Common Mistakes in Implementing PPN 06/21

It’s over six months since the new PPN 06/21 regulations came into play, which stipulate that from the 1 April 2024, all suppliers on our framework agreements are required to provide a compliant Carbon Reduction Plan (CRP).

We are dedicated to helping our suppliers navigate PPN 06/21, so to support you, here’s some of the most common mistakes we have found:

1. Lack of board or director-level sign-off: A CRP needs to be signed off by senior leadership – without board or director-level endorsement, it may lack the authority and accountability it requires. This could raise questions about the commitment of your business to achieving its carbon reduction targets.
2. Reporting “0 emissions” without explanation: Stating that you have “0 emissions” may sound impressive, but without context, it raises red flags. Be transparent about how you’ve achieved this figure or provide a detailed roadmap if it’s a future target. Any unexplained claims could lead to your submission being questioned.
3. Not measuring Scope 3 emissions: While Scope 1 and Scope 2 emissions are critical, many businesses overlook or delay measuring Scope 3 emissions. Under PPN 06/21, partial Scope 3 reporting is required, including five key categories:

1. • Business travel
   • Employee commuting
   • Waste generated in operations
   • Upstream transportation and distribution
   • Downstream transportation and distribution

Capturing these categories is essential to ensuring compliance and demonstrating a full commitment to emissions reduction.

1. Submitting a CSR statement instead of a CRP: CSR statements, policies, or case studies cannot replace a CRP. The CRP template in PPN 06/21 has been designed to streamline the process and ensure consistency in reporting. All suppliers, including SMEs and VCSEs, are encouraged to use this template to make the process easier and meet compliance requirements. Deviations from the template are only accepted if all the necessary information is included.
2. Providing a carbon net zero strategy instead of a CRP: A carbon net zero strategy is valuable but doesn’t fulfil the same purpose as a CRP. Your CRP must include tangible, measurable steps toward reducing carbon emissions, with the target set to achieve net zero on or before 2050.
3. Failure to make the CRP publicly available: Your CRP must be accessible, transparent and publicly available on your website for all stakeholders to view. A lack of public availability could result in your business being excluded from procurement opportunities.
4. Reporting year end date: The reporting period should fall no more than 12 months prior to the date of commencement of the procurement or six months from your financial year end date.

We encourage all of our suppliers to follow the PPN 06/21 CRP template, as this is the easiest way to ensure you remain compliant. If you have any questions or need further guidance, we’re here to help you every step of the way.

Let’s work together to meet the NHS net zero target and make a difference.