Event:16 September | Carbon Removal Policy Summit
Statutory CDR Industry Levy and BoardSystem and Capacity Enablers

STATUTORY CDR INDUSTRY LEVY AND BOARD

Lever last updated: 14 September 2026

A legal charge on CDR market activity funding a jointly governed industry board.

Cost

Low to Medium

Gross cost includes the levy-funded programme, collection, governance and audit. Public budgets may be insulated, but compulsory expenditure by covered companies remains a direct implementation cost.

Complexity

Medium

Legislation must define payers, rates, collection, permitted spending, governance, audits and review. The board also needs systems for invoices, arrears, procurement, conflicts, publication and coordination with existing sector bodies.

Timeline

Short to Medium

Existing levy powers can establish collection and change payer behaviour within one to two years. New legislation, representative appointments and operating systems can delay funded services toward five years.

Integrity, Transparency & MRV

1–3

Innovation & Cost Reduction

1–3

Social & Environmental Safeguards

N/A

Energy, Transport & Storage Infrastructure

N/A

Inputs & Capacity

1–3

Demand Formation

N/A

Bankability and Cost of Capital

N/A

Policy Architecture & Coordination

2–3

Overview

A law can require CDR market participants to pay a small charge based on verified tonnes, transactions, turnover or another measurable activity. The proceeds go to a ring-fenced board, governed jointly by levy payers and overseen by a public authority, which finances services benefiting the whole sector. These may include shared measurement research, open market data, technical training and common guidance. The compulsory contribution solves the problem that individual firms can use those services without paying. It differs from general taxation because the money is reserved for a statutory purpose, and from association dues because covered firms cannot opt out.

Key Considerations

The design needs to identify who pays, the levy base and rate, who ultimately bears the cost and whether small or new suppliers receive thresholds or graduated rates. Charging each verified tonne is simple but may penalise early growth, while turnover or transaction charges distribute costs differently. Board appointments, voting rights and public oversight need to prevent the largest payers from controlling spending. The statutory mandate needs to confine funds to shared services rather than subsidies for individual members. Collection, cross-border activity, competition law, conflicts, audits, publication, complaints and periodic consent or review also affect legitimacy.

Opportunities

A levy creates a predictable shared budget without relying on voluntary contributions from a few companies. The board can commission data, research, training and technical tools that many suppliers need but none has a strong reason to finance alone. Ring-fencing links payments to visible sector services, while representative governance can reveal common operational problems. A common programme may reduce duplication and strengthen institutional capacity. Benefits depend on a useful spending mandate and fair representation, not simply on collecting money or calling the board industry led.

Risks

The levy raises the cost of supplying or buying removals and may be disproportionate in an early market. Firms can capture board seats and direct funds toward preferred methods, regions or promotion. A weak mandate may finance advertising, confidential research or existing services rather than shared goods. Cross-border transactions can evade collection or face overlapping charges. Compulsory payments without meaningful review invite challenge, while volume-based funding may discourage the board from supporting stricter quality rules.

Monitoring and Evaluation

Reporting should connect levy income and cost with spending, contractors, published outputs and use across the sector. Evaluation should examine payer coverage, distribution by firm size, board representation, conflicts and whether services would otherwise exist. Research quality, training uptake and use of data show value. Concentrated benefits, low use or payer opposition should inform the rate, mandate, exemptions or continuation.

Stakeholder Engagement

Levy payers should shape the base, rate, spending priorities and review process before compulsion begins. Smaller suppliers and buyers need separate representation so established firms cannot define sector needs alone. Researchers and training providers identify missing shared services. Competition authorities, auditors and civil society scrutinise self-dealing and public-benefit claims, while the responsible authority retains final legal and oversight responsibility.

Governance Levels

SupranationalNationalRegional / StateCorporate / Industry

Supranational, national, regional and state lawmakers can create a compulsory charge within their fiscal or sector-regulation powers. The producer-governed board then administers the ring-fenced proceeds, giving Corporate/Industry a materially joint role without independent power to compel payment. International bodies or municipalities need a specific legal mandate before they qualify, and philanthropy cannot impose the levy.

Implementation Strategies

  • Legislation should define payers, the levy base, rate limits, collection powers, permitted shared services and treatment of small or new firms.

  • Board rules can balance representation by contribution, firm size, method and geography while managing conflicts of interest and protecting minority interests.

  • Independent audit, open procurement and publication of funded outputs should connect compulsory payments with visible sector value.

  • Periodic ballots or statutory reviews can adjust the rate and mandate or end the levy when payers no longer support it.

Case Studies

United Kingdom Agriculture and Horticulture Development Board.

The Agriculture and Horticulture Development Board operates under a 2008 statutory order and raises compulsory levies from specified agricultural sectors. Money collected from each sector is ring-fenced for that sector, and ministerial approval is required to change rates. AHDB currently collects six levies and must hold a ballot if the statutory request threshold is met, although ministers retain the final decision. As an agricultural analogue rather than a CDR scheme, it demonstrates a national law, sector-specific collection, shared-service spending and a formal route for payers to challenge continuation.

United States beef check-off.

The US Beef Promotion and Research Program began collecting compulsory assessments in October 1986 under federal legislation and an implementing order. It charges USD 1 each time cattle are sold, with comparable charges on imports. The Department of Agriculture reports roughly USD 75 million in annual assessments, divided between the national board and qualified state councils. Board members are appointed by the Agriculture Secretary from industry nominations. This non-CDR analogue demonstrates a durable unit-based levy and joint public-industry governance, but its promotion mandate does not prove value for CDR measurement or research.

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©2026 Alexander Mäkelä and Carbon Gap.
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