PPN 022: Procuring steel in government contracts · first published 26 June 2025
PPN 022 sets out the rules for how central government departments, executive agencies and non-departmental public bodies (NDPBs) must handle the procurement of steel in public contracts. It does not mandate that UK steel must be used, but it does require buyers to consult UK Steel's Digital Catalogue before making design and procurement decisions — and to push that obligation down to Tier 1 contractors and their subcontractors. From 1 October 2026, a new transparency measure requires buyers to declare in the Contract Details Notice (CDN) whether UK-produced steel will be used, on projects worth £10 million or more or requiring over 500 tonnes of steel. Buyers must also collect and report annual steel data returns to the Department for Business and Trade (DBT), including quantity, product type and origin data — submitted by contractors within 10 weeks of the financial year end. This PPN does not directly bind suppliers, but the obligations are pushed down through contract clauses, so if you supply or use steel in government contracts you will be asked to provide origin data and comply with the catalogue consultation requirement.
WHO THIS APPLIES TO
THE ENKII VIEW
For SMEs already supplying steel or working as Tier 1 or Tier 2 contractors on construction and infrastructure projects, this PPN creates real contractual obligations — expect new clauses requiring you to consult UK Steel's Digital Catalogue and to report steel origin data. The transparency push is an opportunity: SMEs producing or sourcing UK steel can now make a stronger, evidenced case in bids, since buyers must justify not using UK steel. However, the reporting and data obligations (EN10204 Type 3.1 certificates, origin tracking, annual returns) add administrative weight that smaller firms should prepare for now.
1. Register with and regularly consult UK Steel's Digital Catalogue before making any design or material decisions — and be ready to demonstrate you have done so, as buyers must include a contract clause requiring this of you.
SMEs acting as Tier 1 contractors or subcontractors on central government construction/infrastructure contracts involving steel — The PPN requires buyers to include a contract clause extending the Digital Catalogue consultation obligation to Tier 1 contractors and their subcontractors for all relevant steel procurements, regardless of value.
2. Set up a system now to track and record the origin of all steel you procure, using the EN10204 Type 3.1 Inspection Certificate as your source, and note whether the certificate records where the steel was melted and poured.
SMEs supplying steel or working on central government contracts ≥£10m or involving ≥500 tonnes of steel — Actuals data (quantity, product type, origin) must be submitted to the buyer within 10 weeks of the financial year end, and origin must be recorded as set out in the EN10204 Type 3.1 certificate.
3. Build the 10-week post-financial-year-end steel data submission into your contract management calendar and assign a named person responsible for collating and submitting this data to the contracting authority.
SMEs supplying steel or working on central government contracts ≥£10m or involving ≥500 tonnes of steel — Actuals data must be submitted no later than 10 weeks after the end of the financial year by the contractor to the relevant in-scope organisation.
4. Proactively promote your products via UK Steel's Digital Catalogue and make it easy for buyers and Tier 1 contractors to specify UK-produced steel — buyers must now declare in the CDN if UK steel is not being used and provide a rationale, which raises the bar for choosing overseas alternatives.
UK steel producers and fabricators bidding for or supplying into central government contracts — The new transparency measure requires buyers to confirm in the Contract Details Notice whether UK-produced steel will be used, and to record a rationale where it will not — creating a new commercial incentive to consider UK supply.
5. In bids and early supplier engagement, clearly identify and evidence the origin of your steel supply chain — including whether UK-produced steel will be used — to help buyers satisfy their new CDN transparency obligations from 1 October 2026.
SMEs bidding for central government construction or infrastructure contracts where steel is in scope — From 1 October 2026, buyers must confirm in the Contract Details Notice whether UK-produced steel is to be used by the prime contractor or within the supply chain, making supply chain origin a visible evaluation and reporting factor.
6. Review your standard subcontract terms to ensure they flow down the Digital Catalogue consultation requirement and the steel origin data reporting obligations to any sub-tier suppliers you use.
All SMEs supplying into central government steel-related contracts — Buyers must include contract clauses extending the Digital Catalogue obligation to Tier 1 contractors and their subcontractors, and origin data must be collected through the supply chain for the annual data return.
This briefing is enkii's interpretation of the official document — the official text always governs.
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