If you bid for major UK government contracts, PPN 06/21 is the reason you're being asked for a Carbon Reduction Plan. Here's what it actually requires, in plain English, and how to produce a plan that passes.
What is PPN 06/21?
Procurement Policy Note 06/21 — "Taking account of carbon reduction plans in the procurement of major government contracts" — took effect on 30 September 2021. It makes a supplier's commitment to Net Zero a formal condition of bidding for large public contracts.
In practice, it means that before you can win qualifying work, you must publish a Carbon Reduction Plan (CRP) that measures your emissions and commits your organisation to Net Zero by 2050. No compliant plan, no bid. It is a pass/fail selection requirement, not a scored "nice-to-have".
Which contracts and suppliers does it apply to?
PPN 06/21 applies to procurements carried out by central government departments, their executive agencies, and non-departmental public bodies for contracts with an anticipated annual value above £5 million (excluding VAT).
Two things catch construction firms out:
- It's about your organisation, not the project. The CRP reports your company's total emissions, not just the emissions of the contract you're bidding for.
- It cascades down supply chains. Even if you never bid for the central government directly, a main contractor that does will increasingly ask you for the same emissions data, so the requirement reaches far beyond the £5m threshold.
What must a carbon reduction plan include?
A compliant CRP has to do five things:
- Confirm a commitment to Net Zero — a clear statement that your organisation is committed to achieving Net Zero carbon emissions in the UK by 2050.
- Report your baseline and current emissions — your Scope 1 and Scope 2 emissions in full, plus a defined subset of Scope 3 (see below).
- Set out your reduction measures — the environmental management measures and carbon-reduction projects you have in place or plan to introduce.
- Be published on your UK website and kept up-to-date, reviewed and republished at least annually.
- Be signed off at board or director level — the plan must be formally approved by a director (or equivalent).
The Scope 3 categories you must measure
PPN 06/21 does not require full Scope 3 reporting, but it does mandate a specific subset. As a minimum, your CRP must include these Scope 3 categories:
- Business travel
- Employee commuting
- Upstream transportation and distribution
- Waste generated in operations
- Downstream transportation and distribution
All figures should be calculated using the UK government's DEFRA greenhouse gas conversion factors for the reporting year and reported in tonnes of CO₂e.
Scope quick refresher. Scope 1 = emissions you burn directly (site diesel, plant, company vehicles). Scope 2 = purchased energy (grid electricity). Scope 3 = everything else in your value chain (materials, subcontractor transport, waste). PPN 06/21 requires Scope 1, Scope 2, and the five Scope 3 categories above.
Common mistakes that fail a bid
- An out-of-date plan. A CRP published two years ago and never refreshed is non-compliant; it must be reviewed and republished at least annually.
- Missing the Scope 3 subset. Reporting only Scope 1 and 2 is the most common failure. The five Scope 3 categories are mandatory, not optional.
- No director sign-off. The plan has to be formally approved at board level and said so.
- Not actually published. The CRP must be publicly available on your own website. A PDF emailed only to the buyer doesn't meet the requirement.
- Emissions that don't add up. Figures that aren't traceable to a recognised methodology (DEFRA factors) invite challenge.
How to produce a compliant Carbon Reduction Plan
The workflow is the same every year:
- Measure. Capture fuel, energy, materials, transport, and waste, and convert them to CO₂e using the current DEFRA factors.
- Report. Split the total into Scope 1, Scope 2, and the required Scope 3 categories, against a fixed baseline year.
- Commit. State your Net Zero-by-2050 commitment and the specific measures you're taking to reduce emissions.
- Approve and publish. Get the director's sign-off and publish the plan on your website.
- Repeat annually. Update the numbers and republish each year so it never lapses.
The hard part isn't the template; it's keeping accurate emissions data throughout the year so the numbers are ready when a tender lands.