What is the NHS Net Zero Supplier Roadmap?
The NHS Net Zero Supplier Roadmap is the framework through which NHS England is progressively increasing sustainability requirements for organisations supplying goods, services and works to the NHS. It supports the NHS’s ambition to reach net zero for emissions it controls directly by 2040 and for emissions it influences, including its supply chain, by 2045.
For suppliers, one of the most significant elements is the requirement to produce and publish a Carbon Reduction Plan (CRP). A CRP sets out an organisation’s carbon footprint, its commitment to achieving net zero and the measures it will take to reduce emissions.
Requirements were initially introduced for higher-value NHS procurements in April 2023 and proportionately extended to all new procurements from April 2024. From 1 April 2027, requirements will expand significantly to cover relevant global Scope 1, Scope 2 and Scope 3 emissions.
Who does the NHS Net Zero Supplier Roadmap apply to?
The requirements are relevant to organisations supplying goods, services and works to NHS organisations in England, including pharmaceuticals and healthcare services. NHS organisations commissioning or procuring these goods and services are responsible for applying the requirements to relevant procurement activity.
Under the current arrangements, a full CRP applies to high-value procurements of £5 million or more per annum, including VAT, and to relevant new frameworks. Lower-value procurements below £5 million per annum (including VAT), but above the relevant published procurement thresholds, are subject to proportionate requirements.
From April 2027, NHS England will introduce a two-tier approach: the enhanced 2027 NHS CRP will apply to procurements of £5 million or more per annum and relevant new frameworks, while the existing 2024 CRP requirements will continue to apply proportionately to lower-value procurements.
What are the key requirements?
A compliant CRP must demonstrate that the supplier understands its emissions and has a credible plan for reducing them.
Under the existing requirements, suppliers must:
- Commit to achieving net zero by 2050 or earlier.
- Report relevant Scope 1 and Scope 2 emissions.
- Report a defined subset of Scope 3 emissions.
- Report emissions in tonnes of CO₂e.
- Set out environmental management measures and carbon reduction actions.
- Obtain appropriate senior-level/board approval.
- Publish the CRP prominently on the supplier’s website.
- Review and update the CRP at least annually
From 1 April 2027, the enhanced NHS CRP will require reporting of both the supplier’s baseline and current global Scope 1, Scope 2 and relevant Scope 3 emissions, using the GHG Protocol framework, alongside targets and environmental management measures.
What are the timelines and deadlines for the NHS Net Zero Supplier Roadmap?
The roadmap progressively increases supplier requirements over time:
April 2022
- NHS procurements began incorporating a minimum 10% net zero and social value weighting.
April 2023
- CRPs became mandatory for relevant new contracts worth £5 million or more per annum.
April 2024
- CRP requirements were proportionately extended to all new procurements.
1 April 2027
- New NHS CRP requirements come into effect, including reporting of relevant global Scope 1, 2 and 3 emissions.
April 2028
- The NHS plans to introduce requirements relating to carbon footprinting of individual products supplied to the NHS.
2030
- NHS plans indicate that suppliers will need to demonstrate progress through published progress reports and continued carbon emissions reporting to qualify for NHS contracts.
Suppliers should not wait until 2027: establishing robust Scope 3 data and reporting processes can take considerable time, particularly where emissions data must be obtained from suppliers and other parts of the value chain.
What are the risks of non-compliance?
The most immediate risk is loss of eligibility for NHS procurement opportunities where a CRP or other net zero requirement forms part of the procurement conditions.
For relevant procurements, the CRP requirement can operate as a condition of participation, meaning suppliers may need to demonstrate compliance to proceed in the procurement.
Poor-quality or incomplete carbon data can also create difficulties during tender evaluation and contract management. Suppliers may face increasing scrutiny of their emissions data, targets and delivery against their commitments.
Looking further ahead, the roadmap states that from 2030 suppliers will only be able to qualify for NHS contracts if they can demonstrate progress through published progress reports and continued carbon emissions reporting.
There is therefore a strategic risk for organisations that treat CRPs as a compliance document rather than embedding carbon reduction into procurement, operations and supply-chain strategy.
What are the business opportunities?
The NHS is one of the UK’s largest purchasers, making sustainability performance increasingly relevant to market access and competitive advantage. A strong CRP can help suppliers demonstrate environmental leadership during NHS tenders and distinguish themselves where sustainability forms part of evaluation. NHS procurement has included a minimum 10% net zero and social value weighting since April 2022.
The process can also identify opportunities to reduce energy, fuel, waste, logistics and resource costs. Better Scope 3 data can reveal carbon hotspots across the supply chain and support more efficient procurement and product design.
For suppliers operating beyond healthcare, developing robust CRP capability can provide a transferable advantage in other public-sector procurement, particularly because the NHS requirements build on UK Government procurement policy, including PPN 006.
The NHS Net Zero Supplier Roadmap therefore represents both a compliance requirement and a potential commercial differentiator.
How should organisations prepare?
Organisations should start by treating the CRP as a strategic business requirement rather than simply a tender document.
Key actions include:
- Establish organisational ownership at board/director level.
- Define the organisational and operational boundaries of the CRP.
- Calculate a robust baseline carbon footprint using the GHG Protocol.
- Ensure Scope 1 and 2 data is accurate, consistent and auditable.
- Identify and improve data for relevant Scope 3 categories.
- Develop measurable emissions-reduction targets and a credible delivery plan.
- Identify carbon reduction measures that can be applied when delivering NHS contracts.
- Establish an annual process for updating the CRP.
- Obtain board approval and publish the latest CRP prominently on the organisation’s website.
- Prepare now for the broader global Scope 3 requirements coming into force in April 2027.
Suppliers should also review the 2027 NHS CRP technical requirements and the latest government PPN 006 technical standard when developing their methodology.