Publications

Following the rapid growth of the voluntary carbon removal market, and the need to scale high-integrity, internationally recognised standards, the EU has developed a Carbon Removal and Carbon Farming Regulation (CRCF) (2024/3012) for DACCS (direct air carbon capture and storage), BioCCS (biomass with carbon capture and storage) and biochar. The UK Government has signalled its intention to align British Standards Institution (BSI) greenhouse gas removal (GGR) standards with the EU Carbon Removal and Carbon Farming Regulation (CRCF), including for biochar carbon removal, to avoid duplication and divergence as both markets develop. This report provides a timely assessment of whether the CRCF biochar methodology meets the requirements of internationally recognised, high-integrity carbon crediting frameworks and informs considerations around potential UK–EU carbon market compatibility. Download the full report from the link on the right-hand side of this page. A standalone executive summary is available here.

Since the release of the previous edition of The State of Carbon Dioxide Removal, the carbon dioxide removal (CDR) landscape has continued to evolve rapidly. Deployment of novel CDR approaches has expanded, new policies have emerged, and growing evidence has strengthened understanding of CDR’s role in achieving climate goals. This latest edition brings these developments together in a comprehensive assessment of the global state of carbon dioxide removal. Key findings from this year’s report: Analysis of costs and potential: A dedicated deep-dive chapter examines the latest scientific evidence on the costs, scalability, and potential of different CDR approaches. Continued growth in novel CDR: While novel CDR remains small at approximately 0.002 GtCO₂ per year, deployment continues to expand rapidly, growing at around 40% annually. Scaling is ambitious but achievable: The growth rates required for novel CDR to align with Paris-compatible pathways are challenging, yet comparable to those achieved by other rapidly scaling climate technologies such as solar photovoltaics (PV) and electric vehicles. Investment remains resilient: Despite a broader slowdown in climate technology investment, funding for CDR companies has remained relatively robust. At the same time, expectations around future demand have become more uncertain. Expanded evidence on future CDR needs: New scenarios developed in collaboration with modelling teams provide a […]

As biochar transitions from a niche soil amendment to a component of carbon dioxide removal (CDR) strategies, its governance has largely developed within product-based regulatory frameworks. This article synthesises soil science evidence to assess the extent to which current regulatory approaches are aligned with soil processes, heterogeneity, and long-term soil functioning. We argue that prevailing frameworks, exemplified by the EU Fertilising Products Regulation (FPR) 2019/1009 and illustrated through its national implementation in Portugal, assess biochar as a standardised input, despite its role as a persistent and soil-dependent amendment. This framing positions biochar primarily as a discrete material rather than as an intervention whose function emerges through interactions with soil physical, chemical, and biological processes over time. By analysing the interface between waste, product, and soil-related legislation, we highlight how regulatory pathways—particularly those related to waste classification and End-of-Waste procedures—may influence the deployment of biochar in Mediterranean contexts. We conclude by outlining elements of a soil-informed governance approach that complements existing frameworks by better integrating soil processes, hydrological function, and long-term soil resilience.

All Paris-aligned pathways to limiting warming to 1.5°C require large-scale deployment of carbon dioxide removals (CDR) by mid-century. Political will is required to create the associated CDR market, by kick-starting significant demand and then sustaining this demand. Policy development is a vital part of this market development process. The UK, EU and US are taking different approaches to their CDR policies, with each jurisdiction making headway in CDR scale-up in light of unique constraints. The UK has begun constructing a CDR demand architecture through Contracts for Difference and planned integration into its Emissions Trading Scheme, but support is still considered insufficient due to the risks associated with CDR deployment. The US has mobilised substantial fiscal support, yet lacks a durable regulatory framework to transition from subsidy dependence to sustained market integration. The EU is developing comprehensive regulatory foundations but is facing uneven implementation across Member States. This policy briefing examines the challenges of scaling up CDR in the UK, US and EU, drawing on engagements conducted through the CO2RE Ecosystem 26+ project with policymakers, market actors and CDR initiatives. The authors find that each jurisdiction has distinct strengths and constraints. They call for policymakers and intermediary organizations to increase their […]

The transition to net zero requires coordination across public, private and civil-society sectors. Systemic transition intermediaries play a central role in this process by connecting diverse actors while also seeking to accelerate system-level change. This dual objective creates inherent tensions: Intermediaries must mobilise actors especially from the private sector while simultaneously pushing them towards ambitious transformation. This paper examines these tensions through an in-depth case study of the Science-Based Targets Initiative (SBTi) and the controversy surrounding proposed changes to its corporate net-zero standard. We conceptualise SBTi as a systemic transition intermediary whose authority rests on scientific credibility and procedural rigour, but whose influence depends on voluntary corporate participation. This dual positioning exposes the organization to competing pressures and political dynamics. Our findings illustrate the challenges associated with the strategic and political role of the SBTi. We show that the key tension with the private sector involves an ongoing balance between pushing ambition on the one hand, and at the same time relying on voluntary participation of corporations. This tension shapes the ability for SBTi to influence policy and to collaborate with other intermediaries. We contribute to the literature on systemic transition intermediaries by highlighting that this is an ongoing tension […]

Carbon dioxide removals (CDR) have become central to climate policy. Current policy approaches, however, are insufficient to create the basis for CDR technologies to scale because they are not yet aligned with the complexity shaping the emerging sector. In this article, we provide an approach to understanding the characteristics of CDR which we argue is composed of both market-creation and market-led complexity. Our engagement with market actors since 2020 suggests that we have entered this new paradigm of complexity earlier than was the case for renewables and in a different way due to the nature of demand. We illustrate how these complexity characteristics are not well captured by existing tools that support policymaking. And we provide an alternative approach to the support of decision-making which is both exploratory and participatory in nature. We call for governments to embrace new tools to facilitate engagement between the public and private sector actors in ways that can more directly capture the sector’s complexity. Public-private collaborations for the next phase of CDR investment will be needed to allow governments to both guide the sector whilst also providing a backstop to risk for private sector partners. Participatory and dialectic stakeholder deliberation processes should be integrated […]

This article examines the regulation of environmental advertising claims—commonly termed ‘greenwash’—through the lens of private governance and legitimacy theory. While climate law scholarship often foregrounds public regulation or litigation, the UK’s Advertising Standards Authority (ASA) offers a distinctive case of an autonomous private legal regime exercising public-facing authority. Against entrenched scepticism about self-regulation and its democratic deficit, the article argues that the ASA demonstrates notable epistemic competence and procedural robustness in adjudicating complex environmental claims. Analysis of recent rulings against major corporations, including banks and oil majors, suggests that the ASA’s enforcement model, though reliant on reputational sanctions and soft law, achieves high compliance and enjoys judicial deference. At the same time, limitations persist: opacity in case selection, informal resolution practices, and the unexamined deployment of AI monitoring tools raise concerns about transparency and accountability. Situating the ASA within debates on private environmental governance, output legitimacy, and the hard/soft law continuum, the article contends that while the ASA cannot overcome structural drivers of climate-harmful consumption, it offers a rare example of sustained success in climate-related dispute resolution.

Greenhouse gas removals technologies are required to meet national and global net zero goals. Credible and comparable removals require standardised methods and approaches. International standards are being rapidly developed. This report presents a critical comparative analysis of the Draft Delegated Acts to the EU Carbon Removal and Carbon Farming (CRCF) (EU/2024/3012) which includes draft methodologies for BioCCS and DACCS and related regulations against the Integrity Council for the Voluntary Carbon Market (ICVCM) Core Carbon Principles (CCPs) and Article 6.4 of the Paris Agreement which establishes the Paris Agreement Crediting Mechanism. This assessment is in the context of UK Greenhouse Gas Removal (GGR) standards development led by the UK Department for Energy Security and Net Zero (DESNZ) and executed by the British Standards Institution (BSI). It explores a scenario where the UK Government endorses the ICVCM as a minimum quality best practice for the voluntary carbon markets, as per the recent Voluntary Carbon and Nature Markets (VCNM) consultation.

Demonstrating methods for removing carbon dioxide from the atmosphere is now a focus of research and development programmes designed to support decision making about future technology deployment. In this perspective piece, we outline some of the approaches to responsible research and innovation (RRI) being put to work in a United Kingdom-based programme organising field trials of various carbon removal methods. Unlike the disruptive technologies that predominate in RRI scholarship, many land-based methods for carbon removal have already been deployed, in some cases over many decades, with governance closely linked with longstanding fields of research and practice. We highlight why responsible innovation frameworks that developed in the context of geoengineering controversies may be only partially-suited to field trials of land-based carbon removal methods. We suggest that field trials of carbon removal methods are not simply evidentiary procedures but also strategic sites within an emerging innovation regime where RRI approaches can be both implemented and critically tested.

Since 2021, the GGR-D programme has piloted several GGR methods and investigated sustainable routes for large-scale removal of greenhouse gases from the atmosphere, to inform decisions about greenhouse gas removal (GGR) deployment in the UK and globally. This report delivers important findings on technology potential as well as policy, legal and evaluation insights and methodologies. It reveals insights into entirely new approaches involving co-deployments of GGRs. Looking across the broad portfolio of GGR methods that could support the UK’s climate ambitions, it sets out a series of actions that would help scale up a portfolio of sustainable GGR options in the UK. For the five individual GGR methods that have been piloted – woodland creation and management, enhanced peatland restoration, enhanced rock weathering, biochar and perennial biomass crops for bioenergy with carbon capture and storage (BECCS) – the report summarises key findings and policy implications, and provides cross-cutting lessons on land-based GGR emerging from these demonstrator projects.