What this document is
A single-page action instrument: the one thing to authorise before the Capital Region’s incineration build-out is committed.
- 1There is a stream with nowhere to go: 1.28 Mt/yr of municipal residual, barred from the route it takes today.
- 2The economics work because the ban removed the cheap benchmark — the live alternative is outsourced treatment at ~$149/t.
- 3One action: an LOI/MOU with the Ministry of Climate, Energy and Environment, opening a Joint Working Group and feedstock characterisation.
1.28 million tonnes a year, and the route it takes is closing
Korea processes roughly 6.96 million tonnes of municipal material a year: 4.40 Mt to public incineration, 1.28 Mt to public landfill, 0.84 Mt to private incineration, 0.44 Mt to private recycling. The 1.28 Mt/yr going to public landfill is the stream this brief is about. Direct landfill of combustible municipal residual is already closed in the Capital Region and closes nationally in 2030 under the Framework Act on Resource Circulation. That volume is not being diverted from anywhere; it needs a destination, and 27 incineration plants are planned in the Capital Region to be that destination. The window is before that capacity is committed.
Carbotura was built for exactly this remaining stream. Advanced Circular Manufacturing (ACM) takes the post-recycling residual — the mixed material left after Korea’s ~54% recycling has done its work — and converts it by primary elemental dissociation into Circular Materials: synthetic graphite, graphene compounds, recovered minerals, plus net-positive ultrapure water. Not landfill, not incineration, not waste-to-energy — manufacturing. It competes with none of Korea’s recycling; it takes what recycling leaves behind.
The counterparty’s verified all-in cost is ~$149/tonne — private-contractor municipal treatment at KRW 192,196/t (US$142) plus the statutory disposal charge on incineration at KRW 10,000/t (US$7). Against that, a Beneficiation Fee (TMC Fee) quoted at $100–150/tonne sits at or below across its entire range. Against in-house public incineration at ~$114/t all-in it clears only at the lower end — so the offer is strongest exactly where the counterparty already outsources, and 105 municipalities do.
Beginning 13 months after Carbotura’s receipt of the first Beneficiation Fee payment, the counterparty receives a rolling monthly Circular Royalty™ — 120% of that year’s fee in Year 1, adding one percentage point every year, uncapped. Over the 30-year term at Phase Initial that is a gross royalty of approximately $874M; at full build-out, approximately $2.62B. The fee and the royalty are two independent transactions and are shown separately throughout this package.
Why Korea, and why now
Against public landfill at ~$60/t no manufacturing fee competes, which is why Korea never looked like a market. Direct landfill of combustible residual is closed in the Capital Region and closes nationally in 2030. The benchmark is gone; what remains is outsourced treatment at ~$149/t.
Most jurisdictions require an argument to be won against a statute drafted without ACM in mind. Korea’s 2018 Framework Act on Resource Circulation provides a Circular Resource certification — a statutory end-of-waste route that already exists in law. Carbotura pursues it. Nothing in this proposal depends on it, and no classification claim is made here.
105 municipalities rely on external treatment today; 96 have expansion plans and 12 are in construction. The offer is strongest where a municipality is already paying the outsourced rate rather than operating its own plant.
ACM Modular Production Units are manufactured and replicated under a Design for Manufacturability (DFM) model in 100 TPD increments — 400 TPD at Phase Initial, 1,200 TPD at full build-out, roughly 69% of one displaced stream and no diversion from capacity already incinerating.
Build-Own-Operate: Carbotura funds 100% of capital at every phase. The project entity reports under K-IFRS. The US municipal GASB 18 argument does not transfer and is not assumed.
The structure, stated once
The Beneficiation Fee and the Circular Royalty™ are independent gross transactions with different payers. They are reported separately and never netted against one another.
The same physical mass is counted once in each of three dimensions — asset, revenue, attributes — and never summed as three independent masses.
Build-Own-Operate. Carbotura funds 100% of capital at every phase. The counterparty commits feedstock, not money.
One Circular Supply Agreement
+ Circular Royalty™
- Beneficiation Fee: $100–150/tonne · set at Term Sheet against the verified FWDC · 2.5%/yr escalator
- Circular Royalty™: 120% of the current-year Beneficiation Fee in Year 1 ($120–180/tonne), +1pp/yr, uncapped
- Royalty commencement: 13 months after the first Beneficiation Fee payment, rolling monthly on delivered tonnage
- Perpetual CSA, 30-year minimum term · Build-Own-Operate · zero counterparty capital
- Feedstock transfers under the CSA — ownership and liability pass at collection or delivery
- Accounting basis: K-IFRS (jurisdiction-appropriate; US GAAP is not the basis)
The Sudokwon legacy landfill mass is carried as an Exogenesis™ candidate — converting accumulated legacy material into a structured Legacy Remediation Royalty alongside the primary CSA. Whether any of it is characterisable, and on what terms, is unresolved. Nothing in the base case depends on it.
Subject to feedstock characterisationKey figures at a glance
KFEM via Eco-Business, Apr 2026
set at Term Sheet · 2.5%/yr escalator
+1pp/yr, uncapped
~1,750 t/day Capital Region MODELED
Circular Royalty™ projections by phase
Beneficiation Fee and Circular Royalty™ shown independently per the Separate Transaction Principle. No figure on this page nets one against the other.
| Capacity | Annual TPY | Beneficiation Fee · Year 1 | Circular Royalty™ · Year 1 basis | 30-Year Gross Royalty | Direct FTE |
|---|---|---|---|---|---|
| 400 TPD ← Phase Initial | 146,000 | $14.60M | $17.52M | ~$874M ESTIMATED | — |
| 800 TPD · Phase Medium | 292,000 | $29.20M | $35.04M | ~$1.75B ESTIMATED | — |
| 1,200 TPD · Phase Expanded | 438,000 | $43.80M | $52.56M | ~$2.62B ESTIMATED | — |
FWDC ~$149/t VERIFIED. Beneficiation Fee modelled at the floor of the $100–150/t range; the range is what is offered. Circular Royalty™ (Year n) = (120% + (n−1)pp) × that year’s Beneficiation Fee; payments commence 13 months after Carbotura’s receipt of the first fee payment and roll monthly on delivered tonnage. 30-Year Gross Royalty is gross royalty over 30 payments. Direct FTE is a characterisation output and is not modelled before feedstock data is in hand. The fee and the royalty are independent gross transactions and are not netted anywhere in this document.