Since April 2024, it has become mandatory for all NHS suppliers to calculate and report their carbon footprint when bidding on contracts, regardless of size. Furthermore, any organisation bidding for public sector contracts worth over £5 million per annum must commit to achieving Net Zero by 2050 and provide a detailed Carbon Reduction Plan (CRP). These requirements mandate compliance with Procurement Policy Note (PPN) 06/21. As such, compliance errors with PPN 06/21 could potentially cost organisations valuable public sector contracts worth millions. For organisations subject to it, here are the PPN 06/21 Mistakes to Avoid:
Board Level Sign-off
One critical mistake organisation make with PPN 06/21 compliance involves neglecting proper governance documentation. According to government guidelines, your CRP must be approved by a director or equivalent senior leadership position within your organisation. This requirement exists primarily because senior leadership approval demonstrates organisational commitment at the highest level to achieving carbon reduction targets.
A compliant CRP must include:
- Organisational carbon footprint baseline year
- Current greenhouse gas (GHG) emissions split by Scope 1, 2 and 3 categories
- Defined carbon reduction targets
- Description of emissions reduction measures in place
- Board-level approval and a public statement
Read More: A Step-by-Step Guide to a PPN 06/21 Plan
Without proper sign-off, contracting authorities may question your company's dedication to environmental sustainability. In fact, the absence of appropriate leadership endorsement is explicitly listed as grounds for exclusion from bidding opportunities. The technical standard for CRPs clearly states that all plans must indicate that board of directors (or equivalent management body) approval has been given, along with the specific date of approval.
This is intended to send a powerful message both internally and externally that your organisation genuinely prioritises its environmental responsibilities. For Limited Liability Partnerships (LLPs), the requirements differ slightly but remain equally stringent. Your CRP must receive members' approval rather than board approval, with the plan clearly stating that such approval has been granted along with the approval date.
Tip: Use the official government CRP template and cross-reference the checklist provided in the guidance documents
Neglecting Mandatory Scope 3 Emissions
Many organisations fall short in their PPN 06/21 compliance by overlooking or underreporting Scope 3 emissions. Unlike Scopes 1 and 2, which cover emissions directly owned or controlled by an organisation, Scope 3 encompasses all other indirect emissions occurring throughout the value chain.
Read More: What are Scope 1, 2, and 3 Emissions?
Scope 3 emissions typically constitute the lion's share of an organisation's carbon footprint, often representing up to 80% of total greenhouse gas emissions. Given their significance, the UK government has made reporting on specific Scope 3 categories mandatory under PPN 06/21, albeit not requiring all 15 categories defined by the GHG Protocol. PN 06/21 explicitly requires the inclusion of select Scope 3 categories:
- Business travel
- Employee commuting
- Waste generated in operations
- Upstream transportation and distribution
- Downstream transportation and distribution
Failing to report on these five categories is a direct breach of the policy. Some suppliers mistakenly exclude Scope 3 emissions due to perceived data gaps or complexity, but government guidance is clear that estimated data is acceptable where actuals are not yet available.
Tip: Focus on materiality and use established emissions factors and boundary setting methodologies (e.g. GHG Protocol). You can also engage third-party sustainability experts to support and advice on calculating Scope 3 emissions.
Using CSR Statements Instead of a CRP
A recurring error among bidders for government contracts involves submitting Corporate Social Responsibility (CSR) statements in place of properly formatted Carbon Reduction Plans (CRPs). This fundamental misunderstanding could immediately disqualify even environmentally committed organisations from the procurement process. CSR statements typically cover broad environmental and social initiatives but lack the specific carbon emissions data and reduction commitments required under PPN 06/21. While a CSR document might outline general sustainability goals, it rarely includes comprehensive scope 1, 2 and mandatory scope 3 emissions data that procurement teams need to evaluate.
Although a CSR is distinct from other environmental documents, you may reference these complementary commitments within your CRP as examples of your broader environmental management approach: "Suppliers may detail their membership of schemes such as SBTI or Race to Zero within their CRP as an example of the environmental management measures they have in place".
Tip: To ensure compliance, suppliers should strictly follow the CRP template provided in the PPN 06/21 guidance. Keep your CRP document separate from other environmental documents to avoid potential conflicts.
Failing to Update or Publish Your CRP
CRPs must be reviewed and updated at least annually. Several organisations fall short by submitting the same plan for multiple tenders without refreshing the emissions data or progress made.
Updating the CRP: The technical standard explicitly requires regular CRP updates "at least annually". This stipulation ensures your environmental data maintains relevance and accuracy.
Publishing the CRP: Where you publish your CRP matters for compliance. The technical standard requires publication "on your UK website" with the link "in a prominent place on your homepage". Evaluators can find and check your plan during selection. Organisations without websites have a clear alternative: "You must provide a copy of the statement in writing to anyone who requests one within 30 days". This helps smaller suppliers stay eligible while keeping transparency.
Best practises for publication include:
- Your CRP should be easy to find on your website homepage
- Keep previous CRPs archived to show progress
- Include everything required like emissions data and board approval
- Get clear approval from your board of directors or equivalent management
Tip: Set a reminder at the start of each financial year to review, update and revalidate your CRP.
The Bottom Line
While awareness of the policy has increased, many organisations still fall short of full compliance. These errors can delay procurement timelines, damage reputations, or even result in disqualification from bidding. For Sustainability Directors, Heads of Environmental Compliance and Supply Chain Directors, avoiding common PPN 06/21 mistakes is essential to maintaining contract eligibility and demonstrating environmental credibility. For tailored support in preparing or reviewing your CRP, explore Tunley Environmental’s PPN 06/21 guidance and consulting services.