Procurement Policy Note 06/21: Taking account of Carbon Reduction Plans in the procurement of major government contracts · first published 5 June 2021
PPN 06/21 requires suppliers bidding for major central government contracts (valued at £5 million per annum or above, subject to the Public Contracts Regulations 2015) to produce and publish a Carbon Reduction Plan (CRP). The CRP must confirm your organisation's commitment to reaching Net Zero by 2050, report your greenhouse gas (GHG) emissions across required Scopes, and describe the environmental management measures you will apply when performing the contract. This is assessed on a strict pass/fail basis at the selection stage — fail the CRP check and you are excluded from the bid, regardless of how strong the rest of your submission is. The CRP must have been published no more than 12 months before the procurement starts, must be signed off appropriately, and must be published on your website. New market entrants (trading less than 12 months) get some flexibility, but must still commit to Net Zero by 2050 in writing.
WHO THIS APPLIES TO
THE ENKII VIEW
For SMEs, the CRP requirement is a hard gateway — get it wrong and you are out before evaluation even begins, so preparation well ahead of any bid is essential. The good news is that the standard is binary (pass/fail, not scored), meaning a well-prepared smaller firm stands on exactly the same footing as a large corporation at this gate. SMEs that are subsidiaries or part of a group can use a parent company CRP, but only if they meet all the additional requirements (wholly owned, parent commitment adopted by bidding entity, published on the bidding entity's own website) — a common trip-hazard for group structures.
1. Create, sign off, and publish a Carbon Reduction Plan (CRP) on your company website before you bid — use the government's Technical Standard for CRPs as your template to ensure you cover all required Scopes and environmental management measures.
SMEs bidding for central government contracts worth £5m+ per annum — The CRP is a pass/fail gateway: 'Carbon Reduction Plan not submitted … Fail.' No CRP means automatic exclusion, regardless of bid quality.
2. Keep your CRP up to date — check that its reporting period falls within 12 months of the date any new procurement you are entering begins, and refresh it annually as standard practice.
SMEs bidding for central government contracts worth £5m+ per annum — The document states a CRP with a 'Reporting period is more than 12 months from the date of commencement of the procurement' results in a Fail, unless an acceptable explanation is provided.
3. Include an explicit, signed organisational commitment to achieving Net Zero by 2050 in your CRP — and confirm a target date (e.g. 2050) when asked in the selection questionnaire (Question 2b).
All SMEs targeting in-scope contracts — Failure 'to make an organisational commitment to reduce their emissions over time to achieve Net Zero by 2050' is one of the five named grounds for exclusion.
4. Within your CRP, spell out the specific environmental management measures your firm will apply when delivering the contract — generic sustainability statements are not sufficient.
All SMEs targeting in-scope contracts — Suppliers that 'fail to indicate the environmental management measures that the supplier will be able to apply when performing the contract' receive a Fail at the selection stage.
5. If you plan to rely on your parent company's CRP, check all four extra conditions are met: you are wholly owned by the parent; the parent's Net Zero commitment is explicitly adopted by your bidding entity in writing; the environmental measures stated apply to your entity; and the CRP is published on your own website — not just the parent's.
SMEs that are subsidiaries or part of a corporate group — The document lists all four conditions as mandatory: 'The CRP is published on the bidding entity's website' — a parent-website-only publication will fail.
6. Ensure every consortium member produces and submits their own individual CRP — you cannot share one document across the group.
SMEs bidding as part of a consortium — 'Where the response is being completed on behalf of a consortium of suppliers, a CRP should be completed by each consortium member.'
7. Even if you cannot yet produce a full CRP, publish a formal written commitment to Net Zero by 2050 now and set a timeline to publish your full CRP as soon as practicable — document this in your bid response.
New SMEs (trading less than 12 months) targeting in-scope contracts — 'Suppliers should not be disadvantaged where they are a new entrant to the market (trading for less than 12 months). In these circumstances the supplier should confirm their commitment to achieving Net Zero by 2050 and should publish a full CRP as soon as possible.'
Every rule below quotes the official document verbatim.
The CRP requirement applies to contracts subject to the Public Contracts Regulations 2015, with a value of £5 million per annum or above, procured by In-Scope Organisations (central government departments, agencies and NDPBs). (Central government In-Scope Organisations; contracts ≥£5m per annum)
“those subject to the Public Contracts Regulations 2015, with a value of £5 million per annum or above and where the measure is related and proportionate) by In-Scope Organisations”
Suppliers must submit a Carbon Reduction Plan that: confirms Net Zero commitment by 2050, reports GHG emissions for all required Scopes, indicates environmental management measures for contract performance, and has a reporting period no more than 12 months before the procurement start date. (All suppliers bidding for in-scope contracts)
“Carbon Reduction Plan submitted which: confirms the supplier's commitment to achieving Net Zero by 2050, contains emissions reported for all required Scopes (in accordance with the required methodology), indicates the environmental management measures that the supplier will be able to apply when performing the contract and reporting period is falls no more than 12 months prior to the date of commencement of the procurement”
The CRP assessment is pass/fail — a supplier failing any of the CRP requirements is excluded from the procurement. (All suppliers bidding for in-scope contracts)
“Questions 1, and 2 should be assessed on a pass/fail basis based on self-declarations by the supplier.”
A supplier must be excluded if they fail to commit to Net Zero by 2050, fail to declare GHG emissions to the required standard, fail to provide a properly signed-off CRP, fail to detail environmental management measures for the contract, or fail to meet the Technical Standard for CRPs. (All suppliers bidding for in-scope contracts)
“A supplier should only be excluded if they: a - fail to make an organisational commitment to reduce their emissions over time to achieve Net Zero by 2050 b - fail to declare their organisational Greenhouse Gas emissions in accordance with the required reporting standard c - fail to provide a Carbon Reduction Plan which has been appropriately signed off d - fail to provide details within the Carbon Reduction Plan of the environmental management measures that will be applied in the performance of the contract e - fail to provide a Carbon Reduction Plan which meets the Technical Standard for completing a Carbon Reduction Plan.”
The CRP reporting period must be no more than 12 months prior to the date of commencement of the procurement; a CRP older than 12 months results in a fail unless an acceptable explanation is provided. (All suppliers bidding for in-scope contracts)
“Reporting period is more than 12 months from the date of commencement of the procurement ... Supplier has failed to meet the required reporting standard ... Fail”
New market entrants trading for less than 12 months are not automatically excluded; they must confirm their Net Zero by 2050 commitment and publish a full CRP as soon as possible. (New-entrant suppliers (trading <12 months) bidding for in-scope contracts)
“Suppliers should not be disadvantaged where they are a new entrant to the market (trading for less than 12 months). In these circumstances the supplier should confirm their commitment to achieving Net Zero by 2050 and should publish a full CRP as soon as possible.”
A subsidiary bidding entity may use its parent's CRP, but only if: the entity is wholly owned by the parent; the parent's Net Zero commitment is adopted by the bidding entity with a supporting statement; the environmental measures apply to the bidding entity; and the CRP is published on the bidding entity's own website. (Subsidiary bidding entities using a parent company CRP)
“The bidding entity is wholly owned by the parent; The commitment to achieving net zero by 2050 is set out in the CRP for the parent and is supported and adopted by the bidding entity together with a statement that this will apply to the bidding entity; The environmental measures set out are stated to be able to be applied by the bidding entity when performing the relevant contract; and The CRP is published on the bidding entity's website”
Each member of a consortium must complete their own CRP. (Consortium bids for in-scope contracts)
“Where the response is being completed on behalf of a consortium of suppliers, a CRP should be completed by each consortium member”
Emissions data declared in Questions 3 and 4 (current and baseline GHG figures) is for information only and cannot be used as a basis for assessment in the procurement. (All suppliers bidding for in-scope contracts)
“The provided emissions data is not to be used as a basis for assessment in the procurement process, but may be used to track suppliers' progress in reducing their emissions over time.”
Buyers may disapply the CRP requirement in exceptional circumstances, including where the relevant market is severely distorted or during a civil emergency, but must document their reasons. (In-Scope Organisations considering disapplying the requirement)
“It may not be relevant or proportionate to apply this PPN in the following exceptional circumstances ... where the market for a contract of this type is distorted/narrowed/struggling to such a significant extent that delivery of public services is likely put at risk, or value for money is likely to be severely compromised; where there is a civil emergency.”
Contracting authorities must verify that the successful supplier meets the CRP selection criterion before awarding the contract, appointing to a framework, or entering any call-off under a framework or dynamic purchasing system. (Central government contracting authorities; all in-scope contract awards)
“Contracting authorities must verify that the successful supplier meets the selection criteria prior to award of the contract or appointment to a framework agreement or dynamic purchasing system.”
This briefing is enkii's interpretation of the official document — the official text always governs.
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