Does the 2027 change affect contracts under £5 million?

Not directly. Contracts below £5 million a year keep the current requirements. But the new rules apply to every new NHS framework at framework level, so if you sell through frameworks, check each tender.

What does 'all relevant Scope 3' mean?

Every Scope 3 category that applies to your business, not just the five that PPN 006 asks for. For most product suppliers the biggest new one is category 1, purchased goods and services.

What if I can't measure every Scope 3 category in time?

The 2027 guidance lets SMEs with acceptable reasons explain gaps in their emissions data, judged case by case. Estimating a category with a clear method is better than leaving it out.

What changes for NHS suppliers in April 2027

Q: What changes for NHS suppliers on 1 April 2027?

For procurements starting from 1 April 2027, contracts of £5 million a year or more and all new NHS frameworks need a Carbon Reduction Plan with a global boundary, covering Scope 1, Scope 2 and all relevant Scope 3 categories, with baseline and current emissions.

Q: What comes after 2027?

From April 2028 the NHS asks for carbon footprints of individual products supplied to it, and from 2030 it will only buy from suppliers that meet or exceed its net zero commitments.

From 1 April 2027, NHS contracts of £5 million a year or more and all new NHS frameworks need a Carbon Reduction Plan with a global boundary, covering Scope 1, Scope 2 and all relevant Scope 3 categories, not just the five PPN 006 asks for. The work that takes longest is Scope 3 category 1, purchased goods and services, so start gathering spend and supplier data now.

Updated 6 October 2026 by the Carbon Recycling team. Figures use the official UK government conversion factors and are checked against the current gov.uk guidance.

What is changing

The NHS Net Zero Supplier Roadmap raises its requirements in steps. The next big step comes on 1 April 2027, when new NHS England guidance replaces the current requirements for procurements that start from that date. Here is how the plan the NHS asks for changes, for the contracts it applies to:

	Now	From 1 April 2027
Boundary	UK operations as a minimum, global encouraged	Global: every country you operate in
Scope 3	Five categories: 4, 5, 6, 7 and 9	All relevant categories
Gases	In tonnes of CO2e	The seven Kyoto Protocol gases, in tonnes of CO2e
Other content	Net zero by 2050 or earlier, targets, projects, director sign-off	Net zero by 2050 or earlier, environmental management measures, board or director approval, published

The new rules apply to contracts of £5 million a year or more and to every new NHS framework, at framework level rather than for each call-off. Contracts below £5 million a year keep the current requirements. Our NHS supplier net zero guide sets out the full rules and timeline.

Does it affect you?

You bid for NHS contracts of £5 million a year or more: yes, for procurements starting from 1 April 2027.
You sell through NHS Supply Chain or other frameworks: yes, when a new framework is let, whatever your share of it is worth.
You only hold smaller direct contracts: not directly. But any new framework or larger contract you go for will bring the new rules with it.
You are a subcontractor: the rules sit with the main supplier, but they need your figures for their own Scope 3, so expect to be asked.

If you're not sure which applies, the NHS supplier checker takes five questions and shows what you need now and what changes for you in 2027.

The hard part: the rest of Scope 3

Most suppliers can produce Scope 1 and 2 from their bills, and the five PPN 006 categories from travel, commuting, waste and freight records. The new work is the other Scope 3 categories. The one that matters most for product suppliers is category 1, purchased goods and services: everything you buy in. It is often the largest part of a footprint, and it is usually estimated from spend at first, using emission factors by industry such as those Defra publishes with the UK's carbon footprint statistics. Over time you replace spend estimates with figures from your largest suppliers.

Others to look at, depending on your business, include capital goods (category 2), fuel and energy-related activities such as grid losses and well-to-tank (category 3), and the categories about your products after they are sold. Our guide to the 15 Scope 3 categories explains each one and how to estimate it.

What to start now

Make sure today's requirements are met. A current, published PPN 006 Carbon Reduction Plan keeps you bidding now, and NHS Supply Chain tenders already need Evergreen Level 1.
Pull a year of spend data. Export your purchase ledger by supplier and spend category for your last full financial year. This is the raw material for category 1.
Find your biggest suppliers. A handful usually make up most of your spend. Ask them for their Scope 1 and 2 emissions and revenue, so you can use their figures instead of a spend estimate.
List any operations outside the UK. Sites, vehicles and staff abroad all come into a global boundary.
Decide which Scope 3 categories are relevant, and write down why for any you leave out.
Review your reduction measures. When purchased goods join your footprint, your biggest source may change, and your plan should follow it.

The 2027 guidance lets SMEs with acceptable reasons explain gaps in their data, judged case by case. That is a safety net, not a plan. An estimate with a clear method will look much better to an evaluator than a blank.

Further ahead

The roadmap doesn't stop in 2027. From April 2028 the NHS asks for carbon footprints of the individual products supplied to it, and from 2030 it will only buy from suppliers that meet or exceed its net zero commitments. If you supply products, start keeping data on materials, weights and transport now.

How Carbon Recycling helps

Carbon Recycling covers Scope 1, Scope 2 and Scope 3 with the government factors for each year. You can record emissions your suppliers report to you against the right Scope 3 category, and choose any factor in the full DESNZ set for the less common activities. On the Growth and Enterprise plans you can send your suppliers a secure link to report their emissions, with no account needed on their side.