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NHS England (NHSE) has published new guidance setting out the next milestone of the NHS Net Zero Supplier Roadmap, with new supplier requirements due to take effect from 1 April 2027.
From April 2027, the NHS will implement new proportionate requirements for suppliers to publicly report targets and emissions, and publish a Carbon Reduction Plan (CRP) for all relevant global scope 1, 2, and 3 emissions. The requirements form part of the NHS’s wider commitment to reaching net zero by 2045, as set out in ‘Delivering a Net Zero National Health Service’.
The BHTA encourages members that supply, or intend to supply, goods, services, or works to the NHS to review the new guidance and begin preparing for the April 2027 requirements.
NHSE has published two documents to support suppliers and procurement teams ahead of the April 2027 milestone: ‘2027 NHS Carbon reduction plan requirements for the procurement of NHS goods, services and works’, and ‘Market sounding findings: net zero supplier requirements from April 2027’.
From 1 April 2027, the new guidance replaces the current carbon reduction plan guidance and associated requirements, which should continue to be followed for in-scope procurements commenced before that date.
The accompanying market sounding findings explain how supplier and stakeholder feedback informed the final policy approach, including changes to the net zero target date, target validation, and offsetting requirements.
The requirements apply to the commissioning and purchasing of goods, services, and works by in-scope NHS organisations, including where a third party acts on their behalf.
To ensure the requirements are applied in a proportionate and relevant way, the policy will follow a two-tiered approach.
The 2027 NHS Carbon Reduction Plan (2027 NHS CRP) tier will apply to high-value procurements of £5 million per annum and above, including VAT, and all new frameworks operated by in-scope organisations, irrespective of the value of the framework contract, where relevant and proportionate to the framework. A 2027 NHS CRP covers all scope 1, scope 2, and relevant scope 3 emissions.
The 2024 CRP tier will apply to lower-value procurements below £5 million per annum, including VAT, and above the relevant published procurement thresholds. A 2024 CRP covers all scope 1 and scope 2 emissions, and a subset of scope 3 emissions. NHSE states that this reflects the existing CRP content in place since April 2023 for the NHS and aligns with the CRP content defined in PPN 006.
A compliant CRP must set out the supplier’s baseline and current emissions, environmental management measures, and planned actions to achieve net zero. It must also be approved by the board, or by a company director if no board is in place, and clearly signposted and published on the supplier’s website.
CRPs will be assessed on a pass/fail basis and will not be scored or compared against each other; suppliers that do not meet the minimum requirements may be unable to proceed, except in exceptional circumstances.
Annex 2 of the guidance compares the 2024 CRP and 2027 NHS CRP requirements. In summary, the 2027 NHS CRP expands the requirements by applying a global geographical boundary and requiring suppliers to report scope 1, scope 2, and all relevant scope 3 emissions in line with the GHG Protocol Corporate Value Chain (Scope 3) Standard. The NHS also recommends that suppliers work towards a 2045 net zero target, obtain independent third-party target validation, and disclose the expected proportion of their net zero target that will rely on offsetting.
Suppliers can access a range of support to help them meet the requirements. This includes NHSE webinars on the new requirements, taking place on 16 June at 11am and 23 June at 2pm. Future webinars and on-demand support videos are also available through the NHSE Net Zero and Sustainable Procurement Team webinar programme.
Additional support is available through NHSE’s Sustainable Supplier Accelerator Programme, which provides guidance on areas such as carbon accounting and target setting. Suppliers can also use resources from the UK Business Climate Hub, including free tools and calculators.
NHSE is also encouraging suppliers to use the NHS Evergreen Sustainable Supplier Assessment to check the content of their Carbon Reduction Plan against the policy requirements using the maturity levels.
At ‘The Future of MedTech – Innovating for Tomorrow’ conference, Alexandra Hammond, Associate Director for Net Zero & Sustainable Procurement at NHS England, delivered the second part of a talk titled ‘Building a Sustainable Future through Responsible Procurement’.
Hosted by the British Healthcare Trades Association (BHTA) and AXREM, the conference took place on 13 May 2025 at The Mercure, Northampton.
The first part of the talk was delivered by Chris Taylor, Sustainability Lead UKI at Philips Health Systems.
Alexandra provided an in-depth look at how NHS England is embedding sustainability, social value, and modern slavery prevention into its procurement practices, all in support of the NHS’ broader net zero ambitions.
Alexandra began by highlighting that 66 percent of the NHS’ carbon footprint lies within its supply chain, positioning sustainable procurement as a powerful tool in the journey towards net zero. Her team’s mandate focuses on sustainable procurement and supply chains, while also driving social value and tackling modern slavery.
She reminded attendees of the NHS’ clear commitment: by the end of this decade, it will no longer work with suppliers who are not aligned with its net zero goals. To support this, the NHS Net Zero Supplier Roadmap lays out a series of milestones, several of which are already in place. These include embedding social value in all procurements and requiring suppliers to provide a carbon reduction plan.
From 2027, suppliers will be expected to expand the scope of their carbon reporting, with additional requirements on product-level emissions and disclosure coming in 2028. Alexandra emphasised that these future milestones are still in development and urged suppliers to take part in shaping the final policies.
A key enabler of the NHS’ sustainability work, Alexandra noted, is the National Procurement Policy Statement, published on 13 February 2025. This policy reinforces NHS England’s commitment to embedding net zero, social value, and ethical standards in procurement. Importantly, it aligns with wider government priorities for the public sector, including building an NHS for the future, kickstarting economic growth, and making the UK a clean energy superpower.
Alexandra explained that the statement is more than just guidance – it provides a formal basis for public sector organisations, including NHS bodies, to adopt procurement practices that reflect environmental and social priorities. It marks a shift from policy aspiration to concrete expectation.
Alexandra reassured suppliers that NHS England will take a proportionate, clear, and collaborative approach, with plenty of notice before implementing new policies. She noted that NHS England is listening closely to supplier feedback.
She also pointed to the NHS Evergreen Sustainable Supplier Assessment, hosted within the NHS Atamis e-procurement system, as a key tool for dialogue between the NHS and suppliers on sustainability. This tiered assessment enables suppliers to track and improve their maturity level on sustainability issues, without duplicating information across multiple systems.
Beyond net zero, Alexandra spoke about the evolving expectations around social value. The government’s updated procurement priorities now include building a future-ready NHS, alongside themes such as clean energy, economic growth, and inclusion.
New regulations on modern slavery are also on the horizon, with NHS England working closely with the Department of Health and Social Care to ensure that supply chains are fair, ethical, and transparent. Procurement will play a central role in embedding these requirements across the health system.
For BHTA members, Alexandra’s message was one of opportunity and urgency. The NHS is committed to supporting suppliers, including SMEs, with tools, guidance, and access to events and on-demand resources such as emissions verification webinars and updates on science-based targets.
Alexandra concluded with a strong call to action for suppliers: engage with the NHS on these changes, make use of the Evergreen tool, and help co-design the future of sustainable procurement.
