The Centre for Climate Engagement (CCE) has submitted a response to the UK Government’s consultation on voluntary carbon and nature markets, which seeks to clarify and test the UK Government’s proposed policy and governance framework for helping to ensure the integrity of voluntary carbon and nature credits.
Our response draws on expertise in law, governance, and climate accountability to focus on how Government intervention could address the legal and practical uncertainties currently undermining confidence and participation in these markets. It was researched and written by Nick Scott, Aastha Kapoor, and Dr Paul Jefferiss.
Summary
CCE’s response centres on the need for the Government to play a more active role in clarifying definitions, setting standards, and providing guidance on the legal treatment of voluntary carbon credits. Without this clarity, businesses face reputational, legal, and financial risks that discourage participation. We recommend UK alignment with international efforts to harmonise standards and legal interpretations, and we stress that clarity and consistency are essential for building trust in these markets.
Key points
1. Clear standards and definitions are needed
The voluntary carbon market is currently fragmented by a patchwork of definitions and standards. The Government should establish clear, consistent, and stable definitions for key terms such as ‘net zero’, ‘carbon neutral’, and ‘nature positive’ to give businesses and consumers confidence.
2. Addressing legal uncertainty
There is still ambiguity around the legal status of voluntary carbon credits in the UK, which could deter market participation. The Government should issue guidance to clarify the treatment of different types of credits, particularly as the market evolves. Certainty in this area will help drive investment and growth in high-integrity markets.
3. Risk of greenwashing and greenhushing
The lack of clarity on claims about carbon credits contributes to fears of greenwashing litigation and regulatory action. This in turn can lead to ‘greenhushing’—companies withholding genuine climate efforts from public disclosure, which removes an incentive to enter voluntary carbon and nature markets. Addressing this confusion would help encourage credible, transparent participation.
4. A standard for claims would support integrity
A UK claims standard as proposed by the Government, alongside clear definitions, could help businesses substantiate their use of carbon credits and give consumers confidence. This standard must be accessible, unambiguous, and not overly burdensome to implement.
5. Aligning with international efforts is crucial
The UK should work through international bodies and seek alignment with other jurisdictions to promote consistency. This includes collaborating with other jurisdictions which are setting standards for the voluntary carbon market, supporting efforts towards harmonising international standards, and implementing Article 6 of the Paris Agreement to support a high-integrity global voluntary carbon market.
Slingshot