From 1 October, public buyers are expected to say whether UK steel is used on big projects. Here's what fabricators, stockists and subcontractors should know.
Picture a small fabrication shop with a dozen staff. A lorry drops off a load of structural sections on a Tuesday morning, someone signs the delivery note, and the inspection certificate goes into a folder. If the job is part of a big public project, that certificate may be needed later, because contractors already supply steel data for the buyer's annual return to the government.
What changed on 1 October is smaller, and easy to miss. There's now a short tag in the public contract notice itself, saying whether UK-made steel is going into the job. The buyer writes it, but the answer depends on what's happening several steps down the chain, so it's worth knowing how it works if you're one of those steps.
What's new, and what isn't
The new part: a tag in the contract notice
For new relevant steel procurements starting on or after 1 October 2026, central government buyers should confirm in the Contract Details Notice (the public notice that sets out the details of an awarded contract) whether UK-produced steel will be used by the prime contractor or elsewhere in the supply chain, if that's known when the contract is awarded. The rule applies to any procurement that starts on or after that date, whenever the overall project began.
The buyer writes one of four tags in the notice's "procurement description" box:
- [STEEL-ORIGIN: YES] when all the steel will be UK-produced.
- [STEEL-ORIGIN: NO] when all of it will be non-UK, followed by a reason.
- [STEEL-ORIGIN: MIXED] when it's a combination, with reasons for the non-UK parts.
- [STEEL-ORIGIN: NOT KNOWN] when the origin isn't settled yet, with a reason. One example in the guidance is a cladding subcontractor who hasn't been chosen.
The part that isn't new
Several related duties came earlier. Since 1 September 2025, covered buyers have had to consult UK Steel's Digital Catalogue before design and procurement decisions, whatever the value of the job, and to consider whether the national security exemption in the Procurement Act applies. The annual steel data return to the Department for Business and Trade already existed too. The October change added the tag on top. The details are in the government guidance (PDF) and the FAQ (PDF).
Who and what it covers
The policy applies to central government departments, their executive agencies and non-departmental public bodies. Other public bodies are encouraged to copy it, but they don't have to. The new tag only applies to projects or programmes worth £10 million or more, or ones expected to need more than 500 tonnes of steel. The threshold is about the whole project, not just the size of one contract.
A nudge, not a ban
Nothing in the guidance tells buyers they must choose British steel, and the legal duty not to discriminate against suppliers from countries covered by UK trade agreements stays in place. UK Steel, the industry body, calls it a "comply or explain" approach: buyers have to think about UK steel and say why when they go elsewhere.
Why steel, and why now
The government says the data will support its steel strategy and show where UK production falls short of what public projects need. The guidance points to the steel pipeline, which in 2024 showed more than 8 million tonnes needed in the coming years for motorways, railways, schools and hospitals.
It's been a busy year for steel in Westminster. British Steel was taken into public ownership on 16 July 2026, as the House of Commons Library explains. The guidance also points buyers to separate advice on the national security exemption for steel, shipbuilding, AI and energy infrastructure, and Louise Haigh's 6 August letter to two parliamentary committee chairs names the same sectors. The FAQ is clear that the exemption is only appropriate where procurement is indispensable for national security, so it isn't a routine route for steel. For the wider Back British context, see our post on defence spending with UK industry.
Who ends up doing the paperwork?
The buyer fills in the notice, but the guidance says steel is usually bought by subcontractors rather than by the buyer or the main contractor. So the facts come from the firms closest to steel.
If you fabricate or subcontract
Origin is taken from the EN10204 Type 3.1 inspection certificate (the steel producer's test certificate) that arrives with the steel. Contractors send the data to the buyer no later than 10 weeks after the end of the financial year, and buyers are encouraged to ask suppliers to collect it as the steel is delivered rather than scrambling at year end. The annual return covers domestic projects only, and only steel that was actually delivered to site in the previous financial year counts.
The line between what you report and what you don't is worth knowing. If you buy steel sections and make them into a fabricated structure for a public project, you should report where the sections came from. If you buy finished steel containers, you aren't expected to report on the steel inside them. The product headings are plate, flat rolled products, sections and shapes, reinforcing bar, other bars and rods, tubes, pipes and hollow sections, wire, rail and sheet piling. Items like screws are outside the rules.
If you stock and distribute
Expect questions about certificates. The guidance says UK steel producers include a melt and pour indication (a record of where the steel was made) on test certificates from 2023, but the FAQ admits not every certificate has one. If it's missing, you record the origin shown and note it isn't confirmed as where the steel was melted and poured. You aren't required to trace it any further. Keep your certificates complete and easy to find, and consider the forward-looking pipeline data too, which the FAQ says is meant to tell producers, manufacturers and stockists about future opportunities.
If you make steel products
Buyers have to consult UK Steel's Digital Catalogue and are meant to pass that duty to contractors and subcontractors through their contracts. So it matters whether your products appear in it. The Cabinet Office says UK Steel compiles the catalogue and it isn't responsible for the catalogue's accuracy. We couldn't confirm how companies get listed, so the best move is to ask UK Steel directly.
An edge for suppliers who know their lead times
This part is our own reading, not something the guidance promises. The guidance gives example reasons for choosing non-UK steel, and several are practical: a product not made in the UK, limited availability, or a long lead time. A buyer or main contractor may find it easier to write YES if a UK supplier has said clearly what they can deliver and when. It also seems likely that buyers will start asking main contractors earlier where the steel will come from, and main contractors will ask you.
One more thing to check in your contracts. The guidance says buyers should make sure main contractors pay subcontractors within 30 days of a valid, undisputed invoice. If you're a subcontractor, look for that clause alongside the steel data one.
A tidy-up list for this month
- Keep the Type 3.1 certificate for every delivery and file it against the project.
- Note product type, tonnage and stated origin for each public job. A basic spreadsheet will do.
- Read your subcontracts for clauses on steel data and the Digital Catalogue.
- Check whether your products are in the catalogue, or ask UK Steel how to get in.
- Watch pipeline notices and early market events. The guidance says buyers should involve producers, fabricators and stockists.
- Tell the main contractors you work with what you can supply, in what quantities and by when.
If public sector work is still fairly new to you, our guides to the Procurement Act 2023 and to how buyers score tenders cover the basics.
A quick word from us
Steel origin is a small tag in a notice most suppliers never open, yet the effort around it lands on small firms a few layers below the buyer. Rules like this will keep coming, and they tend to hide in the detail of tenders and notices. We built SupplierVerse to read that detail for you and line it up against what your business can actually do. If you'd rather not trawl through notices yourself, that's the job.