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A cement alternative is acceptable only when the authority having jurisdiction (AHJ)—usually your local building department—approves its proposed use under the code edition and amendments adopted for that project. A material specification, ASTM evaluation, or ICC-ES report can supply technical evidence, but none is a universal permit to install the material. Confirm the jurisdiction, code edition, project use, structural status, and the AHJ’s required evidence before ordering tests, writing the specification, or placing concrete.
What approval actually means
Building-code approval is an installation decision, not merely a statement that a cement substitute has been tested. The building official reviews the proposed material, the concrete mixture, the use and exposure, the supporting calculations and test data, and the conditions of the project. The official may accept the proposal under an alternative-material provision, require a recognized-agency evaluation report, request a site-specific review, or reject it if the evidence does not demonstrate equivalence.
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The 2024 International Residential Code (IRC) illustrates the model-code approach. Section R104.2.2.3 states: “An alternative material, design or method of construction shall comply with the intent of the provisions of this code.” The following alternative-material provisions address equivalency evidence, test scale, qualified testing, and submittals. They do not create nationwide approval. A jurisdiction must first adopt that code edition, and it may amend the language or use a different code and review process.
An evaluation report is therefore supporting evidence for the official’s decision. It can document what was evaluated, under which criteria, and with what limitations. It does not override local amendments, a project-specific engineering judgment, inspection requirements, or a written condition imposed by the AHJ.
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1. Identify the authority, code and project before evaluating the product
Start with the project location and the official who will issue the permit. Ask the building department, plans examiner, or the project’s code consultant for the information below in writing.
- The AHJ responsible for the permit and inspections.
- The adopted building-code edition and all local amendments, including the edition of any referenced concrete, fire, energy, or material standard.
- The permit type, occupancy or use, construction type, and whether the work is new construction, an addition, a repair, or a change of use.
- Whether the concrete is structural, nonstructural, architectural, paving, masonry-related, precast, shotcrete, or another application.
- The submittal route the department uses for an alternative material: ordinary plan review, an evaluation-report process, a site-specific approval, or a separate technical certification.
- Required professional seals, testing laboratories, inspections, field tests, fees, forms, and review stages.
Do not rely on a citation from another city, a previous project, or an unadopted model-code edition. The same product may be acceptable for a nonstructural slab in one jurisdiction and require a formal engineering review for a load-bearing frame in another. A project’s accepted mixture and source also matter; approval of a product family does not automatically approve every formulation manufactured under that name.
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2. Define what the proposed alternative replaces
The phrase cement alternative can describe materials that follow different code and testing paths. Write a precise description in the permit documents before searching for a standard or report.
Alternative cement as the binder
Some products replace portland cement or blended hydraulic cement as the principal binder. They may require water activation, a proprietary activator, special curing, or mixture controls. The applicable acceptance criterion must cover that chemistry and the proposed end use; a supplementary-cementitious-material standard may not be appropriate.
Alternative supplementary cementitious material (ASCM)
An ASCM is used alongside cement. ASTM C1709-22 provides a framework for evaluating ASCMs outside the listed specifications ASTM C618, C989/C989M, C1240, and C1866/C1866M. ASTM describes common specified SCMs as fly ash, slag cement, raw and calcined natural pozzolans (including calcined clays), silica fume, and ground-glass pozzolan. A C1709 evaluation is source-specific and must be related to the concrete mixture and intended use.
Specified blended cement or SCM
If the material is already covered by an applicable ASTM material specification, the submittal may follow that specification’s certification and quality-control provisions. Confirm that the exact product, manufacturing source, and grade are represented by the documentation. A specification listing alone does not resolve project-specific durability, fire, structural, or local inspection requirements.
Admixture, activation system or other component
An admixture or activator is a separate approval question from the binder. Document its dosage, compatibility, storage, batching, quality control, and effects on setting, strength development, durability, and job-site procedures. Ask the AHJ which standard or evaluation route it expects rather than treating the component as part of a generic cement approval.
3. Ask the AHJ what evidence it will accept before testing
Contact the official and the licensed design professional before commissioning laboratory work. Provide a short project description and the exact proposed material, then ask for written answers to these questions:
- Which alternative-material provision or local acceptance procedure will govern?
- Will the department accept a current evaluation report, and from which evaluating body?
- What performance criteria must be demonstrated for this use, exposure and construction type?
- Which laboratory qualifications and accreditation will be accepted?
- What test scale and concrete-mixture proportions are required?
- Must a registered design professional prepare or seal the equivalency report, calculations or specifications?
- What inspections, batch records, sampling, field-cured cylinders, maturity measurements or other quality-control checks will be required?
- Will the approval be project-specific, limited to a product source, or usable on later projects?
The 2024 IRC alternative-material provisions say equivalency tests should use a scale sufficient to predict performance in the end-use configuration and should be performed by a party acceptable to the building official. The official can require submittals prepared and stamped by a registered design professional. Agreeing on these details first prevents paying for tests that the department will not recognize.
4. Assemble a product-specific evidence package
Request a complete package from the manufacturer and have the design professional map each item to the AHJ’s checklist. At minimum, obtain:
- Exact product name, formulation, manufacturer, manufacturing plant or source, lot controls, and revision date.
- Intended applications, prohibited uses, exposure limits, curing requirements, activation instructions, and installation controls.
- The applicable ASTM specification or acceptance criterion, including the edition and scope.
- Any current evaluation report, report number, supplements, conditions of use, and expiration or revision status.
- Laboratory test reports identifying the tested source, mixture proportions, specimen size, curing regime, test method, results, and acceptance criteria.
- Concrete mixture designs, expected strength-age relationships, setting behavior, temperature limits, water demand, shrinkage or expansion information, and compatibility data for admixtures and aggregates.
- Durability and fire-performance evidence appropriate to the exposure and construction type.
- Quality-control, batching, storage, sampling, acceptance-testing and corrective-action procedures.
- Engineering calculations, drawings, specifications and professional seals required by the AHJ.
An ICC-ES Evaluation Service Report (ESR), when applicable, describes the evaluation findings, the code provisions used, product identification, installation guidelines, and conditions of use. ICC-ES also offers optional regional supplements that can address additional jurisdiction-specific provisions. Read every condition and limitation: an ESR is evidence for review, not an automatic authorization for your installation.
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5. Understand what ASTM C1709-22 can and cannot establish
ASTM C1709-22 is specifically concerned with evaluating alternative supplementary cementitious materials outside the listed ASTM specifications. It is not a blanket method for every alternative cement, activator, admixture, or binder technology.
The guide’s scope matters in three ways:
- Each specific material source must be evaluated separately. Results for one plant, feedstock, or formulation cannot simply be transferred to another source.
- The evaluation should be tailored to the end use and the test mixtures that represent the project. Preconstruction testing is commonly used to check performance in specific concrete mixtures.
- Following the guide does not establish conformance to ASTM C618, C989/C989M, C1240, or C1866/C1866M, and it does not evaluate every possible performance criterion.
Ask the laboratory and design professional to identify which criteria are covered and which remain outside the test program. For a structural or exposed application, the project may need additional evidence for strength development, durability mechanisms, fire resistance, dimensional stability, compatibility, or other requirements in the adopted code and referenced standards.
6. Check whether an ICC-ES route or AC529 applies
ICC-ES reports
An ICC-ES report can be useful when its scope matches the exact product, source, mixture or installation and the report addresses the code provisions adopted by the jurisdiction. Verify the report’s current status, product identification, conditions of use, required inspections, and any regional supplement. Give the report to the AHJ and ask whether it will be accepted for this permit; do not infer acceptance from a report issued for a different use or location.
AC529 for low-carbon alternative cements
ICC-ES announced AC529 in 2022 as acceptance criteria for low-carbon alternative cements activated by water or by a proprietary manufacturer-supplied activator. The current ICC-ES criteria directory lists AC529 (24). A proposed revision dated May 2026 references 2024 IBC Section 104.2.3 and 2024 IRC Section R104.2.2, but that document is a draft, not a final criterion. Confirm its status directly with ICC-ES and determine whether the product has a current report under the criterion.
Even when AC529 and a current report apply, the local official still decides whether the report satisfies the project’s adopted code and conditions. The report’s scope must match the proposed activation system, concrete use, exposure, installation controls and source.
7. Treat structural concrete as a coordinated engineering approval
For structural concrete, involve the licensed design professional at the beginning rather than adding the alternative after the drawings are complete. ACI’s published discussion of ACI 318-19 describes approval by both the licensed design professional and the building official. The decision is based on test data showing that the proposed mixture meets requirements for its application, including structural, fire and durability performance.
That discussion is edition-specific. Confirm which ACI 318 edition the local building code adopts and whether amendments modify material, strength, durability, detailing, inspection or acceptance provisions. The design professional should determine how the alternative affects:
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- Load combinations, member design, prestressing or post-tensioning, anchorage and construction sequencing.
- Fire-resistance design, temperature exposure, spalling risk and required fire tests.
- Durability classes, permeability, freeze-thaw exposure, sulfate or chloride exposure, alkali-silica reaction and service-life assumptions.
- Curing, temperature control, placement windows, finishing, cold joints and repair procedures.
- Inspection, sampling, acceptance testing and documentation needed to verify that the placed concrete matches the approved mixture.
ACI Committee 93’s ITG-10R Practitioner’s Guide for Alternative Cements covers available and emerging alternative-cement technologies, properties, applications and testing needs. It is a technical guide, not a substitute for the locally adopted code or the building official’s approval.
8. Design an equivalency test program that the official can use
Testing should answer the code questions for the actual installation, not merely produce favorable laboratory numbers. Write a test plan that identifies the material source, mixture proportions, aggregate and admixture sources, water-to-binder ratio, curing conditions, specimen geometry, test ages, laboratory qualifications, acceptance criteria and reporting format.
Represent the proposed concrete
Use mixtures that represent the proposed production concrete, including realistic aggregate gradation, admixture dosage, water content, cement or binder replacement, activation procedure and curing. If the project has multiple strength classes or exposure conditions, explain why each is represented or test each materially different mixture.
Match the end-use performance
Choose tests that correspond to the application. Structural members may need strength and stiffness evidence; exterior or below-grade work may require durability evidence; fire-rated assemblies may need fire-resistance evidence; pavements or slabs may require abrasion, shrinkage, curling or fatigue information. The AHJ and design professional should approve the list before testing.
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Use an acceptable laboratory and report format
Confirm that the laboratory and test personnel are acceptable to the official. Require reports to identify methods, deviations, calibration, specimen preparation, curing, individual results, statistical treatment and conclusions against the agreed criteria. Include the limitations and conditions under which the results apply.
Plan production controls
Laboratory equivalence does not prove that a batch plant can reproduce the mixture. Document material receiving, storage, weighing, activation, mixing sequence, temperature control, delivery time, placement, curing, sampling and nonconformance response. If the AHJ requires field trials or mock-ups, complete them before full production.
9. Follow the jurisdiction’s application route
Ask the AHJ which of these routes applies; the names and forms differ by jurisdiction:
| Possible route | What the submittal normally demonstrates | Important limitation |
|---|---|---|
| Alternative-material review under the adopted building code | Code intent, equivalency analysis, supporting tests, professional responsibility and installation conditions. | Only the local official can approve the proposed installation. |
| Recognized-agency evaluation report | Technical evaluation, identified product, code provisions, installation instructions and report conditions. | The report does not override local amendments or guarantee acceptance for every use. |
| Site-specific technical review | Evidence and calculations for one project, location, mixture, source and installation. | Approval may not transfer to another project or manufacturing source. |
| Material covered by an applicable specification | Certification and quality-control evidence showing the exact material meets the adopted specification. | Project-specific structural, durability, fire and inspection requirements still apply. |
New York City shows why local research is essential. Its Department of Buildings Technical Certification & Research forms describe separate paths: OTCR 1 initiates review of acceptance criteria for alternative-to-code products; OTCR 2 starts a site-specific evaluation; and OTCR 3 documents required testing when a site-specific review requires laboratory data. These forms illustrate one city’s process, not a nationwide procedure. Use your own department’s forms and instructions.
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10. Compare proposed alternatives on approval-relevant evidence
If two or more products are under consideration, compare them using the same project-specific questions. A lower embodied-carbon claim does not demonstrate code equivalence.
| Comparison axis | Questions to answer |
|---|---|
| Code pathway | Is the material covered by an adopted specification, an applicable AC529 criterion and report, another recognized-agency report, or a site-specific AHJ review? |
| Use and limitations | Is structural or nonstructural use allowed? What exposure, curing, activation, mixture, placement and inspection conditions apply? |
| Performance evidence | Do the tests and acceptance criteria address the project’s strength, durability, fire and other applicable requirements at an agreed scale? |
| Source consistency | Do the manufacturer, product formulation, plant or feedstock, lot controls and concrete mixture in the report match the material proposed for the project? |
| Local acceptance | Does the package address the adopted code edition, amendments, supplements, professional seals, inspections, field tests and written approval route? |
The available evidence does not establish a universal winning alternative or a generic performance ranking. The appropriate choice is the one whose documented properties, controls and approval route fit the intended use and the local requirements.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.11. Keep a complete approval record
Do not treat approval as a verbal conversation. Retain the written determination and the exact documents on which it relies:
- AHJ correspondence identifying the adopted code, amendments, review route and acceptance conditions.
- The approved product identity, manufacturing source, formulation, mixture design and activation instructions.
- Evaluation reports, supplements, acceptance criteria, test reports, calculations, drawings and professional seals.
- Approved laboratory qualifications, test plans, results, field-trial records and inspection procedures.
- Batch tickets, material certificates, delivery records, sampling results, curing records and nonconformance reports.
- Any required revisions, expiration dates, change-notification obligations or restrictions on substituting a source.
At the job site, make the approved mixture and installation controls available to the batch plant, concrete contractor, testing agency, inspector and superintendent. A change in source, activator, dosage, aggregate, curing method or mixture proportions may require the design professional and AHJ to review the change before placement.
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Relying on a model-code citation without checking adoption
Problem: The submittal quotes the 2024 IRC or IBC even though the jurisdiction adopted another edition or amended the alternative-material section.
Correction: Obtain the local adoption ordinance and amendments, then revise the code analysis and referenced standards to match the permit jurisdiction.
Submitting a report for the wrong product or source
Problem: The report covers a different formulation, plant, activator, strength class or use.
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Correction: Ask the evaluating body or manufacturer to identify the exact covered product and conditions. If the proposed material falls outside the scope, obtain a new evaluation or pursue the AHJ’s site-specific route.
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Problem: The submittal says a C1709 evaluation proves compliance with ASTM C618, C989/C989M, C1240 or C1866/C1866M.
Correction: State precisely what C1709 testing evaluated, identify the source and mixtures, and provide separate evidence for criteria not covered by the guide.
Testing before agreeing on the criteria
Problem: Results come from a laboratory or test scale the official will not accept, or they omit a required performance category.
Correction: Obtain written agreement from the AHJ and design professional on laboratory, test methods, scale, mixtures, acceptance limits and report format before testing.
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Problem: A product accepted for a slab, fill or architectural application is proposed for a load-bearing member.
Correction: Start a structural review under the locally adopted ACI 318 provisions, with application-specific structural, fire and durability evidence and professional approval.
Changing the mixture after approval
Problem: A plant substitutes a source, changes activator dosage, adds an admixture or alters curing conditions for convenience.
Correction: Stop the substitution, document the proposed change and obtain the design professional’s and AHJ’s direction before placing concrete.
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A practical pre-submittal checklist
- Record the project address, permit type, occupancy, construction type and concrete application.
- Identify the AHJ, adopted code editions and local amendments.
- Classify the material as an alternative cement, ASCM, specified blended cement, admixture, activator or another component.
- Confirm whether the work is structural and identify the responsible licensed design professional.
- Ask the AHJ for the acceptance route, required evidence, acceptable laboratories, professional seals and inspections.
- Obtain the exact product, source, formulation, report status, conditions and installation instructions.
- Check whether an applicable specification, ASTM C1709-22 evaluation framework, ICC-ES report, AC529 (24) criterion or site-specific process fits the proposal.
- Agree on the test program, mixtures, scale, criteria, laboratory and report format before commissioning tests.
- Submit the technical package and respond to every condition in writing.
- Preserve the approval record and control all field changes against the approved source and mixture.
Why the review matters
Concrete is produced at a global scale: ICC Evaluation Service quoted Senior Staff Engineer Dr. Mahmut Ekenel in a February 16, 2022 announcement saying, “On average, over 10 billion tons of concrete are produced every year worldwide, and demand is expected to increase as population grows.” That scale makes consistent evidence and local oversight important, especially when a material falls outside familiar specifications.
The decisive question is not whether a cement alternative sounds innovative or has passed a test somewhere. It is whether the exact material, source, mixture and installation can satisfy the requirements adopted for this project, with evidence the AHJ and design professional accept. Obtain that answer in writing before procurement and placement.
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