The NHS net zero supplier roadmap sets out the steps suppliers must take to align with the NHS net zero ambition through to 2030. The purpose of this guidance is to provide further details on the implementation of the following milestones in the roadmap (‘CRP and Net Zero Commitment Policy’):

This guidance outlines how this requirement is applied in an NHS context and is intended to be used in conjunction with central government’s guidance documents on PPN 06/21 and PPN 006. This policy is in the process of being updated to reflect the requirements of the Procurement Act 2023 and new PPN 006.

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

To ensure the Carbon Reduction Plan (CRP) requirements are extended in a proportionate and relevant manner to all procurements from April 2024 the policy is applied in a two-tiered approach. Extending the policy in a two-tiered approach ensures the majority of NHS suppliers are advancing along the NHS net zero supplier roadmap and supports suppliers to take early steps to prepare for future roadmap milestones.

From April 2024, a tiered approach applies as follows:

• a full CRP, as defined in the section “CRP Requirements”, is required for procurements of high value (£5m per annum exc. VAT and above) and new frameworks operated by in-scope organisations, irrespective of the value of the contract, where relevant and proportionate to the framework.
• a Net Zero Commitment, as defined in the section “Net Zero Commitment – Requirements”, is required for procurements of lower value (below £5m per annum exc. VAT and above £10k exc. VAT).

The Net Zero Commitment includes selected key requirements that have been taken from the CRP template. More details on the requirements and when they apply are included in this guidance.

To ensure compliance with NHS England’s Commercial Function framework accreditation scheme, all future accredited frameworks are expected to apply the requirements set out in Table 1 below.

The requirement to provide a CRP or Net Zero Commitment is in addition to the inclusion of a minimum 10% weighting on net zero and social value in NHS procurements, which has been required since April 2022.

The Provider Selection Regime (PSR) replaces the National Health Service (Procurement, Patient Choice and Competition) (No 2) Regulations 2013 (the PPCCR) and, alongside its introduction, removes the procurement of health care services, when procured by relevant authorities under the PSR, from the scope of the Public Contracts Regulations 2015 (the PCR). Relevant authorities under the PSR are:

• NHS England
• Integrated care boards (ICBs)
• NHS trusts and NHS foundation trusts; and
• Local authorities or combined authorities

This guidance will be updated in due course to provide clarity on how CRP and Net Zero Commitment requirements should be applied in the context of the PSR.

NHS supplier CRP and Net Zero Commitment requirements

The following table summarises the requirements, scopes, implementation route and date of the requirements.

Table 1: Application of CRP and Net Zero Commitment Policy

* Where NHS framework owners determine the CRP requirements not to be proportionate and relevant to the nature of the framework and the framework is out of scope of PPN06/21, the owner should apply the Net Zero Commitment requirements.

The extension of the policy to procurements below the relevant PCR threshold will be reviewed prior to 1 April 2026 following the implementation of the 2024 requirements.

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.

CRP requirements

A CRP identifies a supplier’s current carbon footprint and their plan to achieve net zero emissions.

The ‘CRP 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.

To comply with the NHS CRP 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 as a minimum geographical boundary. Note a global emissions boundary meets the requirements.
• provide the supplier’s baseline and current emissions for the sources included in scope 1 and 2 of the GHG Protocol, and a defined subset of scope 3 emissions (at a minimum). The five relevant GHG Protocol scope 3 categories are:
  • upstream transportation and distribution
  • waste generated in operations
  • business travel
  • employee commuting; and
  • downstream transportation and distribution.
• 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; and
• 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 template, though stylistic differences are acceptable.

Net Zero Commitment – requirements

A Net Zero Commitment is a public commitment to achieve net zero by 2050 or earlier, and a confirmation that the supplier is taking steps to reduce their GHG emissions over time. An example of a Net Zero Commitment can be found in the “Commitment to achieving Net Zero” section of central government’s PPN 06/21 CRP template. The Net Zero Commitment requirements are a subset of the CRP requirements, therefore a supplier already complying with the CRP requirements is also complying with the Net Zero Commitment requirements and does not require further action.

A ‘Net Zero Commitment’ is required for all new procurements above the relevant Public Contracts Regulations 2015 (PCR) threshold up to the value of £5M per annum and where new NHS framework owners determine the CRP requirements not to be proportionate and relevant to the nature of the framework, the owner should apply the Net Zero Commitment requirements, and is out of scope of PPN 06/21.

The extension of the policy to procurements below the relevant PCR threshold will be reviewed prior to 1 April 2026 following the implementation of the 2024 requirements.

To comply with the NHS Net Zero Commitment requirements, a supplier must:

• confirm the bidding supplier’s commitment to achieve net zero by 2050 or earlier for their UK operations on the sources included in scope 1 and 2 of the GHG Protocol, and the defined subset of scope 3 emissions, outlined in the “CRP Requirements” section. Note the UK is a minimum geographical boundary, and a global emissions boundary meets the requirements; and
• clearly signpost and publish the commitment on the supplier’s website.

To help the suppliers structure their Net Zero Commitment, an example format is provided in Annex 3. The commitment should clearly state the year by which net zero will be achieved, the emissions included, and the name of the entity committing to net zero.

To demonstrate the public commitment at contract award stage, a supplier will be asked by the contracting authority to provide a website URL where the commitment is clearly stated. The supplier should ensure the commitment is board approved or company director approved if no board is in place and be able to demonstrate this if asked to do so by the contracting authority. The supplier should also be able to provide evidence of activities to reduce their GHG emissions over time if asked by the contracting authority. For example, this evidence could include the carbon footprint measurement of the organisation.

Supplier entity in scope

Both a CRP and a Net Zero Commitment should be specific to the bidding entity, or they may cover the bidding entity and its parent organisation if the following criteria are met:

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

CRP and Net Zero Commitment assessment and reporting mechanism

Assessment methodology

The assessment confirms whether a supplier’s CRP or Net Zero Commitment meets the minimum requirements.

Depending on the type and value of the contract, the assessment takes place either at Selection Questionnaire (SQ) stage or at contract award stage. See Table 1 in the section “NHS supplier CRP and Net Zero Commitment Requirements” for more details.

Suppliers whose CRP or Net Zero Commitment does not meet the minimum requirements will not be able to proceed to the next stage of the procurement process, except in exceptional circumstances as set out in Annex 1. CRPs and Net Zero Commitments 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 and/or Net Zero Commitment.

Reporting mechanism

CRP and Net Zero Commitment requirements have been designed where possible to be reported via the Selection Questionnaire, where this is not possible the requirements will be included in the conditions of award.

Annex 2 provides a decision flow diagram to help contracting authorities understand how the CRP and Net Zero Requirements should be reported for their procurement.

Procurements above the relevant PCR threshold

Contracting authorities 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.

For procurements which require a CRP, the contracting authority should use all 4 Selection Questionnaire questions.

For procurements that require a Net Zero Commitment only, the contracting authority should only use question 2 of the Selection Questionnaire questions. In addition, the URL to the page of the supplier’s website where the commitment is clearly stated should be requested at contract award stage.

Selection questionnaire

Supplier emissions declaration

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

For procurements below the relevant PCR threshold

From 1 April 2026, the Net Zero Commitment requirement will be extended to all new procurements below the relevant PCR threshold. The extension of the policy to procurements below the relevant PCR threshold will be reviewed prior to 1 April 2026 following the implementation of the 2024 requirements. This section will be updated with the full reporting mechanism for procurements below the relevant PCR threshold prior to 1 April 2026.

CRP and Net Zero Commitment requirements within the procurement process

Frameworks and dynamic purchasing systems (DPS)

All new NHS framework or DPS agreements, irrespective of contract value, are required to apply the full CRP requirements.

Where NHS framework owners determine the CRP requirements not to be proportionate and relevant to the nature of the framework and out of scope of PPN 06/21, the owner should apply the Net Zero Commitment requirements.

Commissioned healthcare services

Commissioned Healthcare services are in scope of the requirements, which should be applied by contracting authorities through relevant procurement processes in line with the implementation dates and contract values set out in this document.

Due care should be taken by decision-making bodies to ensure providers are ready to comply with all future requirements outlined in the NHS net zero supplier roadmap whenever contracts for healthcare services are coming to an end, changing considerably, or being awarded for the first time. Further details around changes to the commissioning process are provisionally outlined in the Provider Selection Regime.

Single Tender Actions (STAs) and Direct Awards (DAs)

STAs and DAs (where the requirement is not otherwise covered, for example in framework or DPS agreements) are in scope of the requirements outlined in this guidance. Due to the nature of these procurements, the requirements should be included where possible as mandatory supplier questions but not assessed as a pass-fail requirement, evidence is provided for informational purposes only.

Further information

NHS to NHS contracts

Where NHS organisations (including primary care organisations) are bidding for contracts with other NHS organisations, a current and published NHS trust and/or integrated care board (ICB) Green Plan is considered equivalent to a CRP and the NHS Net Zero Target is considered equivalent to a Net Zero Commitment, given the NHS England Public Board-approved public commitment to net zero and the regular public update of the NHS emissions.

NHS organisations should provide a link to their published Green Plan and complete the relevant required reporting questions, questions 1 and 2 of the Selection Questionnaire questions in the “CRP and Net Zero Commitment reporting mechanism” section of this document. NHS organisations do not need to complete the emissions reporting questions, 3 and 4, of the Selection Questionnaire as NHS organisations report emissions via central reporting processes.   

Public bodies

Where other public bodies are bidding for NHS contracts, the public body will need a compliant CRP and/or Net Zero Commitment. Public bodies should provide a link to the published CRP and/or Net Zero Commitment and complete the required questions as part of the Selection Questionnaire as detailed in section ‘CRP and Net Zero Commitment reporting mechanism’.

Subcontractors

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

Small and medium-sized enterprises (SMEs) and voluntary, community and social enterprises (VCSEs)

SMEs can find support and advice on how to take climate action on The UK Business Climate Hub, the hub is a collaboration between the UK Government, businesses and business groups across the UK to empower SMEs to take climate action.

In exceptional circumstances, for procurements where a CRP is required, 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.

In line with PPN 06/21, this provision can apply to all suppliers. Please see ‘supplier response’ 7 of Annex 1 of this document for more information.

A supplier’s explanation will be assessed on a case-by-case basis by the contracting authority. Suppliers are also required to provide the steps they will take to improve the 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.

To account for the specific barriers that some suppliers may face, the Net Zero Commitment requirements apply from 1 April 2024 for procurements above the relevant PCR threshold and from 1 April 2026 for procurements below the relevant PCR threshold. The exceptional circumstances that apply to the Net Zero Commitment requirements are set out in Annex 1. The extension of the policy to procurements below the relevant PCR threshold will be reviewed prior to 1 April 2026 following the implementation of the 2024 requirements.

Useful resources

1. PPN 06/21: Taking account of Carbon Reduction Plans in the procurement of major government contracts
2. Carbon Reduction Plan Template
3. Guidance on adopting and applying PPN 06/21: Selection criteria
4. Technical standard for completion of Carbon Reduction Plans
5. PPN 06/21: Frequently asked questions
6. UK Business Climate Hub – find advice on energy saving and net zero for SMEs

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.

NHS England is offering support for suppliers to help them fulfil the requirements, including regular webinars and a CRP checking service. Suppliers can access the checking service by contacting the following email address: england.crp-check@nhs.net.

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

Exceptional circumstances

It may not be relevant or proportionate to apply these CRP and Net Zero Commitment requirements 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 (for example patient care) 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 and in-scope organisations should ensure they apply the requirements in a relevant and proportionate manner. Reasons for not applying the measure should be documented by the contracting authority.

Annex 2: Decision flow of CRP and Net Zero Commitment reporting mechanisms

The below diagram has been designed to aid contracting authorities understand which CRP or Net Zero Commitment reporting mechanism should be applied for their procurement.

Annex 3: Net Zero Commitment format

Below is a suggested format for suppliers to use to help clearly format their Net Zero Commitment. Note this is only a suggested format and suppliers can provide a Net Zero Commitment in a different format as long as the commitment is clear, concise and easy to locate on the supplier’s website (via a link).

“[Supplier name] is committed to achieving Net Zero emissions by 20XX for emissions scopes X, X and X. The commitment was made on DD/MM/YY by the [approving board/equivalent management body]”

Publication reference: PRN00711