NHS Supplier Requirements: What You Need to Know for 2025, 2027 and Beyond

As the NHS continues its journey towards becoming the world’s first Net Zero national health service, sustainability requirements for suppliers are becoming more ambitious — and more complex. Whether you’re a long-term NHS partner or a new entrant to the healthcare supply chain, understanding and preparing for these evolving carbon reporting requirements is essential to remain compliant and competitive.

Below, we break down what’s required now, what’s changing in 2027 and 2028, and how your business can prepare.

Current NHS Supplier Requirements (2024–2026)

At present, NHS suppliers must publish a Carbon Reduction Plan (CRP) to be eligible for new contracts above ~£5 million per year — and from April 2024, this applies to all new procurements, regardless of contract value.

Your CRP must report on:

Scope 1 emissions: Direct emissions from owned or controlled sources (e.g. company vehicles, onsite fuel use).
Scope 2 emissions: Indirect emissions from purchased electricity, steam, heating and cooling.
A subset of Scope 3 emissions: Specifically:
- Upstream transport and distribution
- Waste generated in operations
- Business travel
- Employee commuting
- Downstream transport and distribution

If you already supply the NHS, you should have these areas covered in your carbon reporting.

From April 2027: Global Full-Scope Reporting Becomes Mandatory

From April 2027, NHS supplier requirements will take a major step forward.

All suppliers, regardless of size, sector or geography, will need to publish a CRP covering:

All Scope 1, 2 and 3 emissions globally, aligned with the NHS Net Zero Supplier Roadmap.

This means your reporting boundary will need to expand significantly. Even if your NHS contracts are delivered by your UK operations, global emissions across your value chain will need to be included.

What does this mean in practice?

Your business will need to account for emissions from sources you may not currently measure, including:

Upstream activities: Purchased goods and services, capital goods, and emissions from your supply chain.
Downstream activities: Use of sold products, product end-of-life disposal, product processing, and emissions from customer use.
Other categories: Leased assets, franchises, and investments.

This is a significant expansion from the current five Scope 3 categories, and for many suppliers, it will require new data collection systems, supplier engagement processes, and emissions modelling approaches.

From April 2028: Product-Level Carbon Footprinting

From April 2028, the NHS will introduce a further layer of supplier requirements — this time focused on carbon footprinting for individual products.

While details are still being defined, suppliers will need to provide lifecycle-level emissions data for the products they sell into the NHS supply chain. This is likely to include cradle-to-grave analysis of manufacturing, use, and disposal emissions.

Although this isn’t an immediate requirement, getting ahead with life cycle assessments (LCAs) now can give you a competitive advantage and streamline future compliance.

How to Prepare for NHS Carbon Reporting Requirements

The scale of change coming between now and 2027 is significant — but the good news is that there’s still time to prepare. Here’s how we support suppliers in building a robust carbon reporting strategy:

1. Confirm Your Current Baseline

We start by reviewing your existing CRP: Scope 1 and 2 data, plus the five mandatory Scope 3 categories. Then we identify gaps — particularly in the downstream categories that will become essential from 2027.

2. Assess Materiality and Product Representation

You don’t need to model every product individually. Instead, we group similar products and model representative examples, prioritising those that account for the majority of sales or emissions. This ensures accurate reporting without unnecessary complexity.

3. Use Estimates & Assumptions to Fill Early Gaps

Where primary data isn’t available, we can use standard emission factors, life-cycle databases, or spend-based methods to generate estimates. These assumptions are clearly documented and can be refined over time.

4. Map and Engage Your Value Chain

Future compliance will rely on high-quality data from your upstream and downstream partners. We help you identify and engage key stakeholders — from suppliers and customers to waste handlers and recyclers — and start building data pipelines early.

5. Build Internal Systems and Workflows

A strong reporting process requires consistent data collection. We can help you set up simple tools (e.g. spreadsheets, surveys, or software) and assign internal responsibilities to make annual reporting straightforward and reliable.

6. Review and Improve Over Time

Treat 2025–2026 as a learning period. By starting now, your first global Scope 3 report in 2027 will be more complete, credible, and compliant — and you’ll be ready to meet evolving NHS expectations with confidence.

Final Thoughts: Start Preparing Now to Stay Ahead

The NHS Net Zero Supplier Roadmap is reshaping how suppliers approach carbon reporting. By 2027, full global emissions reporting will be mandatory — and by 2028, product-level carbon data will be the norm. The suppliers that start preparing early will be the ones best positioned to retain NHS contracts, win new business, and stand out as sustainability leaders.

Ready to Future-Proof Your NHS Supplier Status?

At Positive Planet, we support organisations across the healthcare supply chain to build credible, compliant, and future-ready carbon reduction strategies.