Comparative Analysis of the Characteristics of Public Procurement Systems in Germany, France and Romania

In public procurement, an important role is played by the analysis of the way public procurement takes place in other European Union (EU) countries. Although public procurement in EU Member States are governed by the same general rules established by a series of Directives that Member States have to transpose into national law, there are a number of significant differences and characteristics between public procurement systems. These differences are very important as they can lead to the identification and adoption of measures that can generate a number of effects, such as: increasing the efficiency of the use of budget funds, reducing the time of a procurement procedure, reducing the number of complaints, increasing the number of tenderers that participate in procurement procedures, encouraging the participation in procedures of small and medium enterprises, etc. The article describes an analysis of the main features of public procurement in the two most important EU member states, namely Germany and France, which are analysed in comparison with the public procurement system in Romania.