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Independent review

GGR Independent Review

Independent Review of Greenhouse Gas Removals
Awaiting Government Response
Dr Alan Whitehead CBE · Published 23 October 2025 · Commissioned by DESNZ

Independent review commissioned by the Secretary of State for Energy Security and Net Zero in February 2025 to consider how greenhouse gas removal options, including BECCS and DACCS, can assist the UK in meeting its net zero targets to 2050. The review assessed the GGR portfolio, economic mechanisms, policy and regulation, and makes 30 recommendations including five headline recommendations, among them establishing an Office for Greenhouse Gas Removals and adopting a Net Zero Aviation Mandate. No formal government response has been published; Energy Minister Michael Shanks issued a statement on publication welcoming the review and committing to careful consideration.

Government Response

On publication day the government responded via a Written Ministerial Statement (HCWS983, 23 Oct 2025) by Minister of State Michael Shanks. The government welcomes the report's findings and commits to consider its recommendations as part of its clean energy mission. No point-by-point acceptance or rejection of the 30 recommendations is set out.

23 October 2025

Recommendations

Recommendation 1a
UK Government response_pending
Government must continue to aim to achieve net zero as far as possible through emissions mitigations, with only supplementary roles for GGR solutions that balance emitted GHGs.
Recommendation 1b
UK Government / Climate Change Committee response_pending
Government should request advice from the CCC on post-2050 net-negative emissions, as part of its advice on the Eighth Carbon Budget in 2030.
Recommendation 1c
UK Government response_pending
The principle of geological net zero should be embraced within both the deployment pathways that the Government produces for its Carbon Budgets and within policy design, ensuring that residual fossil fuel emissions are balanced with geologically permanent removals.
Recommendation 1d
UK Government response_pending
Government should ensure GGRs are included in the public attitudes tracker to monitor public acceptance of GGRs. Government should also prioritise public interaction and a focus on social licence in GGR policy development, with consideration of fairness, to build trust in the institutions developing these solutions.
Recommendation 3a
UK Government (DEFRA / DESNZ) response_pending
Government should publish the Land Use Framework. The Framework should be used to evaluate options for increasing domestic supply of sustainable biomass based on updated evidence on potential and contributions to net zero. Consideration should be given to the incentivising of energy crop production on marginal land and the further development of planned and supported reafforestation.
Recommendation 3b
UK Government response_pending
Government should adopt a strategic aim to minimise use of imported biomass feedstocks, through identifying greater scope for GGRs based on UK sustainable feedstocks (e.g. wastes) to contribute and through minimising the overall need for GGRs.
Recommendation 3c
UK Government response_pending
Government should set out its view on priority uses for biomass.
Recommendation 3d
UK Government (DESNZ / DfT) response_pending
To maximise the opportunities for reducing net emissions, any SAF production occurring in the UK based on sustainable biomass feedstocks should incorporate CCUS from the outset.
Recommendation 3e
UK Government response_pending
Government should assess the feasibility and opportunities for energy and co-product synergies for example low-temperature DACCS plants based on waste heat such as from nuclear, data centres and other sources.
Recommendation 4a
UK Government response_pending
Government should ensure that decisions on GGRs do not narrowly focus on removal potential but include an assessment of GGRs' economic growth channels or apply an economic growth framework to understand all costs and benefits linked to GGRs.
Recommendation 4b
UK Government response_pending
Government should exploit UK growth opportunities, including by positioning the UK as a leader on GGRs, and making use of our comparative advantages in science and technology, CO2 storage potential and financial services.
Recommendation 4c
UK Government response_pending
Government should use a variety of different levers to support GGR supply chains, to avoid risks and harness opportunities. Possible interventions, in addition to the demand-pull impact on the supply chain via Contract for Difference support, could include direct funding of the supply chain, further extension of the Clean Industry Bonus or the use of voluntary industry commitments.
Recommendation 5a
UK Government response_pending
Government must give serious consideration to whether to increase ambition for AD, subject to other key policy objectives on land use, alternative uses of feedstocks, economic costs and lifecycle emissions.
Recommendation 5b
UK Government response_pending
Government should develop a GGR Strategy to outline the contribution of GGR solutions required to meet Carbon Budgets and net zero. This should include maximising GGRs based on UK waste and other underutilised resources, and setting out any role for BECCS based on imports and other international dimensions.
Recommendation 6a
UK Government response_pending
Government should ensure that the deployment of GGRs is funded in a way that has acceptable distributional consequences and is likely to be perceived to be fair.
Recommendation 6b
UK Government (DESNZ) response_pending
The Government is continuing to develop a full standard for BECCS and DACCS, as well as developing a standard for biochar and ERW. Due to the costs, complexity and length of time it takes to develop a standard, we encourage government to endorse a suitable existing standard for biochar and ERW in the interim period (when available for ERW), while a government standard is developed.
Recommendation 6c
UK Government response_pending
Ensure that a mechanism is put in place to fund woodland creation, from revenues from emitters under the ETS. Ideally this should not involve direct inclusion of woodland creation in the ETS, because only geologically permanent removals should be included in the ETS.
Recommendation 6d
UK Government (DfT) response_pending
Amend and rename the SAF Mandate to become a Net Zero Aviation Mandate, with a trajectory that means that by 2045 all flights taking off from the UK are made climate-neutral. The amended Mandate should drive procurement of both SAF and permanent GGRs, with competition between these solutions.
Recommendation 6e
UK Government response_pending
Government should consider the appropriateness of overseas DACCS deployment and lead internationally on GGRs, by convening a coalition of countries committed to achieving net zero by 2050.
Recommendation 7a
UK Government response_pending
Government should undertake an audit of regulatory barriers to GGR deployment and include a plan to address them as part of the proposed GGR strategy.
Recommendation 7b
UK Government (DESNZ) response_pending
Government should accelerate planned policies to enable non-pipeline transport. Government should also accelerate decisions on the future CCUS clusters, further expansion and look to launch a process for selling storage capacity internationally.
Recommendation 7c
DEFRA response_pending
For RO-based energy generation based on UK wastes and residues (e.g. waste wood, sawmill residues or poultry litter) for which support is due to expire from 2027, Defra should urgently review the waste management options and the case for extended support via energy generation with longer-term capacity to deliver GGRs.
Recommendation 7d
UK Government response_pending
Government should introduce new policies to provide routes to market for new AD capacity, with CO2 from biogas upgrading able to access GGR support and support for biomethane primarily to be used in sectors able to deploy CCS.
Recommendation 7e
UK Government (DEFRA / DESNZ) response_pending
Government should introduce measures to reduce the proportion of plastic going into EfW plants, thereby increasing capacity and GGR potential, through the establishment of plastic receiving and recycling plants in the UK.
Recommendation 7f
UK Government (DEFRA) response_pending
Update the waste hierarchy to include a key role for carbon sequestration alongside energy recovery for non-recyclable waste.
Recommendation 7g
UK Government (DESNZ) response_pending
Ensure all GGR technologies have regulated MRVs to govern their output.
Recommendation 7h
UK Government (UKRI / DESNZ) response_pending
Government should recognise the importance of innovation funding and R&D in the GGR sector and commit to additional support for pilot- and mid-scale projects to address "valley of death" issues and secure a pipeline of diverse GGRs.
Recommendation 7i
UK Government (DESNZ) response_pending
Government should publish the findings from its GGR innovation funding to date and ensure that innovation funding continues to help projects move from demonstration to commercial deployment stage.
Recommendation 7j
UK Government response_pending
Government should explore the possibility of creating a GGR Catapult.
Recommendation 7k
UK Government response_pending
Government should establish an Office for Greenhouse Gas Removals to produce more coordinated action on GGRs, and to enable quicker and more efficient rollout of policy and project deployment.
No recommendations with this response.