What Is ENM (Excavated Natural Material) and When Can You Reuse Soil?
If you're planning excavation, earthworks, or demolition in NSW, you’ve likely heard of ENM — Excavated Natural Material. But what exactly is it, and when can you legally reuse soil without paying costly disposal fees or breaking EPA rules?
At Confluence Environmental, we help contractors, developers, and property owners understand their responsibilities — and unlock cost savings through compliant soil reuse. Here’s what you need to know.
What Is ENM?
ENM (Excavated Natural Material) is a classification under the NSW Resource Recovery Exemptions that allows certain types of virgin soil to be legally reused without being classified as waste — provided specific conditions are met.
According to the NSW EPA, ENM is:
"Naturally occurring rock and soil (including materials such as sandstone, shale, clay and soil) that has been excavated from the ground and contains no other waste materials."
What ENM Is Not:
Soil mixed with demolition waste or fill
Soil contaminated with asbestos, chemicals, hydrocarbons or heavy metals
Soil altered by industrial activity, acid sulfate conditions or imported materials
Soil from unknown or suspect sources
When Can You Reuse ENM?
You can reuse ENM on-site or off-site if:
It meets the EPA’s ENM definition and exemption conditions
It is assessed by a suitably qualified consultant (such as a contaminated land specialist)
It is accompanied by documentation proving compliance
It is used for a beneficial purpose — such as fill, landscaping, or site levelling
If these criteria aren’t met, the material may be considered waste — requiring licensed disposal, tracking, and higher costs.
What Are the ENM Conditions?
To be reused under the ENM Resource Recovery Exemption, your material must:
Be naturally occurring
Be uncontaminated
Not contain any man-made waste (e.g. bricks, concrete, plastics, wood)
Be sampled and tested according to a proper sampling plan
Be fit for purpose (i.e. used in a way that doesn’t cause harm to people or the environment)
You must also comply with record-keeping obligations, including:
Source site details
Testing results and reports
Volume and destination of material reused
Failure to meet these conditions may result in EPA penalties or notices — even if the material “looks clean.”
Benefits of ENM Classification
Avoid landfill and tipping fees
Reduce truck movements and emissions
Speed up project timelines
Support sustainable construction
Comply with NSW EPA regulations
Proper ENM classification can save thousands on disposal while supporting circular economy practices.
How We Help at Confluence Environmental
We provide fast, compliant ENM assessments to help you classify and reuse soil with confidence. Our services include:
✔ Site investigation and soil sampling
✔ Laboratory analysis (including metals, asbestos, hydrocarbons, pH/EC)
✔ ENM eligibility assessment
✔ Reporting that meets EPA requirements
✔ Expert advice on reuse options
Whether you’re dealing with in-situ material or stockpiled soil, we’ll help you meet your obligations and minimise waste costs.
Need ENM Testing or Advice?
Contact Confluence Environmental for reliable, cost-effective ENM assessments across the Central Coast, Newcastle, Sydney, and NSW.
Book an assessment or call 0493 042 642 to speak with an environmental consultant today.
Final Thoughts
Not all soil is waste. If your excavated material is clean and natural, it may qualify as ENM — allowing you to reuse it legally and affordably. But you must follow the rules, and testing is essential.
At Confluence Environmental, we help clients navigate ENM regulations and make smarter, more sustainable decisions about soil reuse.