Ethical Consumer Climate Gap reports: Critique of methodology

This web page contains a critique of the methodology of Ethical Consumer's Climate Gap reports.

The conclusion is that the methodology is fatally flawed since the report compares UK government actions against a timescale of emission cuts that is grossly inadequate. The reports are therefore seriously misleading and should be withdrawn.

The box below shows two extracts from the 2021 Climate Gap report produced by Ethical Consumer (EC) ( The extracts [1] were provided by Ethical Consumer as part of the correspondence in March 2023 with Carbon Independent over whether the updated 2022 Climate Gap report is consistent with the scientific consensus, as reported by the IPCC. The assessment by Carbon Independent is that it is not consistent and should be withdrawn - see The correspondence is published at The full 2021 and 2022 EC Climate Gap reports are available online [2][3].

Areas of concern in the extracts are highlighted in red (major flaws) or yellow (less major flaws), or by underlining (on printouts), and annotated with comments. Comments can be displayed by selecting the highlighted text, or by selecting "Show all comments".

Box: Text extracts provided by Ethical Consumer with comments by Carbon Independent

From the 2021 Climate Gap Report

1.5 The Climate Change Committee and our research
The Climate Change Committee (CCC) was set up under the Climate Change Act 2008 to advise UK governments on decarbonisation.1
It is an independent body comprised mainly of economists and environmental experts It is a fallacy that the UK CCC is independent.
UK Government advisory committees are not free to say what they think. As examples, (a) Prof. David Nutt was sacked from his position as chairman of the Advisory Council on the Misuse of Drugs because the Home Secretary disagreed with his comments [4], and (b) the Independent SAGE group ( is an independent group of scientists that was formed to provide independent transparent advice during the COVID crisis, resulting from concerns that the UK Government's SAGE group is not properly independent or giving transparent advice.
and its main role is to report to Parliament annually on progress made in reducing greenhouse gas emissions. It is a bit like SAGE, the group of scientific advisors that has become well known during the pandemic, in that they both issue politely exasperated reports about the need to take urgent action in key areas.

The CCC's 200 page reports have provided most of the data for three of the impact areas we are examining for this report: Food, Transport and Heating. A core element in this project is therefore trying to convert their work into something more digestible for ordinary consumers.The use of the CCC reports as the basis for the Ethical Consumer (EC) report would be a reasonable approach if it had been established that the CCC reports are consistent with the scientific consensus.
But this question of consistency of CCC reports with the scientific consensus is never properly answered in the EC reports. In this section, the EC report assumes that the CCC reports are reliable. Elsewhere in the EC report, the CCC reports are referred to as "controversial", or reference is made to the timescale of emission cuts being too slow. This is very unsatisfactory. If the Climate Gap reports are going to assess government action against the action that should be taken, it is essential that a clear standard for assessment is established.
An analysis of the speed of emission cuts needed is given in the CUSP (University of Surrey) report [5]. The chart shown is the CUSP preferred analysis. The CCC timescale of emission cuts approximates to the linear decline in Option 1 — it can be seen to be grossly inadequate because the UK's per capita share of the CO2 budget for 1.5°C runs out in 2025. Instead of the CCC timescale, urgent radical cuts in emissions are needed to comply with the UK's Paris commitments (Option 2). Further information on the calculations and other academic sources is available online [6][7].
The maths and physics are simple enough for the calculations to be given in any report, along the following lines.
  • The more CO2 that is added to the atmosphere, the higher the global temperature.
  • To limit the temperature rise to 1.5°C, further global emissions have to be limited to 400 billion tonnes CO2 from 2020 (according to the IPCC report of 2021 [8]). This is the global CO2 budget.
  • Since global CO2 emissions are currently around 36 billion tonnes per year, the global CO2 runs out in 2030
  • The Paris Agreement specifies equity between nations and developed countries cutting emissions faster than developing countries [9].
  • Since the UK's annual CO2 emissions are about double the world average, its per capita share of the global CO2 budget runs out twice as quickly, i.e. in about 2025 [7].
There is near universal denial in the developed countries of the implications of this simple mathematics, which is termed implicatory denial by sociologists [10]
For the fourth impact area, Consumer Goods, we have conducted our own research and extrapolated targets and campaigns from elsewhere.

We talk more about
the CCC's reports and controversies with its approach in section 4 of this report, It is misleading to refer to the problems with the CCC's approach as "controversial". The EC report should present the simple mathematics that shows it to be grossly inadequate.
on page X.

1.6 There are many roads up the mountain
There is, however, no single route to decarbonisation.This is misleading — it implies that there is a luxury of choice, whereas the UK has to cut emissions as fast as possible if it wants to stay within its per capita share of this global CO2 budget.
We are using the 'Balanced Scenario' (see page X) produced by the CCC for many of our targets, because it is comprehensive, based on thorough up-to-date research, and gives consumers an idea of the direction we need to be headed in. It is for this reason that we are describing this report as containing 'science-based targets' for consumers. The CCC approach is not comprehensive since (a) it ignores the Paris commitment to developed countries cutting emissions faster than the global average, and (b) it ignores emissions embedded in imports — see comments on Section 4.
Consumers already know the direction we need to be headed in (i.e. cutting emissions) — the key point to be resolved is the speed of cuts needed.
However, there are plenty of arguments to be had with the CCC's scenario - in particular that it does not cut fast enough -, and we discuss some of these in more detail in section 4.1 below. The EC report should come to a clear conclusion and say that the CCC's scenario does not cut emissions fast enough.
At the moment, however, while we are still such a long way from meeting even these targets, we felt that it makes sense to be using these in the first instance.The EC report should highlight how bad the targes are rather than endorsing them, and undermining the IPCC which is calling for urgent radical change.

The CCCs Balanced Scenario is based around plans for decarbonisation by 2050. Where the CCC has publicly available interim goals for 2030, we have used these to assess whether we are going fast enough. Where it doesn't, we have just measured how well we are doing against linear annual cuts from now until 2030.

1 Both UK and Scottish

4. The Climate Change Committee and its reports

As mentioned in the introduction, the Climate Change Committee was set up under the Climate Change Act 2008 to advise UK governments on emissions targets.
It is an independent body comprised mainly of economists and environmental experts,As commented already, it is a fallacy to consider the UK Climate Change Committee to be independent.
and its main role is to report to Parliament annually on progress made in reducing greenhouse gas emissions.

In order for the CCC to create targets and track progress, it has modelled a range of scenarios where different events result in different outcomes. It issued its Sixth Budget Report in December 2020.
The CCC is the obvious source for targets and performance data on 'territorial emissions'2, as its budgets provide the most comprehensive overview of the way that consumer choices interact with all the other changes that need to occur of the UK's route to net zero emissions. There are various other decarbonisation scenarios in existence, but none that are so detailed, up-to-date, and comprehensive, with mathematically modelled targets based on information about what can be achieved at each stage. As commented already, the CCC's Sixth Budget Report is not comprehensive since (a) it ignores the Paris commitment to developed countries cutting emissions faster than the global average, and (b) it ignores emissions embedded in imports — see comments on Section 4.

Behavioural change is one element in its scenarios, and its behavioural modelling and recommendations were based partly on the recommendations of the UK Climate Assembly - a citizens' group chosen to be representative of the population, which reported in September 2020.

The CCC's scenarios are as follows:
  • Balanced - its main scenario, assuming a balance of technologies and behavioural change;
  • Widespread Engagement - more optimistic on behaviour change;
  • Widespread Innovation - more optimistic on technology development;
  • Headwinds - less optimistic on behaviour, greater use of hydrogen and carbon capture and storage (CCS);
  • Tailwinds - wildly optimistic on both behaviour & technology.

Based on its Balanced Scenario, the CCC sets annual targets for certain indicators, against which it reports progress each year to parliament.

Despite some controversies with its 'balanced pathway' scenario (see below), we are using targets from it for our own report. Again the EC report leaves unresolved the question of whether the CCC timescale is acceptable. This is unsatisactory. The CCC timescsale is not "controversial" — it is grossly inadequate.
We were not able to get enough detail on their 'widespread engagement' scenario from the CCC in time to use it for this report, but most of the 2030 targets do not appear to be too dissimilar anyway.

4.1 Controversial areas within the CCC's approach and its Balanced Scenario

There are three particularly controversial areas within the CCC's approach and its Balanced Scenario. The first is its choice of carbon budget.
CCC argues that its budget is sufficient for the UK to meet its obligations under the Paris agreement. However, others disagree, arguing that it involves the UK taking too much of the international carbon budget compared to developing countries. The EC report should scrutinise how the CCC justifies its timescale of emission cuts, and come to a conclusion as to whether the justifications are valid. The CCC's Sixth Carbon Budget report [11] was published in 2020. There are two major differences from the analysis by CUSP (referred to in previous comments).
Firstly, the CCC report makes no allowance for the commitment to equity between nations in the Paris Agreement [9]. The meaning of "equity" is not clearly defined in the Paris Agreement, but Articles 4.1 and 4.4 of the agreement clearly state that emissions in developed countries should fall while emissions in developing countries can rise for a period to facilitate economic development, i.e. that emissions in developed countries fall faster than the global average. The CCC Sixth report has a section considering the meaning of global equity (Box 7.2), and points out that there are a number of interpretations, but ultimately makes no mention of and no allowance for the commitment of developed countries to cut emissions faster than the global average. It is thus not consistent with the Paris Agreement. A common interpretation of equity between nations is an equal per capita share of the residual global CO2 budget for 1.5°C. The UK's CO2 emissions are currently over double the global per capita average, so UK emissions need to fall at least twice as fast as the global average if the UK is to stay within its per capita share. Cutting emissions in line with the global average (as the CCC suggests) would result in total emissions being over double the UK's per capita share. Understandably, developing countries such as India are very unhappy with this policy, with reference made to colonialism regarding the CO2 budget.
Secondly, the CCC budgets count only territorial emissions, saying e.g. that "Territorial emissions (i.e. those arising from UK sources, plus its contribution to international aviation and shipping) remain the right basis for the UK's carbon budgets and Net Zero target" (p19). This is a much criticised approach. Since the 1990's when international agreements to limit global warming were first made, there has been much transfer of UK manufacturing to abroad. The CCC approach treats emissions from such goods as no longer the UK's responsibility. This goes against common sense, and the Rio Declaration principles of 1992. The UK Government does not make a distinction that allows imported goods to be treated as zero carbon in company emissions reporting, i.e. double standards are in operation. UK consumption emissions (including imports) are roughly 50% higher than territorial emissions.
In summary, the CCC's timescale of emission cuts would take about three times the UK's per capita share of the global CO2 budget for 1.5°C [12], and it has to be assessed as grossly inadequate. The responsible approach to the harm that the UK is has done and is continuing to do via its CO2 emissions is urgent radical emission cuts e.g. as explained in the CUSP report (see comments above). This is the line that Ethical Consumer should take.

The organisation Carbon Tracker for example, which looks at government actions and targets globally, says the following:

"We rate the UK's 2030 domestic emissions reduction target of at least 68% below 1990 levels as 'Insufficient' when compared to its fair-share emissions allocation. The 'Insufficient' rating indicates that the UK's fair-share target in 2030 needs substantial improvement to be consistent with the Paris Agreement's 1.5°C temperature limit. Given that its domestic target is Paris compatible, these improvements need to, at least partially, come in the form of additional financial support for emissions reductions achieved in developing countries. If all countries followed the UK's approach, warming would reach up to 3°C."3
As well as the Carbon Tracker report, the EC report could cite (a) the CUSP report (as commented above), and (b) the Tyndall Climate Centre reports for UK local authorities [13] which are a useful resource for local UK campaigners wishing to scrutinise and challenge their local authority.

The second criticism is related: the CCC's budget relies considerably upon land-based net-negative technologies, such as Biomass with Carbon Capture and Storage (BECCS), in order to cancel out emissions. Once the need for urgent radical emission cuts is accepted, net-negative technoloigies can be seen to be an ineffective distraction since they cannot contribute within the available timescale of just a few years.

BECCS is relied on by most decarbonisation scenarios, in which emissions invariably overshoot the carbon budget in the next few decades, and then are sucked out of the atmosphere again by BECCS in the second half of the century.4 However, land-based net negative technologies like BECCS require a lot of land, raise complex governance issues, and may have damaging impacts on biodiversity. Very large scale deployment might steer the world closer to other planetary boundaries like those associated with freshwater use and soil health.5

The CCC's Balanced Scenario removals for 2050 are mainly from BECCS, and are over 100 million tonnes CO2e/ year which is not insignificant (our current total consumption emissions are about 700).6

A third related controversial area is the CCC's choices of where to allow 'residual emissions' (which need to be cancelled out with 'net negatives') and where to demand behaviour change. The CCC allows a considerable amounts of residual emissions in aviation, while assuming a reasonable - though not huge - amount of dietary change. The UK government has intimated that it it is unhappy about the dietary change,7 while others such as George Monbiot argue that it isn't ambitious enough, and that lab-grown food will shortly be able to replace farmed food on a grand scale, lowering emissions much further.8

Questions have also been raised about how equitable it is to allocate so much of our net negative capacity to aviation, when it is largely rich people who fly. The argument on CCC's side is that it is following the recommendations of the UK Climate Assembly in this, which has some democratic weight behind it. The Assembly was very reluctant to significantly reduce aviation.

4.2 Targets for non-territorial (consumption) emissions

The CCC does not currently deal with non-territorial consumption emissions in any detail, because it views them as largely out of our control. As commented above, this is not a responsible attitude. UK purchasers can choose to buy products manufactured abroad, to choose an equivalent product manuactured in the UK, or not to buy the product at all.
It hopes that other (producer) countries will manage down their own emissions in line with the Paris agreement. In its own slightly more complex language, it says:

"If UK territorial emissions are reduced to Net Zero and UK trading partners reduce their emissions in line with the Paris Agreement, then we estimate that UK consumption emissions would be around 90% below 1990 levels in 2050...around 50% of the UK's imported emissions are from territories due to be covered by Net Zero targets."9

This approach appears to suggest that there is no space at all for consumer agency here, which is not consistent with its view in other areas. This is partly why we have introduced our own impact area calculations for this report on Consumer Goods.

2 Those that take place within a country's territorial boundaries.
5 Fajardy et al, January 2019, BECCS deployment: a reality check, Imperial College Grantham Institute briefing paper no 28
6 CCC, December 2020, The Sixth Carbon Budget, the UK's path to net zero.


In summary, the timescale of emission cuts put forward by the UK Climate Change Committee is grossly inadequate and should not be used as a basis for climate action by responsible organisations.

The methodology of Ethical Consumer's Climate Gap reports is thus fatally flawed since the report compares UK Government actions against a timescale of emission cuts that is grossly inadequate. The reports are therefore seriously misleading and should be withdrawn.

In order to inform its readers about ethical choices, Ethical Consumer should advocate policies that are in line with the IPCC and the need for urgent radical cuts in CO2 emissions, and support those groups (e.g. Climate Uncensored and Fridays for Future) that are already doing so.


[2]Ethical Consumer 2021 Climate Gap report (2021)
[3]Ethical Consumer 2022 Climate Gap Report (Oct 2022) (accessed 22.2.23)
[4]Sacked — for telling the truth about drugs (2009) the Independent
[5]See the commentary at document 128; or the report: Jackson T (2021) Zero Carbon Sooner: Revised case for an early zero carbon target for the UK. CUSP Working Paper No 29. Guildford: University of Surrey.
[6]Ian R Campbell (2021) UK's share of the global carbon budget will be used up in 3.3 years (letter) BMJ 2021;374:n2391
[9]The Paris Agreement (2015) and
[10]Iain Walker and Zoe Leviston (2019) There are three types of climate change denier - and most of us are at least one The Conversation
[11]The Sixth Carbon Budget: The UK's path to Net Zero (2020) Committee on Climate Change, UK
[13]Tyndall Centre The Tyndall carbon budget tool (2019)

First published: 15 Mar 2023
Last updated: 20 Jul 2023