UK publishes revised Procurement Policy Note for steel procurement

The revised guidance applies to procurements covered by the Procurement Act 2023 where steel is used directly or indirectly within the supply chain. The new transparency requirements will come into force on October 1, 2026.

Under the new rules, for projects valued at GBP 10 million or more, or expected to require more than 500 tonnes of steel, contracting authorities must state in the contract details notice whether UK-produced steel will be used by the main contractor or within the supply chain, if this information is known at the time the contract is awarded.

If UK-produced steel will not be used, or if the origin of the steel is unknown at the time of contract award, the reason must be explained in the contract notice.

In addition, regardless of contract value or steel volume, all relevant public-sector buyers will be required to consult the UK Steel Digital Catalogue before making design or procurement decisions. This requirement must also be passed on contractually to main contractors and, where appropriate, subcontractors.

Public authorities will also be required to submit annual reports to the Department for Business and Trade (DBT) detailing steel usage. These reports will include forecasts of future steel demand, as well as information on the volume, product type and origin of steel used during the previous year. Actual steel usage data will only be required for projects worth GBP 10 million or more or involving more than 500 tonnes of steel.

Contractors must submit the required information to the relevant public authority within 10 weeks of the end of the financial year. The origin of the steel will be recorded based on the EN10204 Type 3.1 Inspection Certificate.

The government emphasized that the new rules do not require the mandatory use of UK-produced steel. However, contracting authorities are expected to engage with domestic producers before making procurement decisions and to record the reasons whenever steel is sourced from overseas. It also noted that any national security exemption will be assessed on a case-by-case basis in line with the Procurement Act 2023 and the UK's international trade obligations.