This Procurement Policy Note (PPN) is relevant to Suppliers where steel forms part of a project or supply chain.
From 1 October 2026, suppliers are likely to be asked to provide information about the steel being supplied and its origin for procurements involving projects worth £10 million or more, or where more than 500 tonnes of steel are expected to be required.
PPN 022 provides policy requirements and guidance for how central government departments procure steel.
The policy aims to support the Government’s Industrial Strategy, strengthen economic resilience and improve understanding of UK steel demand and production capability. The latest update introduces a transparency measure to capture whether UK-produced steel is being used by the prime contractor or within the supply chain.
The policy covers both direct and indirect procurement of steel. This means the requirements can be relevant even where a contracting authority (buyer) is not purchasing steel directly from a steel producer.
For suppliers, this makes the wider supply chain important. Information held further down the supply chain may need to be passed back to the prime contractor and contracting authority.
Steel-origin transparency
From 1 October 2026, relevant new procurements must record whether UK-produced steel is expected to be used. The requirement applies where the project or programme.
The contracting authority records this information in the Contract Details Notice (CDN).
Where steel will not be UK-produced, or its origin is not known at contract award, the contracting authority must record this along with a rationale. Where steel is a mixture of UK and non-UK production, the reason for the non-UK elements should also be provided.
Existing requirements continue to apply
For relevant steel procurements, contracting authorities are also required to consult the UK Steel Digital Catalogue before design and procurement decisions are made.
They must also consider whether the national security exemption in Schedule 2 of the Procurement Act 2023 is relevant. These requirements took effect from 1 September 2025.
Non-UK-produced steel can still be used
The UK government states that contracting authorities should engage with steel producers and fabricators to understand the available options and record reasons where overseas steel is selected.
The guidance recognises that there may be legitimate reasons for using non-UK-produced steel, including cost, quality, availability, lead times and environmental considerations.
Steel-origin information may become more important
For projects covered by the reporting requirements, the guidance states that steel origin should be recorded using information contained in the EN10204 Type 3.1 Inspection Certificate. Contractors are also expected to indicate whether the stated origin is recorded on the certificate as the location where the steel was melted and poured. Businesses supplying steel, steel products or components containing steel should therefore ensure relevant documentation is accessible and can be passed through the supply chain where required.
Requirements can be passed down the supply chain
Steel is often not purchased directly by the contracting authority, so relevant requirements may need to be cascaded through the supply chain.
For suppliers, this means a requirement that initially sits with the contracting authority may become a contractual or information requirement for a prime contractor, subcontractor or other supply-chain partner.
Your ability to evidence your supply chain could matter
For businesses involved in affected projects, being able to provide accurate information about steel products, their origin and supporting documentation may become an important part of contract delivery. The guidance also highlights the importance of effective supply-chain management and ensuring obligations and commitments are appropriately cascaded through the supply chain.
Technical specifications still need to allow fair competition
PPN 022 does not give contracting authorities a blanket ability to specify a particular country of origin, producer or supplier. The guidance states that technical specifications should not unnecessarily narrow competition. For suppliers, this means PPN 022 should not be interpreted as requiring affected contracts to use only UK steel producers.
This article provides a supplier-focused summary of PPN 022. The Government publications remain the authoritative source for the full requirements and guidance.
Official PPN: PPN 022: Procuring Steel in Government Contracts – GOV.UK
Guidance: PPN 022: Guidance on Procuring Steel in Government Contracts – GOV.UK
FAQs: PPN 022: FAQs on Procuring Steel in Government Contracts – GOV.UK
