PPN 022 Procuring Steel in Government Contracts: the official action note, explained

The key facts

• PPN 022 is an action note previously issued in June 2025 and updated in July 2026.
• It applies to all central government departments, their executive agencies and non-departmental public bodies, and covers covered procurements under the Procurement Act 2023 where steel is procured directly or indirectly, referred to as relevant steel procurement.
• A new transparency requirement takes effect from 1 October 2026. Other actions under the PPN are already in effect.
• The transparency requirement applies to projects or programmes valued at £10 million or more, or anticipated to require more than 500 tonnes of steel.
• For those procurements, in-scope organisations should confirm in the Contract Details Notice whether UK produced steel will be used by the prime contractor or in the supply chain, and give a rationale in the procurement description free text box where it will not be used or origin is unknown.
• For all relevant steel procurements regardless of value, organisations must consult UK Steel's Digital Catalogue before design and procurement decisions, and include a contract clause extending that obligation to Tier 1 contractors and their subcontractors.
• Organisations must also consider whether the national security exemption in paragraph 25 of Schedule 2 to the Procurement Act 2023 is relevant, in light of PPN 025.
• An annual steel data return to the Department for Business and Trade is required, covering pipeline data of projected steel requirements and actuals data on steel procured in the previous year including quantity, product type and origin.
• Actuals data should be submitted by the contractor no later than 10 weeks after the end of the financial year, with origin recorded as set out in the Inspection Certificate EN10204 Type 3.1.
• The PPN does not mandate the use of UK produced steel.

What PPN 022 is and who it applies to

PPN 022 is the action note on procuring steel in government contracts, previously issued in June 2025 and updated in July 2026. Its stated purpose is to ensure public procurement plays its full role in delivering the Industrial Strategy and fostering a resilient economy that supports British businesses and creates good jobs, with UK produced steel identified as having a significant role in construction and infrastructure projects.

The note applies only to central government departments, their executive agencies and non-departmental public bodies. Other public sector contracting authorities may wish to adopt the approach. Within those bodies it applies to covered procurements under the Procurement Act 2023 where steel is being procured in the supply chain, meaning both direct and indirect procurement of steel. The note calls this relevant steel procurement.

It should be circulated to those with commercial, procurement or contract management roles, and may also be relevant to finance, operational and sustainability colleagues. Given the reporting obligations, finance and data colleagues are not an afterthought here.

The new transparency requirement from October 2026

The July 2026 update adds a transparency measure. From 1 October 2026, for all new relevant steel procurements meeting the thresholds, in-scope organisations should confirm in the Contract Details Notice whether UK produced steel is to be used by the prime contractor or within the supply chain. The thresholds are projects or programmes valued at £10 million or more, or where it is anticipated the project will require in excess of 500 tonnes of steel.

Where UK produced steel will not be used, or where origin data is not known at the point of contract award, that should be recorded in the free text box labelled procurement description, with a rationale provided as set out in the guidance to the PPN. Origin is expected to be indicated as set out in the Inspection Certificate, EN10204 Type 3.1, which accompanies the steel when purchased.

The stated purpose of collecting this data is to support the UK steel strategy and help identify gaps in UK production capability and UK demand for steel. It is a data gathering measure rather than a preference mechanism, which is consistent with the note's explicit statement that it does not mandate the use of UK produced steel.

Obligations that apply to every relevant steel procurement

Two requirements apply to all new relevant steel procurements regardless of value or steel volume. The first is to consult UK Steel's Digital Catalogue prior to design and procurement decisions being made, and to include a contract clause which extends that obligation to Tier 1 contractors and their subcontractors where relevant. The note is careful to state that the Cabinet Office is not responsible for the accuracy or availability of the Catalogue, and that nothing in it removes legal obligations.

The second is to consider, in light of PPN 025 on protecting the UK's national security through public procurement, whether the national security exemption in paragraph 25 of Schedule 2 to the Procurement Act 2023 is relevant, and to apply it as appropriate. The note stresses this must only be considered in accordance with the Act and, where relevant, consistently with the UK's international trade agreements relating to procurement, on a case by case basis.

Alongside these, in-scope organisations should consider the Green Book, the National Procurement Policy Statement, the Construction Playbook and the Social Value Model when designing relevant steel procurements, applying each in accordance with its own instructions. Running through all of it is a non-negotiable constraint: organisations must comply with their legal obligations, in particular not to discriminate against treaty state suppliers or to treat suppliers differently without justification.

The annual steel data return

In-scope organisations are required to provide an annual steel data return to the Department for Business and Trade, which is collated and published on GOV.UK. It has two parts: pipeline data of projected steel requirements, and actuals data on steel procured in the previous year including quantity, product type and origin data. The return applies to domestic projects and programmes only.

The actuals element carries the same threshold as the transparency measure, applying to projects or programmes valued at £10 million or more or anticipated to require more than 500 tonnes of steel. Actuals data should be submitted no later than 10 weeks after the end of the financial year, by the contractor to the relevant in-scope organisation, which then consolidates it into its return.

Origin data should be recorded as set out in the Inspection Certificate EN10204 Type 3.1, and contractors should indicate whether the stated origin is also recorded in the certificate as where the steel was melted and poured. Where the in-scope organisation is an executive agency or non-departmental public body, its data goes to its parent department, which is responsible for collating and submitting the return. The guidance to the PPN sets out the full requirement, including which steel product types fall in scope, and provides an example clause to push data requirements down to suppliers through contract terms.

How eSourcing Data helps

The steel requirements are essentially a data flow problem: information has to be requested at the right point, captured in a consistent format, pushed down through contract terms, and pulled back annually within a fixed deadline. eSourcing Data supports that by keeping the competition documents, the contract clauses and the supplier records in one place, so the obligation you wrote into the contract is traceable to the data you later need to collect.

Notice publication is the other half. The transparency measure sits in the Contract Details Notice, including the rationale text where UK produced steel will not be used or origin is unknown. Managing notices alongside the award record reduces the risk of the notice and the underlying decision telling different stories, and keeps the reasoning retrievable when the published data is questioned.

For the annual return, structured supplier and contract data makes it far easier to identify which projects cross the £10 million or 500 tonne thresholds, to chase contractor submissions inside the 10 week window, and to consolidate returns from agencies and arm's length bodies into a parent department submission.

What to do about it

1. 1Identify which of your pipeline projects are relevant steel procurements, including indirect steel in the supply chain.
2. 2Flag projects valued at £10 million or more, or expected to need more than 500 tonnes of steel, for the transparency requirement from 1 October 2026.
3. 3Update Contract Details Notice drafting so UK produced steel use, or the rationale for its absence, is recorded correctly.
4. 4Build UK Steel Digital Catalogue consultation into the design stage, before specification decisions are fixed.
5. 5Insert the contract clause extending catalogue consultation and steel data reporting to Tier 1 contractors and subcontractors, using the example clause in the guidance.
6. 6Set a calendar for actuals data collection so contractor submissions arrive within 10 weeks of financial year end.
7. 7Agree how agency and arm's length body data will be consolidated by the parent department for the return to the Department for Business and Trade.
8. 8Assess case by case whether the national security exemption in Schedule 2 paragraph 25 is relevant, consistent with trade agreement obligations.