EPS Certification, Scope 3, and the Reality of Government Carbon Reporting
Environmental reporting is no longer a Tier 1 contractor problem. What started with central government frameworks is now cascading rapidly into smaller public sector contracts and many organisations are being caught unprepared.
At the centre of this shift is PPN 06/21 and the government’s expectation that bidders can evidence not just their own emissions but also those of their supply chain, known as Scope 3. For many SMEs, this is where bids stall, deadlines are missed, or submissions are weakened by vague assumptions.
This is where EPS certification, supported by ISO 14064-1, becomes a practical tool rather than a theoretical exercise.
The Problem: PPN 06/21 Is Trickle Down Carbon Regulation
PPN 06/21 requires suppliers bidding for major government contracts to publish a Carbon Reduction Plan and commit to Net Zero. Initially, this applied to contracts over five million pounds per year. In practice, it is now:
Being referenced in lower value contracts
Passed down through Tier 1 and Tier 2 suppliers
Used as a bid differentiation tool, even where not strictly mandatory
Crucially, contracting authorities increasingly expect visibility of Scope 3 emissions, particularly where delivery relies heavily on subcontractors, materials, logistics, or outsourced services.
The message is clear.
The government wants to understand your supply chain emissions.
The Reality: Scope 3 Data Is Messy, Late, or Non Existent
Scope 3 emissions are, by definition, outside your direct operational control. They include:
Purchased goods and services
Capital goods
Waste and logistics
Business travel
Subcontracted activities
In theory, suppliers should provide their emissions data. In reality:
Many do not measure emissions at all
Others measure inconsistently or without recognised standards
Data arrives late, incomplete, or in unusable formats
Smaller suppliers often ignore requests entirely
Waiting for perfect supplier data is not compatible with procurement timelines. This is where many bids fail, not because organisations are unwilling, but because they are stuck chasing information that will never arrive in time.
EPS Certification: Turning Carbon Reporting into a Controlled System
EPS certification provides a structured, auditable framework for managing environmental performance, including carbon accounting. Its value is not just compliance, it is governance.
When aligned properly, EPS certification:
Demonstrates a credible environmental management structure
Shows that emissions reporting is systematic, not ad hoc
Provides assurance to buyers that assumptions are method based, not guesswork
Supports defensible Scope 3 estimates where primary data is unavailable
However, EPS alone is not enough. The technical backbone that makes Scope 3 reporting workable under pressure is ISO 14064-1.
The Tool: Using ISO 14064-1 to Control Scope 3 Chaos
ISO 14064-1 is the internationally recognised standard for organisational greenhouse gas inventories. Its real strength lies in how it handles uncertainty.
Setting Clear Organisational and Operational Boundaries
ISO 14064-1 requires you to define what is included, what is excluded, and why.
This is critical for Scope 3. Instead of attempting to measure everything, you can:
Focus on material categories
Exclude immaterial sources with justification
Align boundaries directly to the contract being bid for
This boundary setting is often what procurement evaluators look for. Not total precision, but clear logic.
Accepting That Estimation Is Sometimes Necessary
ISO 14064-1 explicitly allows the use of secondary data where primary data is unavailable. This legitimises estimation methods, provided they are transparent, consistent, and documented.
For Scope 3, the most practical of these is spend based estimation.
Spend Based Estimation: Submitting the Bid on Time
Spend based methods calculate emissions using financial spend multiplied by emissions factors.
For example, five hundred thousand pounds spent on subcontracted construction services multiplied by a recognised emissions factor for that sector.
This approach is not perfect, but it is accepted under ISO 14064-1, commonly used in public sector reporting, and far better than leaving Scope 3 blank or speculative.
Crucially, it allows you to meet bid deadlines, demonstrate methodological competence, and commit to improving data quality over time.
When framed correctly, spend based estimates signal maturity, not weakness.
What Assessors and Buyers Actually Want to See
Contrary to popular belief, most contracting authorities are not expecting flawless Scope 3 data from SMEs. What they are assessing is:
Have you used a recognised standard
Are your assumptions clearly explained
Is there a plan to improve supplier data over time
Does your approach align with the scale and risk of the contract
EPS certification, underpinned by ISO 14064-1, answers these questions directly.
The Strategic Advantage
Organisations that succeed with Scope 3 reporting do not chase perfection. They build a defensible carbon framework, use estimation methods correctly and transparently, treat Scope 3 as a managed risk rather than an obstacle, and position themselves as a low risk, high maturity supplier.
In a procurement environment increasingly shaped by carbon disclosure, this approach is no longer optional. It is competitive strategy.
Final Thought
PPN 06/21 may have started at the top, but its effects are now embedded throughout public sector supply chains. Scope 3 reporting is where many bids falter, not because the requirement is unreasonable, but because organisations lack a structured way to respond.
EPS certification, combined with ISO 14064-1 and pragmatic estimation methods, provides exactly that structure.
Not perfect data.
Not endless chasing.
Credible, timely, and defensible carbon reporting when it matters most.
Ready to stop Scope 3 holding your bids back?
If PPN 06/21, Scope 3 reporting, or EPS certification is becoming a blocker rather than a differentiator, now is the time to fix it properly. A structured, standards based approach means you can submit compliant bids on time, defend your assumptions with confidence, and build a carbon framework that stands up to scrutiny.
Speak to an expert about EPS certification, ISO 14064-1, and practical Scope 3 reporting.
