Ministers have spent much of the past two years intervening directly in the UK steel industry, from stepping in to keep British Steel's blast furnaces running at Scunthorpe to backing Tata Steel's transformation at Port Talbot. That level of political attention was always going to filter through into how government actually buys the material, and in July 2026 PPN 022 was updated again.
For the first time, the revised Procurement Policy Note introduces a transparency measure requiring certain contracting authorities to state whether UK-produced steel is expected to be used by the prime contractor or somewhere in the supply chain when a qualifying contract is awarded.
For suppliers and subcontractors working on construction, infrastructure and works contracts, this isn't just a Whitehall reporting exercise. It changes the information that may need to move through the supply chain, and it sits within a much wider wave of reform reshaping UK public procurement. Here's what's actually changed, who it applies to and what you should be doing to prepare.
What is PPN 022, and what's changed?
PPN 022 sets out how central government buyers should approach procuring steel, and it replaced the older PPN 010 in June 2025. It applies to covered procurements under the Procurement Act 2023 where steel is being procured either directly or indirectly through the supply chain.
From 1 September 2025, in-scope organisations have been required to consult UK Steel's Digital Catalogue before relevant design and procurement decisions are made, and to include a contract clause extending that requirement to Tier 1 contractors and their subcontractors where relevant.
The July 2026 update goes further by adding a new transparency measure. From 1 October 2026, qualifying procurements will require the contracting authority to report, through the Contract Details Notice, whether UK-produced steel is expected to be used by the prime contractor or within the supply chain.
The full PPN 022 guidance explains why this matters to government. The intention is to improve visibility of UK steel demand and help identify where domestic production capability does or doesn't meet public sector requirements.
Who needs to comply?
PPN 022 formally applies to central government departments, their executive agencies and non-departmental public bodies, referred to throughout the guidance as "in-scope organisations". Other public sector contracting authorities aren't automatically brought within that scope, but the official guidance says they may wish to adopt the approach. Given the direction of travel elsewhere in government policy, including steel's formal designation as one of the sectors deemed critical to UK national security, suppliers bidding to buyers outside the strict scope of PPN 022 would be sensible to assume similar expectations will follow sooner or later.
As a result, you shouldn't assume the PPN formally applies to every contract involving steel, but it's worth understanding the requirements. If you're bidding to local authorities, NHS bodies, housing associations or other wider public sector buyers, similar evidence may still be requested.
The guidance also applies to covered procurements establishing frameworks under the Procurement Act 2023. For call-off contracts, it applies as appropriate, particularly where contract management is needed to make sure existing steel-related obligations are being met. So, if you hold a framework place involving structural steel or steel-heavy works, don't assume the requirement stops at appointment.
The new transparency requirement, explained
The new transparency measure isn't universal. It applies to relevant steel procurements starting on or after 1 October 2026 where the wider project or programme:
- has a value of £10 million or more, or
- is expected to require more than 500 tonnes of steel
Where a procurement meets either threshold, the buyer should confirm in the Contract Details Notice whether UK-produced steel is expected to be used by the prime contractor or somewhere in the supply chain.
There are four possible positions provided by the guidance:
- UK-produced steel will be used
- non-UK-produced-steel will be used
- there will be a mixture of UK and non-UK steel
- origin is not yet known
Where the answer is no, mixed or not known, the buyer is expected to provide a rationale. It's important not to confuse this transparency measure during the contract award stage with the separate reporting of actual steel delivered during the contract.
How steel origin data is reported
PPN 022 also requires actuals data on steel procured during qualifying projects. This looks backwards rather than forwards. Contractors record data on the steel actually delivered and use the origin information shown on the EN10204 Type 3.1 inspection certificate that accompanied it.
That information should be submitted by the contractor to the relevant in-scope organisation no later than ten weeks after the end of the financial year. The contracting organisation then consolidates the information into its annual steel data return to the Department for Business and Trade.
There's an important reassurance here for suppliers. Not every EN10204 Type 3.1 certificate states where the steel was melted and poured. If it doesn't, suppliers are not required to trace that information independently. The official FAQ says to record the origin contained on the certificate and indicate that this is not confirmed as the melt-and-pour location. That makes accurate record-keeping important, but it doesn't create an open-ended investigation requirement for subcontractors.
What this means for suppliers and subcontractors
The most immediate practical change is the amount of steel origin information that may need to move reliably through a contract's supply chain. Because the obligation to consult UK Steel's Digital Catalogue and relevant contract clauses can extend to Tier 1 contractors and subcontractors, businesses several layers removed from the public sector buyer may still be asked to provide information they've never routinely supplied before.
If you fabricate, distribute or install steel products as part of a larger contract, it's worth assuming that evidence around product and origin data may increasingly be requested on relevant projects, even where you don't deal directly with the contracting authority.
There's also a less obvious point worth flagging. Paragraph 25 of Schedule 2 to the Procurement Act 2023 allows a contracting authority to exempt a contract from most of the Act's requirements, including the duty to compete it, where doing so is genuinely necessary for national security. Steel-heavy contracts tied to defence, energy or critical infrastructure could, in principle, be handled this way. It's not a route buyers will reach for often, since the bar is deliberately high, but suppliers working in those sectors should understand that it exists and factor it into how they read a buyer's approach to market.
For smaller businesses further down the supply chain, the practical risk is simpler: being asked for documentation you weren't expecting, at a stage in the project when there's no time to chase it up. A subcontractor who can't quickly confirm where their steel was melted and poured risks becoming a bottleneck on somebody else's contract.
How to prepare for PPN 022
The sensible move is to start treating steel product and origin information as standard contract data rather than something you scramble for when you're asked. A few practical steps can make a difference:
- Talk to your mills and stockists now. Understand what information their EN10204 Type 3.1 certificates normally contain and how those certificates are supplied.
- Collect documentation as steel arrives. Government guidance specifically encourages real-time collection rather than trying to rebuild the information retrospectively at year-end.
- Know what you are, and aren't, expected to establish. If the inspection certificate doesn't identify the melt-and-pour location, you don't need to carry out a separate trace simply to satisfy this reporting requirement.
- Check contractual requirements early. If you sit beneath a Tier 1 contractor on a public sector project, establish whether steel-related clauses have been flowed down to you and what data format the contractor expects.
- Make somebody responsible for the records. A simple internal ownership point can avoid certificates being split across site teams, procurement staff and finance records.
It's also worth seeing this in its proper context. PPN 022 forms part of a much wider government focus on domestic steelmaking capability, supply chain resilience and the economic impact of public spending. That's a signal worth taking seriously if UK-origin steel could become a genuine differentiator in how you position a bid, not just a compliance line to tick.
How Thornton & Lowe can help
None of this changes the fundamentals of what makes a strong, compliant tender response. Getting the basics of a well-evidenced bid right still matters just as much as understanding a specific policy update, and that's particularly true for anyone bidding into construction and infrastructure contracts where steel content is often significant. At Thornton & Lowe, we help clients translate policy changes like this into practical, evidenced answers that score well, rather than generic statements of compliance.
If PPN 022 affects contracts you're currently targeting, we can help you get ahead of it, from reviewing how your supply chain evidence stacks up to building stronger, more specific responses around UK content and origin. Our free Tender Pipeline tool is also worth a look if you want to keep track of upcoming steel-heavy opportunities as they come to market.
