Carbon Reduction Plans in Wales: WPPN 006 explained

A carbon reduction plan in Wales is the same short, standard document used for UK government contracts, applied under Welsh Procurement Policy Note (WPPN) 006. Welsh public bodies should make a Carbon Reduction Plan (CRP), or an equivalent, a selection requirement for public contracts valued at £6 million or more including VAT, and may ask for one on smaller contracts in high-emission sectors. It is pass or fail, and the GOV.UK PPN 006 template is strongly recommended.

If you already have a plan for an English tender, you are most of the way there. If you have never measured your emissions, the footprint is the main job, and it is very manageable for a small firm.

What is WPPN 006?

WPPN 006 is Welsh Government guidance on asking suppliers for Carbon Reduction Plans. It was published on 24 February 2025 and applies to procurements started on or after that date under the Procurement Act 2023 and the Procurement (Wales) Regulations 2024. For procurements started earlier, its predecessor WPPN 06/21 still applies.

It is aimed at Welsh Government departments, NHS Wales bodies and Welsh Government Sponsored Bodies, and recommended as best practice to all Devolved Welsh Authorities, which include councils. The reason is Wales’s ambition of a net zero public sector by 2030, set out in Welsh Government’s 2021 route map. Supply chains are where most public sector emissions sit, so buyers want suppliers who are measuring and reducing their own.

The note says it reflects the new procurement law and “does not constitute a change in policy”. A CRP compliance checklist (an XLSX file) is published alongside it, and it is worth opening before you write anything, because it shows exactly what the buyer checks.

How is the Welsh CRP different from England’s PPN 006?

The underlying plan is the same. WPPN 006 tells Welsh buyers to follow the UK government’s PPN 006 guidance, departing from it only on a few points.

Point	England: PPN 006	Wales: WPPN 006
Who it applies to	Central government departments, executive agencies and non-departmental public bodies	Welsh Government, NHS Wales bodies, sponsored bodies; best practice for all Devolved Welsh Authorities
Threshold	Above £5 million a year including VAT, averaged over the contract life	£6 million or more including VAT
Below threshold	Not required	Buyers strongly advised to use a risk-based approach in high-emission categories
Template	Annex A of PPN 006	GOV.UK PPN 006 template strongly recommended
Alternatives	Plan in the standard format	A CRP “or equivalent”, including Scope 1, 2 and 3 emissions reported on a different template
Frameworks	Where call-offs are likely to exceed £5 million a year	At framework selection, or at call-off where the call-off is £6 million or more
Checking	Buyer assessment against the Technical Standard	Published CRP compliance checklist

Two details deserve care. First, England’s threshold is explicitly per year; WPPN 006 states “public contracts valued at £6 million or more” without adding per-year wording, so read the tender notice for how the buyer applies it. Second, the Welsh below-threshold advice names the sectors with the largest public sector emissions in Wales: manufacturing, construction, transportation, and human health and social work. If you work in one of those, expect plans on smaller contracts too.

What must a Welsh carbon reduction plan contain?

Because the template is the GOV.UK one, the content follows the PPN 006 Technical Standard:

1. A commitment to net zero by 2050 at the latest for your UK operations.
2. Baseline emissions for a full year, in tonnes of CO2e.
3. Current emissions for your latest reporting year.
4. Emissions reduction targets, usually projected over the next five years.
5. Carbon reduction projects, completed and planned.
6. A declaration and sign-off by a director, confirming board approval.

Emissions follow the GHG Protocol Corporate Standard and UK Government (DEFRA) conversion factors. You report all of Scope 1 and Scope 2, plus five Scope 3 categories: upstream transportation and distribution, waste, business travel, employee commuting, and downstream transportation and distribution.

One Welsh point is worth knowing. WPPN 006 says the completed carbon reduction projects section is “for information only”. How you would apply those measures to the actual contract should be asked as a separate tender question and scored against the award criteria. So keep your CRP factual, and save the contract-specific detail for the quality response. Our guide to the sustainability section of a public sector tender covers that part.

What does WPPN 016 mean for suppliers?

WPPN 016, also published on 24 February 2025, is advice to Welsh public bodies on the Scope 3 emissions in what they buy, focusing on purchased goods and services. It notes that these typically account for around 60% of a public body’s footprint, citing Natural Resources Wales (59%), NHS Wales (62%) and Denbighshire County Council (58%).

It does not place a direct duty on suppliers. It does change what you are likely to see in tenders:

• Carbon in specifications and award criteria. Buyers are told to make sure specifications and award criteria “require lower and preferably zero CO2e solutions”.
• Carbon KPIs in contracts. Buyers should agree KPIs and gather management information, “preferably activity / usage data”, during the contract.
• A preference for real data. It ranks emissions data in three tiers. Spend-based estimates are the least accurate (Tier 1), industry averages are Tier 2, and supplier-specific activity data, such as litres of fuel, kWh or miles travelled, is the most accurate (Tier 3).

That last point is good news if you have measured your footprint from bills and mileage. It is exactly the kind of data WPPN 016 wants buyers to collect. The note also states that business travel and employee commuting are controlled by a public body’s own HR policies, so they sit outside its scope.

How do ESG Now figures map onto your CRP?

ESG Now does not write the plan. It gives you the footprint, baseline and figures to complete the official template yourself.

CRP requirement	What ESG Now gives you	What you add
Scope 1	Gas, heating oil, LPG, generator and plant fuel, refrigerant top-ups, company cars, vans and HGVs	Nothing
Scope 2	Electricity (location-based and market-based) and EV charging	Nothing
Cat 4: upstream transport	Courier deliveries your business pays for	Freight built into supplier prices is not covered
Cat 5: waste	Waste from your operations	Nothing
Cat 6: business travel	Flights (with radiative forcing), rail, staff cars, taxis, hotel nights	Nothing
Cat 7: commuting	An estimate from how your team travels to work, plus homeworking	Nothing, though a staff survey can firm it up
Cat 9: downstream transport	Not covered	Delivery of products you sell, where the customer or another party pays; often “not applicable” for service firms
Baseline and targets	Previous footprint, target type, baseline and target year	Your five-year projection and wording
Reduction projects	A private, prioritised action plan	Your chosen projects and dates

Every line of working is shown and each figure is labelled measured, estimated or a data gap. That suits the Welsh checklist and WPPN 016’s preference for activity data. Read the methodology for more.

How long will yours take?

Pick the option that sounds most like your business. You will see a realistic time, what to have nearby and a head start on the questions.

Which sounds most like you?

Sole trader working from homeConsultants, designers, developers, coaches10 to 15 minSole trader or freelancer in a co-working spaceA desk at a WeWork, Regus or local hub10 to 15 minSmall team in a co-working or serviced officeStartups and agencies with 2 to 25 people15 to 20 minSME with its own office and no vehiclesProfessional services, tech firms, studios20 to 30 minSME with vans, cars or regular staff travelTrades, field services, consultancies on the road30 to 45 minShop, cafe, workshop or product businessRetail, hospitality, makers and manufacturers30 to 45 min

Your estimate

About 30 to 45 minutes

Around 55 to 60 questions, most of them multiple choice

A bit more detail, and a much stronger report.

Vehicles are often the biggest part of a small firm's footprint, so this is where your report gets really useful. Fuel receipts or mileage logs both work, and estimates are fine too.

Handy to have nearby

• Fuel card statements, receipts or rough annual mileage per vehicle
• A recent energy bill for your office or yard
• Your headcount and any training records

Missing something? Estimates are fine, and you can come back to any answer later.

Vehicle emissions are the area grant funders and green lenders most want to see. Having them measured puts you ahead.

Start with this profile

First report free. No card needed.

Why do carbon reduction plans fail the check?

Welsh buyers read WPPN 006 alongside the UK government’s PPN 006 guidance, so the same common failures apply on both sides of the border:

• Missing Scope 3 categories. All five must be addressed. If one does not apply, say so and why, rather than leaving it blank.
• No director sign-off. The declaration needs a director’s name, job title and date, and confirmation that the board approved the plan.
• Not published. The plan should be on your UK website, linked from the homepage.
• Out of date. Plans should be reviewed at least once a year. A reporting period that ended long before the tender notice will raise questions.
• The wrong document. The PPN 006 FAQs are clear that CSR statements, policies and case studies are not accepted in place of a plan.

If you have never measured before, your first full year of data becomes your baseline. Estimates are acceptable as long as you say they are estimates.

How to get a Welsh carbon reduction plan ready

1. Check the tender. Confirm the plan is a selection requirement, which template is wanted and how the threshold applies.
2. Download the CRP compliance checklist from the WPPN 006 page on GOV.WALES.
3. Build your footprint. Start your free report. An office SME without vehicles takes 20 to 30 minutes; a business with vans takes 30 to 45. Answers save as you go.
4. Fill in the GOV.UK template. Our carbon reduction plan template guide shows where each figure goes, and the PPN 006 guide covers publication and sign-off.
5. Write a short net zero commitment. Our net zero commitment example helps.
6. Get board approval, sign and publish. Then run your plan against the checklist before you submit.

Your first report is free, with no card needed. For more on bidding, visit the public sector tenders hub.