The Cabinet Office’s latest Procurement Policy Note (PPN)* announces an update to the Government’s guidance on procuring steel in government contracts. This is the third version of the guidance which is now couched in the context of 'supporting UK businesses and industry, decarbonisation and levelling up'.  It is an important read for sustainable procurement more generally.  

The guidance has been updated to reflect new policies, tools and methodologies introduced since the last version of this PPN was issued in 2016 including, amongst others, the introduction of the National Procurement Policy Statement (PPN 05/21) and the Social Value Model (PPN 06/20). It also clarifies the scope of reporting requirements on steel origin data. 

Whilst addressed to central government departments, executive agencies and non-departmental government bodies, all contracting authorities are encouraged to apply the guidance where relevant and proportionate to do so. Local authorities will need to ensure they act in accordance with their relevant obligations including section 17 of the Local Government Act 1988 and their Best Value Duty.

By focusing on signposting other government guidance, the PPN might be viewed as explicitly less directive than previous versions. However, by drawing together the various strands of guidance into one place and encouraging the wider public sector to apply the best practice, it signals a green light for policy-led procurement in a more forceful way.

Over the past couple of decades, in addition to the PPNs on steel procurement plenty of government guidance has been issued on how to procure in a sustainable and socially responsible way. This includes the seminal 'Procuring the Future' in 2006* and 'Sustainable Procurement in Government' in 2011*. Some examples of initiatives that have been adopted can be found by reviewing the Government’s record of compliance with its steel procurement guidance. The last report was issued in June 2022* and includes examples from the Ministry of Defence, HS2 Ltd, Highways England and other government departments.

The required flexibilities to procure steel sustainably already exist in the Public Contracts Regulations 2015 but are often not seized upon in practice. These include provisions for early market engagement, compliance with relevant social and labour laws, design of specifications, lifecycle costing, incorporating relevant social and environmental award criteria and ensuring supply chain visibility. 

This latest guidance highlights the stages in the commercial lifecycle at which the various policies, tools and methodologies recently introduced should be considered and the key outcomes and actions to focus on. There is some helpful guidance on bringing all tiers of the market together through early engagement, the design and cascading of technical requirements, selection and exclusion, evaluation and award criteria and contract conditions. 

A lot of the guidance is equally relevant to other types of procurement and mirrors what can already be found in other PPNs, Playbooks and the like. The tools are already there and this PPN encourages their use. It is therefore time to seize the potential available and not throw sustainable procurement on the 'it’s too difficult' pile…because it shouldn’t be!  

*References

• https://www.gov.uk/government/publications/ppn-0423-procuring-steel-in-government-contracts
• https://www.gov.uk/government/publications/procuring-the-future
• https://www.gov.uk/government/publications/sustainable-procurement-in-government-guidance-to-the-flexible-framework
• https://www.gov.uk/government/publications/steel-public-procurement-2022