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A new class of American manufacturing is contracting for a different stream directly with the communities that generate it. The useful question is what genuine circularity looks like when it shows up, and how to tell it from a label.
By Tyler Wood

The U.S. imported 100 percent of the natural graphite it consumed last year and has done so for decades. No American mine has produced natural graphite since 1989. Nearly half of those imports came from China. For rare earth elements, import reliance stands at 67 percent, with China again the leading supplier.

This dependency now has a deadline. In October 2025, China placed artificial graphite anode materials and related production equipment under formal export controls. One month later, following trade negotiations, Beijing suspended those controls. The suspension expires in November 2026. Whether the controls return is entirely a decision for China’s Ministry of Commerce.

For most of the country, this is a trade policy story. For the solid waste industry, it is much closer to home. The materials at the center of this dependency, carbon above all, move through American collection routes every single day. A new class of American manufacturing is already contracting for that stream, and it is contracting directly with the communities that generate it. The useful question is what genuine circularity looks like when it shows up, and how to tell it from a label.

The Dependency in Numbers
U.S. companies consumed an estimated 71,000 tons of natural graphite in 2025, valued at $128 million, according to the U.S. Geological Survey. Domestic mine production was zero. Over the past four years, import sources were: China 46 percent, Canada 13 percent, Mozambique 13 percent, Mexico 12 percent. Natural graphite is only part of the picture: total U.S. graphite use in 2025, synthetic grades included, runs an estimated 350,000 to 400,000 metric tons a year, a practical midpoint of about 370,000 tons, and most of it is synthetic.

Graphite is the anode of nearly every lithium-ion battery. It also goes into brake linings, refractories, powdered metals, steelmaking, and a growing set of defense applications. Demand is neither optional, nor shrinking.

In February 2026, the U.S. Department of Commerce imposed combined antidumping and countervailing duties of at least 160 percent on anode-grade graphite materials imported from China. The direction is clear: Washington wants domestic supply, and the price of the imported alternative is rising.

If China allows its suspension to lapse and reinstates export controls, American battery, defense, and industrial buyers will compete for licensed volumes from a single dominant supplier. If the suspension is extended, the underlying dependency remains unchanged. Neither outcome solves the domestic supply problem. Only new domestic sources do that.

What is Actually in the Municipal Stream
The municipal stream is, at the elemental level, carbon-dominant, with meaningful fractions of metals, minerals, and water. Every collection route in the country moves carbon in enormous quantities: paper, plastics, textiles, wood, food scraps, rubber. It also moves aluminum, iron, copper, silica, and trace metals distributed through products and packaging.

For a century, the industry’s job has been to manage that stream safely and put it somewhere. Landfilling takes the carbon out of the economy; under the disposal predicate, a filled cell is a closure and post-closure liability to be monitored for decades, not an asset in waiting.

Combustion converts it to heat, ash, and emissions. Recycling recovers the narrow fraction that can be sorted and leaves the rest to the first two. All three are disposal-predicate activities, and they can remain exactly that: the manufacturing predicate does not convert or upgrade them, it routes committed material past them before it ever reaches them.

A different industry treats the same stream as manufacturing feedstock. Advanced circular manufacturing facilities are classified as manufacturing under NAICS 31-33, not waste management: production plants that source raw material from the municipal stream the way a mill sources ore. They are not an upgrade path for disposal or recycling assets; the manufacturer finances, owns, and operates them end-to-end. Non-combustion conversion processes break down incoming material into its elemental constituents and then synthesize manufactured outputs from those constituents: synthetic graphite, graphene compounds, recovered minerals, and ultrapure water. No flame, no incineration. This is not waste-to-energy, and it is not recycling as the industry knows it: nothing is pre-sorted, and no input molecule survives to be reprocessed. Revenue at these facilities comes from materials sold into the same supply chains that currently depend on imports, with process energy used internally rather than sold.

That distinction is about to become a regulatory question: the predicate. Material bound for a disposal cell is regulated as waste, and a century of rules assume that is where the stream ends. Material committed under a long-term supply agreement to a manufacturing facility is contracted feedstock; ownership of and liability for it transfer to the manufacturer at delivery, and it does not enter a disposal facility at all. Tonnage committed down the manufacturing predicate is redirected from disposal in its entirety, and the process converts approximately 100 percent of input into manufactured outputs with near-zero residual. For states and communities that have spent two decades setting landfill-reduction targets, the manufacturing predicate is how those numbers finally move.

What True Circularity Looks Like
Any operator reading this has earned the right to be skeptical, because the industry has heard conversion promises before. The fair questions are commercial ones. Who bears the capital cost? What happens if the technology underperforms? And if this material is suddenly valuable, who captures that value?

Circularity answers them structurally. A circular system is one where the material loop and the value loop both close: materials return to productive use as manufactured products, and value returns to the place the material came from. That standard gives any community a usable test. In a genuinely circular arrangement, the facility is financed at the project level by the manufacturer under a build-own-operate model, the municipality funds nothing and carries no technology risk, and the relationship runs through a long-term supply agreement in which the community commits its material stream and the manufacturer commits to take it for decades.

The value loop is the part that separates circularity from marketing. In a closed loop, the community that supplies the carbon is paid a royalty on the graphite and other materials manufactured from its feedstock, running for the life of the agreement. A century of economics ran the other way: communities paid, every year and forever, to make the same material disappear. Circularity that does not close the value loop is a supply contract wearing a costume.

Structures like this have moved from paper to deployment already. The first of a dozen planned facilities is being deployed now, expected to begin manufacturing circular materials in late 2027. For readers trying to gauge whether the category is real, an executed long-term contract is the evidence that matters.

What this Means for Operators Over the Next Decade
None of this changes what happens at the tipping floor tomorrow morning. Landfills and transfer stations will run next year the way they ran last year. But the ground under long-term planning assumptions is shifting, and the November decision in Beijing will accelerate the shift regardless of which way it goes. Four planning implications deserve attention now.

First, long-range disposal and recycling contracts need a second read. A municipality signing a 20-year commitment today is betting on what its material stream will be worth in 2046. For most of industry history, that was a safe bet because the answer was always the same: less than nothing. A functioning domestic market for manufactured materials from municipal feedstock changes that bet.

Second, municipalities should ask conversion vendors sharper questions, and the industry should welcome that pressure. Who finances the facility? What does the community pay, what is the community paid, and when? What happens to nonconforming material? What third party has evaluated the process? Does value return to the community that supplies the material, or stop with the vendor? A commercial structure that can answer those questions is worth a conversation.

Third, the hauling business survives the shift by changing cargo. As communities commit their streams to manufacturers, the waste hauler becomes a feedstock hauler: same trucks, same routes, a different destination, and a load that is manufacturing feedstock rather than material to be buried. A decade from now, the fleets still growing will be the ones whose routes already end at a production plant. The critical materials conversation is coming to this industry whether the industry joins it or not; federal policy is now explicitly organized around domestic supply of graphite and rare earths. Municipal leaders who understand that connection will be in the room when infrastructure decisions get made, alongside the manufacturers already building for it.

Fourth, the predicate question is headed for regulators. Every state that set landfill-reduction targets will eventually be asked whether tonnage committed to a manufacturing facility should still be counted, permitted, and taxed as disposal. Communities that want their committed streams recognized under a manufacturing predicate should start that conversation with their agencies now, and the manufacturers will be beside them when they do.

Upcoming Shift
The molecules moving through American collection routes do not know that they are classified as waste. They are carbon, metals, and minerals, the same constituents the country currently ships in from overseas. In November, China will remind everyone how uncomfortable that arrangement is. The manufacturers building the domestic alternative, and the communities supplying them, should be ready to answer. | WA

Tyler Wood, VP of Circularity, Carbotura. Tyler leads the company’s work with municipalities and economic development offices across the U.S., helping communities evaluate circular alternatives to landfill and combustion infrastructure. He has spoken on circularity and materials at NYC Climate Week, the Wall Street Green Summit, and Smart Cities Expo Miami. Tyler can be reached at (617) 899-6745.
Carbotura Inc. is an Advanced Circular Manufacturing company headquartered in Naples, FL. Its first facility is now in deployment, with commercial operations targeted for late 2027. For more information, visit .

Sources
U.S. Geological Survey, Mineral Commodity Summaries 2026: Graphite. pubs.usgs.gov/periodicals/mcs2026/mcs2026-graphite.pdf
U.S. Dept. of Commerce, Final Determinations: Active Anode Material from China, Federal Register, Feb. 17, 2026. federalregister.gov/documents/2026/02/17/2026-02999
USGS 2026 rare earth import data, via Visual Capitalist, Feb. 2026. visualcapitalist.com/ranked-u-s-import-reliance-on-critical-minerals/
China MOFCOM Announcement No. 70 (2025), suspension of graphite export controls to Nov. 2026, analysis by Herbert Smith Freehills Kramer. hsfkramer.com/notes/mining/2025-posts/china-suspends-export-controls-on-lithium-batteries-and-artificial-graphite-anode-materials