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Strengthening CO2 supply chain resilience

The UK has launched a 10-week Call for Evidence, inviting stakeholders to share views and evidence to inform measures aimed at strengthening the resilience, security and sustainability of the UK's CO₂ supply chain.

The call for evidence closes at 11:59pm on 20 August 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 CNIsectors 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.

The UK Government has 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, they 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

You can respond to the Call for Evidence by completing the online survey.

If you have any technical problems with using the online survey, contact CO2callforevidence@businessandtrade.gov.uk.

Read the full guidelines and respond to the call for evidence below.
 

Source: UK Government: https://www.gov.uk/government/calls-for-evidence/strengthening-co2-supply-chain-resilience-call-for-evidence

The Critical Supply Group consists of companies and professionals committed to secure and resilient critical supply chains. CSG is managed by MAP UK & International. For more details, including how to get involved, or to make contact with any of the entities involved, please email info@mapukinternational.com.