Steel data is becoming a contract deliverable: getting ready for PPN 022 before October 2026
The most common misreading of PPN 022 is that it pushes buyers towards UK steel. It does not. The note says so directly: it does not mandate the use of UK produced steel. What it does is far more demanding in practice. It asks central government to know, and to publish, whether UK produced steel is being used on major projects, and to report actual quantities, product types and origins to the Department for Business and Trade every year. Knowing where your steel came from, several tiers down a construction supply chain, is not a policy preference. It is a data engineering problem with a contractual solution.
The clock that matters is 1 October 2026
The transparency requirement added by the July 2026 update takes effect for new relevant steel procurements commencing from 1 October 2026. Everything else in the note is already in effect. That single date is what turns steel origin from a nice to have into something recorded in the Contract Details Notice.
The trigger thresholds are worth internalising because they are unusual: a value test of £10 million or more, or an anticipated volume test of more than 500 tonnes of steel. A project can be well under the value threshold and still be caught by tonnage. Programme teams that screen only on contract value will miss cases.
Where UK produced steel will not be used, or origin is not known at award, the note does not treat that as failure. It asks for the position to be recorded in the procurement description free text box with a rationale. The unacceptable outcome is silence, not overseas steel.
The obligation you must not leave out of the contract
Two requirements apply to every relevant steel procurement, whatever its size. Consult UK Steel's Digital Catalogue before design and procurement decisions are made, and include a contract clause extending that obligation to Tier 1 contractors and their subcontractors.
The timing on the first one is the part teams get wrong. Consulting the catalogue after the specification is written is close to pointless. Its value is in understanding what types of steel are manufactured in the UK and how UK steel products are specified, which is information that has to reach the designer, not the buyer at tender stage.
The contract clause is the mechanism for everything downstream. Actuals data comes from the contractor, no later than 10 weeks after the financial year ends, with origin recorded per the EN10204 Type 3.1 Inspection Certificate and an indication of whether that origin is also where the steel was melted and poured. If that requirement is not in the contract, you will be asking for it as a favour.
The constraint that keeps this lawful
PPN 022 repeatedly returns to the same guardrail: in-scope organisations must comply with their legal obligations, in particular the obligation not to discriminate against treaty state suppliers or to treat suppliers differently without justification. That is the boundary between transparency and preference.
It is why the note asks organisations to record reasons where overseas steel is selected rather than to avoid selecting it, and why the national security exemption in paragraph 25 of Schedule 2 to the Procurement Act 2023 is framed as a case by case assessment to be made consistently with international trade agreements, not a general route around competition.
Early market engagement is the constructive answer. The note encourages engaging steel producers and fabricators early to understand the range of solutions available and the deliverability of requirements, with an accurate assessment of UK market capacity and capability forming an important part of that, particularly given global supply chain pressures and reliability issues.
The takeaways
- PPN 022 does not mandate UK produced steel, it mandates visibility of origin.
- The transparency measure applies from 1 October 2026 at £10 million or more, or over 500 tonnes.
- Catalogue consultation and the flow down clause apply to every relevant steel procurement regardless of size.
- Actuals data is due from contractors within 10 weeks of financial year end, so it must be a contract term.
- Everything is bounded by the duty not to discriminate against treaty state suppliers.
Want the full breakdown?
The complete explainer covers the key facts, the requirements in detail and a practical action list, free and printable in the Procurement Library.