In short
- The carbon reduction plan requirement is a procurement condition with a binary outcome. Evergreen is a voluntary self-assessment NHS England says is not scored in procurement.
- Evergreen is mandatory in two places: NHS Supply Chain Frameworks, and NHS England Medicines tenders, where a valid assessment is needed at the point of submission.
- What actually changes in April 2027 is the plan itself: global instead of UK, and every relevant Scope 3 category instead of a fixed five.
PPN 006 and the NHS Evergreen assessment get confused because both involve a Carbon Reduction Plan, but they do different jobs. The plan requirement is a procurement condition with a binary outcome: you have a compliant published plan or you cannot bid. Evergreen is an online self-assessment that returns a maturity level, and NHS England is explicit that it is not designed to be scored or evaluated in a procurement. One decides whether you are allowed to compete. The other tells you, and your customer, how ready you are.
Why do suppliers confuse the two?
Because right now the documents mostly agree with each other, and it is easy to mistake overlap for identity.
New NHS contracts above GBP 5 million a year have carried a Carbon Reduction Plan requirement since April 2023, pitched at UK Scope 1 and Scope 2 plus a subset of Scope 3, which is the specification PPN 006 already sets. From April 2024 the NHS proportionately extended the plan requirement to cover all new procurements, so the threshold is no longer the line it was. An NHS supplier who built a plan to the PPN standard has, until now, been able to point at the same document in both directions and be broadly fine.
That will not hold. From April 2027, NHS suppliers must publicly report their targets and emissions and publish a Carbon Reduction Plan covering all of their relevant global Scope 1, 2 and 3 emissions, reporting every Scope 3 category deemed relevant under the GHG Protocol Corporate Value Chain (Scope 3) Standard and explaining any category deemed not relevant. The plan has to be published on your own website and board approved, or director approved if you have no board. At that point the two stop being the same document with two names.
How do they compare side by side?
| Dimension | PPN 006 | NHS Evergreen |
|---|---|---|
| What it is | A procurement policy requirement | An online self-assessment where suppliers share sustainability information with the NHS |
| Set by | UK Cabinet Office | NHS England |
| Outcome | Pass or fail. Compliant published plan, or no bid | One of four maturity levels, Level 1 at entry to Level 4 at the highest |
| Used as a scored award criterion | No. It is a gate | No. NHS England states it "has not been designed to be included as a scored or evaluated requirement in procurement" |
| Is it mandatory | Yes, where the contract is in scope | Largely voluntary, but mandatory for NHS Supply Chain Frameworks and NHS England Medicines tenders |
| Trigger | In-scope central government contracts above GBP 5 million per annum including VAT | Supplying the NHS, with a valid assessment needed at the point of submission for Medicines tenders |
| Geography of the plan | UK operations as a minimum | UK today, relevant global emissions from April 2027 |
| Scope 3 | Five categories: business travel, employee commuting, upstream transport and distribution, waste generated in operations, downstream transport and distribution | The same subset today; from April 2027 every category deemed relevant, with a reasoned explanation for those deemed not |
| Targets | Reduction targets against a baseline, stated in the plan | Publicly reported from April 2027 |
| Covers | Carbon only | More than carbon: modern slavery, and transparency reporting through CDP, EcoVadis and B Corp |
| Cadence | Per procurement | NHS England recommends reassessing annually; the score is valid for twelve months |
The baseline requirements behind each column are set out in the PPN 006 checklist and in NHS Evergreen: what suppliers must provide from April 2027.
If Evergreen is not scored, what is it for?
This is the question worth getting right, because the wrong answer sends money in the wrong direction.
It is not a competition. A higher maturity level does not beat a rival's lower one in a bid evaluation, because the assessment was not built to be evaluated in one. Any advice telling you to climb the levels in order to out-score a competitor is describing a mechanism that does not exist.
What it is instead is a gate in two specific places and a mirror everywhere else. The gate: it is mandatory for NHS Supply Chain Frameworks, and for NHS England Medicines tenders a valid assessment is required at the point of submission. If you sell through either, an expired or missing assessment stops the bid, which makes it binary in exactly the way the plan requirement is. The mirror: everywhere else it tells you, in the NHS's own categories, how far your sustainability position is from what your largest customer is asking for, a year or more before the requirement arrives.
That second use is the one worth budgeting for, and it is worth more than a score would be. The assessment covers modern slavery and third-party transparency reporting as well as emissions, so it surfaces gaps that a carbon-only view misses. Treat it as a readiness diagnostic with a twelve-month shelf life, run it annually as NHS England recommends, and use what it exposes to sequence the work.
How much bigger is the 2027 plan?
Larger than the table suggests, because two of those rows are not incremental. Note that this is the plan requirement changing, not Evergreen.
Global rather than UK. A supplier with manufacturing overseas or European distribution has been reporting its UK operations. Extending to relevant global emissions is not a refinement of the existing number. An importer typically finds that most of its actual emissions turn up at this point, in entities and currencies that have never sat inside the reporting boundary.
Every relevant Scope 3 category rather than the fixed five. The five PPN categories exclude purchased goods and services entirely, and for most product suppliers that is the dominant category. Adding it is a supply chain data exercise rather than an accounting one, and it depends on companies who have no obligation to answer you. Note the shape of the new rule: it is not "all fifteen". It is every category you deem relevant, plus a reasoned explanation for each one you do not, which means you have to consider all fifteen and defend your answer either way.
The third change, moving from disclosure to public target commitment, is comparatively cheap in data terms and expensive in decision terms. It needs a board to commit publicly to a trajectory, and the plan needs that board's approval in any case, which is a slower conversation than it sounds.
Can one plan satisfy both?
Yes, if you build it in the right direction.
A plan built to the wider 2027 specification contains everything the PPN subset asks for, because relevant global Scope 1, 2 and 3 includes UK operations and the five named categories. The reverse is not true. A plan built to the PPN minimum is missing the two hardest components and cannot be extended quickly, because both gaps are data problems with long calendar times rather than analysis problems you can solve in a week.
So the practical answer for an NHS supplier is to design the boundary once, at the wider size, and report the narrower view out of it while the narrower view is what is asked for. That costs more in year one and less in total. If you already hold a PPN plan, the honest question is whether it was built as the first year of a series or as a one-off bid artefact, because the second kind does not extend.
Which of the two should you be planning around?
Take them in order of consequence.
If you bid for in-scope central government work above the threshold, PPN 006 is the immediate constraint, because it is the one that can stop you bidding at all. Get it valid and keep it valid.
If you supply the NHS, the plan requirement is still the gate, and April 2027 is the date that matters, because that is when the plan gets substantially harder to produce. Run Evergreen alongside it as the diagnostic, and treat it as a hard requirement if you sell through NHS Supply Chain or into Medicines tenders. The suppliers who are ready in April 2027 are the ones who started supplier engagement well before it.
If you do neither but sell into a supply chain that does, you are likely to meet a diluted version of both as a customer questionnaire, which is a different exercise with no prescribed format. Comparable pressure exists elsewhere in Europe, for example the CO2 Performance Ladder, and the underlying capability is the same in each case.
Where does Hedgehog sit in this?
The platform names PPN 006 as a reporting output alongside the GHG Protocol and the CO2-Prestatieladder, handles entity management across locations and sites with roles for data owners, auditors and managers, and carries over 20,000 spend-based and activity-based factors that you can supplement with your own supplier-specific data. That combination is what lets a single boundary serve both the narrow report and the wider one.
The limitation to state plainly: a mid-market reviewer on G2 in June 2026 rated it 3.5 out of 5 and said that if you want a broader ESG and CSRD reporting platform this one is less complete, with no data source management feature and no decarbonisation target monitoring. Evergreen spans more than carbon, so expect the emissions calculation to be covered and the rest of the assessment to be your own work.
For the parts that are judgement rather than calculation, the wider boundary, the materiality assessment and the target trajectory, that is Scope 3 consulting and science-based targets work.
Sources: NHS England's 2027 carbon reduction plan requirements (last updated 21 July 2026), the Evergreen sustainable supplier assessment, the NHS net zero supplier roadmap, PPN 006 and its technical standard, and the GHG Protocol Corporate Value Chain (Scope 3) Standard. NHS and PPN 006 facts verified 15 September 2026. Hedgehog platform and Hedgehog on G2, verified 27 August 2026.
Facts on this page were last verified on 2026-09-15.
