The big news in carbon removal last week was the revision of the EU Emissions Trading System (ETS). Specifically, the European Commission's proposal to integrate carbon dioxide removal (CDR) into the scheme. It arrived with much fanfare, and rightly so; it’s the largest demand signal for CDR to date and an important step forward for the maturity of the industry.
On the very same day, the UK Government published its response to Lord Alan Whitehead's Independent Review of Greenhouse Gas Removals (GGRs). This landed with rather less fanfare, emerging as it did just before Parliamentary recess and in the interregnum between two Prime Ministers. In many ways it was more notable for what it didn't say than what it did. Nevertheless, a striking theme runs through it: the UK Government is thinking carefully about how it integrates with policy development across the international carbon removal landscape.
Its interim response could be summed up with one yes, two maybes, and a no.
One “yes”
The most significant announcement was that the UK Government will work with the British Standards Institution (BSI) to develop a UK GGR biochar methodology which builds on the EU CRCF, while implementing targeted improvements that drive alignment with the Core Carbon Principles of the Integrity Council for the Voluntary Carbon Market (ICVCM) and Article 6.4.
This has been widely trailed, and an expert group, of which Isometric is a member, is already in place advising on the methodology's development. But confirmation of the approach is welcome for two reasons. First, it cements the UK's strategy of aligning closely with the architecture of the CRCF. Second, it signals that, in targeted areas, the UK will go above and beyond the CRCF's requirements. This mirrors the approach Isometric has taken in developing its own CRCF protocols.
Taking the best parts of the CRCF is the right principle. But it needs to be complemented by speed. The market and project developers need certainty. The UK Government needs to finalize the biochar methodology quickly, and provide clarity on how external certification schemes, like Isometric, will be approved to operate these CRCF-aligned methodologies. The open question is whether the UK will replicate the EU's authorization architecture for certification schemes.
Two “maybes”
There were two areas where the UK Government essentially deferred the decision. Integrating GGRs into the Sustainable Aviation Fuel (SAF) Mandate was the Review's headline recommendation. The response defers any decision to 2027, though it leaves the door open: "further work is therefore needed to explore options for driving demand for GGRs, including a fuller review of this proposal." This could be a very significant demand driver for CDR. But the Government will be mindful of not undermining an established policy intervention and committed investment, as was clearly signaled in the response to the Review. The key question will be how removals can be integrated while providing certainty for existing SAF suppliers. Isometric is working closely with others in the industry as part of the Jet Zero Taskforce to consider practical answers to this question.
Perhaps the most surprising response concerned overseas Direct Air Capture (DAC). The Government explicitly "reserves the right" to use carbon markets established under Article 6 of the Paris Agreement, and committed to examining whether high-integrity overseas DAC should complement domestic deployment. This is surprising both because it cuts against the protectionist trend in geopolitics and, more significantly, because it marks a softening of the UK's previous reticence toward Article 6 markets for CDR. If the Government explores this for DAC, it should consider whether the same approach should apply to other pathways.
And a “no”
The Government essentially declined to establish an Office for GGRs, though it will keep the question under review. We think that this is the right decision. Carbon removal already has a natural home in government, at the Department for Energy Security and Net Zero, and another agency risks introducing friction into the system rather than driving the right policy outcomes.
The UK Government's response to the GGR Review may have flown under the radar, but the decision to develop a biochar methodology in deliberate alignment with the EU CRCF is an important step forward. The door also remains open to integrating GGRs into the SAF Mandate, which could be an important further intervention to drive meaningful demand for GGRs.
