Pyrolysis is Reductive Thermal Processing.

The 3R Recycle-Reuse-Reduce is a zero emission low temperature carbonization (pyrolysis) – reductive thermal decomposition processing. The 3R slow pyrolysis process is based on a horizontally arranged indirectly heated rotary kiln designed for reductive thermal decomposition of plant biomass at 450 °C (842 °F) or animal origin biomasses up to 850 °C (1562 °F) material core temperature ranges in vacuum (absence of oxygen).

The system works with zero emission, comprehensive recycling and reuse of all process materials and gases. The target of the 3R Zero Emission Pyrolysis Process is the added value upgrading/valorisation of agro/food industrial organic by-products into safe and high value soil amendment and nutrition products.

Pyrolysis of biomass substances produces solid residue rich in carbon content “biochar” and separated volatile crude pyrolysis gas which may be condensed into liquid crude oil and non condensable gases. After catalytic conversion of crude pyrolysis liquid products, refiner bio-oil produced. The 3R pyrolysis is safer, better, faster, more economical and environmental friendly than any other solutions.

The 3R system is also integrated into the novel agro biotechnological – solid state fermentation and formulation, and syngas/bio-oil refinery processing units.

The 3R is an engineered full scale industrial design, that development has been completed by the end of 2018.

The “3R” Recycle–Reduce-Reuse Zero Emission Carbon Refinery and Phosphorus Recovery processing is a mimic of the Nature that emits no any waste products that pollutes the environment or disrupts the climate, in which process all and any materials and energy are recycled and reused into useful products.

The Nature cannot afford to waste materials and/or waste of energy, while it always finds the most efficient material and energy recycling, recovery and reuse conversion pattern during the ever ongoing bio-geo-chemical cycles. In order to mimic the Nature, the 3R bio-geo-chemical process - where it is possible, necessary and/or advantageous - coherently integrates the carbon, phosphorus and nitrogen related cycles, such as:

  1. Carbon Recycling and Refining, thermal processing by carbonization for recycling of carbon for wide range of natural and carbon negative product applications.
  2. Carbon Bio-formulation, biotech formulation of carbon for efficient bio and plant availability of NPK nutrient uptake process support.
  3. Phosphorus recovery from animal by products, including NPK-C and micronutrient formulations.
  4. Carbon Bio-energy, chemical processing of pyrolysis gases and refined oils for liquid fuel bio-energy production.

The "3R" Recycle-Reduce-Reuse technology is a circular economical system, where all martial streams are added value recycled and reused, that is the “3R zero emission “ concept and converted to fully safe products, such as the “ABC” Animal Bone Char and the formulated ABC titled  as PROTECTOR.

The 3R is an industrial case to demonstrate the full implementation of the circular economy, where critical elements are equally important, such as

  1. economical processing and operations resulting economical and hgh quality products,
  2. having high energy efficiency,
  3. ecological applications,
  4. based on comprehensive environmental/climate protection aspects, and
  5. market demands under market competitive conditions.

All these aspects are on the same page already from the beginning. The 3R is utilization of unexploited biomass resources, high efficient conversion of organic waste streams into an high added value products, while providing strong job creation opportunities for the interests and benefits of SMEs. As the 3R system is highly flexible, it can be tailor made formulated country by country, region by region, that flexibility is highly important to meet the local technical, environmental, climate, economical and social conditions in the different areas of the world on global level. The 3R is a resource efficient, low carbon and improved industrial production of FOOD with better utilization of resources that is combined with improved WATER management.

Generally the 3R is using un-exploited biomass by-product streams from the agricultural and food industries for added value processing. In all cases the basic sustainability criteria for 3R feeds, that these input material streams do not compete with human food, animal feed and plant nutrition supply. The inputs are always low grade non food & agri by-products and not from primer or secondary agricultural land use that are related to food production. The high feed flexibility provides high added value and wide range of different types of output products together with wide range of market demanded application possibilities targeted in the rapidly developing natural soil fertilization agro markets, green energy and environmental adsorbent business.

Biochar/pyrolysis material is plant and/or animal bone biomass origin stabile carbon carboniferous and legally labelled product with functionality of solid organic fertilizer and/or solid organo-mineral fertilizer and/or organic soil improver. Biochar/pyrolysis material is a chemically modified substance, which – depending on the highly variable feed materials - may have either variable composition and complex reaction products (REACH-UVCB) or well defined mono and multiconstituent character. All biochar/pyrolysis material products in the EU are characterized by:

  1. Mandatory EU and MS Government Authority permitted for import, manufacturing, placing on the market and application above 1 t/year capacity,
  2. REACH certified above 1 t/year capacity import, manufacturing, placing on the market and application,
  3. labeled and full value chain safe product,
  4. having Extended Producer Responsibly product guarantees,
  5. the input material made from is sustainable sourced, e.g. not competing with human food, animal feed and plant nutrition supply, not from primarily and secondarily land use and having environmentally sustainable logistics, while meets the EU Circular Economy incentive relevant sections.

In this context the safe biochar/pyrolysis product equally importantly meets all the four elemental criteria and it is:

  1. commonly used for specific purposes with functionality of natural solid organic fertilizer and/or solid organo-mineral fertilizer and/or organic soil improver; and
  2. there is an existing market and demand for safe biochar; and
  3. the use is lawful, fulfils the technical requirements for the specific purposes and meets all the exisitng legislation and standards applicable to biochar product; and d) the use will not lead to overall adverse environmental and/or human health impacts.

The high mineral content animal bone based biochar/pyrolysis material, ABC (Animal Bone Char) recovered organic P/Ca fertilizer at 100-600 kg/ha dose rate and growing media in the horticultural sector. The high carbon content plant based biochar/pyrolysis material is soil improver usually at approx. 5000-20000 kg/ha dose rate for water/nutrient retention and carbon sequestration applications, but providing no fertilizer effects with economical importance. For both biochar/pyrolysis material types there is a long list of additional beneficial effects. Legal notice: Biochar/pyrolysis material soil applications are irreversible; therefore commercial key players such as industrial producers, market distributors for placing product on the market and users having high legal, economical and social responsibilities with joint and several liability for their activities. In this context, beyond the mandatory EU/MS permits, operational and use licenses the preventive and precautionary principle (connected to international, EU and Member State legislations) and its instruments are to be fully implemented as well.

Plant based biochar/pyrolysis material: this type of biochar is made of plant material residuals and characterized by high carbon content, usually at 90% level, and used as soil improver with 5 – 20 t/ha doses, in average 10 t/ha in wide range of agricultural cultivations. Plant based biochar/pyrolysis material does not have fertilizer direct value with economical importance, but rather having water and nutrient retention effects, sequester carbon in the soil; improving crop yields, nutrient cycling and immobilize trace metals.

No, biochar/pyrolysis material is not a new product. In modern age since 1870, the time of the technology revolution, many carbon processing technologies and many different types of carbon products developed, produced and applied in large industrial scale, especially related to the WWI., WWII. and past decades of activated carbon operations. The carbon processing technologies and carbon products are the most extensively scientific/technical researched and technological developed past 130 years. Majority of the carbon processing technologies and carbon products developed for energetic and activated carbon adsorbent applications. Some of them have been successful, others are not.

However, the knowledge based environmental norms and standards have been significantly upgraded past 20 years that have been impacting the performance and safety requirements of the carbon processing technologies and its products as well. Therefore, new generation safe and efficient pyrolysis technology and product system need to be developed in modern age.

Since 1980’s Edward Someus is specialized for pyrolysis and carbon processing technologies (“3R” zero emission pyrolysis) and different types of biochar products, while since 2002 primarily focused on a new generation ABC Animal Bone Char S&T and industrial engineering under the European Commission RTD programmes, that development has successfully reached large industrial scale-up capacity by the end of 2018.


Plant based biochar/pyrolysis material: this type of biochar/pyrolysis material is made of plant material residuals and characterized by high carbon content, usually at 90% level, and used as soil improver with 5 – 20 t/ha doses, in average 10 t/ha in wide range of agricultural cultivations. Plant based biochar does not have fertilizer direct value with economical importance, but rather having water and nutrient retention effects, sequester carbon in the soil; improving crop yields, nutrient cycling and immobilize trace metals.

ABC Animal Bone Char: this type of pyrolysis material is made of food grade animal bones and characterized by as high as 92% mineral carbon and 8% carbon content only. This is a full value recovered organic Phosphorus fertilizer with high calcium and content.

Animal Bone Char "ABC" is a recovered organic P-fertiliser, made from animal bone grist, having high nutrient density (30% P2 O5) and pure P-content. The rendering industrial origin food grade category animal bone grist processed ABC Animal Bone bioChar is a nutrient dense (30% P2O5) organic fertilizer with as high as 92% pure calcium phosphate and 8% carbon content only. Therefore the ABC product functionality is fertilizer, soil improver, growing medium and/or fertilising product blend, with usual doses between 100 kg/ha to 600 kg/ha.

  1. biochar is not fine ground charcoal, not a labile carbon, not hydrochar, not activated carbon, not torrefraction processed energetic char and/or
  2. having no biochar specific and mandatory EU and MS Authority permits for import, manufacturing, placing on the market and application above 1 t/year capacity, and/or
  3. having no biochar specific and mandatory REACH certification above 1 t/year capacity import, manufacturing, placing on the market and application, and/or
  4. having no labelled Extended Producer Responsibility certificate, and/or
  5. the output biochar product economical value and free market valorisation is not based on common market demands and commercialization process, e.g. biochar product valorization may not be based on grants and subsidies, and/or
  6. does not meet quality to be irrevocably put into open ecological soil environment, and/or
  7. made from input feed material, that is not sustainable, and/or
  8. made for renewable biofuel for energy (gasification, torrefraction, hydrothermal carbonization chars), whereas biochar/energetic carbons are
    1. two very different products with
    2. two very different product functionalities and product criteria requirements,
    3. two very different production scenarios and processing conditions,
    4. two very different product safety aspects,
    5. two very different accredited product quality laboratory assessments,
    6. two very different EU/MS Authority permits, permit procedures and legal environments that are to be applied in two different site installations,
    7. two very different application areas, and
    8. two very different markets and users with very different product functionality demands.

Remarks on waste derived carbon products: There are several basic research projects to process waste materials into different carbon type products.. Based on my 30 years of biochar S&T experience and biochar specialization with long term core competence, focused on biochar/pyrolysis technology and product development, I have rather difficult to believe that most waste-to-biochar projects, could meet legal, technical, economical and market demand user criteria for biochar products under market competitive conditions.

YES, in Europe there is mandatory requirement to get permit from the MS Authorities according to EU regulations to install/operate a pyrolysis plant for commercial production of all and any types of biochar and usually ten advising Authorities involved in this mandatory permit process. The REACH regulation is also defining mandatory certificate for import, placing on the market and manufacturing of commercial biochar above 1 t/y capacity.

YES, there is mandatory requirement to get permit from the MS Authorities to commercialize and commercial use biochar/pyrolysis material (both plant based and animal bone char) in agriculture in any production ranges in the EU, which is having three mandatory elements:

  1. Mandatory MS Authority permit to commercial use biochar/pyrolysis material, valid in the applicant MS only with possibility for Mutual Recognition (Reg. EC 764/2008) in EU28. As soon as the revision of the EC 2003/2003 Fertilizer Regulation will include biochar/pyrolysis material (as expected in 2018/2019), than this EU regulation will be valid in all EU28 Member States (EC Fertiliser). In case the MS defined stricter standard than the EC Fertiliser, than this upgraded standard will be valid and applied. Once adopted, it will be directly applicable, without the need for transposition into national law, after a transitional period allowing companies and public authorities to prepare for the new rules.
  2. “REACH” certification (Registration, Evaluation, Authorisation and Restriction of Chemicals[1]) is mandatory for import, manufacturing, placing on the market and use of biochar above 1 t/y capacity (1 t/y is valid from 2018 but in 2016 the mandatory certification limit is already above 10 t/y). “REACH” certification is a complex eco toxicological investigation measured according to GLP (Good Laboratory Practice) and is highly challenging both technically and from cost point of view as well.
  3. “EPR” Extended Producer Responsibility certificate.

Related to the Circular Economy Package:

The Fertilisers Regulation revision aims at establishing a regulatory framework enabling production of fertilisers from recovered bio-wastes and other secondary raw materials. This would boost domestic sourcing of plant nutrients which are essential for a sustainable European agriculture, including the critical raw material phosphorus. [1]

Related to the Internal Market Strategy:

The initiative supports the aim to create a deeper and fairer internal market with a strengthened industrial base, by removing existing barriers to free movement of certain innovative fertilisers and facilitating the market surveillance by Member States. The Fertilisers Regulation revision aims at addressing a well-known barrier to free movement on the internal market. [2]


[1] Roadmap to the Revision of the Fertilisers Regulation (EC) No 2003/2003, http://ec.europa.eu/smart-regulation/roadmaps/docs/2012_grow_001_fertili...

[2] Roadmap to the Revision of the Fertilisers Regulation (EC) No 2003/2003, http://ec.europa.eu/smart-regulation/roadmaps/docs/2012_grow_001_fertili...

The proposal, COM(2016)157[1], contains several elements that will help create a level playing field for all fertilising products, while at the same time ensure high safety and environmental protection standards. The proposal:

  1. provides rules for free movement of all CE marked fertilising products across the EU: The current rules cover only inorganic fertilisers and agronomic additives. The proposal will allow all fertilising products, including those derived from recycled bio-waste and nutrients, to benefit of CE-marking that ensures free movement in the single market.
  2. updates the current requirements for inorganic CE marked fertilisers;
  3. maintains optional harmonisation – a manufacturer who does not wish to CE-mark the product and have unrestricted access to the entire EU single market can choose to opt for compliance with national rules instead – in line with the subsidiary principle.
  4. introduces new harmonised requirements for all CE marked fertilising products regarding
    • quality – such as minimum nutrient content, organic matter content, neutralizing values that are specific to each category of fertilising products;
    • safety – such as maximum limits for heavy metals, including cadmium, for organic contaminants, for microbial contaminants and for impurities specific to each category of fertilising products;
    • labelling – such as the actual nutrients content and their forms which will allow the farmers to modulate the use of the fertilisers depending on the plant needs;
  5. modernises the declaration of conformity and conformity assessment procedures manufacturers of fertilising products have to comply with if they want to trade their products in the EU single market;
  6. delineates the borderlines between fertilising products and Plant Protection Products, to avoid overlap between plant bio-stimulants and plant growth regulators;
  7. enables derived animal-by-products to move freely on the single market as fertilising products after the end point in the manufacturing chain would be laid down in the Animal by-products Regulation[2] [3];
  8. includes recovery rules for bio-waste transformed into composts and digestates. If these products are incorporated in CE marked fertilisers, they are no longer considered to be waste within the meaning of the Waste Framework Directive[4]. This allows waste-derived products to freely circulate in the EU.

STRUBIAS TWG is a technical working group for the development of possible process and product criteria for struvite, biochar and ash based products for use in fertilising products.

The Commission services have selected 31 members[1] and 2 observers for STRUBIAS expert group on recovery rules for fertilising products. Edward Someus/Terra Humana Ltd. has been selected as a Member of the STUBIAS expert group.


The STRUBIAS DG GROW-JRC expert group is a sub-class of the Commission Working Group on fertilisers. It will be operational until the completion of its work which is foreseen to be at the end of 2018. Based on the experts’ inputs, the Commission will prepare a report for a future amendment (Adaptation to Technical Progress) to the proposal for a revised Fertiliser Regulation (COM (2016) 157). This is currently under negotiations with the Council and the EU Parliament.

  1. The initiative will mainly affect those producers of innovative fertilisers produced from organic or secondary raw materials in line with the circular economy model, who will be able to reach a critical mass through radically facilitated access to the internal market. Such producers will benefit from the initiative in particular in those Member States which are not providing a sufficiently large home market for new types of fertilisers.
  2. Private and public recovery operators
  3. National authorities: decreased workload when national registration or authorisation systems for fertilisers are fully or partially replaced by EU-wide control mechanisms
  4. Farmers and other fertiliser users: increase in the product variety
  5. General public: will be better protected from contamination of soil, water and food. [1]

[1] Roadmap to the Revision of the Fertilisers Regulation (EC) No 2003/2003, http://ec.europa.eu/smart-regulation/roadmaps/docs/2012_grow_001_fertili...

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Contact information

Terra Humana Ltd.

(Edward Someus)





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