Educational resource for environmental regulators, government officials, and policy makers worldwide. Converting manufacturing feedstock into high-value manufactured materials through Advanced Circular Manufacturing and Total Material Conversion.
Carbotura is an Advanced Circular Manufacturing (ACM) company that operates modular factories achieving Total Material Conversion (TMC). The system operates without combustion, and every stage is engineered to maximize material recovery and minimize environmental impact.
Carbotura modular factories are classified as Advanced Circular Manufacturing operations under US NAICS codes 325120, 325199, 335991, 325998, 334413, and 331492 (EU NACE equivalents: 20.11, 20.14, 23.99, 20.59, 26.11, 24.44). All incoming materials are purchased as manufacturing feedstock under Circular Offtake Agreements and classified as manufacturing inputs upon facility entry under US 40 CFR §241.3(b)(4) / EU Waste Framework Directive Article 5 & 6. Carbotura never applies for, accepts, or operates under a solid waste permit.
The Recyclotron uses Microwave Catalytic Reforming — a molecular electromagnetic activation process, not gasification or pyrolysis. It is designed to operate without combustion or oxidation in an anoxic environment, producing high-value manufactured materials through the Regenesis Protocol. This is a reactor-based manufacturing system, not a thermal processing facility.
Designed to comply with and exceed all applicable environmental standards. The near-zero-emission, near-zero-residual design profile means the regulatory rationale for waste-specific requirements does not apply.
Atmospheric Protection System operates in a closed-loop configuration, designed to eliminate the need for conventional stacks or scrubbers. The system operates without combustion in an anoxic environment (40 CFR §63.2).
EU equivalent: Industrial Emissions Directive (IED) 2010/75/EU — exempt due to near-zero emissions to air.
All incoming manufacturing feedstock is purchased under commercial Circular Offtake Agreements for use as manufacturing inputs under 40 CFR §261.2. Material purchased under a commercial supply agreement has not been discarded. Carbotura never applies for, accepts, or operates under a solid waste permit.
EU equivalent: Waste Framework Directive 2008/98/EC — Materials classified as by-products (Article 5) or end-of-waste (Article 6).
Designed for near-zero discharge. Ultrapure water is a manufactured product refined through Liquifact™ extraction and process water recovery, meeting or exceeding ASTM D1193 and EPA industrial reuse standards (40 CFR §122.2). No process water discharged to municipal systems.
EU equivalent: Water Framework Directive 2000/60/EC — Near-zero discharge system.
Hydrogen, carbon, and refined metals are existing chemicals. Testing and reporting meet TSCA §8(e) for chemical data maintenance. PFAS destroyed at 1,200°C+ — complete molecular breakdown, not filtration or transfer.
EU equivalent: REACH Regulation (EC) 1907/2006 — All products are registered substances.
Total Material Conversion — the outcome of the Circular Advantage program and all four Carbotura Protocols — is designed to convert virtually all incoming manufacturing feedstock into saleable manufactured materials, eliminating pollution at the source (42 U.S.C. §13101).
EU equivalent: Circular Economy Action Plan — Full alignment with waste hierarchy and circular economy principles.
| US NAICS | EU NACE | Classification |
|---|---|---|
| 325120 | 20.11 | Industrial Gas Manufacturing |
| 325199 | 20.14 | Other Basic Organic Chemical Manufacturing |
| 335991 | 23.99 | Carbon and Graphite Product Manufacturing |
| 325998 | 20.59 | All Other Miscellaneous Chemical Product Manufacturing |
| 334413 | 26.11 | Semiconductor Manufacturing |
| 331492 | 24.44 | Secondary Smelting, Refining, and Alloying of Nonferrous Metal |
Carbotura's ACM technology addresses material management challenges across multiple government departments. Our framework-agnostic approach establishes manufacturing classification within existing US federal, EU, and international regulatory structures.
EU: DG ENER
DOE Order 435.1 · EU Energy Efficiency Directive 2012/27/EU
Carbotura's ACM technology addresses material management challenges across multiple government departments. Our framework-agnostic approach establishes manufacturing classification within existing US federal, EU, and international regulatory structures.
EU: DG ENER · DOE Order 435.1
EU: EDA · DOD 4715.1-MM · NATO STANAG 7141
EU: EMA · 21 CFR Part 211 · EU GMP Directive 2003/94/EC
EU: DG AGRI · USDA NRCS Conservation Practice Standards
EU: EEA · 40 CFR Parts 241, 260–270 · WFD 2008/98/EC
EU: European Commission Services · Executive Order 14057
Carbotura's classification defense framework is designed to establish manufacturing classification in every jurisdiction — including under the EU Waste Framework Directive, UK Environmental Permitting Regulations, Canadian Environmental Protection Act, Australian National Environment Protection Measures, and other international frameworks. Regulatory counsel reviews all filings for classification consistency before submission.