Starting from April this year, NHS suppliers will be required to publish a Carbon Reduction Plan (CRP) if their anticipated contract value is above £5m.

Used in partnership with the UK government’s Procurement Policy Note (PPN) 06/21, the requirement will involve the commissioning and purchasing of goods, services, and works by in-scope organisations. This includes organisations that are a part of the NHS itself as well as those that are acting on behalf of the NHS.

The NHS is encouraging suppliers to set their net zero goals for 2045 to ‘best prepare for future NHS roadmap milestones.’ This would supersede the CRP’s 2050 requirement by 5 years, setting an ambitious front for suppliers. Subcontractors are not included in the scope of the report, but the NHS encourages suppliers to engage with subcontractors to make sure they are actively working towards reducing emissions.

Additionally, suppliers must assume that their CRPs will be disclosed during the procurement process and have a public version of them on their websites.

NHS CRP requirements

A supplier’s CRP must comply with PPN 06/21 and the NHS’s requirements by:

  • Explicitly outlining the organisation’s commitment to reaching net zero by 2050, or earlier, for their UK operations
  • Setting out the environmental management measures already in place
  • Be board approved, or company director approved in the event of no board being in place
  • Being easily found on the supplier’s website
  • Being updated regularly; at the very least annually
  • Detailing the bidder’s current emissions for the sources included in scope 1 and 2 of the Greenhouse Gas Protocol, and a defined subset of scope 3. The relevant scope 3 categories include:
  • Upstream transportation and distribution
  • Downstream transportation and distribution
  • Waste generated in operations
  • Business travel
  • Employee commuting
  • Providing carbon dioxide equivalent emissions for the seven greenhouse gases covered in the Kyoto Protocol, which are: Carbon dioxide, Methane, Nitrous oxide, Hydrofluorocarbons, Perfluorocarbons, Sulphur hexafluoride, Nitrogen trifluoride.

Other CRP guidelines to follow

As organisations are creating their CRPs, the NHS suggests that they should adhere to the government’s Technical standard for Completion of CRPs while following the length and structure of the government’s PPN 06/21 CRP template.

CRPs may also be specific to the bidding company, but can ‘cover the bigging organisations and its parent entity’ if:

  • The parent business fully owns the bidding organisation.
  • The parent organization’s CRP contains information about the 2050 net zero pledge, and the plan also makes clear that the bidder company supports it and that it also applies to it.
  • The firm submitting the proposal may carry out the proposed eco-friendly initiatives throughout the contract.
  • The website of the soliciting organisation posts the CRP.
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