Circular Procurement Fails at the Evidence Clause

Open almost any public or corporate tender with a circularity component and you will find a question shaped like this: describe your approach to the circular economy and how your organisation minimises waste.

It is a reasonable sentence. It is also unanswerable in any discriminating way. Every supplier has an approach. Every supplier minimises waste, in the sense that no supplier maximises it. The question sorts respondents by the quality of their copywriting, which is not the quality the buyer intended to procure.

The alternative is not a harder question. It is a differently shaped one. Ask for a record rather than a description, and the field separates immediately.

Two developments are pushing buyers towards evidence based criteria whether or not they were planning to get there.

In Europe, green public procurement is progressively moving from encouraged practice to specified criteria attached to particular product categories, running alongside procurement thresholds that were reset for 2026. The Netherlands and Sweden are among the more advanced markets, with mature digital procurement infrastructure through TenderNed and TendSign respectively, which makes structured supplier data easier to demand and easier to compare.

In Australia, the direction is being set by extended producer responsibility. In May 2026 the Senate referred the Extended Producer Responsibility Scheme for Packaging Bill to committee. The bill would replace voluntary arrangements with binding obligations on producers, importers and distributors for the end of life management of packaging placed on the market, and would make the national packaging targets legally binding rather than aspirational.

The context is uncomfortable. Recycled content across Australian packaging rose from thirty five to forty four per cent against a fifty per cent target, and plastic recycling sits near twenty per cent against a seventy per cent target. Voluntary targets were missed, so mandatory ones follow.

Replacing narrative criteria with evidentiary ones does not require a longer tender. It requires a small number of questions that cannot be answered from a marketing brochure.

The fourth question is the one most often omitted and the one most likely to prevent an embarrassment later. Physical segregation and mass balance are both legitimate chain of custody methods, but they support different public claims. A buyer who does not ask which method applies will eventually make a physical claim on the basis of a mass balance supply chain, which is precisely the mismatch that consumer regulators have begun litigating.

There is a legitimate objection to evidentiary criteria, which is that they favour large suppliers with compliance departments over small suppliers doing genuinely circular work. The objection is real and it is manageable.

The manageable version distinguishes between the maturity of the supplier's systems and the truthfulness of the supplier's claims. A small operator may not hold certification, but can usually produce a weighbridge record, a named handler at each stage and a photograph tied to a batch. That is evidence. What should be penalised is not the absence of a certificate. It is the inability to substantiate the specific claim being made.

The phrase circular supply chain is often used to mean a supply chain with recycled inputs. That is a material characteristic, not a structural one, and it undersells the concept.

A circular supply chain is one in which the buyer retains visibility of material after the point of sale, and in which the return path is contractually defined rather than assumed. That is a governance arrangement. It requires somebody to be responsible for what happens at end of life, somebody to record what happened, and a mechanism by which that record reaches the buyer.

Product stewardship, in its serious form, is the name for accepting that responsibility explicitly. Extended producer responsibility is the name for having it imposed. Organisations that build the first tend to find the second considerably less disruptive.

Most organisations run procurement and waste management as separate functions with separate reporting lines, separate budgets and no shared data. The consequence is a familiar absurdity: the organisation pays to dispose of material at one gate and pays to purchase similar material at another.

Closing that loop is frequently the highest return circular initiative available, and it is a procurement decision rather than an environmental one. Decommissioned uniforms, retired signage, event materials, packaging and operational textiles all have both a disposal cost and a latent input value.

Answering it requires an inventory of outbound material streams with weights and disposal costs attached. Most organisations do not hold that inventory, which is itself informative.

Building one is rarely a technology project. It is usually a matter of asking facilities management for twelve months of waste contractor invoices, breaking the line items down by stream, and putting a weight and a cost against each. The exercise takes a few days and routinely surfaces two or three streams of sufficient volume and consistency to support a product programme. Textiles, signage and packaging materials appear most often, because they are generated continuously, arrive in predictable formats and are usually disposed of under a single contract that nobody has examined closely in years.

Once those streams are visible, the procurement conversation changes shape. Instead of asking a supplier to source sustainable goods, the buyer can offer the supplier a defined feedstock with a known volume and a known specification. That is a materially stronger negotiating position, and it produces products with a provenance claim no competitor can replicate.

REZET Hub was built to make the evidence clause answerable. It records circular material programmes at batch level, so a supplier response is a record rather than a narrative and a buyer's own reporting is supported by the same document.

For each project it captures material origin and category, chain of custody with named parties, verified intake weight, processing yield, residual routing, transformation partner, products created and supporting media, all held against a batch identifier and exportable for assurance or tender response.

Where the buyer's own waste is the feedstock, the loop is documented end to end: the material leaves the buyer's site, is recovered, becomes a product, and returns to the buyer with a record of the journey attached.

Wholesale reform of procurement policy is a multi year exercise and usually stalls. Rewriting a single criterion in the next tender is not.

Take the existing circularity question. Replace the request for a description with a request for one batch level record from a comparable delivery. Add a line requiring the chain of custody method to be stated. Score the responses on whether the evidence supports the claim rather than on how the claim is phrased. Then observe how many bidders can comply.

That single change tends to produce two useful outcomes. It identifies which of your existing suppliers already operate to an evidentiary standard, which is valuable information. And it signals to the rest of the market that the next tender will ask the same thing, which is how procurement criteria actually change supplier behaviour.