NACE 32 – Other Manufacturing | Public Tenders

Definition: NACE 32 brings together the manufacture of various goods that cannot be assigned to any other manufacturing division — including jewellery, musical instruments, sports goods, toys, and medical and dental instruments. Group 32.5 (medical devices) is of outstanding importance in public procurement.

Legal basis: NACE Rev. 2 (Regulation (EC) No 1893/2006) · Last updated: April 2026

What does NACE 32 cover?

NACE 32 (Other manufacturing) brings together heterogeneous product groups under a common heading — what they share is less the similarity of the products than their distinction from other divisions of the NACE system.

Division 32 within Section C (Manufacturing) is broken down into the following groups:

For contracting authorities, group 32.5 is by far the most important: hospitals, clinics and health authorities continuously procure medical instruments, diagnostic equipment and dental products. Groups 32.3 and 32.4 are relevant for schools, nurseries and sports facilities.

Public Tenders: Scope of NACE 32

NACE 32 displays an extreme breadth in public procurement — medical instruments are subject to strict regulatory requirements, while sports goods and toys are often procured through simplified procedures.

Typical Contract Types

• Medical instruments for hospitals (32.5): Surgical instruments, endoscopes, operating sets, laparoscopes and specialised tools for public hospitals and university clinics
• Diagnostic devices and single-use articles: Blood pressure monitors, stethoscopes, wound care material and single-use instruments for medical practices under municipal sponsorship and health centres
• Dental products for dental institutions: Drills, impression materials, dental alloys for dental clinics at university hospitals
• Sports goods for schools and sports facilities: Balls (football, basketball, volleyball), gymnastics equipment, athletics gear for schools, university sports facilities and municipal sports facilities
• Fitness equipment for municipal sports facilities: Strength and endurance equipment for publicly sponsored gyms, outdoor fitness installations
• Play equipment for nurseries and parks: Swings, slides, climbing frames, sand toys for municipal nurseries, schoolyards and public playgrounds
• Musical instruments for public schools: School instruments for music and general education schools under municipal sponsorship

Specifics for Medical Devices (32.5)

In the EU, medical devices are subject to the Medical Devices Regulation (MDR, EU 2017/745). For contracting authorities this means:

• Obligation to tender CE-marked products in the appropriate risk class (I, IIa, IIb, III)
• Technical specifications must focus on performance characteristics, not brand names
• For highly regulated products (e.g. implants, Class III), references from accredited Notified Bodies are decisive

Thresholds and Procedure Types

Supply contracts for goods from NACE 32 are subject to the general EU threshold for supply contracts (EUR 221,000). For medical devices (some of which fall under NACE 26 but are substantively linked to 32.5), framework agreements for recurring consumables demand and open procedures for equipment procurement are frequently used.

Relevant CPV Codes for NACE 32

Current tenders with these CPV codes can be found on TED (Tenders Electronic Daily) and on national procurement platforms.

Who is NACE 32 relevant for in public procurement?

Public Contracting Authorities

University hospitals and regional hospitals are the highest-volume buyers of group 32.5 products — surgical instruments and endoscopes alone account for millions. School authorities (districts, municipalities) procure sports goods and musical instruments. Youth welfare offices and non-statutory providers (as delegated bodies) buy play equipment for nurseries. Sports facility administrations are buyers of fitness equipment and indoor sports equipment.

Companies and Bidders

Requirements vary strongly by product group:

• Medical devices (32.5): CE marking under MDR, designation of the manufacturer and its EU representative, declarations of conformity, where applicable clinical evaluation reports
• Sports goods (32.3): DIN/EN standards for pitch equipment, TÜV test certificates for play equipment under EN 1176 (children's play equipment)
• Musical instruments (32.2): No specific regulations; quality and manufacturer evidence is sufficient
• Toys (32.4): CE marking under the Toy Safety Directive (2009/48/EC), safety evidence under EN 71

Frequently Asked Questions on NACE 32 and Public Tenders

Why is group 32.5 particularly important for contracting authorities?
Public hospitals and healthcare institutions in Europe are major buyers of medical instruments and consumables. In Germany and Austria, the health sector accounts for a significant share of public spending — with a corresponding procurement volume for medical devices.

Can technical specifications for medical devices refer to specific brands?
No — product specifications must be formulated in performance- and function-related terms. Brand references are only permissible where the subject matter of the contract cannot otherwise be described with sufficient precision, and must be accompanied by the addition "or equivalent" (§ 31 (6) VgV / § 97 (6) GWB).

Which standards apply to play equipment on public playgrounds?
Play equipment on public playgrounds must comply with EN 1176 (Playground equipment) and EN 1177 (Impact-absorbing playground surfacing). In addition, the accident prevention regulations of the public accident insurance funds apply. Regular safety inspections by qualified persons are mandatory.

Can musical instruments be procured centrally?
Yes — individual federal states have concluded framework agreements for school instruments. In addition, schools can often order directly from specialist retailers below the thresholds. Larger procurements (e.g. complete orchestra equipment) must be tendered.

NACE 32 in context: Section C and related divisions

• NACE C – Manufacturing: Parent section covering all manufacturing activities
• NACE 26 – Computer, electronic and optical products: Medical technology, diagnostic devices
• NACE 31 – Manufacture of furniture: School and hospital equipment
• NACE 33 – Repair and installation of machinery and equipment: Maintenance and upkeep of equipment

Last updated: April 2026
All information is provided without guarantee. For legally binding advice, please consult a law firm specialising in public procurement law.