compliance officers must ensure all documentation aligns with the reference texts of EU legislation. Tender procedures must explicitly reference the environmental criteria required by Regulation (EU) 2026/718, or face invalidation. Non-EU subcontractors must guarantee the conformity of their products and processes, under penalty of exclusion from contracts and possible administrative sanctions.

Next Steps

The regulation applies immediately from March 20, 2026. The industry must update internal audit procedures, integrate sustainability requirements into the documentation submitted to contracting authorities, and train personnel on the new criteria. Bidders aiming to participate in public tenders for net-zero technologies must promptly audit their supply chains for conformity and adapt their tariff classification practices in accordance with European environmental requirements.

20 March 2026: new minimum sustainability requirements are imposed on EU public procurement.

Source: EUR-Lex OJ Legislation, Implementing Regulation (EU) 2026/718