Publications

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.

In the summer of 2025, CO2RE commissioned ERM to produce greenhouse gas removal (GGR) cost updates building on ERM’s prior analysis, “Greenhouse gas removal methods and their potential to scale UK deployment”. This report presents the updated costs, reflects on changes from 2021 GGR cost estimates, and contextualises the findings within CO2RE research to inform GGR investment and policy decisions.

Natural CO2 removal is increasingly being claimed as anthropogenic climate mitigation. This misrepresentation is already prevalent for forests and coastal ecosystems; there is now the risk of the error reoccurring for open-ocean CO2 uptake via the biological carbon pump.

A clear, established and harmonious legal framework is crucial for the operation and scaling of any emerging industry, and this is no different for greenhouse gas removals (GGRs). The framework for GGRs is not a bespoke area of law tailored to GGR activities, but rather a complex landscape of pre-existing bodies of law applicable to particular GGRs or parts of GGR value chains. Based on 31 semi-structured interviews with stakeholders in governments, industry, and the research community, this report serves as the first comprehensive review of these diverse bodies of law in the UK. It explores the common legal challenges across all major GGR techniques currently being developed in the UK and looks at potential solutions.