“Business as usual, with carbon credits thrown in.” This week’s briefing by Simon Counsell and Jutta Kill looks at the UK Woodland Carbon Code, with examples of carbon projects in Scotland.1 The briefing can be downloaded here.
Chris Lang || The UK Woodland Carbon Code was established in 2011. It is run by the Scottish government agency Scottish Forestry and operates across the UK. The Woodland Carbon Code claims to generate “high integrity independently verified carbon units” and to be “backed by government, the forest industry and carbon market experts”.
The Woodland Carbon Code states that the Code, “sets out requirements for voluntary woodland creation projects which tackle climate change by removing carbon dioxide from the atmosphere”.
This is supposed to allow landowners and farmers to earn money and is “a way for companies to support woodland creation and compensate for unavoidable emissions”.
14.8 million tonnes of CO₂ removal?
The Woodland Carbon Code has validated 845 projects covering a total area of 42,799 hectares. It claims “14.8 million tonnes of planned carbon dioxide removal.” Almost two-thirds of validated projects are in Scotland. By area, 85% of the total is in Scotland.
A further 1,369 projects are under development with a projected carbon sequestration of 15.4 million tCO₂e.
In July 2024, Carbon Pulse reported that units from the scheme were selling at about £25 each.
The Woodland Carbon Code states that more than 400 companies have bought units from its projects. Buyers of carbon credits under the scheme include Premier Paper Group, Heathrow Airport, Marks & Spencer, NatWest Bank, Shell, Waitrose, and BWOC, a fossil fuel supplier.
Almost all carbon credits under the scheme are generated by tree planting projects rather than avoided emissions from protecting forests. The carbon credits are called “Pending Issuance Units” and as the name suggests are issued on an ex-ante basis. The PIUs are issued based on forecasts of what will happen in the future. The Woodland Carbon Code charges 15 pence for issuing each PIU, and 10 pence to convert these to verified Woodland Carbon Units.
The vast majority of issuances, more than 13 million, are PIUs, which can be issued up to 100 years in the future. About 3.5 million have been sold. According to Carbon Pulse, only about 12,000 verified Woodland Carbon Units have been issued, sold, or retired.
The Woodlands Carbon Code encourages landowners to sell PIUs to “recoup money spent on establishing your woodland”. However, it adds that,
Pending Issuance Units can’t be used to compensate for your buyer’s emissions. They help companies to plan for compensating future UK-based emissions. As a responsible seller, it’s vital you make this clear to anyone buying your units.
Counsell and Kill reviewed the websites of the four largest project developers and found that only one of them, Scottish Woodlands, actually provided this guidance. (A second project developer, Forest Carbon, makes it clear that PIUs “are not offsets and cannot be used by businesses to support net-zero claims” in “A Personal View” post, but not in the company’s FAQ page.)
Counsell and Kill note that many things can go wrong between a carbon project starting and the date when the carbon is supposed to be stored. Trees can grow slower than anticipated. Disease, weather damage, and fire are all increasing as the climate crisis intensifies.
BrewDog’s “Lost forest”
One example of what can go wrong is BrewDog’s plans to go “carbon negative” by planting trees in Scotland. In 2020, BrewDog bought the Kinrara estate, near Aviemore. The 3,800 hectare plot of moorland cost £8.8 million. BrewDog planned to plant a “lost forest” of 3 million trees by 2025, partly funded by sales of “Lost Lager” beer.
But after a summer drought in 2023, about half of the 500,000 trees planted died. In December 2023, the Advertising Standards Agency ruled that BrewDog’s “carbon negative” advertising was misleading.
Counsell and Kill write that,
An inspection carried out for this briefing found in July 2024 that around 85-90 percent of the young broadleaf saplings in one parcel of land were dead. Those remaining alive were mostly very stunted birch saplings.
Nick Kempe, a campaigner at Parks Watch Scotland found extensive and unnecessary fencing and heavy machinery on the peatland prior to planting. Kempe argued that natural regeneration would have been better.
In October 2025, The Observer reported that BrewDog had sold the Kinrara estate to a “natural capital” company called Oxygen Conservation. The company has bought 12 estates in the UK covering a total of more than 20,200 hectares. By 2030, Oxygen Conservation aims to have “the leading natural capital portfolio in the world, valued in excess of £1 billion”.
Additionality?
According to official statistics, the area of woodland in the UK on 31 March 2025 was 3.29 million hectares. Woodland is a euphemism — very nearly half of the area consists of monoculture conifer plantations. In Scotland this figure is 71%.
The area of “woodland” in the UK has increased slightly over the past two decades. “According to official figures, less woodland has been created in the twelve years since the scheme was started than was created in the twelve years prior to it,” Counsell and Kill write. “This suggests that the scheme overall has been having a limited or negligible effect on stimulating planting that would not have happened anyway.”
Initially, the Woodland Carbon Code required that, “The project would not have gone ahead without the availability of carbon finance.”
In 2022, the Woodland Carbon Code was amended to state that, “without carbon finance the woodland creation project is either not the most economically or financially attractive use for that area of land or is not economically or financially viable on that land at all” (emphasis added).
Counsell and Kill comment that,
The first part of this new definition fundamentally changes the requirement that carbon finance is essential for the project to exist at all, with the provision that some other (or existing) use would be more profitable.
Business as Usual: Existing tree planting projects and commercial forestry operations
The Woodland Carbon Code initially even allowed existing plantings to generate carbon credits. Obviously, these are not additional. One example is the “Scottish Forest Alliance” project submitted by BP-Aramco in 2014 (and now held by BP Exploration Operating Co. Ltd.). This was validated in 2019. The project covers a total of 4,800 hectares, or about 12% of the Woodland Carbon Code’s total validated project area.
Planting started in 2000, 11 years before the Woodland Carbon Code existed. The project has been issued with 61,000 units.
In July 2021, the Woodland Carbon Code changed its rules to require projects to register before planting started.
Counsell and Kill argue that a significant number of Woodland Carbon Code projects are normal commercial forestry operations. For example, Scottish Woodland’s 252-hectare Cambusurich project is described on the Woodland Carbon Code registry as a “Mixed mainly thin and clearfell project”.
The project document states that,
The management objective is to create a commercial woodland using a wide variety of conifers to limit the risk of climate and tree disease along with planting native species adjacent.
About half the planting area is Sitka spruce, Norway spruce, and Scots pine — typical commercial forestry species in Scotland. The plantation fills in a gap in a landscape dominated by commercial forestry operations.
Counsell and Kill ask whether this is just “Business as usual, with carbon credits thrown in?” They calculate that 45% of the area of all validated Woodland Carbon Code projects will be “solely or mainly” clearfelled. Which sounds an awful lot like commercial forestry operations.
“Whatever other objectives the WCC might be achieving, it is probably close to worthless in climate policy terms,” Counsell and Kill conclude.
1 This is the ninth in a collection of posts on REDD-Monitor under the headline “Crooked Carbon Business”. The posts are based on a series of briefings about carbon offset projects written by Simon Counsell and Jutta Kill.
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