Working Collaboratively with Industry Sectors

EPA's Smart Sectors program pursues opportunities to collaborate with industry trade associations, individual companies, and other interested parties to improve environmental outcomes. Below are some examples of the program's work.

Providing Regulatory Clarity on the use of Biomass Residuals as Fuel in the Cement Industry

The cement industry is working to reduce its environmental footprint through a lifecycle approach that involves multiple actions across the full cement value chain, from the manufacture of clinker, cement, and concrete, to the end-of-life management of these products.  Key strategies the industry is exploring towards this objective include:

• Material Substitution:  Increasing the use of recycled and alternative materials.
• Use of Alternative Fuels: Increasing the use of biogenic fuels (including biomass residuals).
• Advanced Technologies: Introducing advanced production and control technologies.

As the cement industry looks to expand its use of biomass residuals (such as agricultural residuals and residues from logging and wood processing operations), many companies were concerned that biomass residuals could be considered solid wastes.  If so, this would require cement kilns burning them to be permitted as commercial or industrial solid waste incinerators. Although EPA’s Non-Hazardous Secondary Materials (NHSM) regulations define which types of biomass are considered to be wastes, some uncertainty remained in the minds of corporate decision-makers in the cement industry. 

To address this uncertainty, Smart Sectors coordinated with EPA’s Office of Land and Emergency Management and ACA to clarify how biomass residuals are treated under EPA’s NHSM regulations. As part of this effort, Smart Sectors facilitated a meeting between OLEM staff, ACA representatives, and ACA member companies where industry representatives offered examples of where clarification from EPA on the use of biomass residuals would be helpful to ensure that companies are able to pursue opportunities to use such material as fuel while correctly adhering to EPA’s regulatory requirements. 

In September 2024, EPA issued a Fact Sheet on Clean Cellulosic Biomass and Non-Hazardous Secondary Materials Determinations to help generators and combustors of clean cellulosic biomass better understand how to make Non-Hazardous Secondary Materials determinations for this fuel source. The fact sheet defined “clean cellulosic biomass” and clarified that biomass residuals that qualify as such are considered equivalent to traditional fuels unless they have been discarded, and that they are only considered discarded when they have been mixed with solid waste (e.g., municipal solid waste or construction and demolition debris) or otherwise disposed of (e.g., buried in a landfill).

To further support the cement industry’s efforts to increase the use of biomass residuals as fuel, Smart Sectors hosted a forum with the cement industry and the solid waste management industry on June 18, 2025, to highlight the release of the EPA fact sheet and the regulatory clarifications it provides. The forum also initiated a multi-stakeholder dialogue to explore how the cement industry can work with the solid waste management industry to achieve its goal of increasing the use of biomass fuels. The event featured speakers from EPA, a cement company that uses biomass fuels at its facility, Idaho National Labs, and the National Waste and Recycling Association, and was attended by representatives of over 60% of ACA member companies. 

Read more about the Smart Sectors Program’s work with the cement sector and concrete sector.