Open call for evidence

Strengthening CO2 supply chain resilience

Published 11 June 2026

Executive summary

This call for evidence seeks views and data from:

• industry (including manufacturers, suppliers and distributors)
• trade associations
• academia
• consumers
• other stakeholders

It will inform development of measures to improve the resilience, security, and sustainability of the UK’s supply of food and medical grade CO2 for usage across important sectors, including Critical National Infrastructure (CNI).

The UK CO2 industry lacks resilience and has been subject to repeated market failures in 2018, 2021 and 2026 requiring government intervention.

Challenges include:

• global market shocks, driven most recently by global conflict
• the UK’s heavy reliance on imports leaving the domestic market exposed to disruption
• market concentration and fragile supply chains where CO2 is often produced as a by-product

Together, these challenges present strategic risks, with potential implications for CNI sectors that require reliable and affordable supplies of CO2 such as agri‑food, water, healthcare, nuclear and chemicals. The government is therefore exploring market‑led options to diversify CO2 supply, boost lower‑carbon sources, and improve transparency across the value chain, informed by an assessment of the UK CO2 usage market.

These risks have recently increased due to higher gas prices driven by the conflict in the Middle East, and planned and unplanned outages at European ammonia plants.

Context and strategic importance

CO2 is a critical input for a range of essential uses, including:

• healthcare
• medicine
• nuclear power generation
• food and drink processing
• animal slaughter
• water treatment

CO2 is traditionally captured as a by-product of other industrial production processes (such as gas-based ammonia and fertiliser production) and is not directly manufactured for use.

Closures of important production facilities in the fertiliser and bioethanol industries have significantly reduced UK supply of CO2 from traditional sources. Therefore, the UK has become more reliant on imported CO2. Currently, the majority of UK demand for CO2 is imported, with domestic sources only making a relatively small contribution.

Similarly, a few large distributors dominate the CO2 market, causing a dependency on European supply chains, and even greater vulnerability to external shocks. Combined with a lack of suitable alternatives for many industries, disruptions to supply can rapidly cascade into production stoppages, wastage, and safety risks.

In addition, CO2 can be challenging and costly to transport due to the need for specialist, capacity‑constrained logistics and limited storage. As a result, supply is highly sensitive to location, infrastructure availability, and source disruption.

Because CO2 is captured as a by-product, it is inherently dependent on other markets and therefore is particularly vulnerable to external factors. There have been repeated knock-on effects from market failures in the past, including 2018 and 2021, requiring government intervention.

At present, CO2 supply across Europe is fragile due to a combination of factors including planned maintenance outages, reduced fertiliser production (as manufacturers respond to increasing gas prices) and resulting disruption to imports.

In April 2026, the government took the decision to temporarily support the restart of activity at Ensus, a previously mothballed bioethanol plant, to safeguard CNI needs in the short-term and maintain a resilient supply of CO2. This type of intervention is only intended to support continuity of supply for a short period of significant shock, and more sustainable approaches to strengthening market resilience are required to ensure such costly interventions are not required in future.

Addressing resilience now can help reduce exposure to import shocks, de-risk the transition to net zero and increase private investment. The UK’s pathway to net zero requires a shift away from fossil-derived by-product CO2, towards lower-carbon sources such as biogenic capture and Direct Air Capture (DAC). More sustainable sources of CO2 include, for example, breweries and anaerobic digestion plants. In turn, CO2 that is delivered via shorter, more local supply chains will be less exposed to market shocks.

The information you provide as part of this call for evidence will help to build the evidence base that will inform the development of policy measures to accelerate the UK’s transition to a resilient, transparent, and sustainable CO2 market, for the benefit of businesses and the public.

Detailed policy rationale

The government is considering action because:

1. Import dependence and concentration risks expose UK supply to single point failures and external shocks.
2. Market signals have so far failed to promote investment in reliable, lower-carbon domestic supply (for example, price volatility, uncertain offtake, information asymmetries).
3. Voluntary approaches to transparency and certification have been adopted inconsistently across the CO2 market. As a result, there is limited visibility of supply chains, including the origin, sustainability, and resilience of CO2 supplies, constraining the ability of government and industry to assess risks, compare options, and identify effective long‑term approaches to improving resilience.

The government objectives are therefore to:

1. Strengthen the long-term resilience and reliability of the UK’s CO2 supply, particularly for uses within CNI sectors, where disruption could affect critical industries. This will reduce our exposure to supply risks arising from import dependence and market concentration, strengthening the UK’s ability to respond to or weather external shocks.
2. Consider the role of more sustainable sources of CO2 that are less reliant on fossil fuels, alongside novel solutions, and substitution options, where this is feasible.
3. Understand how to achieve a more transparent and functional market, with better outcomes for consumers.
4. Minimise transitional costs and impacts on businesses as we seek to move towards a more resilient UK supply.

Scope

This call for evidence focuses on the capture, supply, and use of European Industrial Gases Association (EIGA) and International Society of Beverage Technologists (ISBT) certified food and medical grade CO2 as a product across UK supply chains.

Based on market engagement to date, we understand biogenic sources of CO2 are likely to be viable for uses of CO2 that require a high degree of purity (EIGA) and are also economically viable due to these sources being compatible with carbon and environmental policy.

We have also been informed that CO2 that has been sequestered via pipeline as a part of cluster decarbonisations plans will present technical barriers in terms of capture and distribution, particularly when compared to biogenic sources. However, we wish to retest this feedback with the market.

In scope

Carbon Capture for Usage (CCU), including EIGA/FSSC/AIGA certified, food, medical or other specialist-grade CO2 production, capture, purification, distribution, and end-use across UK supply chains.

Out of scope

Carbon Capture for Storage (CCS), including CO2 transport and storage solely for permanent sequestration without resale for usage, CO2 for sequestration in building materials, or CO2 for the development of alternative fuels (for example, Sustainable Aviation Fuels).

Audience

We welcome responses from:

• food and medical grade CO2 producers, manufacturers, suppliers, distributors (including logistics operators), and end-users (including, but not limited to, beverage, food processing, healthcare, horticulture, nuclear, chemicals, and manufacturing)
• CO2 capture technology providers
• academia
• trade bodies
• equipment suppliers
• investors and financiers
• certification and standards bodies
• local authorities and devolved governments
• individuals

How to respond

This call for evidence opened on 11 June 2026 and will be open for 10 weeks. Please respond by 23:59 on 20 August 2026.

Use the online survey to send your response, especially if you are responding on behalf of an organisation. Using the online survey greatly assists our analysis of the responses, enabling more efficient and effective consideration of the issues raised.

The purpose of this survey is to collect evidence surrounding CO2 resilience across the UK. This exercise will be conducted in partnership with Department for Environment, Food and Rural Affairs (Defra) colleagues. Defra analysts will work alongside Department for Business and Trade (DBT) analysts to evaluate the responses.

You do not need to answer every question. Due to the way the consultation responses are processed we cannot guarantee your comments will be captured if you answer a question by citing a previous answer, or comment ‘see above’.

Any points you wish to raise in response to a question should be set out in full as part of that question’s response. Any evidence submitted will be reviewed but will not be analysed, summarised, or included in the published government response. 

If you have any questions or if you require a downloadable version of the online survey, please contact us at CO2callforevidence@businessandtrade.gov.uk.

We recognise that respondents may choose to use some standard text to inform their response. Campaigns are when organisations (or individuals) co-ordinate responses across their membership or support base, often by suggesting a set of wording for respondents to use. Campaign responses are usually very similar or identical to each other. 

For this consultation, campaign responses may be analysed separately from other responses to ensure the breadth of views received can be summarised effectively and efficiently. All campaign responses will be considered in the final analysis of public views and campaigns help indicate the strength of feeling on an issue. We prefer for you to provide your views (including where a response is based on a campaign) through the online survey.

Submitted responses can be withdrawn or amended by request during the consultation period.

Using and sharing your information

How we use your personal data is set out in the consultation and call for evidence privacy notice.

Complaints procedure

You can contact DBT’s Data Protection Officer for further information about how your data has been processed by the department or to make a complaint about how your data has been used.

Email: data.protection@businessandtrade.gov.uk

Consultation principles

Although this is not a consultation, this call for evidence is being conducted in line with the Cabinet Office consultation principles.

Annex A: glossary and definitions

Biogenic CO2: CO2 captured from biomass-based processes (for example, anaerobic digestion, bioethanol) after suitable purification for end use.

Carbon Capture and Storage (CCS): technologies that capture CO2 from industrial processes, Part combustion, or the atmosphere and permanently store it in geological formations (for example, depleted oil and gas reservoirs or deep saline aquifers).

Carbon Capture and Utilisation (CCU): processes in which CO2 is captured from industrial, biogenic, or atmospheric sources and then used as a feedstock in products or processes rather than being directly released to the atmosphere.

Critical National Infrastructure (CNI): sectors whose assets, systems, and networks are essential to national security, the economy, public health, or safety.

Direct Air Capture (DAC): technology that captures CO2 directly from ambient air, followed by purification for end use.

Distributor: an entity that purchases CO2 for resale to end users, including transport and logistics providers.

Food grade CO2: CO2 meeting specifications suitable for use in food and beverage applications.

Industrial CO2: CO2 used in industrial processes (for example, welding, pH control, coolant chemistry), with quality specifications appropriate to the application.

Low carbon CO2: CO2 whose production, capture, and supply result in significantly lower lifecycle greenhouse gas emissions than CO2 produced from unabated fossil fuel processes, when assessed on a lifecycle basis. Low Carbon CO2 is typically considered “low carbon” if it comes from CCU, CCS, Biogenic CO2 or DAC.

Medical grade CO2: CO2 meeting specifications suitable for use in medical applications.