Do manufacturers need a Carbon Reduction Plan?

If you bid for UK central government contracts worth more than £5 million a year, yes, under PPN 006. Most manufacturers are asked for carbon data first by their own customers, who need it for their Scope 3, and those requests often follow the same format.

Does a Carbon Reduction Plan include the raw materials we buy?

No. A PPN 006 plan covers Scope 1, Scope 2 and Scope 3 categories 4, 5, 6, 7 and 9, which leaves out purchased goods. For most manufacturers purchased materials are the largest part of the full footprint, so customers asking for product footprints will want them, but the plan does not.

We have process emissions as well as fuel. How do we report them?

Carbon dioxide released by a chemical reaction rather than by burning fuel, such as from calcining or some coatings and treatments, is Scope 1. The DESNZ conversion factors do not cover most process emissions, so they are usually calculated from the chemistry or from figures in an environmental permit, and the method explained in your plan.

Is gas for our forklifts Scope 1?

Yes. LPG or diesel burned in forklifts and other site machinery you run is Scope 1. Electric forklifts charged on site use electricity, which is Scope 2 and already in your electricity bills.

Do we also need to report under SECR?

Only if you are a quoted company, or a large unquoted company or LLP meeting two of 250 employees, £36 million turnover or an £18 million balance sheet. Many mid-sized manufacturers cross the turnover line, so check with our free SECR checker.

Carbon reporting for manufacturers

Manufacturers bidding for UK government contracts worth more than £5 million a year need a PPN 006 Carbon Reduction Plan, and large ones must report energy and carbon under SECR. Most are asked first by their customers. The usual big sources are process heat and electricity, site vehicles, refrigerant leaks, waste and freight, with purchased materials dominating the wider footprint.

Updated 3 October 2026 by the Carbon Recycling team. Figures use the official UK government conversion factors and are checked against the current gov.uk guidance.

Manufacturers are asked for carbon data from several directions at once: public sector buyers asking for a Carbon Reduction Plan, large customers asking for the emissions behind what they buy, and sometimes questions about individual products. A good footprint of your own operations is the base for all of them, so start there.

Who asks manufacturers for carbon data

Central government and the NHS, on contracts above £5 million a year, under PPN 006 and the NHS supplier rules.
Large customers working out their own Scope 3. Your Scope 1 and 2 become part of their purchased goods, so they send supplier questionnaires and may ask for a figure per product or per tonne.
Your own annual report, if you are large enough for SECR.
Customers in the EU, if you export iron, steel, aluminium, cement, fertiliser or hydrogen products: EU importers of those goods have to report the emissions embedded in them, and will ask you for the figures.

The UK is introducing its own Carbon Border Adjustment Mechanism from 1 January 2027 for imports of aluminium, cement, fertiliser, hydrogen, and iron and steel. It applies to businesses importing £50,000 or more of those goods in 12 months, so check it if you buy those materials from abroad.

Where manufacturing emissions come from

Source	Scope	What to collect
Gas for ovens, kilns, boilers, dryers and space heating	Scope 1	Gas bills in kWh, by site
Other fuels: LPG, gas oil, fuel oil, biomass	Scope 1	Delivery notes in litres, tonnes or kWh
Forklifts and site machinery on LPG or diesel	Scope 1	Cylinder or fuel deliveries
Process emissions from chemical reactions	Scope 1	Process data or permit returns, if you have them
Refrigerant leaks from chillers, process cooling and air conditioning	Scope 1	F-gas service records: gas type and kilograms topped up
Electricity for motors, compressed air, lighting and charging	Scope 2	Half-hourly or monthly bills in kWh
Raw materials and parts delivered by carriers you pay	Scope 3, category 4	Weight and distance, or the carrier's own figures
Production waste, offcuts and packaging waste	Scope 3, category 5	Waste transfer notes: tonnes by material and treatment
Sales visits, trade shows and travel to other sites	Scope 3, category 6	Expenses, mileage claims and booking reports
Staff getting to the factory, including shift workers	Scope 3, category 7	A commuting survey, scaled to headcount
Delivery of finished goods that your customer pays for	Scope 3, category 9	Weight and distance, where you can get it

Which government conversion factors apply

A PPN 006 plan and an SECR report must use the UK government (DESNZ) conversion factors. For a manufacturer the relevant parts of the set are usuallyFuels (natural gas, LPG, gas oil, fuel oil), Bioenergy if you burn wood or biofuels, Refrigerant & other,UK electricity, Delivery vehicles for your own vans and lorries, Freighting goods for carriers,Waste disposal, and the business travel tabs. The Material use factors cover the emissions of producing common materials, which helps if a customer asks for more than the plan requires.

Boundary questions and common mistakes

Gas billed in kWh versus cubic metres. Gas bills show both; use the kWh figure, which already includes the calorific value.
Scrap you sell. Metal or other material you sell for recycling is still waste generated in your operations, and the DESNZ waste factors for recycling are low. Record it rather than leaving it out.
Biomass boilers. The carbon dioxide from burning wood is reported separately as biogenic, outside the scopes, but the methane and nitrous oxide are Scope 1.
Shared and leased sites. A unit you lease and run is yours to report. A unit you own but have let to another business is not part of your Scope 1 or 2.
Intensity ratios. Absolute emissions rise when output rises. Report tonnes of CO2e per tonne produced or per £ million turnover as well, so a buyer can see efficiency.

Reductions buyers recognise

Finding and fixing compressed air leaks, and turning compressors down outside production hours;
heat recovery from compressors, ovens and process cooling;
variable speed drives on motors, pumps and fans;
LED lighting with sensors in warehouses and production areas;
electric forklifts in place of LPG or diesel;
lower-impact refrigerants and fixing leaks quickly;
on-site solar or a renewable electricity tariff.

How Carbon Recycling handles it

Add each factory, warehouse and office as a site, then import a year of energy bills, fuel deliveries, refrigerant records and waste notes from a spreadsheet. Every line is calculated with the matching DESNZ factor, with the factor recorded next to it, and the same figures produce your PPN 006 Carbon Reduction Plan and your SECR report. Customers' questionnaires can be answered from the same footprint, and on the Growth plan you can ask your own suppliers for their emissions through a secure link.

Check whether you need SECR with the SECR checker, try your gas and electricity figures in the kWh to CO2e calculator, or download the free Carbon Reduction Plan template. Plans and prices are on the pricing page.