How France takes an ambitious approach to the roll-out of the CO₂ Performance Ladder

In 2024, the first tenders using the CO₂ Performance Ladder in France were launched. And not by any old procuring parties. Participants include the national postal company La Poste, grid operator RTE and RESAH, the central purchasing body for the healthcare sector. Together, the tenders cover an amount of several billion euros. This could make a huge impact in terms of CO₂ reduction. Jenny Bourhis explains how ASEA built trust with these parties to start working with the CO₂ Performance Ladder and how together they are putting the Ladder on the map to roll out the system as widely and as quickly as possible.

Several tools for setting emissions targets and measuring and managing CO₂ reductions already existed in France. What was still lacking was a powerful tool that could be used in tenders to make a broad impact when it comes to reducing CO₂ emissions in industry, says Jenny Bourhis, director of ASEA, an organisation dedicated to sustainable procurement in France. ‘The strength of the CO₂ Performance Ladder lies mainly in its overall package. The Ladder is aimed at both contracting authorities and executing parties, is suitable for different types of sectors and different sized companies, and focuses not only on figures and numbers, but also on communication and cooperation. Such an all-in-one tool is indispensable to take real steps and structural progress.’

Building a robust system

In 2023, ASEA officially decided to roll out the Ladder in France. To build a robust system as soon as possible, you have to go big right away, was ASEA’s conviction. Bourhis: ‘So instead of approaching small contracting authorities first, we immediately started looking for authorities with a high profile and whose tenders had a huge reach. In the end, we approached three parties: RTE, the operator of the transmission network in France; La Poste, the national postal operator; and UGAP, an organisation that publishes public tenders on behalf of authorities such as cities and regions. Together, they spend around €10 billion annually on procurement. By using the CO₂ Performance Ladder in tenders, they can make a huge impact with CO₂ reductions, for example when carrying out works.’

In line with procurement legislation

All these stakeholders, like other public services, must work on emission reduction as part of their climate goals, says Bourhis. ‘So they were definitely open to the CO₂ Performance Ladder. But there was also caution. The main question from the parties was whether deploying the Ladder would be in line with procurement law from France and Europe. We ourselves had already engaged a lawyer to look into this in depth. Through several workshops, we discussed this with the three parties, where they were able to share all their concerns and questions with the expert. In the end, we were able to show that using the CO₂ Performance Ladder is fully in line with French public procurement legislation and European Public Procurement Directives. That cleared the biggest hurdle. The only thing is that parties in France – toward a French jurisprudence – are not recommended to work with a fictitious price as an award advantage. Instead, they can, for example, use a points system as a reward.’

Explaining the Ladder and communication

Besides the question of whether implementing the Ladder is in line with national and international regulations, it was also important that parties know exactly what the CO₂ Performance Ladder entails and how to use it, Bourhis continues. ‘For that too, we organised a workshop. For this, we had invited, among others, a certifying body and contracting authority from Belgium. Not only because they already have a lot of experience with the Ladder in that country, but also because they speak French. That makes communication a little bit easier. Finally, we held a workshop on how contracting authorities communicate externally on the Ladder and how they can motivate contractors to get certified. Ultimately, you want to use tenders to encourage the market to actively engage in CO₂ reduction.’

Launching first tenders with the Ladder in France

After the parties were convinced to start using the Ladder in tenders, they could start publishing them. Bourhis: ‘The interesting thing is that the tenders are very diverse, which means we can immediately address a broad market. In the case of La Poste, for example, it concerns a tender contract for all their data hosting. Data centres emit a huge amount of CO₂, so there are a lot of gains to be made there. RTE’s tender concerns the laying of underground electric cables. For this, they are looking for a total of 30 contractors. At 4 billion euros, this is also the largest tender. That is really a huge amount. The UGAP tender is a framework agreement covering several strategic advisory lots and represents a major initiative to strengthen public institutions’ capabilities in real estate, sustainability policies, and finance. La Poste’s, RTE’s and UGAP’s tenders all have been published.’

Even more parties on board

Meanwhile, two other major organisations have also decided to start tendering with the Ladder, Bourhis is pleased to say. ‘The first is RESAH, the central purchasing body for the healthcare sector. They have published a tender for asbestos removal, with one party already selected to carry out the work. The other party is Grand Lyon, the conurbation around the city of Lyon. Lyon is the second largest city in France after Paris, so sustainable procurement of works and services could be a huge hit. They are expected to publish their Ladder tender focusing on infrastructure maintenance by the end of 2025.’

Knowledge sharing through community of practice

Besides launching the individual tenders, ASEA also tries to join forces of the parties involved. This is done through a community of practice. Bourhis: ‘In this community, we meet every two weeks digitally. During such meetings, we share experiences and knowledge, for example on how to reward tenders or what to do if a party does not meet the requirements of the set ambition level. We also invite experts, including from SKAO. We had them observe and discuss on the first tenders. We have now even developed a do-it-yourself kit containing the most important tools. With the idea that procurers will be able to work more and more independently. So in the first few years it is mainly a lot of capacity building to sort everything out and set it up properly, after which we hope that parties will increasingly pick it up themselves and we will be able to support more from afar.’

Challenging parties in ambition

Although the Ladder is still in its infancy in France, Bourhis already dares to look further into the potential of using it in tenders. For example, when it comes to extending or amending contracts with parties carrying out the work. ‘To further challenge suppliers, you could, for example, promise them a financial reward if they raise their level of ambition after a year. A supplier then performs the contract to the requirements of level 3 (version 3.1) the first year, but to level 4 the second year. For the contracting authority this is very simple, you don’t have to start setting all kinds of additional requirements yourself. Only the level of ambition changes, but whether a party meets it is checked by an independent certifying body. I think it will be very interesting to see how that works out.’

Cooperation with SMEs

ASEA is currently trying to land the CO₂ Performance Ladder in France not only among contracting authorities, but also with the market itself. For instance, it has recently entered a partnership with Pacte PME, an association that works to promote good relations between procurers and SMEs. ‘Pacte PME launched a decarbonisation alliance last year to help SMEs reduce their CO₂ emissions. The CO₂ Performance Ladder can play an important role here. So with our partnership, we are creating a win-win situation. We have already done a first webinar. SMEs are the largest target group for the Ladder. 75 per cent of the companies that are now Ladder-certified in the Netherlands and Belgium are SMEs. It is important that we have a tool that is accessible to a broad group.’

Support from national government

Ultimately, Bourhis hopes that within a few years the CO₂ Performance Ladder will become a standard tool that cannot be left out of the French procurement landscape. ‘Not only in the field of public, but also for private tenders. Because there is a lot of potential there too. Private procurers are already watching with great interest how we roll out the Ladder. I am convinced it will work well for that segment too. What would help with the further roll-out would be for national government bodies such as ministries to embrace and promote the tool. We now notice that there is interest, but also reluctance. This is the typical wait-and-see culture: first they want to see proof that it actually works. So we are working hard on that now and we welcome every support from the national government. All in all, the future for the Ladder in France is bright.’

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