Exhibit 21

Subsidiaries

1.       Headwaters acquired a 100% interest in Hydrocarbon Technologies, Inc.
         by agreements entered into in May 2001and that closed in August 2001.
         Headwaters formed Headwaters Technology Innovation Group, Inc. ("HTI")
         a Utah corporation in April 2003. Hydrocarbon Technologies, Inc. merged
         with HTI in October 2003, with HTI as the surviving corporation. HTI's
         subsidiaries are:

         a.       Headwaters NanoKinetix, Inc., a Utah corporation;
         b.       Headwaters Clean Coal Corporation, a Utah corporation;
         c.       Hydrocarbon Technologies of Canada, Inc. ("HTC"), a Canadian
                  corporation located in the province of Alberta;
         d.       Hydrocarbon Technologies, Inc., a Utah corporation; and e. HTI
                  Chemical Sub, Inc. (f/k/a Chemsampco, Inc.), a New Jersey
                  corporation.

2.       Headwaters formed Covol Services Corporation, a Utah corporation, in
         September 2003.

3.       Headwaters is a 50% member in Environmental Technologies Group, LLC, a
         Utah limited liability company of which Headwaters serves as manager.

4.       Headwaters formed Global Climate Reserve Corporation, a Utah
         corporation, in January 2003.

5.       Headwaters formed American Construction Materials, Inc., a Utah
         corporation, in August 2003.

6.       Headwaters acquired a 100% interest in Industrial Services Group, Inc.
         ("ISG") by merger with Headwaters Oly Sub Corporation, a Delaware
         corporation, by agreements entered into in July 2002 and that closed in
         September 2002 with Headwaters Oly Sub Corporation d/b/a ISG ("ISG") as
         the surviving corporation. ISG's operating subsidiary is ISG Resources,
         Inc., a Utah corporation. The subsidiaries of ISG Resources, Inc. are:

         a.       ISG Canada Limited, a Canadian corporation located in the
                  Province of New Brunswick;
         b.       ISG Manufactured Products, Inc., a Utah corporation;
         c.       ISG Partner, Inc., a Utah corporation;
         d.       ISG Swift Crete, Inc., a Utah corporation;
         e.       Flexcrete Building Systems, L.C., a Utah limited liability
                  company (ISG Resources, Inc. is a 90% member);
         f.       Best Masonry & Tool Supply, Inc., a Texas corporation;
         g.       Don's Building Supply, L.P., a Texas limited partnership;
         h.       Lewis W. Osborne, Inc., a California corporation;
         i.       Magna Wall, Inc., a Texas corporation;
         j.       Palestine Concrete Tile Company, L.P., a Texas limited
                  partnership;
         k.       United Terrazzo Supply Co., Inc., a California corporation.

         The ownership of each direct subsidiary is 100%, except in the case of
Environmental Technologies Group, LLC, in which Headwaters owns a 50% interest.
The ownership of each indirect subsidiary is 100%, except in the case of
Flexcrete Building Systems, L.C., in which ISG Resources, Inc. owns a 90%
interest.