Could New ‘Made in Europe’ Procurement Rules Affect UK Exporters?

UK businesses supplying goods and services to public-sector organisations across Europe may need to keep a close eye on proposed changes to EU procurement rules.

Published by the European Commission on 9 September 2026, the proposed Public Procurement Act includes plans to introduce new ‘Made in Europe’ criteria as part of a wider reform of how public contracts are awarded across the EU.

While the proposals do not suggest that UK businesses would be excluded from EU procurement opportunities, they could place greater emphasis on European origin, supply chain resilience and wider strategic considerations when public authorities evaluate tenders.

What’s Being Proposed?
Public procurement is a major market. Across the European Union, public authorities spend around €2.6 trillion annually on goods, services and works, covering everything from infrastructure and transport to healthcare, technology and professional services.

The European Commission’s proposals aim to use public procurement not only to secure value for money but also to support broader economic objectives, including:
· Strengthening European industry
· Improving supply chain resilience
· Enhancing economic security
· Supporting innovation
· Encouraging environmental and social goals

As part of this approach, contracting authorities could be given greater scope to consider European preference criteria when assessing bids.

What Does ‘Made in Europe’ Mean?
The proposed measures form part of a wider EU strategy to encourage investment in European production and reduce reliance on external supply chains in strategically important sectors.
In practical terms, the proposals could allow greater consideration of where products are manufactured, where key components originate and how resilient supply chains are when contracts are awarded.

However, this should not automatically be interpreted as a barrier to UK suppliers.

The European Commission has indicated that any new procurement framework would continue to operate in line with the EU’s international obligations, meaning existing procurement commitments will remain an important consideration.

What Could This Mean for UK Businesses?
Since Brexit, UK companies are classed as third-country suppliers when bidding for EU public contracts.

However, both the UK and the EU are members of the World Trade Organization’s Agreement on Government Procurement (GPA), which provides access to specified procurement markets among participating economies.

As a result, the key issue for UK businesses is unlikely to be whether they can bid for contracts, but how tenders are assessed under any new framework.

Businesses may increasingly need to consider:
· The origin of products and components
· The location of manufacturing and assembly operations
· Supply chain resilience
· Environmental credentials
· Strategic importance of the sector concerned

Depending on how the final legislation is drafted, these factors could become more influential during the evaluation process.

Areas Businesses Should Monitor
UK exporters already active in European public-sector markets should pay particular attention to:
✔ Which sectors become subject to European preference requirements.
✔ How any ‘Made in Europe’ criteria are applied during tender evaluations.
✔ How suppliers from countries covered by international procurement agreements are treated.
✔ Whether product and component origin becomes a scoring factor.
✔ The role of supply chain resilience, sustainability and strategic security in procurement decisions.

The proposals are likely to be particularly relevant for businesses supplying industrial products, technology, engineering solutions, infrastructure projects and other strategically important goods and services.

No Immediate Changes
It is important to note that the proposals have not yet become law.

The Public Procurement Act must still progress through the EU legislative process and its final form could change considerably before implementation.

For that reason, UK exporters do not need to make immediate changes to their procurement strategies.

However, businesses that rely on EU public-sector contracts should be aware of the direction of travel. The EU is increasingly seeking to use public procurement as a tool to support industrial resilience, strengthen supply chains and encourage investment in key sectors.

For UK suppliers, the important question is not simply whether European preference measures are introduced, but how they are applied in practice and whether existing international procurement commitments continue to ensure fair access to procurement opportunities across the European market.

With the detail yet to be finalised, this is an area that exporters should continue to monitor closely over the coming months.