Where does the steel in public projects come from? The question PPN 04/23 made routine
Steel is one of the few commodities with its own procurement policy note, and for good reason: the public sector buys enormous quantities of it, indirectly, buried inside contracts for railways, roads, hospitals and defence equipment. PPN 04/23, issued in March 2023, was the moment the government stopped treating steel origin as a curiosity and made it a routine, structured reporting requirement. Understanding what it did, and why, explains a lot about where UK procurement policy has gone since.
A seven-year-old policy, rebuilt around data
The previous steel guidance, PPN 11/16, predated almost the entire modern commercial policy stack: no Construction Playbook, no Social Value Model, no National Procurement Policy Statement, no Value Toolkit. PPN 04/23 did not add much new machinery of its own. Its real move was to wire steel procurement into that stack, telling buyers to design steel-heavy projects around whole-life value, pre-market engagement with the full supply chain, social value outcomes and a level playing field.
The sharper change was reporting. The annual steel data return, pipeline plus actuals, gained clarified scope: projects at £10 million or more, or any project expected to consume over 500 tonnes of steel. Origin had to be evidenced through the EN10204 Type 3.1 inspection certificate, including whether the certificate records where the steel was melted and poured. That phrase, melted and poured, is the whole game: it is the difference between knowing where steel was finished and knowing where it was actually made.
What most organisations got wrong
The predictable failure was the flow-down. A buying organisation carries the reporting duty, but the data lives with contractors and their fabricators. Teams that did not put the example data clause, or something like it, into their contracts discovered at year end that they were chasing suppliers for information nobody was obliged to provide. Ten weeks after financial year end is not a long runway to reconstruct a year of steel purchases across a programme.
The subtler miss was treating the PPN as a reporting chore rather than a market-shaping tool. The Steel Procurement Taskforce, whose February 2022 report set the direction, was explicit that better data and transparency were meant to help the UK steel sector position itself for public demand. Pre-market engagement, publishing pipelines, and understanding domestic capability were the active ingredients. Filing the return while skipping the engagement missed the point.
The direction of travel since
PPN 04/23 belongs to the era of the previous procurement regulations, and steel policy did not stop moving when the Procurement Act 2023 arrived. The successor note, PPN 022, first issued in June 2025 and updated in July 2026, keeps the same data return and thresholds and goes further, asking buyers to state in the published contract details whether UK-produced steel will be used, and to consult the UK steel industry's catalogue before design decisions are made.
That trajectory vindicates the 2023 groundwork. Organisations that built proper steel data collection under PPN 04/23, with clauses in contracts and certificates on file, found the newer transparency requirements an increment rather than a scramble. Organisations that improvised each year face the same chase, now with more visibility when the data is missing. The lesson generalises: when government starts asking for structured data in procurement, it rarely asks for less later.
The takeaways
- PPN 04/23 replaced PPN 11/16 and tied steel procurement to the modern commercial policy stack.
- The reporting thresholds were £10 million, or 500 tonnes of steel, with returns due 10 weeks after year end.
- Melted and poured origin evidence via EN10204 Type 3.1 certificates was the decisive data upgrade.
- Flow-down clauses are what make buyer-side reporting duties deliverable.
- Steel policy has since moved on under the Procurement Act 2023 via PPN 022, building on this foundation.
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