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Carbon reduction plans to be mandated for suppliers, the NHS says

From April 2023, NHS entities will require all their suppliers with an anticipated contract value above £5m to publish a carbon reduction plan (CRP).

This requirement will be used in tandem with the Government’s procurement policy note (PPN) 06/21 and will pertain to the commissioning and purchasing of goods, services and works by in-scope organisations – in other words, those acting on behalf of the NHS or organisations that are directly part of the NHS itself.

Whilst a goal of 2050 would still meet the CRP’s minimum requirements, the NHS has encouraged suppliers to set their net zero targets for 2045 to “best prepare for future NHS roadmap milestones.”

The health service has also stated that it will require suppliers to have their CRPs publicly accessible via their websites, as well as an expectation that it will be shared during the procurement process.

In order to align with central government’s PPN 06/21 and the NHS’s stipulations, a supplier’s CRP must:

  • Explicitly outline the organisation’s commitment to reaching net zero by 2050 or earlier for their UK operations
  • Detail 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
  • Provide 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
  • Set out the environmental management measures already in place
  • Be board approved, or company director approved in the event of no board being in place
  • Be easily found on the supplier’s website
  • Be updated regularly; at the very least annually

The NHS also highlights that, when organisations are developing their CRPs, they should adhere to the Government's Technical standard for Completion of CRPs and the plans should follow the length and structure of central government’s PPN 06/21 CRP template – though stylistic discrepancies will be accepted.

Such CRPs should also be specific to the bidding company but can cover the bidding organisations and its parent entity if:

  • The parent company owns the bidding organisation in full
  • The 2050 net zero pledge is detailed in the parent organisation’s CRP as well as a statement in the plan outlining that it applies and is supported by the bidding company
  • The eco-friendly measures put forward can be performed by the bidding entity during the contract
  • The CRP is published on the bidding organisation’s website

More information is available here.

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