In early February 2025 NHS England published “refreshed” green plan guidance for systems and trusts. The guidance builds on the learnings of a three-year cycle of action and commitment by healthcare organisations and their suppliers to deliver a net zero NHS.
NHS green plans matter, and not just to the teams and individuals responsible for delivering them. The NHS manages more than 1.7 million patient contacts each day, employs more that 1.3 million people, and is responsible for between four and five per cent of total UK carbon emissions. With such a wide sphere of influence, action on net zero by the NHS has far-reaching impacts in the UK and beyond.
Here is a brief overview of the latest green plan requirements and what to expect next.
Key dates
2020 The NHS is the world’s first healthcare system to commit to net zero.
2021 NHS England publishes its first green plan guidance asking systems and trusts to develop green plans spanning three years (2022/23 to 2024/25).
2022 The green plan “ask” becomes a duty under the Health and Care Act 2022.
April 2022 A minimum 10% net zero and social value weighting is included in all NHS procurements.
April 2023 For all new contracts above £5 million per annum, the NHS requires suppliers to publish a Carbon Reduction Plan in alignment with PPN 06/21.
31 July 2025 NHS systems and trusts are required to publish refreshed, board-approved green plans for the next three-year cycle.
From April 2027 NHS supplier obligations increase with all suppliers required to publish a Carbon Reduction Plan for all Scope 1, 2, and 3 emissions.
From April 2028 New requirements for the carbon footprinting of individual products supplied to the NHS will be introduced.
From 2030 In order to qualify for NHS contracts, suppliers must be able to demonstrate progress to net zero through published reports and continued GHG emissions reporting.
2028 to 2032 Interim 80% reduction target for the NHS Carbon Footprint.
2036 to 2039 Interim 80% reduction target for the NHS Carbon Footprint Plus.
2040 Net zero target year for the emissions the NHS controls directly (NHS Carbon Footprint).
2045 Net zero target year for the emissions the NHS has the ability to influence (NHS Carbon Footprint Plus).
Green plan refresh
The latest guidance recommends NHS organisations take a collaborative approach to refresh their green plans in alignment with updated priorities. The approach should include:
- a review of green plan progress to date,
- stakeholder engagement on priorities, particularly clinical and staff groups,
- reference to national targets and interim 80% emissions reduction goals,
- definition of SMART actions and KPIs for each area of focus,
- governance processes to measure and report on progress, and
- mechanisms to ensure legal compliance where required.
Areas of focus
NHS green plans are structured around areas of focus drawn from contributions by NHS staff and external expertise. The refresh guidance takes into account progress to date in prioritising actions for the next cycle in each area of focus. Here are some of the key refresh priorities.
Workforce and system leadership
- Appointment of a designated board-level net zero lead is recommended along with upskilling and specialist training for staff delivering on green plan actions.
Net zero clinical transformation / Digital transformation
- Green plans should support commitment to preventative, out-of-hospital, and digitally-enabled care where clinically appropriate and focus actions on carbon-intensive clinical areas such as critical care, emergency care, and mental health.
Medicines
- 25% of NHS emissions are from medicines, with a significant proportion originating from anaesthetic gases (2%) and inhalers (3%).
- Guidance for decommissioning desflurane, an anaesthetic with high global warming potential, is available, and mitigation guidance to reduce nitrous oxide emissions will soon be published.
- Green plans should support patients and primary care providers to reduce inhaler waste and other impacts.
Travel and transport
- Specific time-bound goals are set out in the NHS Net zero travel and transport strategy towards the target of a fully decarbonised fleet by 2035.
- Green plans should include a sustainable travel plan by 2026 underpinned by a clear understanding of employee commuting patterns and including a shift to zero-emissions vehicles in all lease and purchase agreements.
Estates and facilities
- Employee and expert engagement has identified many opportunities for reducing energy consumption and emissions while lowering costs across the NHS estate.
- Key priorities include electrification and heating system upgrades, aligning estate decarbonisation plans with local priorities, and compliance with the NHS Net Zero Building Standard.
Supply chain and procurement
- A strong priority for green plans this cycle is action to tackle supply chain emissions, estimated to be 62% of total NHS emissions.
- Required actions of suppliers are detailed in the NHS net zero supplier roadmap, with monitoring and reporting obligations steadily increasing over the next three to five year period.
Food and nutrition
- Priorities in this focus area include delivery of healthy and sustainable food and control of waste through monitoring and reporting against reduction targets.
Adaptation
- Continuity planning and emergency preparedness must be part of green plans to ensure organisational resilience in adverse weather and other climate emergencies.
Further resources
Refreshed green plans should be board approved and delivered to the NHS by 31 July 2025, with reports on progress due annually as per NHS sustainability reporting requirements. Green plans should also be published on organisations’ websites in a location accessible to the public.
Further guidance, checklists, toolkits, case studies and other supporting resources for reporting organisations are available on the Future NHS knowledge hub.
Working with Grain
At Grain we have wide experience supporting clients in the healthcare sector on their sustainability journeys and with carbon footprinting and PPN06/21 compliance. Our expertise makes us an ideal partner on green plan refresh for organisations within the NHS and for carbon footprinting, Carbon Reduction Plan development, and progress reporting for NHS suppliers.
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