On 9 June, NHS England published detailed guidance on the Net Zero Supplier Roadmap, providing further information on how the policy will be implemented.

BritishAmerican Business (BAB) supports the UK’s broader climate ambitions and recognises its commitment to reduce emissions across the healthcare system. Many of our members have already made significant commitments to sustainability and are investing heavily in emissions reduction across their operations. This includes complying with the existing procurement requirements for all suppliers to commit to net zero 2050, scopes 1, 2 and certain scope 3 emissions for UK operations.

However, significant concerns remain that expansion of the new requirement to include extra-territorial non-UK operational emissions and all the Scope 3 categories will place an undue and disproportionate burden on some companies with extensive global supply chains. This expanded scope now includes whole global supply chains – not just in the UK.  Without a global scope 3 commitment, companies will be excluded from participating in supply tenders with the NHS, subject to certain targeted exemptions.

We support calls from industry organisations for government and NHS England to ensure the impact of this new net zero requirement on supply resiliency and fair competition is properly understood and assessed. Any such approach should be as proportionate and achievable as possible, consistent with the Life Sciences Sector Plan. We note from the NHS’s market sounding response that a significant proportion of respondents did not support the proposed expansion of the Net Zero commitments geographical boundary beyond the UK.

Life sciences and medical technology companies play an important role in supporting the NHS, investing in the UK economy, and providing innovative medicines, technologies, and healthcare products for patients. It is important that implementation of the Roadmap supports the NHS’s sustainability objectives while avoiding unintended barriers to cost-effective NHS procurement, inward investment, patient access and choice, or supply chain resilience.

BAB will continue to engage constructively with government, NHS England, and industry partners to request proper assessments are undertaken and changes based on those assessments are included.