Irrefutable's response to DESNZ's Consultation on Building a Market for Low-Emission Industrial Products

There has been a growing number of global policy initiatives focused on supply chain decarbonization. These include measures to price carbon at borders, leverage public procurement to create demand for low-carbon materials, and increase transparency through emissions reporting. Examples include the EU's Carbon Border Adjustment Mechanism (CBAM), buyer's coalitions across a range of carbon intensive sectors, and various carbon labeling schemes.

The United Kingdom has a rare opportunity to establish itself as a global leader in industrial decarbonization. As Department for Energy Security and Net Zero’s (DESNZ) develops its policy framework for low-carbon industrial products, we believe the key to success lies in building high-integrity digital infrastructure for Environmental Attribute Certificates (EACs), a mechanism that transforms verified emissions reductions into tradable, trusted assets.

Below are our principal recommendations, mapped against the consultation’s policy proposals, with emphasis on how cryptographically secured, high-quality EACs can deliver measurable environmental impact and unlock scale.

Recommendation 1

One of the key barriers to reducing industrial emissions today is that the benefits of emission-reduction projects are hard to monetize. Companies face high upfront costs and uncertain returns. EACs solve this problem by broadening the pool of prospective buyers for low-emission solutions beyond direct supply chain counterparts, providing a higher degree of certainty that firms implementing low-emission solutions can monetize them. This, in turn, means more low-emission projects will be financed.

By recognizing the impact of these instruments within emissions reporting guidelines, the UK can unlock new channels of financing for industrial decarbonization.

A market-based approach also promotes fairness and inclusivity by allowing companies to demonstrate credible decarbonization efforts regardless of their physical or geographic constraints.

We therefore recommend embedding the use of EACs, and thus market-based accounting, into the UK’s Embodied Emissions Reporting Framework (EERF).

Recommendation 2

Historically, due to a high costs and a lack of available technologies, embodied emission reporting has relied on estimations or industry averages. The resulting output is not decision-useful. Advances in technology have now dramatically reduced the costs of verification and high-quality data.

Buyers should thus be able to trace evidence of emission intensity through supply chains, viewing not just averages but verified data points at every stage. When created using high-integrity, high-quality data, EACs provide this traceability. This ensures comparability, prevents greenwashing, and enhances the UK’s global credibility.

We therefore recommend requiring verified, cryptographic data on carbon intensity to replace self-reported or estimated figures.

Recommendation 3

Public procurement has the ability to de-risk investments, drive economies of scale, and normalize low-carbon production. The government’s green procurement strategy can anchor demand for low-carbon products by sending a powerful demand signal to industry. We therefore recommend the adoption of “EAC-verified” materials in public projects and setting targets for sectors such as steel and concrete.

Recommendation 4

Transitioning from a voluntary system to a mandatory disclosure regime will be crucial to cement the UK’s position as a leader in industrial decarbonization. Whilst a voluntary stage is crucial to allow the market to evolve through testing and refinement, mandatory disclosure provides certainty to investors. We therefore recommend a phased approach from voluntary to mandatory disclosure. 

Recommendation 5

We further recommend that the UK should ensure its EAC framework is globally interoperable, collaborating with partners to harmonize standards and secure recognition abroad. Compatibility with mechanisms like the EU’s Carbon Border Adjustment Mechanism (CBAM) will protect exporters and reinforce the UK’s leadership in sustainable trade.

Conclusion

The UK has an enormous opportunity to unlock and scale markets for low-emission industrial products. By supporting the adoption of industrial EACs, the UK can increase its global competitiveness and place itself at the forefront of an emerging strategic industry. The regulatory and market infrastructure we recommend would create an EAC ecosystem that would give the UK a head start to establish proof of concept, attract investment, and lay the foundations for a liquid market in low-emission attributes. 

With its strong digital infrastructure, fintech expertise, and history of regulatory leadership, the UK can set the global benchmark for credible, data-driven decarbonization. Verified low-carbon products would not only be aligned with meeting domestic net-zero goals, but also command premiums in international markets.

As demand for verifiable low-carbon materials grows, the message is unmistakable: credibility, not claims, will define competitiveness. By embedding EACs at the core of its industrial strategy, the UK can unlock investment, build trust, and lead the transition to a low-carbon economy built on transparency and innovation.