InsightsProcurement

Greenwashing in medical procurement: five claims to check before you award

How to read supplier environmental data and what a buyer can legally ask for.

Mykhailo Kopyl
Founder and CEO, Seedium · · 7 min read
Five claims, and what to ask forEnvironmental claims that appear most often in medical supply tendersCLAIMWHAT IT USUALLY HIDESASK FOR“Eco-friendly”, “green”Generic claim with no stated basisThe specific benefit, measured how,compared with what“Carbon neutral”Usually offsets, product unchangedFootprint in kg CO2e per unit, method,boundary, share reduced vs offset“Recyclable”, “recycled content”Theoretical property; or a measurable figureRecycled content % with third party statement;which waste stream in your facility“Biodegradable”, “compostable”Rarely relevant after clinical useStandard certified against (EN 13432), conditions,whether your waste chain provides them“ISO 14001 certified”Management system, not product performanceCertificate scope, site addresses, expiry;product evidence separatelyFrom 27 September 2026, generic claims and offset-based neutrality claims are prohibited in EU consumer marketing (Directive (EU) 2024/825).
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A tender for examination gloves closes on Friday. Three bids are on the table. One supplier describes its product as "eco-friendly nitrile". Another says the gloves are "carbon neutral". The third attaches an ISO 14001 certificate and says nothing else. The evaluation sheet has an environmental criterion worth 10% of the score. How do you score it?

Hospital buyers face this question in almost every tender now, and the difficulty is not a lack of information. It is the opposite. Suppliers have learned that environmental language wins points, and the volume of claims has grown faster than the ability of procurement teams to check them. The gap is where greenwashing lives.

European law has become specific about what a claim must be able to prove, and public procurement rules already give buyers the right to ask for that proof. Below are the five claims that appear most often in medical supply tenders, what each one usually hides, and what you are entitled to request.

1. "Eco-friendly", "green", "sustainable"

A generic claim with no stated basis. It tells you the supplier would like you to feel good about the product and nothing else.

From 27 September 2026, generic environmental claims of this kind are prohibited in consumer marketing across the EU unless the trader can demonstrate recognised excellent environmental performance, for example through the EU Ecolabel or an equivalent Type I label.1 The rule applies to consumer-facing marketing, not to B2B tenders, but the same brochures and datasheets land in your inbox, and the same test works: a claim that cannot say what it means cannot be scored.

Ask for: the specific environmental benefit the word refers to, and the evidence behind it. If the answer is "lower carbon than the previous version", ask by how much, measured how, and compared with what.

2. "Carbon neutral" or "climate neutral"

This is the claim to treat with the most care. In most cases it means the supplier bought carbon credits equal to an estimate of the product's emissions. The product itself was made in exactly the same way.

The same EU directive bans product-level neutrality claims that rest only on offsetting, from the same date.1 The reasoning is simple: offsets outside the product's own value chain do not reduce the emissions the product causes, and the quality of many credit schemes has not survived scrutiny. For a buyer, a "carbon neutral" label with no footprint figure attached is a red flag, not a green one.

Ask for: the product carbon footprint in kilograms of CO2 equivalent per unit, the method used (ISO 14067 or a published product category rule), and the boundary. Then ask what share of that footprint was reduced and what share was offset. A supplier that can answer these questions deserves the points. One that cannot has made a marketing claim, not an environmental one.

3. "Recyclable" and "made with recycled content"

Two different claims that are often blurred together.

"Recyclable" describes a theoretical property of the material. It says nothing about whether your waste contractor can or will recycle it, and in clinical settings most of it will go to a clinical or offensive waste stream regardless. A recyclable glove that ends up in an orange bag has the same fate as any other glove.

"Recycled content" is a measurable figure, and ISO 14021, the international standard for self-declared environmental claims, requires that it be stated as a percentage and substantiated.2 It is one of the few product claims a buyer can verify with a document.

Ask for: the percentage of recycled content, pre-consumer or post-consumer, with a third-party statement or mass balance certificate. For "recyclable", ask which waste stream in your own facility the product would actually enter after use. If the answer is clinical waste, the claim is irrelevant to your decision.

4. "Biodegradable" and "compostable"

In healthcare these claims are almost always irrelevant and sometimes harmful. A product that has touched a patient leaves through regulated waste streams designed around infection control, not decomposition. Biodegradable packaging may matter for outer cartons that never enter a clinical area; biodegradable gloves do not.

The EU directive treats "biodegradable" as a generic claim unless it is specified and substantiated.1 For packaging, the relevant evidence is certification against EN 13432 for industrial compostability, and even then the claim only has value if your waste contractor runs an industrial composting route.

Ask for: the standard the claim is certified against, the conditions required (industrial or home composting, time frame), and confirmation of whether those conditions exist anywhere in your waste chain. If not, score the claim at zero and move on.

5. "ISO 14001 certified"

This is a real certificate and a legitimate signal, but it is routinely misread. ISO 14001 certifies that an organisation operates an environmental management system at a given site. It does not certify the environmental performance of any product, and a certified head office tells you nothing about the factory in another country where the gloves are made.

Ask for: the certificate itself, with the certified scope and site addresses, the issuing body and the expiry date. Check that the manufacturing site for the product you are buying is inside the scope. For performance, ask separately for product-level evidence: an environmental product declaration, a product carbon footprint or test reports against the specification you set.

What the procurement rules let you ask for

Buyers sometimes hesitate to push suppliers on evidence because they fear a challenge. The EU public procurement directive is clearer than most evaluation sheets suggest.3

You can write environmental characteristics into the technical specification, including requirements relating to the production process, as long as they are linked to the subject matter of the contract. You can require a specific label, such as the EU Ecolabel, provided you accept equivalent labels and other appropriate means of proof. You can require test reports and certificates from accredited bodies. You can use life-cycle costing, which lets you count the cost of energy, consumables and end-of-life treatment, not just the purchase price. And you can set award criteria on environmental performance, again as long as they relate to what you are buying.

The European Commission's green public procurement criteria, developed for product groups including textiles, cleaning products, furniture and electrical equipment, give ready-made wording for many of these clauses. NHS England's net zero supplier roadmap does the same for carbon reduction plans in the UK.

A short evaluation discipline

Across all five claims, the pattern is the same. A claim is worth points when it names a measurable property, states a figure, cites a method and attaches evidence that a third party could check. It is worth nothing when it names a feeling.

How much weight a piece of evidence can carryType I ecolabel or certified EPDThird party verified, product level, published methodProduct carbon footprint (ISO 14067) or test reportProduct level, method stated, may be self-reportedISO 14001 site certificateOrganisation level, says nothing about the productSelf-declared claim with a figure (ISO 14021)Checkable, but only the supplier stands behind itGeneric claim, no figureCannot be scoredStrongest evidence at the top. A claim earns points when it names a measurable property, a method and a verifier.
How much weight a piece of evidence can carry in an evaluation.Open full-size chart

Three questions cover most cases: What exactly is being claimed? How was it measured? Who, other than the supplier, can confirm it?

The organisations that handle this well have stopped treating environmental evidence as an attachment to read once during evaluation. They record each claim, the evidence behind it, who verified it and when it expires, and they carry that record into contract management so that a certificate that lapses in year two of a four-year contract is noticed in year two, not year five. That is less a procurement reform than a record-keeping one. It is also exactly the kind of record a hospital's sustainability lead needs when the annual report asks what the supply chain is doing.

Mykhailo Kopyl
Founder and CEO, Seedium
Mykhailo leads Seedium, a software company building data and AI platforms for healthcare since 2017.

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