New advice from the UK Climate Change Committee: Don’t add nature-based removals to the UK ETS
June 10, 2025
London – The UK Climate Change Committee (CCC) has issued new advice cautioning against the inclusion of nature-based removals—such as woodland—in the UK Emissions Trading Scheme (UK ETS). In a letter released today, the CCC argues that woodland offsets are not appropriate for balancing fossil CO₂ emissions, and that the UK ETS must prioritise long-term, geological carbon storage to retain environmental integrity.
Key reasons behind the CCC’s recommendation:
Permanence risk: The UK ETS is not currently designed to manage the risk of reversal in nature-based carbon removals like woodland.
Mismatch in timescales: Engineered removals (e.g. direct air capture with geological storage) are required to balance long-lived CO₂ emissions; woodland and other short-lived removals are better suited to offset agricultural emissions or other short-cycle pollutants.
Overvaluation risks: Including woodland could over-reward its value and undermine investment in necessary engineered removals.
Regulatory misalignment: The inclusion would create divergence from the EU ETS, potentially complicating future alignment or linkage between the two systems.
Instead, the CCC calls for stronger policy support for nature-based removals outside the ETS, including:
Integration into post-CAP agricultural policy,
Ecosystem service payments,
Participation in voluntary carbon markets.
The CCC’s position echoes a key argument from Carbon Balance Initiative’s recent blog on the UK’s upcoming Seventh Carbon Budget (CB7): that long-lived CO₂ emissions must be matched by long-lived carbon storage, in line with the scientific principle of geological net zero.
Read our blog post on CB-7
By Rachel Ardiff & Mirte Boot