By Rob Atkins, Founder & Principal Consultant
On central government contracts worth more than £5 million a year including VAT, usually yes. From 1 April 2027, NHS rules reach further, down to procurements below £5 million a year that are above the published procurement thresholds. Elsewhere it's down to the buyer. Here's the part worth knowing: under the central government guidance, the plan is pass or fail and your emissions figures aren't what's being assessed. A foundry with a big footprint can pass. A clean assembly shop with an out-of-date plan can fail. So what you need is a plan that's complete, current and signed off, and that takes data most manufacturers haven't pulled together.
PPN 006 applies to departments, their agencies and non-departmental public bodies on contracts above £5 million a year including VAT, unless it isn't relevant or proportionate. The value is averaged over the contract's life, so a four-year contract worth £21 million is in scope.
At £5 million a year or more, and on new frameworks and dynamic markets by default, the 2027 NHS plan applies and covers all relevant Scope 3 emissions. Below £5 million but above the procurement thresholds, a plan with the shorter Scope 3 list applies. Procurements started earlier stay under the old rules.
Wales has its own policy note, WPPN 006. Councils and other public bodies can set their own requirements, so read the conditions of participation on each tender.
If a bigger customer needs to report on its supply chain, or is bidding for public work itself, it may ask you for a plan as a condition of doing business, even when your own contract is well under £5 million.
The plan has to commit to net zero by 2050 at the latest for your UK operations. Leave that out and it fails, however good the rest of it is. Carbon Reduction Plans and ESG
You need all of Scope 1 and 2, plus five Scope 3 categories: upstream transport, waste from your operations, business travel, employee commuting and downstream transport. For a manufacturer, that means inbound freight and deliveries to customers. Leaving out a required Scope without explaining why is a fail.
A reporting period more than 18 months old fails unless you can explain why. The plan should be reviewed and updated every year, within six months of your financial year-end, so one you wrote two years ago for a tender may no longer count.
The board has to approve it and a director has to sign it. It also has to set out your environmental management measures, and be published on your UK website with a link in a prominent place on your homepage.
You can download the government's template in a minute. Filling it in is another matter, because it needs a full year of energy bills, fuel, waste, freight, business travel and commuting figures, and those usually sit with different people, if anyone's kept them at all.
Start when the tender lands and you could find yourself working out a year's emissions against a closing date. And you'll need to do it again next year.
Get the data flowing first, then write the plan, then tie the annual update to your year-end so it never goes stale. I bring in a carbon specialist from the Cure Alliance who understands manufacturing, and make sure the plan matches what you say elsewhere in your bids.
One relationship. Every specialist. A plan that's ready before the tender asks for it.
No general law says every manufacturer must have one. It's a condition buyers set for taking part in a tender. Larger companies may have separate carbon reporting duties under Streamlined Energy and Carbon Reporting, so check that with your accountant.
Not under the central government guidance. The compliance questions are pass or fail, and your baseline and current emissions are for information only. Other buyers can treat it differently, and carbon commitments can also come up in social value or contract terms, so read each tender's criteria.
Under PPN 006, only in limited circumstances: the bidder must be wholly owned by the parent, adopt its commitment and publish the plan on its own website. PPN 006 treats this as a temporary measure until the bidder has a plan of its own.
The guidance says suppliers trading for under 12 months shouldn't be disadvantaged. You should confirm your commitment to net zero by 2050 and publish a full plan as soon as you can.
Yes. The central government guidance says each consortium member should complete its own plan, so check your partners have theirs in good time.
Not necessarily. From 1 April 2027, the NHS plan for procurements of £5 million a year or more needs all relevant Scope 3 emissions, not just the five categories, and has its own rules on net zero. Check the NHS England guidance that applies to your tender.
Sources: PPN 006: Carbon Reduction Plans (GOV.UK) · PPN 006 guidance on conditions of participation (GOV.UK) · PPN 006 technical standard (GOV.UK) · 2027 NHS Carbon Reduction Plan requirements (NHS England) · WPPN 006: Carbon Reduction Plans in Wales (GOV.WALES)
Written by Rob Atkins, Founder & Principal Consultant, Your Best Solution Limited. Last updated .