NHS Supplier Requirements

Whether you are a long-standing supplier to the National Health Service (NHS) or newly entering the healthcare supply chain, staying ahead of the evolving carbon-reporting mandate is vital to keeping your contracts and competitive edge.

Current Requirements (2024–2026)

At present, suppliers to the NHS must publish a Carbon Reduction Plan (CRP) to qualify for new contracts. Until recently this threshold applied to contracts worth approximately £5 million or more per year — but from April 2024 the requirement extends to all new procurements, regardless of value.

The CRP must include:

• Scope 1 emissions – direct emissions from assets you own/control. 

• Scope 2 emissions – indirect emissions from purchased electricity, heating, cooling. 

• A defined subset of Scope 3 emissions:

  – Upstream transport and distribution 

  – Waste generated in operations 

  – Business travel 

  – Employee commuting 

  – Downstream transport and distribution 

From April 2027: Full-Scope (Global) Reporting

Starting in April 2027, supplier obligations will broaden substantially. Every supplier must publish a CRP covering all Scope 1, Scope 2 and full Scope 3 emissions globally. This includes upstream and downstream activities, such as purchased goods and services, capital goods, use of sold products, and end-of-life disposal.

From April 2028: Product-Level Carbon Footprinting

From April 2028 the NHS will require suppliers to provide life-cycle emissions data for individual products sold into the NHS. This will likely require cradle-to-grave analyses covering manufacturing, usage, and disposal.

How to Prepare

1. Establish your current baseline across Scope 1, 2 and the mandatory Scope 3 categories. 

2. Assess materiality and develop representative product categories. 

3. Use assumptions and recognised emission factors where primary data is lacking. 

4. Map and engage your supply chain to secure better upstream/downstream data. 

5. Build systems and workflows for annual data collection. 

6. Continually review and improve ahead of the 2027–2028 deadlines.

Final Thoughts

The NHS Net Zero Supplier Roadmap is reshaping how suppliers must approach carbon reporting. By 2027, full global emissions disclosure will be mandatory; by 2028, product-level carbon data will likely become standard. Starting now ensures compliance, competitiveness, and long-term resilience.