A non-compliant Carbon Reduction Plan could prevent your business from progressing in certain public sector procurement exercises where the requirements of PPN 06/21 apply. Problems such as missing emissions data, an inadequate Net Zero commitment, incomplete Scope 3 reporting or an out-of-date plan can put an otherwise strong tender at risk.
For businesses pursuing public sector contracts, this makes Carbon Reduction Plan compliance more than an environmental exercise. It can become an important part of procurement readiness.
The good news is that many compliance problems can be identified and corrected before a tender is submitted. In this guide, we explain what can make a Carbon Reduction Plan non-compliant, what the potential consequences are and what businesses can do to reduce the risk.
What Does a Compliant Carbon Reduction Plan Need to Demonstrate?
A Carbon Reduction Plan should provide credible evidence of your organisation’s emissions and its commitment to reducing them.
For businesses responding to procurement requirements based on PPN 06/21, the plan should contain the information required by the relevant guidance and tender documentation.
This includes areas such as:
- Your organisational information.
- A commitment to achieving Net Zero by 2050.
- Your greenhouse gas emissions.
- Relevant Scope 1, Scope 2 and Scope 3 emissions information.
- Carbon reduction initiatives.
- Appropriate declarations and approval.
- Publication of the plan.
- Regular review and updating.
It is important that the information reflects your actual organisation. Simply downloading a template and inserting generic sustainability statements does not demonstrate that your business understands its emissions or has a credible carbon reduction strategy.
What Could Make a Carbon Reduction Plan Non-Compliant?
There isn’t necessarily one single mistake that causes problems. A Carbon Reduction Plan can become inadequate because of missing, inaccurate or outdated information.
Here are some of the areas businesses should check carefully.
Missing or Inaccurate Emissions Data
Your emissions data forms the foundation of your Carbon Reduction Plan.
If the figures are incomplete or calculated incorrectly, the targets and actions built around them may also be unreliable.
Businesses should have a clear understanding of their relevant greenhouse gas emissions and be able to explain how they have been calculated.
This is one reason why accurate carbon measurement is so important. You cannot create a meaningful reduction strategy without first understanding your starting point.
Missing Relevant Scope 3 Emissions
Scope 3 emissions can be particularly challenging because they occur outside the direct control of the organisation.
Depending on the reporting requirements, relevant areas can include emissions associated with:
- Business travel.
- Employee commuting.
- Waste generated in operations.
- Transportation and distribution.
- Purchased goods and services.
- Other activities within the value chain.
Businesses should not simply ignore Scope 3 because the information is more difficult to collect.
Understanding these emissions can also reveal significant opportunities for future carbon reduction.
No Clear Net Zero Commitment
A Carbon Reduction Plan prepared for PPN 06/21 purposes needs to demonstrate the appropriate commitment to achieving Net Zero.
A vague statement such as “we aim to become more sustainable” isn’t the same thing as a formal Net Zero commitment.
Your plan should clearly state your organisation’s position and ensure that the commitments made within the document are consistent with your wider sustainability strategy.
What Happens During a Tender If Your Plan Isn’t Compliant?
This is where the issue becomes commercially important.
When a Carbon Reduction Plan forms part of the selection criteria for a procurement exercise, failing to satisfy the relevant requirements can affect your ability to progress.
That means a business could potentially invest considerable time and resources preparing a tender, only to encounter problems because its Carbon Reduction Plan doesn’t meet the required standard.
The precise consequences will depend on the procurement and its documentation, so businesses should always check the requirements of the individual opportunity rather than assuming the same rules apply to every public sector contract.
However, the important principle is simple:
If a buyer asks for specific sustainability evidence, you need to be able to provide it accurately.
Can You Fix a Non-Compliant Carbon Reduction Plan?
In many cases, yes.
The key is to identify the problems before the document is required for an important tender.
A review may identify issues such as:
- Missing emissions categories.
- Incorrect calculations.
- Outdated reporting periods.
- Missing carbon reduction measures.
- Inadequate Net Zero commitments.
- Missing senior approval.
- Publication issues.
- Targets that no longer reflect the business.
Once the gaps have been identified, the plan can be updated to provide a more accurate representation of the organisation.
This is considerably better than discovering a problem when a procurement deadline is approaching.
Why Annual Reviews Are Important
Your Carbon Reduction Plan shouldn’t remain unchanged year after year.
Your organisation may grow, relocate, change suppliers, purchase new vehicles, employ more people or alter its operations. Any of these changes could affect its emissions profile.
An annual review provides an opportunity to:
- Recalculate emissions.
- Compare performance against previous years.
- Record completed carbon reduction initiatives.
- Set new targets.
- Update organisational information.
- Review future priorities.
It also demonstrates that your commitment to carbon reduction is ongoing.
A Carbon Reduction Plan that shows measurable progress over several years can tell a much stronger sustainability story than one that has simply been created to satisfy a tender requirement.
Don’t Wait Until You Find a Tender
One of the biggest mistakes businesses can make is waiting until an attractive public sector opportunity appears before thinking about their Carbon Reduction Plan.
Tender deadlines can be demanding.
If you discover that you need to:
- Calculate your carbon footprint.
- Gather Scope 3 information.
- Develop reduction targets.
- Gain senior approval.
- Produce the Carbon Reduction Plan.
- Publish it.
you may suddenly have a considerable amount of work to complete alongside the tender itself.
Becoming procurement-ready in advance removes much of this pressure.
It also means your sustainability strategy exists because it is part of how you operate, rather than because a buyer has suddenly requested it.
A Compliant Plan Should Also Be a Useful Plan
Compliance matters, but it shouldn’t be the only objective.
A good Carbon Reduction Plan should help your organisation understand where emissions are generated and where meaningful reductions can be achieved.
For example, measuring emissions could identify opportunities involving:
- Energy consumption.
- Business travel.
- Company vehicles.
- Waste.
- Procurement.
- Supply chains.
- Employee commuting.
Some carbon reduction initiatives can also produce wider business benefits through improved efficiency, reduced waste and lower operating costs.
The strongest Carbon Reduction Plans therefore work on two levels.
They provide the evidence required for procurement while also acting as a practical roadmap for reducing the organisation’s environmental impact.
How Can Businesses Check Their Carbon Reduction Plan?
Before using your Carbon Reduction Plan within a tender submission, carry out a thorough review.
Ask:
- Is the emissions data current?
- Have the required emissions categories been included?
- Is the Net Zero commitment clear?
- Are the carbon reduction initiatives specific?
- Can progress be demonstrated?
- Has senior management approved the plan?
- Is the correct version publicly available?
- Does it reflect the organisation as it operates today?
- Does it satisfy the requirements stated in the tender?
If you’re unsure about any of these areas, it is better to investigate before submitting the document.
Why Carbon Reduction Plans Matter Beyond PPN 06/21
Public sector procurement may be the immediate reason a business creates a Carbon Reduction Plan, but its value can extend much further.
Large organisations are increasingly looking at sustainability throughout their supply chains. Customers may ask suppliers for emissions information, environmental policies or evidence of carbon reduction.
A credible Carbon Reduction Plan can therefore help demonstrate your environmental credentials to:
- Public sector buyers.
- Existing customers.
- Prospective customers.
- Supply chain partners.
- Employees.
- Investors and other stakeholders.
The work involved in developing the plan can consequently support broader commercial and sustainability objectives.
How Carbon Neutral Group Can Help
If you’re unsure whether your existing Carbon Reduction Plan meets the required standard, Carbon Neutral Group can help you review your current position and identify any gaps.
Support can include:
- Carbon emissions measurement.
- Carbon Reduction Plan preparation.
- Review of existing Carbon Reduction Plans.
- Carbon reporting.
- Carbon reduction strategies.
- Net Zero planning.
- Procurement and PPN 06/21 support.
Rather than waiting until a tender deadline is approaching, reviewing your position in advance can help ensure your organisation is better prepared for future procurement opportunities.
Frequently Asked Questions
Can a non-compliant Carbon Reduction Plan stop us winning a government contract?
Where a compliant Carbon Reduction Plan is a condition of participation in a procurement, failing to meet the specified requirements can affect your ability to progress. Always check the requirements of the individual tender.
How do I know if my Carbon Reduction Plan is compliant?
Review it against the applicable PPN 06/21 requirements and the specific tender documentation. Check areas including emissions reporting, Net Zero commitment, carbon reduction measures, approval, publication and the age of the information.
Can an existing Carbon Reduction Plan be corrected?
Yes. An existing plan can be reviewed and updated if information is missing, inaccurate or outdated.
Should we review our Carbon Reduction Plan before every tender?
Your plan should be maintained and updated regularly. It is also sensible to check the latest version against the requirements of an individual procurement before submitting it.
Can Carbon Neutral Group review our existing Carbon Reduction Plan?
Yes. Carbon Neutral Group can help businesses assess their current Carbon Reduction Plan, identify gaps and develop the emissions data and carbon reduction strategy required to strengthen it.
Is Your Carbon Reduction Plan Ready for Your Next Opportunity?
A Carbon Reduction Plan shouldn’t become the weak link in an otherwise strong tender.
Preparing early gives your organisation time to measure emissions properly, address gaps, demonstrate progress and build a credible sustainability strategy.
If you’re planning to bid for public sector contracts or you’re concerned that your existing Carbon Reduction Plan may not meet current requirements, speak to Carbon Neutral Group about reviewing your position.