PPN 04/23: Procuring Steel in Government Contracts · first published 11 April 2023
PPN 04/23 updates the rules on how central government departments and agencies must handle steel procurement, replacing the previous PPN 11/16 from 2016. The core change is a clarified and scoped requirement for buyers to collect and report data on where steel comes from — including quantity, product type, and country of origin — and to push this data obligation down to their contractors via contract terms. This applies to projects worth £10 million or more, or smaller projects where over 500 tonnes of steel is expected to be used. If your firm supplies steel or works on infrastructure contracts where steel is used, you may be contractually required to provide origin certificates and data. The policy is framed around levelling the playing field for UK steel producers and supporting social value, decarbonisation, and levelling-up goals.
WHO THIS APPLIES TO
THE ENKII VIEW
For SMEs supplying steel or working as subcontractors on steel-intensive public infrastructure, this PPN creates a direct contractual data obligation — buyers are explicitly instructed to push reporting requirements down the supply chain via contract terms. Firms that already hold Inspection Certificates (EN10204 Type 3.1) and can readily report steel origin (including where steel was melted and poured) will be better placed to comply and avoid contract disputes. The policy's emphasis on pre-market engagement and supply chain visibility is also an opportunity for UK steel SMEs to get on buyers' radar before procurements launch.
1. Obtain and retain EN10204 Type 3.1 Inspection Certificates for all steel you supply, and ensure they record where the steel was melted and poured — not just the country of origin.
SMEs supplying steel directly or as subcontractors on central government contracts — The PPN requires that steel origin data 'be recorded as set out in the Inspection Certificate (EN10204 Type 3.1)' and that contractors indicate whether the certificate records where the steel was melted and poured. Buyers will push this requirement into contracts.
2. Review your contracts for a steel data reporting clause and set up an internal process to track and report steel quantity, product type, and origin data to your buyer annually.
SMEs working as main contractors or subcontractors on public projects worth £10m+ or using 500+ tonnes of steel — Buyers are required to collate this data and submit it to DBT within 10 weeks of the financial year end, and are given example contract clauses to push this obligation down the supply chain. Non-compliance could put you in breach of contract.
3. Engage in pre-market engagement exercises run by central government buyers — proactively contact buyers and frameworks to signal your capacity and capability before procurements launch.
UK steel producer SMEs and steel-sector supply chain businesses — The PPN explicitly instructs buyers to undertake 'pre-market engagement, involving the whole supply chain, to combine both an understanding of the capability and capacity of the market and to make suppliers aware of future opportunities' — buyers are now expected to do this.
4. When preparing bids, be ready to demonstrate how your offering supports social value, decarbonisation, and levelling-up goals — align these with the government priorities named in this PPN.
SMEs bidding on steel-related public contracts — The PPN instructs buyers to consider the Social Value Model (PPN 06/20), the National Procurement Policy Statement, and other policies that emphasise 'taking account of the wider social, economic and environmental considerations, using policy outcomes aligned with the Government's priorities'.
5. Check whether your local authority buyer has adopted this PPN voluntarily — if so, the same EN10204 Type 3.1 and origin-reporting requirements may apply to your contract even though the authority is not formally in scope.
SMEs supplying to local authorities on steel-intensive contracts — The PPN states that 'other public sector contracting authorities are encouraged to consider applying the approach set out in this PPN' — some local authorities may choose to adopt it and pass the data obligations to their suppliers.
Every rule below quotes the official document verbatim.
The PPN applies to all Central Government Departments, Executive Agencies, and Non-Departmental Public Bodies (NDPBs) where steel is procured directly or indirectly. (All central government departments, executive agencies and NDPBs — relevant steel procurement)
“This PPN applies to all Central Government Departments, Executive Agencies and Non Departmental Public Bodies when conducting procurements covered by Part 2 of the Public Contracts Regulations 2015, the Utilities Contracts Regulations 2016, the Defence and Security Public Contracts Regulations 2011, and the Concessions Contracts Regulations 2016, where steel is being procured directly or indirectly ('relevant steel procurement').”
Other public sector bodies (e.g. local authorities) are encouraged but not required to adopt this approach, and local authorities must consider the Local Government Act 1988 s.17 and their Best Value Duty if they do. (Non-central-government contracting authorities, including local authorities)
“Other public sector contracting authorities are encouraged to consider applying the approach set out in this PPN, where it is relevant and proportionate to do so.”
In-scope organisations must apply this PPN with immediate effect from the date of publication (April 2023). (All in-scope organisations)
“In-scope Organisations should apply the provisions of this PPN with immediate effect.”
Steel origin reporting (actuals data) is required for projects/programmes with a value of £10 million or more. (In-scope organisations — actuals steel data return)
“this PPN applies the requirement to projects/programmes: i) with a value of £10 million or more”
Steel origin reporting is also required for projects valued under £10 million if they are anticipated to use more than 500 tonnes of steel. (In-scope organisations — actuals steel data return, sub-£10m projects)
“a value of less than £10 million where it is anticipated that the project will require in excess of 500 tonnes of steel.”
In-scope organisations must submit annual steel data returns to the Department for Business and Trade (DBT) within 10 weeks of the end of the financial year, covering quantity, product type, and origin data. (In-scope organisations — annual steel data return)
“In-scope Organisations are required to submit, to the Department for Business and Trade (DBT), the data requested within 10 weeks of the end of the financial year.”
Steel origin data must be recorded as set out in the Inspection Certificate (EN10204 Type 3.1), and contractors must indicate whether the certificate also records where the steel was melted and poured. (Contractors supplying steel on qualifying projects — all in-scope organisations)
“The steel origin data should be recorded as set out in the Inspection Certificate (EN10204 Type 3.1) and contractors should indicate whether the origin stated is also recorded in the certificate as where the steel was melted and poured.”
Buyers are provided with an example contract clause to push steel data reporting requirements down to suppliers through contractual terms and conditions. (In-scope buying organisations and their supply chains)
“An example clause, to help ensure the data requirements are pushed down to suppliers through contractual terms and conditions, is also provided.”
The annual steel data return consists of two elements: pipeline data (projected future steel requirements) and actuals data (steel procured in the previous year). (In-scope organisations — annual steel data return)
“This consists of (a) pipeline data of projected steel requirements; and (b) actuals data on steel procured in the previous year – including quantity, product type, and origin data.”
Buyers must consider pre-market engagement involving the whole supply chain to understand market capability and make suppliers aware of future opportunities. (In-scope organisations designing relevant steel procurements)
“undertaking pre-market engagement, involving the whole supply chain, to combine both an understanding of the capability and capacity of the market and to make suppliers aware of future opportunities”
This briefing is enkii's interpretation of the official document — the official text always governs.
Source document © Crown copyright, reused under the Open Government Licence v3.0 via the GOV.UK Content API. enkii tracks every Procurement Policy Note and briefs changes the day they land — see all briefings.