Decarbonizing the Health Care Sector

At a global level, the decarbonization of the health care sector has been coordinated by the World Health Organization (WHO) COP26 Health Programme, launched at the COP26 climate summit in November 2021. Under this program, countries from all regions of the world (including the United States, the United Kingdom, and several European countries) committed to develop a climate resilient and low-carbon sustainable health system and facilities. All participating states must commit to developing an action plan or roadmap by a set date to establish a sustainable low-carbon health system (including supply chains), which also considers human exposure to air pollution and the role the health sector can play in reducing exposure to air pollution through its activities and its actions. 

More than 60 counties have now committed (at the government level) to lower the emissions of health systems. In this article, we briefly consider how such commitments are materializing in Europe, the United Kingdom, and the United States. 


The EU has set the ambitious goal to be carbon neutral by 2050 (European Green Deal). However, the specific role of the health care sector in the journey to carbon neutrality has rarely been discussed at the EU level. Nonetheless, several European Member States have made concerted efforts to decarbonize the health care sector. 

  • Ireland: The Irish Health Service Executive ("HSE") published its Climate Action Strategy for 2023-2050 ("the Strategy"). The HSE aims to reduce its carbon emissions and to become an environmentally and socially sustainable health care service. To reach that ambition, the Strategy sets out six priority areas of focus (i.e., Sustainable Buildings and the Green Environment, Transport and Mobility, Sustainable Procurement, Greener Models of Healthcare, Water and Waste Management and Adaptation and Resilience) with 10 corresponding interconnected strategic objectives. 
  • The Netherlands: A broad range of parties, including government organizations, industry organizations, health care organizations, health insurers, and companies, signed the Green Deal on Sustainable Healthcare ("the Green Deal"). Under the Green Deal, all parties commit to achieve sustainable health care by, among other things, a 55% reduction in CO2 emissions compared with 2018 by 2030. The Green Deal sets out specific commitments to reach that target. For example, as of 2023, health care providers with more than 100 employees must identify their CO2 emissions from transport movements of personnel and draw up a mobility plan containing targets and measures for reducing these CO2 emissions and making these transport movements more sustainable. 
  • Belgium: The Green Deal Sustainable Care is a voluntary agreement between the Flemish government and several private health care partners. One of the aims of that agreement is to reduce the ecological footprint of the care and welfare sectors by reducing carbon emissions, by using materials more sparingly and circularly, by producing less waste, by reducing the presence of pharmaceuticals in Flemish waterways, and by creating a natural environment around and on the sites that contribute positively to both climate and well-being.

United Kingdom

In the United Kingdom, the decarbonization of the health care sector has been mandated by government policy, as all major suppliers to the National Health Service ("NHS") and its organizations are required to detail their commitment to achieving net zero through the publication of a Carbon Reduction Plan ("CRP"). 

The requirement for a CRP stems from Procurement Policy Note 06/21 (PPN 06/21), which took effect on September 30, 2021. PPN 06/21 applies to all central government departments, their executive agencies, and non-departmental public bodies when procuring goods, services, or works with an anticipated contract value exceeding £5 million per annum. 

The CRP must be prepared by the bidding supplier in accordance with detailed government guidance and be published on the supplier's website prior to being eligible for selection. The CRP must include (among other things): 

  • A signed declaration confirming the supplier's commitment to achieving net zero by 2050 at the latest;
  • Details of their emissions from the sources included in scopes 1 and 2 of the Greenhouse Gas Protocol and a defined subset of scope 3 emissions; and 
  • Details of the environmental management measures that can be applied in the delivery of the contract. 

Those companies operating in the UK's health care sector must comply with the requirements of PPN 06/21 in order to be eligible to win major NHS contracts. 

United States

Unlike the United Kingdom, the U.S. government has not mandated its health care sector to decarbonize. Nevertheless, the Biden administration has called on the sector to reduce its greenhouse gas emissions, and the administration's recent initiative is gaining traction among legislators, medical associations, health systems, and other health care-related companies. Last year, the Department of Health and Human Services asked stakeholders to join its initiative to ameliorate the sector's carbon emissions. By participating in the initiative, stakeholders pledged their organizations to cut their emissions in half by 2030 and achieve net-zero emissions by 2050. In addition, pledgors committed to other directives, including publicly reporting their progress and preparing climate resilience plans.

Without wider-reaching initiatives, advocates believe the sector faces an uphill battle to reach the current administration's aspirational targets, considering the carbon footprint of its electricity generation. Many opportunities, however, exist for organizations with a U.S. presence that are looking to reduce their carbon emissions, ranging from analyzing the carbon inventory of their supply chains to evaluating whether they are eligible for any government incentives, such as those in the Inflation Reduction Act of 2022. Such organizations may also want to assess whether they should establish a climate resilience framework.

Whether by a voluntary pledge or compelled by a legal mandate, health care sectors worldwide are having to decarbonize. While for many countries it remains to be seen how the health care sector will be decarbonized, we recommend that those companies operating in the health care sector consider taking the following actions: 

  • Consult with legal counsel to determine how your organization is currently positioned within existing applicable laws and regulations;
  • Consider developing carbon-conscious best practices that can be implemented in the near- and longer-term; and
  • Evaluate whether your organization is eligible for any national, state, or local policies that create significant incentives for energy efficiency and renewable energy.

Read the full Climate Report.

Jones Day publications should not be construed as legal advice on any specific facts or circumstances. The contents are intended for general information purposes only and may not be quoted or referred to in any other publication or proceeding without the prior written consent of the Firm, to be given or withheld at our discretion. To request reprint permission for any of our publications, please use our “Contact Us” form, which can be found on our website at The mailing of this publication is not intended to create, and receipt of it does not constitute, an attorney-client relationship. The views set forth herein are the personal views of the authors and do not necessarily reflect those of the Firm.