Integrating climate-neutrality criteria into sustainable public procurement: A comparative legal study of the United Arab Emirates, European Union and France

Abstract

Public procurement increasingly serves as a legal and regulatory instrument through which governments shape markets and pursue sustainability goals. Using doctrinal, comparative and normative legal analysis, this study examines how climate-neutrality criteria can be incorporated into sustainable public procurement in the United Arab Emirates (UAE), drawing on European Union (EU) and French law. The comparison shows that environmental objectives become legally credible when they are translated into transparent specifications, award criteria, life-cycle costing methods, evidentiary rules and performance obligations, rather than left as broad policy aspirations. The UAE federal procurement framework already recognises public value, sustainable development, environmental specifications and products that reduce carbon emissions, but it does not yet provide a fully operational climate-procurement methodology. The study therefore proposes a four-part Climate-Neutral Procurement Legality Test: a criterion must be connected to the subject matter or performance of the contract, objectively measurable or verifiable, proportionate to the procurement's value and environmental significance, and enforceable after award. It also develops a procurement-cycle model covering needs assessment, technical specifications, supplier qualification, award, performance monitoring and review. The analysis concludes that climate-neutral procurement is legally feasible in the UAE, provided that national climate commitments are converted into contract-specific, reviewable and enforceable requirements while preserving equal treatment, transparency and competition.