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PPN 06/21 for Construction: Scope 3 Guide + CRP Checklist

By Frazer Holroyd · 12 min read · Carbon Reporting · Updated February 2026

Construction companies face unique challenges when creating a PPN 06/21 Carbon Reduction Plan. Complex supply chains, subcontractor emissions, embodied carbon in materials, and multi-site operations create Scope 3 reporting complexities that other sectors rarely encounter.

Construction-Specific Scope 3 Categories

Subcontractor Emissions

Subcontractor emissions typically fall under Scope 3 Category 1 (Purchased Goods and Services) when you procure their services. Start by requesting fuel usage, vehicle types, and any carbon data they already report. For smaller subcontractors, use spend-based estimation methods or sector-average emission factors.

Embodied Carbon

Embodied carbon in materials falls under Scope 3 Category 1. While PPN 06/21 allows category exclusions with justification, for construction companies materials are typically a significant emission source, so inclusion strengthens your CRP.

National Highways Requirements

National Highways contracts over £5 million require a compliant PPN 06/21 Carbon Reduction Plan, plus additional sustainability requirements including specific carbon reporting within project delivery.

Frequently Asked Questions

Do construction subcontractors count as Scope 3?

Yes. Subcontractor emissions typically fall under Scope 3 Category 1 (Purchased Goods and Services).

Does embodied carbon need to be in a CRP?

It falls under Scope 3 Category 1 and inclusion strengthens your CRP, though exclusions with justification are permitted.

Do I need a CRP for National Highways contracts?

Yes, for contracts over £5 million, plus additional sustainability requirements.

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