NHS Supply Chain Carbon Requirements: What PPN 06/21 Means for Your Business

From April 2024, the NHS has extended Carbon Reduction Plan requirements to cover all new procurements, fundamentally changing how suppliers engage with the UK's largest employer. What started as a requirement for contracts above £5m annually now touches every business in the NHS supply chain. With the NHS committed to reaching net zero by 2040 for direct emissions and by 2045 for the emissions it influences through procurement, suppliers face a clear choice: adapt quickly or risk losing access to contracts worth billions.

The stakes are particularly high given the NHS's purchasing power. With NHS contracts valued at over £6bn annually, adhering to mandatory carbon reporting requirements is critical for suppliers who want to maintain their business relationships. But here's the challenge: many suppliers, especially SMEs, struggle to understand what's required and how to comply efficiently.

Understanding PPN 06/21's NHS implementation

Procurement Policy Note 006 (PPN 006) is a procurement policy note issued by the Cabinet Office that outlines the need for suppliers to demonstrate their commitment to reducing greenhouse gas emissions through a formal Carbon Reduction Plan.. While originally targeting central government contracts, the NHS has adopted and expanded these requirements across its entire supply chain.

The policy operates on two tiers:

• Full Carbon Reduction Plans: Required for contracts above £5million per annum and all new frameworks
• Net Zero Commitments: Required for contracts below £5million per annum

This tiered approach ensures proportionality whilst driving universal progress towards net zero. Extending the policy in a two-tiered approach ensures the majority of NHS suppliers are advancing along the NHS net zero supplier roadmap.

What your Carbon Reduction Plan must include

To meet the requirements of PPN 06/21 and be accepted by the NHS and other public sector buyers your CRP must include several mandatory elements:

Net Zero commitment: Confirm the bidding supplier's commitment to achieve net zero by 2050 or earlier for their UK operations as a minimum geographical boundary

Baseline emissions: Current emissions data for Scopes 1 and 2

Scope 3 subset: Report Scope 1, 2 and a subset of Scope 3 emissions, including business travel, employee commuting, waste generated in operations and upstream/downstream transportation

Board approval: The plan must be signed off at board or director level

Public availability: Your CRP must be published on your website

The technical requirements follow the GHG Protocol standards, ensuring consistency across all suppliers. The UK government has released a CRP template which can be utilised as a minimum to ensure a suitable structure is followed and all the reporting requirements are met.

The escalating timeline

The NHS supplier roadmap sets increasingly stringent requirements:

April 2024 marked the watershed moment when The NHS has proportionately extended the Carbon Reduction Plan requirements to cover all new procurements.

Looking ahead:

• April 2027: All suppliers will be required to publicly report targets, emissions and publish a Carbon Reduction Plan for global emissions aligned to the NHS net zero target, for all of their Scope 1, 2 and 3 emissions
• April 2028: Individual product carbon footprinting requirements begin
• 2030: Suppliers will only be able to qualify for NHS contracts if they can demonstrate their progress through published progress reports and continued carbon emissions reporting

The Evergreen Assessment: Your sustainability scorecard

Beyond the CRP, suppliers must engage with the Evergreen Sustainable Supplier Assessment. Launched in June 2023 by NHS England, this platform was created to streamline and simplify sustainability reporting within the NHS.

The assessment operates on four levels:

• No Level: Starting point for new suppliers
• Level 1: Basic net zero commitment and sustainability engagement (The goal is for all suppliers to reach Level 1 within the Evergreen Assessment tool by April 2026)
• Level 2: Comprehensive targets with structured approaches to modern slavery and social value
• Level 3: Independently validated 2045 net zero targets

Practical steps for compliance

1. Start with accurate measurement Begin by establishing your baseline emissions using recognised standards. Focus initially on Scopes 1 and 2, then add the required Scope 3 categories. Financial transaction data often provides the most accessible starting point for emissions calculations.

2. Set realistic but ambitious targets To prepare for future NHS roadmap milestones, suppliers are encouraged to set a net zero target of 2045, although a target of 2050 will still meet the minimum requirements. Align your targets with the Science-Based Targets initiative where possible.

3. Document your methodology Clear documentation of your calculation methods, data sources and assumptions helps during procurement assessments and builds confidence in your approach.

4. Update annually It is also a requirement to update these footprints annually. This allows for progress review of carbon reductions to see if they are on track to reach the planned targets.

5. Leverage available support NHS England will continue to offer a free CRP checking service until further notice. Suppliers can access this service by contacting the following email address: england.crp-check@nhs.net.

Common pitfalls to avoid

• Incomplete Scope 3 data: Ensure you include all required categories, not just the easiest ones
• Missing board approval: Your CRP needs formal sign-off before submission
• Static plans: Annual updates are mandatory, not optional
• Private documentation: Your CRP must be publicly available on your website

Turning compliance into competitive advantage

Those who proactively address these requirements gain a competitive edge in the procurement process. Early adoption demonstrates environmental leadership and operational maturity – qualities increasingly valued in supplier selection beyond mere compliance.

Smart suppliers are using this requirement as a catalyst for broader sustainability improvements, identifying cost savings through energy efficiency and waste reduction whilst building resilience into their operations.

Conclusion

PPN 06/21's implementation across the NHS supply chain represents more than a compliance hurdle – it's a fundamental shift in how healthcare procurement operates. With requirements escalating towards comprehensive global emissions reporting by 2027 and performance-based qualification by 2030, the message is clear: carbon management is now core to NHS supplier relationships.

The good news? Starting with financial transaction data and proven methodologies makes compliance achievable for businesses of all sizes. By establishing robust carbon accounting processes now, suppliers can meet current requirements whilst building the capabilities needed for future milestones.

Emitrics simplifies this journey by automating carbon calculations from your existing financial data, providing the accurate emissions reporting NHS compliance demands. Our platform grows with your needs, from basic CRP requirements to comprehensive Scope 3 analysis. Ready to secure your place in the NHS supply chain? Book a demo to see how we make carbon compliance straightforward.