Suppliers hoping to win NHS contracts must produce carbon reduction plans

15 February 2023

NHS suppliers must commit to net zero by 2050 and publish details surrounding key areas of their scope three supply chain emissions under new requirements. 

Suppliers with contracts worth £5m and above a year will be required to publish carbon reduction plans (CRPs) for their scope one and two emissions, and a “defined subset” of scope three emissions, NHS England said.

The move aligns the organisation with a 2021 UK government Procurement Policy Note that banned bidders with no net zero plan. 

The rules will apply to all new contracts from April 2023. Suppliers whose CRPs do not meet the minimum expectations will not get beyond the pre-qualification stage.

The requirement to provide a CRP comes in conjunction with rules requiring a minimum 10% weighting on net zero and social value in NHS procurement, which was introduced in April 2022.

CRPs must include details on current carbon footprint and plans to achieve net zero emissions. Suppliers must publish data on a website, and they must share this information as part of the procurement process. 

Suppliers must have targets to achieve net zero by 2050 or earlier for their UK operations.

Scope three emissions that will need to be reported by suppliers include:  

  • Upstream transportation and distribution

  • Waste generated in operations

  • Business travel

  • Employee commuting

  • Downstream transportation and distribution

To comply with the requirements, suppliers will further have to establish environmental management measures, including certification schemes or specific carbon reduction measures, which must be clearly signposted on the supplier’s website and updated at least once a year. 

In “exceptional circumstances” – including when considering issues faced by SMEs and voluntary, community, and social enterprises – where suppliers have an acceptable reason for being unable to present their emissions data, such suppliers will be able to present plans with the carbon emissions they have available and include an explanation why any data may not be included in their submission.

However, such suppliers will be required to provide the steps they will take to improve the collection of such data.

The announcement comes as part of the NHS’s broader Net Zero Supplier Roadmap. All suppliers doing business with the NHS will be required to produce CRPs by April 2023, and from 2027 all suppliers will be required to publicly report targets and all their scope one, two and three emissions.

The NHS is responsible for 4-5% of all carbon emissions in England, according to NHS estimates. 

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