Section 45Q treats carbon dioxide sold into a beverage plant as a qualifying use of that CO₂. Puro.earth and Isometric would both decline the same ton as a carbon removal. Nothing about the molecule changes between those two answers. The question changes, and a capture project that has not sorted out which question it is answering tends to find out after carbon negative is already in a slide deck.
The two systems here are the federal tax code and the voluntary carbon registries. They were built for different purposes, they run on different evidence, and they reach opposite conclusions about biogenic CO₂ that ends up in a can. Both conclusions are correct.
Utilization Is a Defined Term
Section 45Q(f)(5)(A) defines utilization of a captured carbon oxide three ways. Fixation through photosynthesis or chemosynthesis. Chemical conversion into a material or compound in which the carbon oxide is securely stored. Or use for any other purpose for which a commercial market exists. Beverage carbonation lands in the third one.
The IRS reads commercial market broadly. It means a market in which a product, process, or service that uses carbon oxide is sold or transacted on commercial terms, and the taxpayer attaches a statement to the credit claim substantiating that the market exists. Carbonated beverages clear that bar without an argument.
The rate question closed in 2025. The One Big Beautiful Bill Act, signed July 4, 2025, equalized 45Q so utilization and enhanced oil recovery earn the same per-ton credit as dedicated geologic storage. The premium the tax code used to pay for burying a ton is gone. A developer working from pre-2025 material is modeling a spread that no longer exists.
The Credit Is Sized by a Lifecycle Report
Qualifying for utilization and getting paid on the captured volume are separate steps. Notice 2024-60, issued July 24, 2024, sets the procedure. A taxpayer prepares a lifecycle analysis report for each qualified facility, conforming to ISO 14040:2006 and ISO 14044:2006 and following the Department of Energy's National Energy Technology Laboratory guidance on CO₂ utilization lifecycle analysis along with its 45Q addendum. The report goes to the IRS and DOE for review.
It has to show a net reduction in CO₂ equivalent against a comparison system. An approved LCA covers the calendar year it was submitted and the two calendar years after that, and then the taxpayer files for re-approval.
For beverage CO₂ the reduction comes out of the comparison system rather than the molecule. Merchant CO₂ in the United States is dominated by ammonia and ethanol byproduct streams, both fossil in origin. A biogenic ton delivered into that market displaces a fossil ton that would otherwise have been produced and sold. Displacement is the number an LCA can defend.
Registries Ask Whether the Carbon Stays Put
CO₂ dissolved in a beverage leaves the system when somebody opens the can. That ends the removal conversation, because a removal has to keep carbon out of the atmosphere on a durability horizon measured in centuries.
Removal-only registries decline these projects outright. Puro.earth and Isometric are both structured around durable storage and neither has a path for CO₂ that gets consumed. Verra's carbon capture and storage methodology, VM0049, was approved June 27, 2024, and is written around storage. The module for CO₂ captured from bioproducts sits under it and is still in feasibility assessment, not approved.
The framework that fits is avoidance. The CDM methodology AM0027 established the reasoning. A biogenic ton delivered to a market currently served by fossil CO₂ avoids the fossil production. Verra, Gold Standard, ACR, and the Climate Action Reserve all run avoidance and reduction programs where that argument is at home. Walking into a removal registry with a utilization project costs credibility in the first meeting, and that is not a thing you get back.
Biogenic Origin Has to Be Measured
Both paths depend on proving the carbon is biogenic, and that is a lab result rather than a contract. ASTM D6866 and ISO 13833 determine the biogenic fraction by radiocarbon. Fossil carbon is old enough that its carbon-14 has decayed away, so the isotope ratio separates a digester stream from a refinery stream regardless of what the feedstock agreement says.
Buyers should know what that result actually does for their own reporting. The GHG Protocol Corporate Standard requires biogenic CO₂ to be reported as a memo item, held separate from Scopes 1, 2 and 3. A beverage producer switching to biogenic CO₂ moves the quantity outside its scope inventory. The quantity does not come off a scope total, and a sustainability report claiming a scope reduction on this basis will not survive assurance.
Decide Who Owns the Ton Before Construction
45Q goes to one taxpayer, the owner of the capture equipment, who then has to physically or contractually ensure the disposal, injection, or utilization. On an RNG site that is rarely the same party as the gas producer earning RINs on the methane. The gas supply agreement and the credit ownership terms live in separate documents and get signed by people with different incentives.
Settle it at term sheet. A capture project financed on a 45Q stream the host facility believes it owns is a dispute waiting on a tax filing.
What This Means for a Project
Pick the system before anyone writes carbon negative. If the answer is 45Q, the deliverable is a lifecycle report built to ISO 14040 and 14044 that survives DOE review, and the entry threshold is real: a facility that does not generate electricity has to capture at least 12,500 metric tons in the tax year to qualify at all. An RNG plant putting 1,000 MMBtu a day into the pipeline vents roughly 38 tons a day, which is about 13,900 a year and clears the floor by eleven percent. A dairy digester at 100 MMBtu misses it by a factor of nine.
If the answer is a registry, the deliverable is an avoidance methodology and a radiocarbon result, and the word removal never appears in the file.
Both paths rest on the same commercial fact. The market 45Q makes you substantiate is a market with a specification attached to it. Beverage grade under the ISBT guidelines means 99.9 percent minimum purity and roughly twenty impurity limits, and CO₂ that misses any one of them has no buyer in food and beverage. Patent-pending cryogenic purification is what closes that gap on a biogenic stream. The carbon accounting is only worth arguing about once the product can be sold.
