NHS England » Carbon reduction plan requirements for the procurement of NHS goods, services and works

Classification: Official
Publication reference: PR1851
14 February 2023, Version 1

The NHS net zero supplier roadmap sets out the steps suppliers must take to align with the NHS net zero ambition between now and 2030. The purpose of this document is to provide further details on the implementation of the following milestone in the roadmap:

In April 2023, NHS organisations will require all suppliers of new contracts for goods, services, and/or works with an anticipated contract value above £5 million per year (excluding VAT) to publish a carbon reduction plan (CRP) for their emissions from the sources included in scope 1 and 2 of the Greenhouse Gas (GHG) Protocol, and a defined subset of scope 3 emissions, aligning with the government’s procurement policy note (PPN) 06/21: Taking account of CRPs in the procurement of major government contracts

This document outlines how this requirement will be applied in an NHS context and is intended to be used in conjunction with central government’s guidance documents on PPN 06/21.

The NHS CRP requirements apply to the commissioning and purchasing of goods, works and services (including healthcare services) by in-scope organisations. In-scope organisations are defined as NHS organisations as well as organisations acting on their behalf.

The requirement to provide a CRP is in addition to the inclusion of a minimum 10% weighting on net zero and social value in NHS procurement, implemented from April 2022.

NHS supplier CRP requirements

The NHS requirements align with those of central government’s PPN 06/21. Therefore, any existing and current CRP developed according to the central government guidelines of PPN 06/21 will be accepted by the NHS for the April 2023 milestone requirement.

To best 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 of CRPs.

A CRP identifies a supplier’s current carbon footprint and their plan to achieve net zero emissions. The NHS will require its suppliers to have a publicly available CRP on their website and to share their CRP information as part of the procurement process.

To comply with the NHS requirements, and align with the UK government’s PPN 06/21, the CRP must:

confirm the bidding supplier’s commitment to achieve net zero by 2050 or earlier for their UK operations at a minimum.
provide the supplier’s current emissions for their UK operations at a minimum, for the sources included in scope 1 and 2 of the GHG Protocol, and a defined subset of scope 3 emissions. The five relevant GHG Protocol scope 3 categories are:
- upstream transportation and distribution
- waste generated in operations
- business travel
- employee commuting
- downstream transportation and distribution.
Suppliers may provide additional categories of scope 3 emissions if the above categories are included and clearly identified.
provide emissions reporting in CO₂e (carbon dioxide equivalent) for the seven greenhouse gases covered by the Kyoto Protocol (carbon dioxide [CO₂], methane [CH₄], nitrous oxide [N₂O], hydrofluorocarbons [HFCs], perfluorocarbons [PFCs], sulphur hexafluoride [SF₆] and nitrogen trifluoride [NF₃]).
set out the environmental management measures in effect, including certification scheme or specific carbon reduction measures adopted; these should be measures the supplier can apply when performing the contract and support the supplier to achieve net zero by 2050 or earlier
be board approved or company director approved if no board is in place
be clearly signposted and published on the supplier’s website
be updated regularly – at least annually.

When producing a CRP, suppliers should follow the government’s Technical standard for completion of CRPs.

The CRP should follow structure and length of central government’s PPN 06/21 CRP Carbon Reduction Plan template, though stylistic differences are acceptable.

The CRP should be specific to the bidding entity, or, providing the following criteria are met, may cover the bidding entity and its parent organisation if:

the bidding entity is wholly owned by the parent entity
the commitment to achieving net zero by 2050 for UK operations is set out in the CRP for the parent entity and is supported and adopted by the bidding entity, demonstrated by the inclusion in the CRP of a statement that this will apply to the bidding entity
the environmental measures set out are stated to be able to be applied by the bidding entity when performing the relevant contract
the CRP is published on the bidding entity’s website.

Further information

NHS to NHS contracts

Where NHS organisations are bidding for contracts with other NHS organisations, a published NHS trust and/or integrated care board (ICB) green plan is acceptable and considered equivalent to a CRP where it meets or exceeds the Carbon Reduction Plan requirements as set out above.

NHS trusts and ICBs should provide a link to their published green plan and complete the required questions as part of the selection questionnaire as detailed in section ‘CRP reporting mechanism’.

Public bodies

Where public bodies are bidding for NHS contracts, a published carbon reduction plan or a net zero commitment is acceptable and considered equivalent to a CRP where it meets or exceeds the Carbon Reduction Plan requirements as set out above. Public bodies should provide a link to the published commitment and complete the required questions as part of the selection questionnaire as detailed in section ‘CRP reporting mechanism’.

Subcontractors

Subcontractors are not in scope of the CRP requirements and do not need to provide a CRP. However, suppliers are encouraged to engage with their subcontractors to ensure they are taking actions to reduce their emissions.

In exceptional circumstances where suppliers have an acceptable reason for being unable to gather emissions data, they can provide a CRP with the carbon emissions they have available and include the explanation why, if applicable, any data is not available. For example, where appropriate SMEs or VCSEs with acceptable reasons may use this provision.

A supplier’s explanation will be assessed on a case-by-case basis by the relevant NHS organisation. Suppliers are also required to provide the steps they will take to improve the collection of such data.

If you are an SME or VCSE supplier to the NHS and require further support or guidance, please contact the NHS England Sustainable Procurement team at england.ccf-sustainability@nhs.net.

As outlined in PPN 06/21, this provision can apply across small, medium, and large suppliers. Please see ‘supplier response’ 7 of Annex 1 of this document for more information.

CRPs within the procurement process

This section summarises how CRPs should be incorporated in the procurement process. More details are available within the PPN 06/21 documentation.

Assessment methodology

At selection stage of the procurement process, the CRP will be assessed in the form of a pass/fail check. The assessment will ensure that the CRP meets the minimum requirements and will be included as a pre-qualification criterion for an individual procurement or framework.

Suppliers whose CRPs do not meet the minimum expectations will not be able to proceed with the process. CRPs will not be scored or compared against each other.

Annex 1 of this document sets out example scenarios and whether these meet the minimum requirements of the CRP.

Guidance for frameworks and dynamic purchasing systems

From April 2023, the CRP requirement applies to new framework agreements and new dynamic purchasing systems only where it is anticipated that the individual value of any contract to be awarded under the framework agreement or dynamic purchasing system is greater than £5 million per year (excluding VAT).

Framework owners should assess whether the new framework is likely to have call off contracts with an annual value of £5 million or more, in which case, the provisions of PPN 06/21 should be applied at the selection stage when establishing the framework.

Due care should be taken by framework owners to ensure suppliers are ready to comply with all future requirements outlined in the NHS net zero supplier roadmap in the development of their framework.

NHS England is working with wider public sector framework providers used by NHS organisations to ensure NHS requirements are consistently and uniformly applied no later than April 2023 for all buying routes.

CRP reporting mechanism

NHS organisations should use the following mandatory questions in their selection questionnaire, which can be found in Annex A of the PPN 06/21 guidance on adopting and applying PPN 06/21 and in the table below:

Selection questionnaire

Please confirm that you have detailed your environmental management measures by completing and publishing a carbon reduction plan that meets the required reporting standard.	Yes / No PASS / FAIL
Provide a link to your most recently published carbon reduction plan here:	<link>
Please confirm that your organisation is taking steps to reduce your greenhouse gas emissions over time and is publicly committed to achieving net zero by 2050.	Yes / No PASS / FAIL

Supplier emissions declaration

Baseline year:
Scope 1
Scope 2
Scope 3
Reporting year:
Scope 1
Scope 2
Scope 3

For those using the Atamis e-commerce system used by NHS organisations, templates will be configured to make this process as user-friendly as possible.

Useful resources

Getting help

Further support for in-scope organisations

In-scope organisations applying the policy can refer to the Technical standard for completion of CRPs for technical questions on the content of CRPs.

For any other questions, NHS England’s Sustainable Procurement team can provide additional support to in-scope organisations to understand and meet the CRP requirements. Please contact england.ccf-sustainability@nhs.net.

Further support for suppliers

Crown Commercial Service runs regular Q&A sessions for suppliers on PPN 06/21. Please visit their website for more information.

Stay up to date on NHS-specific webinars by registering on the NHS England events website. You can also follow NHS England’s Central Commercial Function on Linkedin.

Annex 1: Examples of supplier response scenarios and exceptional circumstances

The supplier responses numbered 1-10 in the table below and the exceptional circumstance section in Annex 1 is taken from the central government document Guidance on adopting and applying the PPN 06/21 – selection criteria.

Supplier response	Assessment criteria	Outcome
1. CRP submitted that: confirms the supplier’s commitment to achieving net zero by 2050 contains emissions reported for all required scopes (in accordance with the required methodology) indicates the environmental management measures that the supplier will be able to apply when performing the contract reporting period falls no more than 12 months prior to the date of commencement of the procurement. Where the CRP applies to the supplier and its parent company, please see requirements detailed in response 2 below.	Supplier has met the requirements	Pass
2. Where the CRP applies to the supplier and its parent company, the requirements of the CRP are met in full, as set out in annex 4, and all the following criteria are met: The bidding entity is wholly owned by the parent company. The commitment to achieving net zero by 2050 is set out in the CRP for the parent company and is supported and adopted by the bidding entity together with a statement that this will apply to the bidding entity. The environmental measures set out are stated to be able to be applied by the bidding entity when performing the relevant contract. The CRP is published on the bidding entity’s website.	Supplier has met the requirements	Pass
3. Parent company CRP fails to meet the requirements of the CRP and additional requirements listed in response 2 above.	Supplier has failed to meet the required reporting standard	Fail
4. CRP not submitted.	Supplier has failed to meet the required reporting standard	Fail
5. CRP fails to confirm supplier’s commitment to achieving net zero by 2050.	Supplier has failed to meet the required reporting standard	Fail
6. Emissions in the CRP are not reported for any scopes or only for some scopes, without explanation why.	Supplier has failed to meet the required reporting standard	Fail
7. Emissions in the CRP not reported for any scopes or only for some scopes, but supplier provides an acceptable explanation why.	Supplier has met the requirements	Pass
8. Reporting period is more than 12 months from the date of commencement of the procurement.	Supplier has failed to meet the required reporting standard	Fail
9. Reporting period is more than 12 months from the date of commencement of the procurement, but provides an acceptable explanation why.	Supplier has met the requirements	Pass
10. Supplier fails to indicate the environmental management measures that the supplier will be able to apply when performing the contract.	Supplier has failed to meet the required reporting standard	Fail
11. An NHS trust or ICB is participating as a supplier in a procurement and completes the CRP selection questionnaire questions by providing the details and a link to their published NHS green plan where it meets or exceeds the Carbon Reduction Plan requirements.	Supplier has met the requirements	Pass
12. A public body bidding is participating as a supplier in a procurement for an NHS contract and completes the CRP selection questionnaire questions by providing the details and a link to their published CRP or net zero commitment where it meets or exceeds the Carbon Reduction Plan requirements.	Supplier has met the requirements	Pass
13. The emissions reported in the CRP are the supplier’s regional or global emissions (including all relevant UK emissions), and the specific UK emissions are not reported separately.	Supplier has met the requirements	Pass

Exceptional circumstances

It may not be relevant or proportionate to apply this policy in the following exceptional circumstances (which may often be temporary):

Where the market for a contract of this type is distorted/narrowed/struggling to such a significant extent that delivery of public services is likely put at risk, or value for money is likely to be severely compromised.
Where there is a civil emergency.

The scenarios outlined above are not an exhaustive list. Reasons for not applying the measure should be documented.

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