UK’s 7th carbon budget – a golden opportunity to lead on global super-pollutant action

On 26 February, the UK’s Climate Change Committee (CCC) published the “Seventh Carbon Budget – Advice for the UK government”, an almost 400-page document outlining recommended legally binding milestones to set the UK’s pathway to achieve Net Zero greenhouse gas emissions by 2050.

Under the UK Climate Change Act (2008), the UK was the first country in the world to set such legally binding targets, which provide caps on the amount of allowable emissions in successive five-year periods, starting in 2008.

The first three carbon budgets were set in law in May 2009, while the fourth carbon budget, which covers the period we are in now, 2023-27, was set in law in June 2011 and requires emissions to be reduced by 50 per cent below 1990 levels. The fifth was agreed in 2016 and the sixth in 2021 – the first to be set under the UK’s new net-zero target (see Table 1).

The UK’s Climate Change Committee (CCC) is required to advise the Government on the level of these budgets and the CCC’s latest report this time recommends a limit on UK greenhouse gas emissions from 2038-42 of 535 million tonnes of carbon dioxide-equivalent (MtCO₂e), an 86 per cent reduction from the baseline.

Table 1: The first six agreed and 7^th proposed UK carbon budgets with their respective periods and percentage reductions below the baseline.

The CCC report also sets out a “Balanced Pathway” for achieving the cuts, based on stakeholder consultations, sector modelling and data analysis. Here we take a look at what the CCC says about climate super pollutants and offer recommendations for UK domestic and global action.

 Methane (CH₄)

Methane is the second most important greenhouse gas after carbon dioxide (CO₂), with a Global Warming Potential (GWP) of more than 80 over a 20-year period. Methane is responsible for nearly one-third of current warming with emissions primarily from the agriculture, energy and waste sectors. Methane emissions have increased globally by 29 per cent since 1990 and already contribute to about 0.5°C of warming.

To meet the CCC’s Balanced Pathway for achieving Net Zero, by 2030 UK methane emissions need to be 23 per cent lower than 2022 levels, while a 44 per cent reduction is required by 2040.

According to the Seventh Carbon Budget, domestic methane emissions will continue to decrease, in large part due to declining industrial activity, cross-economy fuel switching and carbon capture and storage. Yet important methane emissions remain in the fossil fuel, waste and agricultural sectors, which the Environment Agency Methane Action Plan 2024-2026 acknowledges is only partially regulated.

Underlying the expected continued reductions of methane emissions are a series of assumptions about the energy transition and new technologies, such as biogas and blue hydrogen. It is hard to see, however, how the UK can rely on these assumptions without regulatory guardrails on methane that require measurement, reporting, verification (MRV), leak detection and repair (LDAR) and bans on venting and flaring of methane from the fossil fuel sector, both on domestic sources as well as imports which remain an important part of the fuel mix through 2050.

As the CCC notes, “few countries have taken concrete steps to reduce emissions from imports” and the “UK has an opportunity to be a leader in this area and set a useful precedent for similar countries to follow“. Therefore, the UK should regulate methane in the energy sector, both fossil fuels and biogas, setting out mandatory measures on MRV, LDAR and bans on venting and flaring, in addition to requirements for similar measures on imported gas.

Nitrous Oxide – N₂O

Nitrous oxide (N₂O) is a potent greenhouse gas (GWP 273) and the world’s most prevalent ozone-depleting substance. Lingering in the atmosphere for over a century once it is emitted, N₂O traps heat, warms our planet and poses a serious threat to the stratospheric ozone layer. Yet despite a 40% increase in global emissions since 1980, as far as climate policy goes, N₂O is often “the forgotten greenhouse gas”.

In the Balanced Pathway, the UK must achieve an 18% reduction in N₂O emissions by 2030 and a 36 per cent reduction by 2040, at which point N₂O will account for 11 per cent of total greenhouse gas emissions. 

The agriculture sector accounts for roughly 70 per cent of the UK’s total N₂O emissions. Synthetic nitrogen fertilisers are the single largest source, as they are often over-applied to cropland – at great expense to farmers’ as well as environmental health. In addition, manure management and burning also contribute to emissions. The remaining 30 per cent of UK N₂O emissions come from a diverse range of sources, including fossil fuel use in power generation and transport, biomass burning and wastewater treatment.

To reduce N₂O emissions in line with the CCC Balanced Pathway, the UK should leverage its position in the UNEP Nitrogen Working Group to develop and implement a National Action Plan (NAP) for nitrogen. This plan should pursue emissions reductions from power generation, transport and wastewater–where numerous technical mitigation measures already exist – but it must also tackle emissions from agriculture.

In addition to the climate and ozone benefits, better nitrogen management in agriculture (such as targeted fertiliser reductions and sustainable planting practices) would actually boost agricultural efficiency in the UK. Optimising fertiliser use will both lower costs for farmers and minimise nutrient waste. A nitrogen NAP would also strengthen food security by promoting practices that preserve soil health over the long term. Meanwhile, reducing dependence on synthetic fertilisers, which are often reliant on imported energy, would also enhance resilience against supply chain disruptions and market volatility.

F-gases

Thanks to the 2014 EU F-Gas Regulation which passed into UK law after Brexit, UK F-gas emissions in 2022 were already 49 per cent lower than 1990 levels (7.6 MtCO₂e). Almost three quarters of emissions are due to leakage of HFCs from refrigeration, air-conditioning and heat pump equipment, while their use in metered dose inhalers for asthma accounts for 12%. Emissions also come from their use in the electrical grid, fire protection and as chemical feedstocks (e.g., for the manufacture of plastics).

To meet the Balanced Pathway to net zero, F-gas emissions need to be reduced by half by 2030 and 73 per cent by 2040, relative to 2022 levels.

The CCC recognises that alignment with the ambition of the EU’s recently updated 2024 F-gas Regulation will be needed to achieve these reductions. In 2024, the EU set a new path for fast-tracking F-gas emission reductions, agreeing on the world’s first total HFC consumption phase-out by 2050.

The new EU regulation accelerates HFC consumption reductions from 79-95 per cent of the baseline by 2030, which it expects will lead to cost savings of around £31 per tonne of CO₂e reduced through improvements in energy efficiency and other measures. The EU F-Gas Regulation also recognises the need for complementary demand reduction measures to support the switch to alternative refrigerants. Critical to these are new equipment bans, which prohibit the use of F-gases in certain types of equipment. These act as important signposts for industry, driving green innovation and enabling timely investment decisions, as evidenced by the EU’s upcoming bans on F-gases in certain heat pumps, which have resulted in numerous new F-gas free models coming to the European market.

The UK has yet to update its 2014 F-gas Regulation and the UK’s HFC phase-down has begun to lag behind Europe’s. After several years of delay, Defra has committed to consulting on a new regulation this year. However, if the government hopes to meet the CCC’s Balanced Pathway and drive international climate leadership it needs to act quickly and comprehensively to align with the EU’s 2050 HFC phase-out.

Supporting the HFC phase-out through the establishment of mandatory certification and training for handling F-gas alternatives will be critical. F-gases and their alternatives should therefore be included in a Net Zero skills action plan, which the CCC recommends as a key action in order to “identify and address barriers to enable growth of the workforces needed to deliver the Net Zero transition.”

Plastics

Plastic has emission impacts across its lifecycle. The chemicals subsector is the highest contributor to the UK’s industrial emissions (8.2 MtCO₂e, 2023), with petrochemical ethylene production processes the most significant contributor to these emissions. Olefins (such as ethylene and propylene) are primarily produced as precursors to manufacture plastics; globally up to 90% of ethylene is used in plastics production and 68 per cent of propylene is used to manufacture polypropylene.

The CCC’s Balanced Pathway identifies electrification and carbon capture and storage (CCS) as key abatement measures in the chemicals subsector, while waste emission reduction is being proposed by reducing waste sent to landfill and EfW through resource efficiency, increased recycling rates and reduction in certain wastes (like food) as well as CCS use in EfW.

However, given that olefins derive directly from fossil fuels, these alone are inadequate. Oil and gas producers are seeking new markets in the face of reducing emissions in energy supply and petrochemicals and subsequent plastic production are the main contenders and set to increase. Thus, focusing on resource efficiency measures and reducing the production and consumption of plastics, especially non-essential and single-use plastics, should be prioritised.

At end-of-life, plastic also produces emissions throughout waste treatment and current design and waste management policies allow for continued high rates of per capita plastic consumption (and thus waste), including the continued export of plastic waste. Inherent obstacles in recycling plastic at scale (including poor product design) have resulted in failing recycling targets and problematically high levels of plastic in Energy-from-Waste (EfW) facilities. However, specific product design and end-of-life measures for plastic are missing from the Balanced Pathway.

EIA therefore has the following policy recommendations:

• introduce plastic production and plastic consumption reduction targets in line with at least 40 per cent by 2040
• introduce associated reuse targets and incentives for packaging and plastic packaging elimination targets for key product categories in tandem (like elimination of single-use plastic packaging for fresh uncut fruit and vegetables)
• provide stronger definitions on recyclability that ensure recyclable labels are genuine (i.e. are not just theoretically recyclable) and prevent the uptake of false recycling solutions – like chemical recycling.
• ban all UK plastic waste exports by 2027 and introduce an immediate moratorium on new incineration and energy-from-waste capacity across the UK.

Global Action and Leadership

Global leadership on climate super pollutants is needed now more than ever and with Minister McCarthy as incoming Co-chair of the Climate and Clean Air Coalition (CCAC), the UK is well positioned to take on this critical role.

The Seventh Carbon Budget highlights international climate finance and international collaboration and initiatives, including the Global Methane Pledge (GMP) which was opened for signature at CoP26 in Glasgow, in large part due to UK leadership. With the CCAC servicing as secretariat for the GMP, the UK can promote a strengthened institutional framework to underpin the Pledge, in particular through a dedicated fund that supports ODA-eligible signatories with the development and implementation of multi-year country programmes.

Similarly, with a proven track record and strengthened domestic action, the UK is in a strong position to lead global efforts to reduce N₂O, F-gas and plastic-related emissions. By bringing forward ambitious measures in multilateral forums such as the Montreal Protocol and the United Nations Environment Assembly, the UK can foster international collaboration, help set ambitious 1.5°C aligned reduction targets and assist developing nations in adopting cleaner technologies.

EIA looks forward to working with Minister McCarthy to turn the UK’s “unwavering commitment to tackling dangerous super pollutants” into reality.