Policy Matters: UK Independent Review charts path for greenhouse gas removals

The UK's Independent Review of Greenhouse Gas Removals sets out a bold roadmap for scaling carbon removals by 2050. We’ve unpacked its recommendations and what they mean for the sector.

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Direct air capture unit with overlaid text reading 'Independent Review of Greenhouse Gas Removals'.

After six months of investigation, the UK government’s independent review team published a landmark report on greenhouse gas removals (GGRs) in the UK in October 2025. The report is a frank assessment of where UK GGR policy stands today and what's needed for carbon removals to become a significant contributor to Net Zero by 2050.

It's a wide-ranging, comprehensive stocktake — part state-of-the-nation assessment, part roadmap for the future. Here, we unpack what the review covers, its most prominent proposals, and what they mean for greenhouse gas removals as a sector.

What is the Independent Review of Greenhouse Gas Removals and why does it matter?

Commissioned by Secretary of State for Energy Ed Miliband, the review team was tasked with conducting a comprehensive review of UK GGR policy. Their report provides the clearest roadmap to date for how the UK will deploy carbon removals at scale.

For context, the Climate Change Commission — an independent statutory body — forecasts that GGRs will need to deliver 2.6 MtCO₂ per year in 2030, 21.3 MtCO₂ per year in 2040, and 35.8 MtCO₂ per year in 2050 to meet the UK's Net Zero obligations. While neither the Commission's forecast nor the review team's report constitute official government policy, they give a strong sense of direction for where GGR policy is headed and how we might get there.

Top-level takeaways 

The review makes several bold proposals that could reshape how the UK approaches carbon removals. Here are three of the most significant.

Rethinking how we classify GGRs

The report starts by proposing a fundamental shift in how GGRs are categorised. Instead of classifying them by method (engineered versus nature-based), the review recommends classification based on permanence — the expected duration of carbon storage.

The report suggests three categories:

Geologically permanent GGRs — including direct air capture and storage (DACCS), bioenergy with carbon capture and storage (BECCS), and enhanced rock weathering (ERW), that store carbon for hundreds to thousands of years.

Long-term carbon storage GGRs — including afforestation, forest management, and biochar, that store carbon for hundreds of years.

Non-permanent storage GGRs — including soil carbon storage, peatland, and saltmarsh restoration, that store carbon for shorter durations.

Why does this matter?

This is a more rigorous way to categorise GGRs, focusing on the outcome they provide rather than the method by which they remove carbon. As the report notes, "Permanence directly affects the risk of reversal, the integrity of carbon accounting, and the eligibility of removals in emissions trading schemes."

The permanence of storage is the key outcome that buyers of removals are focused on, so this classification system is crucial for establishing a functioning market for high-quality carbon removals in the UK. It gives investors, buyers, and suppliers a common language for decision-making and contracting GGRs.

Industrial pipe with the label 'wet CO₂ gas'.

Net Zero Aviation Mandate

The report also addresses how to scale the GGR market by creating demand for carbon removals. One route is to incorporate geologically permanent removals into the existing Sustainable Aviation Fuel (SAF) mandate, creating a Net Zero Aviation Mandate.

The review team notes that the aviation sector is a strong candidate for GGRs because aviation is projected to be the sector with the highest residual emissions in 2050. In both government and independent forecasts, deployment of SAF alone is insufficient to achieve net zero aviation.

Why does this matter?

Expanding the SAF mandate to incorporate geologically permanent carbon removals would create a pathway for net-zero aviation whilst simultaneously providing an increasing annual target for GGRs to meet. This would enable an established compliance market to drive real demand for GGR capability, product, and market share — which the UK is uniquely positioned to capitalise on.

Plane with refuelling vehicle alongside it.


International versus domestic deployment of GGRs

Finally, the report acknowledges some of the limitations and constraints in the UK for deploying GGRs. As it notes, "International purchases of credits generated by DACCS could offer cost advantages due to lower energy and operational costs overseas."

The report recognises that several jurisdictions could provide lower-cost GGR deployment based on cheaper energy, land availability, and strong policy mechanisms. Jurisdictions such as the US, the Middle East and North Africa, and Nordic countries fit these conditions.

Why does this matter?

It's worth discussing where costs and conditions align to deploy GGRs most efficiently. While the Government currently favours domestic deployment, the report proposes the UK could jointly develop GGR projects abroad, leveraging international cooperation to deliver more cost-effective carbon removals.

This has the potential to foster a more global GGR market whilst acknowledging the comparative advantages other jurisdictions have. It may also open opportunities for UK geological carbon storage to be accessed by other countries seeking to take advantage of the economies of scale in the UK's clusters.

What’s next for GGR policy in the UK?

Ultimately, this report is a roadmap, not a destination. The Government will need to consider its response before any of these proposals can become official policy.

As the report acknowledges, there's a contradiction between the consensus on the necessity of GGRs and the current ability of GGR technologies to deploy at scale. It highlights the need for policy clarity on providing non-pipeline transport of carbon dioxide to cluster storage sites. It also calls for further government support beyond innovation funding — specifically, support for commercial deployment.

This report provides an excellent overview. Now we await the Government's response to chart the path forward.

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