Question to the Department of Health and Social Care:

To ask the Secretary of State for Health and Social Care, what assessment his Department and NHS England have made of (a) the potential impact on the availability of appropriate medical devices on the NHS of the requirement for suppliers to report the carbon footprint of all their products available across the NHS and (b) the cost of this requirement to NHS suppliers.

In 2021, NHS England published the NHS Net Zero Supplier Roadmap, which sets out a series of milestones to support National Health Service suppliers in aligning with NHS Net Zero ambitions. The 2027 requirement for suppliers to publicly report targets and emissions, and publish a Carbon Reduction Plan (CRP) for global emissions aligned with the NHS Net Zero targets, will build on milestones implemented in 2023 and 2024. Further information on the roadmap is available at the following link:

https://www.england.nhs.uk/greenernhs/get-involved/suppliers/

The 1 April 2023 milestone required that suppliers bidding for any new contracts above £5 million per annum publish a CRP for their United Kingdom scope one and two emissions, and a subset of scope three emissions, as a minimum. This requirement was proportionately extended to all new procurements from April 2024, with a full CRP required for new procurements above £5 million per annum, and new frameworks operated by in-scope organisations. A Net Zero Commitment is required for procurements of lower value, as set out in the guidance, which is available at the following link:

https://www.england.nhs.uk/long-read/carbon-reduction-plan-requirements-for-the-procurement-of-nhs-goods-services-and-works/

NHS England has proactively engaged with suppliers prior to and since the launch of the NHS Net Zero Supplier Roadmap, and continues to engage with regulators, suppliers, and industry bodies ahead of implementing future roadmap milestones, including the April 2027 milestone. NHS England’s engagement approach has included regular supplier forums with trade bodies and external webinars, as well as horizon scanning of the global and UK regulatory and reporting landscapes.

A key enabler of decarbonising the NHS supply chain is to ensure our suppliers begin to understand and communicate the potential impacts of the products they supply. In doing so, we will always seek that product data asks be clear, and will not place a disproportionate burden or cost on the supply chain, whilst delivering on the purpose of the policy.  

The NHS has committed to working with suppliers and regulators to determine the scope and methodology of new requirements that enable information sharing regarding the carbon impact of products supplied to the NHS. These requirements are due to be introduced from April 2028, with NHS England currently undertaking engagement in the policy development phase, including aligning with the Government’s medical technology strategy. Details around policy requirements are still being scoped, and as part of this process, we will seek to incorporate the feedback of the supply chain, and will take into account any concerns raised regarding the potential impact on the availability of devices. the Government’s Medical technology strategy is available at the following link:

https://www.gov.uk/government/publications/medical-technology-strategy

NHS trusts are required to provide an annual summary of progress on delivery of their Green Plan, however there is no requirement for trusts to carry out carbon footprinting, as NHS England provides annual estimates of the total NHS carbon footprint in the NHS England Annual Report and Accounts.