A year ago we told you about refreshed NHS Green Plan guidance and what it meant for organisations across the UK health system. From 2027, NHS supplier obligations are set to increase significantly.
Now is the time to check if your organisation is prepared.
Five years on from its commitment to become the world’s first net zero health system, the NHS is now focused on implementation. The NHS accounts for up to five per cent of the UK’s carbon footprint, which means that reducing emissions is a national priority. Sustainability in the NHS is no longer treated as a separate agenda. It is increasingly embedded in decisions about estates, clinical practice, and procurement.
Current NHS supplier requirements
From April 2022: All NHS procurements included a minimum 10% weighting for net zero and social value.
From April 2023: Suppliers on larger NHS contracts (£5m pa+) were required to publish a Carbon Reduction Plan (CRP) aligned with PPN 06/21.
From April 2024: CRP requirements were proportionally extended to all procurements.
What’s coming next
By April 2027: All NHS suppliers, regardless of size or contract value, must publicly report a full emissions statement (Scope 1, 2 and 3) and publish carbon reduction plans aligned to NHS net zero targets.
By April 2028: Suppliers will need to provide product-level carbon footprinting data. Guidance on scope and methodology are currently in development.
The growing importance of the supply chain
The NHS has made clear that it cannot achieve its net zero targets without action across its supply chain. Sustainability is now a routine consideration in NHS procurement processes, and carbon reduction is built into how contracts are awarded and managed.
Tools such as the Evergreen Sustainable Supplier Assessment provide a standard way for suppliers to report their progress and demonstrate alignment with NHS priorities. For the NHS this ensures a more consistent approach to data collection and allows for better visibility of performance across the supply chain. For organisations developing or refreshing Green Plans, this means closer engagement with their own suppliers and a clearer understanding of supply chain emissions and risks.
What you need to prepare
PPN 06/21 emissions calculation requirements include Scope 1 and Scope 2 plus specific Scope 3 categories related to freight, waste, business travel, and employee commuting (categories 4, 5, 6, 7, and 9).
If your current carbon emissions statement and reduction plan includes only this subset of categories, you need to go further and prepare a full inventory of Scope 3 emissions. From 2027, your revised carbon reduction plan (CRP) will need to take into account how you plan to manage your own supply chain in order to realise the required carbon reductions over time. This shift demands a deeper and wider analysis of supply chain data and an often greater degree of engagement and collaboration between procurement teams and suppliers.
From 2028, expectations increase significantly again, requiring high-quality primary component and ingredient data from deep within supply chains and consistent and rigorous analysis methodologies in order to report emissions at the product level.
New NHS supplier reporting obligations are now less than a year away. To navigate these new requirements, our best advice is to plan ahead. Start by analysing your supply chain and prioritising the highest impact areas, by volume, for example, or by value. Follow up by engaging the most impactful suppliers as early as possible to help ensure they are ready with emissions data when you need it.
Working with us
We have wide experience supporting healthcare and other clients with carbon footprinting, PPN 06/21 compliance and carbon reduction plan development and progress reporting. We can help you now to ensure you’re ready for NHS supplier requirements in 2027 and beyond.
Need help? Get in touch!
