Call for Evidence: UK GGR Independent Review
Carbon Balance welcomes the recent call for evidence dated the 16th May 2025, as to how greenhouse gas removals (GGRs) can assist in meeting the UK’s 2050 national net zero target. We recommend stronger UK GGR policy through clearer targets, net-negative ambition, and alternatives to reliance on voluntary markets and subsidy packages.
Read the full submission here
Our Recommendations Included:
Frequent revisions to the expected scale of GGRs can undermine confidence in the UK’s still nascent GGR sector. We recommend that the UK government outline a range of demand for removals, reviewing the existing assumptions and interactions in the modelling carried out for the UK. This should aim to provide robust understanding of the level of demand for GGR.
The role of GGR extends beyond the mid-century, given the need for net-negative emissions from developed parties to the Paris Agreement. The UK government should follow other states by setting out an ambition to achieve net-negative emissions, ideally through a formal commitment.
The government’s current approach to support engineered GGR projects, through the ‘GGR Business Model’, risks relying on voluntary markets to crowd in private investment. As an alternative, we recommend that the Independent Review revisit a GGR mandate, as explored in past policy evaluations commissioned by the UK Government.
The government should plan to meet its national net zero target without the widespread use of international credits, such as through Article 6. If the UK government is to pursue international credits, we advocate that the scope must be decided prior to engagement, limiting credits to direct air carbon capture and storage (DACCS) or engineered GGRs.
Our response, though covering both nature-based and engineered GGR methods, is principally focused on engineered GGRs, given our focus as an organisation