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Win and keep NHS contracts with ESG that stands up to scrutiny. Reach Evergreen Level 1, build Carbon Reduction Plans aligned with NHS requirements and report Scope 3 emissions with confidence.
NHS sustainability requirements are becoming increasingly important for suppliers, with expectations continuing to evolve ahead of key NHS Net Zero milestones.
Important: From April 2027, NHS England will introduce enhanced Carbon Reduction Plan requirements for higher-value contracts, frameworks and dynamic markets, including reporting of all relevant global Scope 1, 2 and 3 emissions. Lower-value contracts will generally remain subject to existing 2024 Carbon Reduction Plan requirements.
From Evergreen assessments and Carbon Reduction Plans to Scope 3 emissions reporting, organisations are expected to demonstrate credible sustainability performance and evidence of ongoing progress.
Under PPN 006, Carbon Reduction Plans must be reviewed regularly and based on emissions data from a reporting period that is less than 12 months old when procurement begins.
Many suppliers underestimate the ongoing effort required to keep plans compliant, up to date and appropriately governed.
For many suppliers, Scope 3 emissions represent the largest share of their carbon footprint.
The challenge is that much of the required data sits with outsourced manufacturers, logistics providers and material suppliers, making accurate reporting difficult without a structured engagement programme.
Knowing your carbon footprint is only the starting point.
Many suppliers struggle to establish realistic reduction pathways where emissions are heavily influenced by activities outside their direct control. Robust Scope 3 data is often critical to setting meaningful targets.
Without clear ownership and accountability, sustainability activities can quickly lose momentum.
Strong governance helps ensure reporting remains current, responsibilities are understood and improvement activities continue over time.
Improving emissions performance requires collaboration across the value chain.
Securing supplier participation and obtaining reliable data are among the most common challenges organisations face when developing ESG reporting programmes.
Whether you're responding to NHS tenders for the first time or strengthening an established sustainability programme, Valpak can help.
Preparing tender responses often requires evidence of sustainability performance, emissions reporting and governance processes.
As reporting expectations increase, manufacturers need stronger emissions data, greater supply chain transparency and preparation for future product-level carbon footprint requirements.
Managing ESG obligations can be complex. We help organisations establish practical reporting processes and improvement plans.
For organisations new to NHS sustainability requirements, understanding where to start can be the biggest challenge.
We support businesses with emissions measurement, supplier engagement and credible target setting.
NHS sustainability requirements continue to evolve, with April 2027 marking a significant milestone for supplier reporting and procurement expectations.
| 2026 | 2027 | 2028 | 2030 |
|---|---|---|---|
| Evergreen Level 1 required before tender close for relevant NHS Supply Chain procurements. | Enhanced NHS Carbon Reduction Plan requirements introduced for higher-value contracts, frameworks and dynamic markets. Suppliers will be expected to report all relevant global Scope 1, Scope 2 and Scope 3 emissions and demonstrate robust emissions management and governance. | Product-level carbon footprinting expected for goods supplied to the NHS. | NHS ambition to buy only from suppliers aligned with net zero commitments. |
Evergreen is a sustainability assessment designed to demonstrate that suppliers have embedded sustainability practices within their organisation.
Evergreen is currently required for NHS Supply Chain Frameworks and certain NHS England medicines procurement routes. Many suppliers also use Evergreen as a benchmark for broader NHS sustainability readiness.
For relevant NHS Supply Chain procurements, suppliers must achieve Evergreen Level 1 before the tender closing date.
Our Position Audit helps organisations understand requirements, identify evidence gaps and prioritise actions.
A Carbon Reduction Plan sets out your organisation’s greenhouse gas emissions and the actions being taken to reduce them.
With enhanced NHS Carbon Reduction Plan requirements coming into effect from April 2027, suppliers bidding for higher-value NHS opportunities will face more comprehensive reporting and governance expectations. Preparing early can help organisations avoid compliance risks and strengthen tender readiness.
To support NHS procurement requirements, plans should:
✓ Be approved by the Board or a Company Director
✓ Align with PPN 006 requirements and future NHS expectations
✓ Include baseline and current emissions
✓ Include relevant Scope 1, Scope 2 and Scope 3 emissions
✓ Include a commitment to achieve Net Zero by 2050 or earlier
✓ Describe environmental management measures already in place
✓ Be publicly available on your website
✓ Be updated regularly and remain current when procurement activity begins
✓ Demonstrate credible reduction activity
Scope 3 emissions are indirect emissions generated across your value chain and are often the largest part of an organisation’s carbon footprint.
From April 2027, suppliers subject to the enhanced NHS Carbon Reduction Plan requirements will be expected to assess all 15 Scope 3 categories defined by the GHG Protocol and report all categories relevant to their organisation. This represents one of the most significant changes in NHS sustainability reporting requirements. Reporting will move beyond the current focus on a limited number of UK-based Scope 3 categories towards a more comprehensive global reporting boundary.
Accurately measuring and reporting these emissions can be challenging because much of the required data sits with suppliers and external partners. We help organisations improve supplier engagement, gather data more effectively and strengthen ESG reporting processes.
Under the enhanced NHS 2027 Carbon Reduction Plan requirements, organisations may need to report relevant emissions associated with international operations and global supply chains connected to NHS delivery.
This shift towards a global reporting boundary often requires earlier engagement with overseas suppliers, improved supply chain visibility and more mature data collection processes.
For many organisations, preparing for these requirements will take time, making early action essential.
Can you confidently answer yes to the following questions?
✓ Do you have a current Carbon Reduction Plan?
✓ Has it been updated within the last 12 months?
✓ Is there clear accountability for sustainability within your organisation?
✓ Can you report Scope 1, Scope 2 and relevant Scope 3 emissions?
✓ Have you identified key supplier data gaps?
✓ Are you engaging suppliers on emissions reporting?
✓ Do you have a credible emissions reduction plan?
✓ Are you prepared for future NHS reporting requirements?
If you’re unsure about any of these questions, a readiness assessment can help identify gaps and prioritise next steps.
Book your free readiness assessmentIdentify compliance gaps, prioritise actions and understand where improvements are needed.
Find out more...Develop and maintain Carbon Reduction Plans aligned with NHS expectations.
Find out more...Measure environmental impacts across products, packaging and services.
Find out more...Use packaging data to support EPR obligations, Scope 3 reporting and sustainability improvement.
Find out more...Provide independent evidence of waste diversion and environmental performance.
Find out more...Collect, manage and reuse supplier data across multiple reporting requirements.
Find out more...Many NHS suppliers already collect information for schemes such as Extended Producer Responsibility (EPR), Energy Saving Opportunities Scheme (ESOS) and Streamlined Energy and Carbon Reporting (SECR).
The same data can often support wider ESG reporting requirements, including Scope 3 emissions calculations and future product-level carbon footprinting.
By making better use of existing data, organisations can:
✓ Reduce duplicate data collection
✓ Improve reporting consistency
✓ Save time completing tender questionnaires
✓ Build stronger foundations for future sustainability reporting
Helping organisations navigate environmental compliance is what we’ve done for decades. We combine regulatory expertise, sustainability consultancy, and data-driven insight to help NHS suppliers stay compliant, demonstrate progress, and remain tender-ready.
Our team supports organisations with Carbon Reduction Plans, Evergreen readiness, emissions reporting and wider ESG requirements.
We help businesses maximise the value of existing compliance and sustainability data.
Supporting 2,000+ businesses, Valpak combines decades of compliance expertise with practical sustainability consultancy.
Requirements continue to evolve. We help organisations stay compliant, improve reporting processes and remain procurement ready.
PPN (Prior Policy Note) 006 is the NHS England policy mandating sustainability requirements in supplier contracts. It establishes that suppliers must have a valid Carbon Reduction Plan, demonstrate ESG governance, and show progress toward Net Zero. It sets the framework for NHS procurement teams assessing suppliers. The key implication: your ESG position is no longer optional or aspirational—it’s contractually relevant. Non-compliance or poor evidence can affect your ability to win NHS business.
Evergreen is a sustainability assessment scheme used by NHS procurement. Level 1 assesses the basics: Do you have a documented ESG commitment? Is there clear governance and accountability? Can you report Scope 1, 2, and relevant Scope 3 emissions? Are you engaging suppliers? Evergreen Level 1 is not complex, but it does require evidence—not just claims. It’s designed to verify that your sustainability work is genuine and embedded, not a box-ticking exercise.
Yes. NHS sustainability requirements apply to organisations of all sizes. While SMEs may face additional challenges due to limited resources, they are still expected to demonstrate governance, credible reporting and evidence of progress.
NHS requirements are specific: Evergreen Level 1 is not applicable elsewhere; CRP standards follow PPN 006 guidance; Scope 3 reporting is tied to supply chain visibility (a known gap for most suppliers). Valpak’s NHS-specific expertise addresses these gaps directly.
A Carbon Reduction Plan (CRP) must be based on emissions data from a reporting period that is less than 12 months old when procurement activity begins. If your plan uses older data, it may be deemed non-compliant and could affect your ability to progress through the NHS tender process.
Yes, an expired CRP can be renewed, but it must be updated with current emissions data and reviewed to ensure it continues to meet NHS requirements. We recommend treating CRP reviews as an annual activity, refreshing emissions data, targets and supporting evidence at least once a year. If your plan is currently out of date, updating it should be a priority, as procurement teams increasingly review the validity and quality of Carbon Reduction Plans during the selection stage.
Common issues include:
✓ Reporting periods older than 12 months
✓ Missing board approval or sign-off
✓ Incorrect or poorly documented Scope 3 boundaries
✓ Missing Net Zero commitments
✓ Inconsistent emissions methodologies
✓ Weak or unsupported reduction targets
Minimally annually. Your CRP needs annual data refresh at minimum. Your targets and strategy should be reviewed at least annually, and ideally more frequently if your business changes materially. Treating this as an annual health check—reviewing progress, updating targets, refreshing supplier engagement—signals active governance and improves data quality year-on-year.
Any NHS Supply Chain tender issued after April 2026 will require Level 1 status at tender close. Without it, your bid cannot be submitted. Existing contracts are not affected, but future opportunities will be blocked. Valpak can help you reach Level 1 within weeks, not months. Book a Postion Audit.
Evergreen Level 1 status doesn’t expire, but your Carbon Reduction Plan and Scope 3 data must stay current (less than 12 months old at tender start). Valpak manages ongoing compliance.
Common challenges include:
✓ Evidence gaps
✓ Unclear sustainability governance
✓ Lack of documented reporting processes
✓ No supplier engagement programme
✓ Limited accountability and ownership
NHS requires all three. Scope 3 is typically the largest.
For many organisations, the challenge is obtaining reliable supplier data. Effective supplier engagement and robust data collection processes are essential to improving accuracy over time.
Start with the essentials:
Provide a simple template or questionnaire. Explain why you need it and how it supports your mutual Net Zero commitment. For first-time requests, offer support or simplified options (e.g., industry-average data for Year 1). Make it easy for small suppliers to participate. Follow up personally where possible.
Most first-time Scope 3 submissions have gaps. Common gaps: fan travel (for sports), supply chain emissions, commercial partner data. Valpak’s audit identifies gaps and prioritises fixes.
No. Each tender requires data current as of procurement start. If your data is 14 months old, it fails. Valpak’s Supply Chain ESG Data platform keeps your data current automatically.
Ground them in evidence, not assumptions. Start with your current emissions baseline. Research sector benchmarks or science-based frameworks (e.g., SBTi if you qualify). Set targets that are ambitious but achievable given your control and influence. For Scope 1 and 2, you have direct control, so targets should be proportionately ambitious. For Scope 3, targets often depend on supplier progress—acknowledge this. Document your rationale. Vague targets (“20% reduction by 2030”) without basis signal lack of rigour. Clear, evidenced targets signal commitment.
Organisations should review existing Carbon Reduction Plans, assess data quality, identify Scope 3 reporting requirements, engage key suppliers and establish clear governance processes.
Early preparation reduces risk and helps build long-term procurement readiness.
Often, yes. Data already collected for schemes such as Extended Prodecer Responsibility, Energy Saving Opportunities Scheme (ESOS), Streamlined Energy and Carbon Reporting (SECR) and wider ESG reporting can often support NHS sustainability requirements and reduce reporting duplication.
If your supply chain includes packaged goods, you’ll report scope 3 emissions tied to that packaging. Valpak can help audit your supply chain to identify where packaging (and packaging data) sits.
Yes, and the NHS values it. Social value might include community employment, apprenticeships, fair wages for supply chain workers, diversity commitments, or local economic benefit. Carbon reduction and social value together tell a fuller story of your business. Document and communicate both. However, don’t confuse them—strong carbon targets remain fundamental. Social value is complementary, not a substitute.
Depends on your current baseline. For most suppliers with moderate governance gaps: 4–8 weeks.
Book a call to discuss your specific situation. Most suppliers find that compliance costs less than losing a tender due to ESG gaps.
Organisations that establish strong reporting processes, reliable emissions data and clear sustainability governance today will be better positioned for future NHS procurement opportunities.
Whether you’re reviewing a Carbon Reduction Plan, preparing for Evergreen Level 1 or looking to strengthen Scope 3 reporting, Valpak can help.
Discuss your organisation’s requirements with our team and explore how we can help you prepare for current and future NHS sustainability expectations.
Book a free consultation